Despite International Protections, Threats to Rays Persist

Rays are among the most legislatively protected aquatic species in the world. Despite these protections, sharks and rays remain the second-most threatened vertebrate group on the planet. Illegal, unreported, and unregulated (IUU) fishing provides an explanation; international law provides a solution.

Ray species enjoy some protections under international law, including listing on the appendices of the Convention of International Trade in Endangered Species of Wild Fauna and Flora (CITES) and the Convention on the Conservation of Migratory Species of Wild Animals (CMS). These protections include prohibition on their “take,” meaning “taking, hunting, fishing, capturing, harassing, deliberate killing, or attempting to engage in any such conduct”; regulation of trade in live animals and their readily recognizable parts and derivatives; and obligations to conserve and restore species and their habitats, reduce factors which endanger the species, and minimize the adverse effects of activities which seriously impede their migration. However these protections have not yet reversed the exploitation that has driven ray species to the brink.

One third of all shark, ray, and chimaera species, otherwise known as class Chondrichthyes, are threatened with extinction. Three species in the class, including the java stingaree and two shark species, have been identified as critically endangered or possibly extinct. Chondrichthyes species have survived at least five mass extinctions throughout their 420-year history, but they are no match for the anthropocene. If these three species are determined to be extinct, they would represent the first global marine fish extinction from overfishing ever.

Ray populations are especially vulnerable to exploitation because of their slow growth rates and late maturation. They typically only give birth to one pup every two to three years and are considered the least fecund of all elasmobranchs, a subclass of Chondrichthyes. Moreover, rays are particularly vulnerable to the threats of human-caused climate change. Warming oceans and decreasing coral reef habitat disrupt the reliability of prey species and important behavioral patterns such as seasonal migration and cleaning stations. These factors increase the vulnerability of rays to the biggest threat affecting their survival: overfishing.

A 2021 study found that of all 391 Chondrichthyes species, overfishing affects 100 percent of them. The study identified that overfishing is the sole threat to 67.3 percent of species in this class. Threats to the other third of species included a combination of overfishing; habitat loss and degradation; climate change; and pollution. Over the past 75 years, rays have declined as much as 80 percent in some areas. Overfishing can be linked to 50 percent of this decline.

The motivations driving overfishing are numerous, but exploitation of rays is especially correlated with demand for meat and gill plates. Of the 43 countries in which manta and devil rays are landed, their meat is consumed in at least 35. Records show that gill plates, which are popular in traditional Chinese medicine and can be worth up to $1,260 USD per kilogram, are exported in 14 countries, with major trade routes in Asia and Africa. Forbes identified Myanmar, Sri Lanka, Bangladesh, India, and Indonesia as the highest priority countries for conservation action.

Emerging action in international law suggests that stronger protections for rays may be necessary. Despite evidence of widespread trade in mobulids, only five parties to CITES have reported engaging in such trade. Because CITES requires parties to submit records of imports and exports to the Secretariat, the lack of record in the CITES trade database suggests significant illegal and unreported trade in rays. In late 2024, the government of Ecuador submitted a proposal to transfer Mobula rays and all other species of the family Mobulidae from Appendix II to Appendix I. This listing change would subject trade in Mobulidae to “particularly strict regulation in order to not endanger further their survival,” making all commercial trade in mobulid specimens illegal. The proposal will be considered at the 20th meeting of the Conference of the Parties in late fall of 2025.

This effort represents a step in the growing movement to enact greater protections for aquatic species, given their increasing vulnerability from the joined/consolidated impacts of overfishing and climate change. In 2017, CMS adopted a concerted action plan on mobulids. The plan encourages Parties to implement a Global Conservation Strategy for rays and provide for conservation interventions, including bettering implementation of CITES and CMS; improving enforcement by developing identification guides and implementing port-state inspections; and conducting surveys on markets.

The Global Law Alliance for Animals and the Environment regularly attends CITES and CMS meetings and works with partner organizations to advocate for stronger and more protective approaches to international wildlife issues. Clinic students work directly with clients and partners to develop the advocacy skills necessary to build careers fighting for wildlife protection.

About the Authors:

Ally Grimaldi is the 2024 Global Law Alliance for Animals and the Environment (GLA) Diehl Fellow. She is a 2024 JD graduate of the Environmental and Animal Law programs at Lewis & Clark Law School. As a student, Ally participated in GLA, the Animal Law Review, and the Women’s Law Caucus. She interned with Phoenix Zones Initiative and worked on a project where she strategized legal pathways for the advancement of a Belmont Report for animal research.

Professor Erica Lyman has over fifteen years of experience in international environmental law, with a strong focus on wildlife protection issues. She also teaches Global Wild Animal Law in the online Animal Law advanced degree program. GLA was launched in the fall of 2020 as an innovative collaboration of the Center for Animal Law Studies and the top-ranked Environmental Law Program at Lewis & Clark Law School. GLA champions wild animals and wild spaces around the world. Law students (JD and LLM) actively participate in GLA’s work for academic credit.

The Center for Animal Law Studies (CALS) was founded in 2008 with a mission to educate the next generation of animal law advocates and advance animal protection through the law. With vision and bold risk-taking, CALS has since developed into a world-renowned animal law epicenter. CALS’ Alumni-in-Action from 30 countries are making a difference for animals around the world. CALS is a self-funded Center within the law school operating under the Lewis & Clark College 501(c)(3) tax-exempt status, and is able to provide these educational opportunities through donations and grants.