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Assessment of the Potential Impact of a Ban of Products Derived from Seal Species

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Assessment of the Potential Impact of a Ban of Products Derived from Seal Species European Commission Directorate-General Environment Assessment of the potential impact of a ban of products derived from seal species March 2008 COWI A/S Parallelvej 2 DK-2800 Kongens Lyngby Denmark Tel +45 45 97 22 11 Fax +45 45 97 22 12 www.cowi.com European Commission Directorate-General Environment Assessment of the potential impact of a ban of products derived from seal species April 2008 Report no. 1 Issue no. final Date of issue 09-04-08 Prepared COWI-team Checked AR Approved PGM Assessment of the potential impact of a ban of products derived from seal species i Table of Contents Executive Summary 1 1 Introduction 6 1.1 Background and contribution from the study 6 1.2 Types of seal hunting 8 1.3 Ethical concerns of seal hunting 9 1.4 Concerns for Inuit people 10 1.5 Community legislation 13 2 Study approach and methodology 17 2.1 Study process 17 2.2 Study limitations 18 2.3 Describing seal hunt management systems 19 2.4 Handling different information sources 20 3 Range state seal hunt management systems 22 3.1 Canada 22 3.2 Finland 35 3.3 Greenland 44 3.4 Namibia 52 3.5 Norway 61 3.6 Russia 71 3.7 Sweden 78 3.8 United Kingdom (Scotland) 87 3.9 Overview and identification of best practices 92 4 Measures to improve animal welfare aspects of seal hunting 97 4.1 Overview 97 4.2 Legislative measures 97 4.3 Non-legislative measures 100 . ii Assessment of the potential impact of a ban of products derived from seal species 5 Impact assessment of measures 101 5.1 Coverage of impacts 101 5.2 Baseline 103 5.3 Impact of prohibition of placing on the market of skins of seals and products derived therefrom 117 5.4 Impact of prohibition of imports into the Community of skins of seals and products derived therefrom 119 5.5 Impact of labelling system 121 5.6 Impact of other measures 122 6 Public perception of seal hunt 124 6.1 Questionnaire results 125 6.2 Observations from e-mails submitted to the Commission 130 6.3 Conclusions for public consultation 131 7 Conclusions and recommendations 133 7.1 Conclusions 133 7.2 Recommendations 136 Table of Appendices Appendix 1: References . Assessment of the potential impact of a ban of products derived from seal species 1 Executive Summary Pressure to improve animal welfare aspects of seal hunting EU Member States Several EU Member States are considering, or have already introduced, na- and European Par- tional legislative measures to ban the import and use of all seal skins and seal liament consider leg- products. Furthermore, in autumn 2006, the European Parliament adopted a islative measures declaration requesting the European Commission to regulate the import, export and sale of all harp and hooded seal products, while ensuring that this regula- tion would not have an impact on traditional Inuit seal hunting. European Commis- The European Commission (EC) has as response to this pressure undertaken to sion undertakes conduct an objective, in-depth analysis of existing information relating to the analysis of animal animal welfare aspects of seal hunting in all respective range states ("range welfare aspects states" are to be understood as all territories where seals are present and are (or could be) hunted, i.e. including EU Member States and Overseas Territories). Assessment of seal hunt management systems in range states Contribution of A possible EU ban of products derived from seal species will affect seal hunt- COWI study ing activities and thus the extent of animal welfare aspects. However, before considering any new measures aiming to ensure high levels of animal welfare during seal hunting activities, the European Commission has asked COWI, Denmark, to look at the regulatory frameworks and the management practices for seal hunting in the different range states: Canada, Finland, Greenland, Na- mibia, Norway, Russia, Sweden and United Kingdom (Scotland). The COWI study documents - for the first time - the extent to which seal hunt management systems differ between range states, hereunder according to the conditions un- der which the hunt is carried out and the size of the hunt. Assessment of legis- The study assesses the seal hunt management systems according to ten dimen- lative and enforce- sions of legislative and enforcement provisions - i.e. legislation: 1) animal wel- ment provisions fare principles; 2) hunting tools; 3) assuring death by monitoring; 4) bleeding- out of animals shot or struck; 5) environmental factors; 6) training of the hunt- ers; and enforcement: 7) independent monitoring; 8) ability of third party to monitor; 9) reporting requirements; and 10) sanctions and compliance. The as- sessments are based on desktop study research and information provided during an overall consultation process - but the study team did not visit the range states. Hence, the assessments of enforcements in practice are limited by this scope of the study. 