Based on dietary and other biological information collected over several years at Bird Island, South Georgia and at the South Shetland Islands (both within Integrated Study Regions (ISRs) of the CCAMLR Ecosystem Monitoring Program), we suggest (and provide a full bibliography of supporting literature) that the gentoo penguin meets the specified criteria qualifying species for inclusion in the CEMP. The extensive dependence of this species in these ISRs on Euphausia superba, (including in winter), its residence in the ISRs in winter and its early attainment of sexual maturity are all features of special relevance to the CEMP.