Concerning data absent from LEMIS wildlife trade records

International wildlife trade is implicitly complex and esoteric. Oftentimes, the data are doubly so, as crucial contextual information is not readily apparent. Working effectively with these data often requires a robust comprehension of international and domestic trade processes as well as their intersections with national policy administration, conservation, and ecological processes. Weissgold (2024) calls attention to important limitations affecting the utility of the U.S. Fish and Wildlife Service (USFWS) Law Enforcement Management Information System (LEMIS) wildlife trade data. However, to prevent further misunderstanding of the LEMIS system, it is necessary to address a sentiment expressed by Weissgold regarding the apparent incompleteness of LEMIS records. The goal of this response is to help researchers working with LEMIS data understand that the LEMIS Declaration subsystem documents a specific subset of international wildlife trade. This understanding is vital for accurate analyses.

As Weissgold states, LEMIS wildlife trade data are typically extracted from the LEMIS Declaration subsystem, which omits many confirmed occurrences of illegal wildlife trade interdiction. Wildlife trade activity must qualify as an import or an export before it is eligible to become a LEMIS wildlife trade database record. LEMIS wildlife trade data are records of wildlife trade events processed by USFWS wildlife inspectors, whose jurisdiction is defined by inspection, search, and seizure authority at international land, sea, and air borders as well as at functional equivalents of the border (USFWS, 2008a). Satisfaction of this “border nexus” condition underpins the USFWS Office of Law Enforcement's (OLE) review of trade declarations for internationally traded wildlife (USFWS, 2008b). Domestic instances of illegal wildlife trade handled by USFWS OLE special agents, whether the wildlife was ultimately intended for export or not, are documented elsewhere within LEMIS and must be specifically requested from the Investigations, Violations, or other LEMIS subsystems (USDOI, 2020). The absence of these records from the LEMIS Declaration subsystem data is not a result of procedural or data entry errors.

LEMIS data users should also note that the LEMIS Declaration subsystem is not a complete record of lawful U.S. international wildlife trade and information gaps abound. If a trade event satisfies any of a series of conditions prescribed by USFWS and the wildlife is not protected by key U.S. legislation such as the Endangered Species Act, Marine Mammal Act, the Lacey Act, etc., then the import (or export) may be exempt from declaration to the USFWS and thus not recorded in LEMIS (Table 1) (U.S.C Title 50 §, 14.62; U.S.C Title 50 §, 14.64). In a dataset as large as LEMIS, records skewed towards or against the recording of certain taxa or types of trade can lead to misrepresentations of the economic, social, and ecological impacts of trade. These resultant data gaps should be acknowledged and explored for their conservation and policy implications as they are likely to contribute towards mischaracterizations in LEMIS data analyses.

The authors warrant no conflict of interest.