EN

|| COMMISSION OF THE EUROPEAN COMMUNITIES

Brussels, 24.7.2008

SEC(2008) 2290/2

CORRIGENDUM: page de couverture : SEC(2008) 2291 au lieu de COM(2008) 2291

COMMISSION STAFF WORKING DOCUMENT

Accompanying document to the Proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL concerning trade in seal products IMPACT ASSESSMENT ON THE POTENTIAL IMPACT OF A BAN OF PRODUCTS DERIVED FROM SEAL SPECIES

{COM(2008) 469 final} {SEC(2008) 2291}

Agenda planning: 2008/ENV/013

The report commits only the Commission's services involved in the preparation and the text is prepared as a basis for comments and does not prejudice the final form of any decision to be taken by the Commission.

TABLE OF CONTENTS

1........... Executive Summary...................................................................................................... 5

2........... Procedural issues and consultation of interested parties.............................................. 7

2.1........ Overview...................................................................................................................... 7

2.2........ Inter-Service Steering Group........................................................................................ 9

2.3........ Independent scientific opinion of the European Food Safety Authority (EFSA) on the animal welfare aspects of the killing and skinning of seals................................................................... 9

2.4........ The Assessment Study (hereafter referred to as "the COWI study")......................... 10

2.5........ Public consultation...................................................................................................... 11

2.6........ Other consultations..................................................................................................... 12

2.6.1..... EFSA stakeholder consultation.................................................................................. 12

2.6.2..... Workshop organised by the Commission................................................................... 12

2.6.3..... Bilateral meetings with stakeholders.......................................................................... 13

2.6.4..... Conference participation............................................................................................. 13

2.7........ Commission fact-finding mission to Canada to observe the 2007 annual seal hunt.. 13

2.8........ Impact Assessment Board.......................................................................................... 13

3........... Problem definition...................................................................................................... 13

3.1........ Animal Welfare Problems during the seal hunts relating to seals suffering avoidable pain, distress, fear and other forms of suffering.............................................................................................. 13

3.1.1..... Description of the hunts............................................................................................. 14

3.1.2..... Types of seal hunting.................................................................................................. 14

3.1.3..... Killing methods.......................................................................................................... 15

3.1.4..... Underlying motives and forces................................................................................... 16

3.1.5..... Who is affected, in what ways, and to what extent................................................... 18

3.2........ Trade in seal products and related measures in place................................................. 19

3.2.1..... Level of trade............................................................................................................. 19

3.2.2..... EU Member States measures / WTO consultations.................................................... 19

3.2.3..... International perspectives........................................................................................... 20

3.2.4..... Community legislation................................................................................................ 20

3.2.4.1.. Community Action Plan on the Protection and Welfare of Animals 2006-2010....... 20

3.2.4.2.. The "Seal pups directive"............................................................................................ 21

3.2.4.3.. The "Habitats Directive"............................................................................................. 21

3.2.5..... Possible evolution of the problem............................................................................... 21

3.3........ Subsidiarity/necessity test........................................................................................... 22

4........... Objectives................................................................................................................... 22

5........... Main policy options.................................................................................................... 24

5.1........ "No additional EU action".......................................................................................... 24

5.2........ Legislative measures................................................................................................... 25

5.3........ Non-legislative measures............................................................................................ 27

6........... Analysis of impacts..................................................................................................... 28

6.1........ General remarks.......................................................................................................... 28

6.1.1..... Coverage and type of impacts.................................................................................... 28

6.2........ Baseline....................................................................................................................... 30

6.2.1..... Welfare of seals.......................................................................................................... 30

6.2.2..... Environmental impacts............................................................................................... 31

6.2.3..... Trade........................................................................................................................... 31

6.2.4..... Local Economy........................................................................................................... 42

6.2.5..... Inuit population.......................................................................................................... 43

6.3........ Impact of prohibition of placing on the EU market of skins of seals and products derived therefrom 44

6.4........ Impact of prohibition of imports into the Community of skins of seals and products derived therefrom.................................................................................................................................... 46

6.5........ Impact of a labelling system....................................................................................... 47

6.6........ Impact of other measures............................................................................................ 48