2 Assessment of the potential impact of a ban of products derived from seal species Seal hunt manage- A first conclusion from the study is that the seal hunt management systems dif- ments systems differ fer between range states - and that within all systems improvements can be between range states made. Seals are hunted within substantially different contexts signifying the type and size of the hunt, and the hunts are taking place within different regula- tory environments. Some range states have implemented comprehensive man- agement systems aimed at minimising the conflict between production and animal welfare, whereas other range states' management systems are less well- developed and to a lesser degree indicate concern of animal welfare. This in- sight can help the EU Commission when considering whether any restrictions should be imposed selectively upon seal products that are produced within the context of weakly developed national seal hunt management systems, or whether any labelling systems can be based on best practices. Three groups of The range states can roughly be grouped into three groups. Seal hunting is range states comprehensively regulated in Norway and it has the most developed manage- ment system. A second group is made up of Canada, Finland, Greenland, Na- mibia and Sweden - all of these range states have relatively well-developed le- gal frameworks. There are, however, pronounced insufficiencies particularly regarding enforcement and training requirements. A third group consists of Russia and the UK. For both of these, data are insufficient to make sound con- clusions. Identified best prac- Measured against the recommendations in the EFSA scientific opinion (EFSA, tices 2007), there seems to be room for improvements within many dimensions for almost all the range states covered by the study. In order to stimulate the policy learning from and between the range states the study has formulated the follow- ing best practices: • On animal welfare principles: Animal welfare principles are highlighted in the applicable hunting legislation - whether this targets seal hunting spe- cifically or hunting in general. • On hunting tools: The characteristics of the weapons used to kill seal are specified. It is made explicit in the legislation which weapons are allowed for stunning and/or killing pups and which are allowed for stunning and/or killing adult seals. The requirements to the weapons are made in accor- dance with the recommendations of the EFSA scientific opinion. • On assuring death by monitoring: Legislation should specifically outline requirements for monitoring and thereby oblige the hunter to assure that the seal is irrevocably unconscious before bleeding it out and before con- tinuing to the next seal. • On bleeding-out animals shot or stunned: Bleeding-out of all animals is required directly following adequate stunning i.e. before proceeding to stun another seal. • On environmental factors: Requirements are specified as to secure that the seal and/or the hunter is sufficiently stable and that the target can be prop- erly visualised. Other environmental factors, relevant for the hunt in ques- tion, are also regulated. Assessment of the potential impact of a ban of products derived from seal species 3 • On training of hunters: A defined level of knowledge and ability of the hunter regarding seal biology, hunting methods and the three step proce- dure, hereunder practical use of the hunting tools, e.g. shooting tests are required. • On independent monitoring: A system for monitoring and observation of the hunt, securing regular supervision of the hunt and that secures inde- pendency of the inspectors is provided for. • On ability of third party to monitor: Third party monitoring of the hunt is possible, with a minimum of administrative or logistic barriers. • On reporting requirements: Clear requirements for reporting targeting both hunters and inspectors. There are requirements to where and when animals are killed and weapons and ammunition used. Also the range of relevant environmental factors (weather conditions, etc.) should be reported. • On sanctions and compliance: Statistical information on the hunt should be compiled and systemised. Assessment of the impact of different policy measures Legislative and non- The study considers in the assessment of impacts both legislative and non- legislative measures legislative policy measures. Furthermore, policy measures that are not linked - linked-to or not- directly to the management systems - such as a total prohibition of placing on linked-to manage- the market or of imports/exports, as well as measures that could be linked to the ment systems good or bad practices of the seal hunt management systems are analysed. Environmental, eco- The environmental dimension of the assessment is limited to discussing the im- nomic and social im- pacts of animal welfare aspects for seals, and the discussion builds to a large pacts extent upon the EFSA scientific opinion. The assessment does thus not address biodiversity issues such as the impacts on others parts of an ecosystem of a possible increase in the number of seals.
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