Sea Cucumber CITES Compliance: What Exporters and Buyers Must Know in 2026

The regulatory landscape for international sea cucumber trade has become significantly more complex in recent years. For buyers and exporters operating in this market, understanding CITES compliance requirements is no longer optional — it is a foundational requirement for uninterrupted cross-border trade.

This guide explains which sea cucumber species are currently subject to CITES controls, what documentation is required, and what the latest decisions from CITES COP20 (December 2025) mean for international buyers sourcing from Indonesia.

What Is CITES and Why Does It Apply to Sea Cucumber?

CITES — the Convention on International Trade in Endangered Species of Wild Fauna and Flora — is an international treaty that regulates cross-border trade in wildlife species to prevent overexploitation. Appendix II of CITES lists species that are not necessarily threatened with extinction but whose trade must be controlled to avoid utilization incompatible with their survival.

An Appendix II listing means that trade in such species is, at least in theory, tightly regulated, with permits required for cross-border trade. For sea cucumber exporters and importers, this translates directly into documentation requirements that must be met before any shipment can legally cross international borders.

Which Sea Cucumber Species Are Currently Listed Under CITES?

This is the most important question for buyers, and the answer has become more nuanced following recent CITES decisions.

• Species Currently Under CITES Appendix II

  The following commercially important sea cucumber species currently require CITES export permits for international trade:

  • Holothuria scabra (Sandfish) — one of Indonesia's highest-value export species, listed under Appendix II since 2020.

  • Holothuria fuscogilva (White Teatfish) and Holothuria whitmaei (Black Teatfish) — both listed under Appendix II, with export requiring non-detriment findings from the country of origin.

  • Thelenota ananas (Prickly Redfish) and Thelenota anax (Amberfish) — all sea cucumber species in the genus Thelenota were included in CITES Appendix II at COP19, with the listing taking effect on 25 May 2024.

• New Listing: Golden Sandfish (COP20, December 2025)

  At the 20th World Wildlife Conference in Samarkand in December 2025, the Appendix II listing for Golden Sandfish was agreed upon by consensus. This is a significant development for buyers sourcing premium-grade sandfish varieties. Exporters of golden sandfish must now obtain CITES permits for all international shipments.

• Species Not Currently Listed

  At COP20, a proposal to list six other sea cucumber species under Appendix II did not pass, as the FAO Expert Panel determined those species did not meet the scientific thresholds and are part of sustainable fisheries. However, buyers should monitor CITES decisions actively, as proposals for additional listings are expected at future meetings.

What Documentation Is Required for CITES-Listed Sea Cucumber?

For any shipment involving a CITES Appendix II sea cucumber species, the following documentation chain must be in place before export:

• Export Permit from Indonesia

  The export of any specimen of a species included in Appendix II requires the prior grant and presentation of an export permit. This permit can only be granted when a Scientific Authority of the state of export has advised that such export will not be detrimental to the survival of that species, and when a Management Authority is satisfied that the specimen was not obtained in contravention of national laws for the protection of fauna and flora.

  In Indonesia, this process is managed through the Ministry of Environment and Forestry (KLHK) in coordination with the Ministry of Marine Affairs and Fisheries (KKP). Exporters must apply for CITES permits per shipment, and applications require traceability documentation from harvest to processing.

• Non-Detriment Finding (NDF)

  A Non-Detriment Finding is a scientific assessment confirming that the export volume will not harm wild populations. Prior to approving a commercial export permit, CITES requires that the relevant government agency from the country of export determine that the activity will not be detrimental to, or contribute to trade which is detrimental to, the survival of the species. In Indonesia, these findings are periodically reviewed and updated by the relevant scientific authority.

• Import-Side Requirements

  International trade in specimens of Appendix II species may be authorized by the granting of an export permit or re-export certificate. No import permit is necessary for these species under CITES, although a permit is needed in some countries that have taken stricter domestic measures than CITES requires.

  Buyers should verify the specific import requirements of their destination country. Several major import markets — including the European Union member states and the United States — have enacted stricter domestic requirements beyond the CITES baseline.

Special Considerations for U.S. Buyers

Sea urchins and sea cucumbers do not meet the U.S. Fish and Wildlife Service's definition of a shellfish or fishery product, and are therefore not exempt from import and export requirements related to wildlife. This is a frequently misunderstood point for first-time U.S. importers. All sea cucumber imports into the United States — including dried product intended for food use — are subject to USFWS import declaration requirements, regardless of whether they are CITES-listed.

U.S. buyers sourcing from Indonesia should ensure their Indonesian supplier can provide a complete compliance package including CITES export permits (where applicable), certificate of origin, and U.S. Fish and Wildlife Service import declaration documentation.

What CITES Compliance Means for Buyers Choosing a Supplier

CITES compliance is where supplier selection becomes critically important. A supplier who cannot produce valid CITES export permits, or who does not have established relationships with Indonesian regulatory authorities, creates direct legal and commercial risk for international buyers.

Key questions to ask any prospective Indonesian sea cucumber supplier:

1. Have you successfully exported CITES-listed species in the last 12 months? Request copies of recent CITES export permits as evidence.

2. Do you have an established process for obtaining non-detriment findings? This process requires coordination with Indonesian scientific and management authorities — suppliers with long operational histories will have this in place.

3. Can you confirm the harvest origin of your product? Traceability from harvest location to processing facility is a prerequisite for CITES compliance and increasingly required by premium buyers.

4. Are you monitoring upcoming CITES decisions? With new listings coming into force and additional proposals expected, suppliers who actively track regulatory changes protect their buyers from unexpected shipment disruptions.

The Compliance Advantage of Working with Experienced Indonesian Exporters

For international buyers, the most practical risk mitigation strategy is straightforward: work with Indonesian exporters who have a documented track record of CITES-compliant shipments across multiple years and multiple species.

Newer or smaller operators may lack the regulatory relationships, documentation infrastructure, and institutional knowledge to navigate CITES requirements consistently. A single shipment held at customs due to documentation deficiencies can result in significant financial loss, product degradation, and supply chain disruption for the buyer.

Sepanjang's 20+ years of operation in the Indonesian ocean products sector includes a sustained history of compliant export across CITES-listed species. Our team works directly with Indonesian regulatory authorities and maintains up-to-date documentation protocols for all applicable species in our portfolio.

Summary: CITES Compliance Checklist for Sea Cucumber Buyers

Before confirming any sea cucumber import order, buyers should verify the following:

1. Confirm whether the species ordered is currently listed under CITES Appendix II

2. Request a copy of the CITES export permit from your supplier before shipment

3. Verify non-detriment finding status for the relevant species and export period

4. Check destination country import requirements — these may be stricter than CITES baseline

5. For U.S. imports, ensure USFWS import declaration is prepared in advance

6. Request harvest traceability documentation from supplier

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Sepanjang — Indonesia's Specialty Ocean Products Co. For inquiries regarding CITES-compliant sourcing of Indonesian sea cucumber, contact our team to discuss your documentation requirements and species availability.