6.6.1..... Bi-/multilateral agreements between the EU and one or more range states............... 48

6.6.2..... Development of guidelines by an internationally recognised organisation................ 48

6.6.3..... EU information campaigns......................................................................................... 49

6.6.4..... “Sufficient information for action”?........................................................................... 49

7........... Comparing the options................................................................................................ 49

7.1........ Total prohibition of placing on the EU market of seal products................................ 49

7.2........ Total prohibition of imports and exports.................................................................... 50

7.3........ Conclusion and preferred policy package................................................................... 51

7.3.1..... Impacts of preferred policy package.......................................................................... 51

8........... Monitoring and evaluation.......................................................................................... 54

8.1........ Monitoring.................................................................................................................. 54

8.2........ Evaluation................................................................................................................... 58

1. Executive Summary

In line with its commitment to high animal welfare standards, the European Commission undertook to conduct an objective, in-depth analysis of the animal welfare aspects of seal hunting in sealing countries. This report presents possible options with respect to further policy and/or legislative measures to address animal welfare concerns with regard to the killing and skinning of seals.

In the framework of this analysis, regulatory frameworks and management practices for seal hunting in the different range states were analysed[1] and, based on findings of the European Food Safety Authority (EFSA)[2], best practices were identified. The following range states were analysed in detail: Canada, Finland, Greenland, Namibia, Norway, Russia, Sweden und the United Kingdom (Scotland).

The assessment showed that the seal hunt management systems differ between range states - and that within all systems improvements can be made. Seals are hunted in substantially different contexts. Both the type and size of the hunt, and the regulatory environments in which the hunts are taking place are different. Some range states have adopted and implemented comprehensive management systems aimed at minimising the conflict between production and animal welfare, whereas other range states' management systems are less well-developed and indicate less concern about animal welfare.

The EFSA scientific opinion indicates that seals can be killed rapidly and effectively, without causing avoidable pain, distress and suffering, using a variety of methods. However, there is reported evidence that in practice effective killing does not always happen and some animals are killed and skinned in a way, which causes avoidable pain, distress and other form of suffering.

Both, legislative and non-legislative policy measures were considered in the impact assessment. Furthermore, policy measures that are not linked directly to the management systems - such as a total prohibition of placing on the EU market or of imports/exports, as well as measures that could be linked to the good or bad practices of the seal hunt management systems were analysed.

The environmental dimension of the assessment is limited to the impacts of animal welfare aspects for seals which, however, are difficult to measure because the effectiveness of killing methods used for seals vary according to the methods used, the skill of the operators and the environmental conditions. Furthermore, economic impacts are limited to those to trade and local economies, both on the side of the sealing countries as well as of potential transit and transformation countries, while the social dimension touches mainly upon the conditions for the Inuit population.

A total prohibition of placing on the EU market of seal products is assessed to have minor economic impacts in EU Member States. This assumes, however, that transhipment of sealskins and other seal products and imports of sealskins for further processing and exports can continue. The impacts are assessed to be slightly more significant for non-EU range state. This is a result of the fact that the size of the seal hunts in these non-EU countries are much larger than in the EU range states, and that the EU market - apart for Russia - is of some importance. This option would also deny consumers the choice to purchase seal products in the EU.

A total prohibition of imports and exports would have medium economic impacts on the EU Member States, although those impacts could be significant for Finland and Germany, if such ban would also cover transit trade. The impacts would be slightly higher for the non-EU range states. This is again a result of the fact that the size of the seal hunts in non-EU countries is much larger than in the EU range states, and that the EU market - apart for Russia - is of some importance. However, if the ban is extended to transit trade Canada will in particular suffer, unless this trade can be shifted from Germany and Finland to outside of the EU e.g. Norway. Hence, Norway may actually strengthen its position as a transit trader. With regard to the consumer, he/she would only have a very limited choice of seal products derived from seal species hunted in the EU and offered for sale on local markets only.

Denmark and Italy are by far the two largest EU importers of raw fur skin from seal for further processing / sales on the EU market, and will thus also be affected by such regulation. Denmark imports the raw fur skins directly coming from Canada and Greenland (that are not categorised as goods in transit), while Italy imports the raw fur skins from Russia, Finland and the UK (Scotland). Greece also has a noticeable trade in raw skins originating in the two latter range states.

