Achieving biodiversity conservation whilst addressing the broader aims of sustainable development, is presenting a challenge for countries the world over. This is particularly so for small island developing states. Top down legal approaches have had limited success and attention has now turned to bottom up, participatory mechanisms. There have been many community-based marine biodiversity conservation projects in the South Pacific but in order to ensure their longevity and legitimacy greater legal support is necessary. One approach that may be effective in this regard involves the blending of customary law and legislation, as illustrated by the experiences of Samoa and Vanuatu.