Benefits from a labelling system allowing consumers to distinguish between individual seal products on the basis of welfare considerations (product-based labelling) might include a price mark-up on the consumer market and at the same an increase of the image of seal hunting in general. If the system is voluntary it might encourage a natural self-selection process regarding compliance and thus maintain the balance between the animal welfare, economic and social dimension - i.e. those who pursue the label might benefit more than it costs, and the welfare of the seals could be enhanced. Furthermore, it is assessed that the impact will be largest if it is a widespread international labelling system rather than a specific EU system.

Bi-/multilateral agreements between the EU and one or more range states could be made, which could enlarge the geographical area not to be covered by any legislative measures. The impact will be similar to that of a limited ban that allows trade if the hunting of the seals complies with some established standards as discussed above.

Given the animal welfare concerns expressed by the public, notably by the European Parliament and Member States, stand-alone non-legislative measures are not considered sufficient to address the issue.

The EFSA scientific opinion clearly indicates that there is reported evidence that, in practice, effective killing does not always happen - which is reinforced by the further assessment findings. There are therefore reasonable grounds to consider undertaking precautionary steps to ensure that products derived from seals, which are killed and skinned in a way that causes them avoidable pain, distress and suffering, are denied access to the European market.

The outcome of the assessment of impacts in relation to the animal welfare, economic and social dimension shows that a combination of several options appears to be the best way to meet the overarching objectives, i.e.

· protect seals from acts that cause them avoidable pain, distress, fear and other forms of suffering during the killing and skinning process

· address the concerns of the general public with regard to the killing and skinning of seals

This should be done through prohibiting the placing on the market and the import, transit through, or export from, the Community of all seal products from a given date. Trade in those products would however be possible when certain conditions, which concern the manner and method whereby seals are killed and skinned, are met. Information requirements would also need to be established aimed at ensuring that seal products whose trade would be possible by derogation to the prohibitions otherwise in force would be clearly indicated as coming from a country meeting the above-mentioned conditions.

This would help to ensure that the general public is not confronted anymore with those seal products derived from seals killed and skinned with avoidable pain, distress or other form of suffering and would seek to provide incentives for the use of killing and skinning methods of seals which do not cause avoidable pain, distress or other forms of suffering. In this way, the option would have a direct impact on the application in practice of animal welfare friendly hunting techniques and thus protect the animals from unnecessary suffering.

2. Procedural issues and consultation of interested parties

2.1. Overview

In response to concerns relating to the animal welfare aspects of seal hunting, several EU Member States are considering, or have already introduced, national legislative measures to ban the import and use of seal skins and seal products covering some or all seal species.

On 17 September 2006, the Council of Europe adopted a recommendation on seal hunting inviting member and observer states practising seal hunting, amongst other issues, "to ban all cruel hunting methods, which do not guarantee the instantaneous death, without suffering, of the animals, and to prohibit the stunning of animals with instruments such as hakapiks, bludgeons and guns".[3]

Furthermore, the European Parliament adopted on 26th September 2006 a written declaration requesting the Commission to immediately draft a regulation to ban the import, export and sale of all harp and hooded seal products while ensuring that this measure would not have an impact on the traditional Inuit seal hunting. This Declaration with a high number of signatories (425) reflects the main issues of public concern, i.e. concerns about the application of humane killing methods and sustainability of the hunting quotas.

The Commission in its response to the European Parliament on 16 January 2007 recognised the high level of public concerns regarding the animal welfare aspects of seal hunting and in line with its commitment to high animal welfare standards, undertook to make a full objective assessment of the animal welfare aspects of seal hunting and, based on the results, to report back to the European Parliament with possible legislative proposals if warranted by the situation. Elements of the assessment are the EFSA scientific opinion, and a study to support the Impact Assessment process carried out for the Commission by the consultancy firm COWI, and a public consultation by internet.

With regard to the conservation concerns also raised in the EP declaration, the Commission expressed the opinion that there were at that time no such concerns for the species targeted by the European Parliaments declaration. It further stated that if such concerns materialised, sufficient Community legislation was in place to address them:

· Council Directive 83/129/EEC[4] as amended by Council Directive 89/370/EEC, prohibiting the importation into the EU Member States of skins of whitecoat pups of harp seals and of pups of hooded seals and products derived therefrom, which was put in place following doubts on the population status of these seal species; as well as

· EU Wildlife Trade Regulations implementing the provisions of the Convention on International Trade in Endangered Species (CITES) in the EU[5] . The Convention's objective is to ensure that trade only takes place if it does not threaten the survival of species of wild fauna and flora.). To be listed under CITES would be the appropriate response, if the survival of these seals species in the wild should be endangered by international trade. This is the case with the Namibian Cape fur seal, which is the only seal species currently listed under Appendix II of the CITES Convention thereby ensuring that trade is not detrimental to the survival to the species.

· Furthermore, Directive 92/43/EEC on the conservation of natural habitats and of wild fauna and flora (Habitats Directive) protects all seal species occurring within EU. Grey seal (Halichoerus grypus), ringed seal (Phoca hispida bottnica) and harbour seal (Phoca vitulina) are listed as Annex V species which means that their exploitation is allowed. However the Member States are under the obligation to maintain or restore these species at favourable conservation status.

Consequently, this Commission overall impact assessment focuses on the animal welfare aspect of seal hunting and trade implications of any measures in all respective range states ("range 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). The following countries have been assessed in detail: Canada, Finland, Greenland, Namibia, Norway, Russia, Sweden and United Kingdom (Scotland).

The proposal and this impact assessment are part of the Commission agenda planning 2007/ENV/013.

2.2. Inter-Service Steering Group

A Commission Inter-Service Steering Group on the Impact Assessment was established. The Group was led by DG Environment with the participation of the following Commission Directorates and Services: Enterprise, External Relations, Health and Consumer Protection, Trade, Secretariat-General. Other services were also contacted but those preferred to be consulted at a later stage in the process.

2.3. Independent scientific opinion of the European Food Safety Authority (EFSA) on the animal welfare aspects of the killing and skinning of seals

In follow-up to the request from the European Commission in May 2007, EFSA adopted on 6 December 2007 an independent scientific opinion on the animal welfare aspects of methods for the killing and skinning of seals.

EFSA concluded that "it is possible to kill seals rapidly and effectively without causing them avoidable pain or distress. However, the Panel also reported evidence that, in practice, effective and humane killing does not always happen."

EFSA does not explicitly condemn the currently used methods for killing and skinning of seals. It rather establishes a number of very useful and clear criteria for assessing the acceptability of methods applied in the different seal hunts.

Given the scarcity of robust, scientifically peer reviewed data (see also chapter 6.6.4), the EFSA Risk Assessment process was conducted in a qualitative way. Nevertheless, the general conclusions and recommendations are considered to be rigorous enough to inform the policy-making process.

Some of the main conclusions:

· Seals are sentient mammals that can experience pain, distress, fear and other forms of suffering.

· Seals can be killed rapidly and effectively, without causing avoidable pain, distress and suffering, using a variety of methods that aim to destroy the brain function. However, there is evidence that in practice effective killing does not always happen and some animals are killed and skinned whilst conscious resulting in avoidable pain, distress and other form of suffering.

· The EFSA opinion stated that "there are only a limited number of studies published in peer-reviewed journals that can be used to evaluate, with a high degree of certainty, the efficacy of the various killing methods employed in different seal hunts around the world on a quantitative basis. This is why the risk assessment had to take a qualitative approach. Nevertheless, there are studies (e.g. by NGOs, industry linked groups) that highlight serious deficiencies and concerns in the hunts, but they may contain potentially unproven biases".

Some of the main recommendations:

· Seals should be killed without causing avoidable pain, distress or other form of suffering.

· This may be achieved using appropriate firearms with appropriate ammunition at appropriate distance. Alternatively, hakapiks or other forms of clubs can be used if of an appropriate design and used with adequate force and accuracy, but only on young seals.

· The killing methods should only be used in appropriate conditions, be applied adequately and respect a 3-steps procedure (stunning, monitoring of unconsciousness, bleeding) before skinning.

· Some methods should not be used as they are inherently inhumane e.g. netting that traps seals underwater and causes death by suffocation as well as harpooning seals through the snow.

· Hunters should be trained and competent in the procedures they use, including killing methods, monitoring death, unconsciousness and consciousness, and in rapid bleeding and skinning.

· Independent monitoring of seal hunts is recommended, thereby meaning independent of both industry/commercial interests and NGOs.

· Hunts should be open to inspection without undue interference.

For further details, please refer to the full text of the scientific opinion published by EFSA on their website[6].

2.4. The Assessment Study (hereafter referred to as "the COWI study")

Building upon the EFSA scientific opinion, a study (commissioned by the Commission) by the consultancy firm COWI[7] examined the regulatory frameworks for and the management practices of the different seal hunts.

Legislative and enforcement provisions in a number of sealing countries, both within the European Community and beyond were assessed and best practices identified. The assessments were based on desk study research and information provided during the overall consultation process - but the study team did not visit all the range states worldwide.

The COWI study also assessed the impact of a possible ban of seal products on trade and other socio-economic aspects. The final report was submitted to the Commission at the beginning of April 2008.

The study shows that in many seal hunting countries, legislation and guidelines for their implementation are in place, but there is evidence of problems with their implementation and effective enforcement. The study also points at the difficulty in establishing a clear link between trade measures such as a trade ban and the way by which those measures would help to improve the animal welfare of the hunted animals.

2.5. Public consultation

A public consultation was conducted between 20th December 2007 and 13th February 2008 via the Commission's Interactive-Policy Making (IPM) tool. The consultation provided the possibility for EU citizens as well as non-EU citizens to express their view on regulation of seal hunting - as an input to the policy decision-making process.

73,153 answers were received from citizens in 160 different countries worldwide. This high number of responses (and additionally around 1,350 e-mails) indicates that seal hunting is a very salient issue to a large number of citizens. The responses show massive dissatisfaction with current seal hunting practices, at least how they are perceived by the general public. A clear majority of respondents in nearly all the geographical areas analysed preferred a ban. The majority of respondents reside in the Anglo-Saxon countries UK, US and Canada. Around 50% of the pro-banners come from two non-EU countries: the US and Canada. When looking at the results from respondents in other countries, the results are somewhat less stark.

Regarding the policy recommendation, over 50% of respondents in each single country - apart from Sweden and Namibia - prefer a ban, particularly respondents from Canada, UK and Russia, whereas the Nordic range states show more diversified answers. In the EU 14.5% prefer alternative measures while 6.1% see no need for further measures.

The results show that many respondents are against seal hunting for reasons of principle - which again may be rooted in a certain perception of the human-nature relation. However, the results also show that for some respondents the level of acceptability of seal hunting is influenced by how the seal hunt is managed and undertaken - and for what reasons. Hence, the results can also be used to develop a list of factors that - if fulfilled - will tend towards increasing the acceptability of seal hunting, namely:

· Motivation of hunt: Seal hunting undertaken for subsistence purposes are more acceptable than hunt for profit.

· The hunter: Seal hunting that is part of the local community’s traditional culture is more acceptable than a hunt disconnected from local culture and communities.

· The use of the seal: Seal hunting that utilises the entire animal is more acceptable than seal hunting using only the skins (acceptance for use of skins only is under 1% - if the whole seal is used acceptance is over 15%).

· Enforcement and monitoring: Seal hunting is more acceptable if it is firmly monitored by an independent inspection authority.

· Struck and lost: Any seal hunting that lead to more than even a very low level of struck-and-lost is not acceptable to the respondents.

It is important to also highlight the possible knowledge gap on hunting methods - i.e. public perception vs. scientific knowledge (EFSA findings) and linked thereto the attitudes towards animal welfare vs. local communities. These are quite striking and underline clearly the complexity of the seal hunting issue from an animal welfare perspective.

2.6. Other consultations

2.6.1. EFSA stakeholder consultation

EFSA held a stakeholder consultation with around 100 participants in Parma on 4th October 2007. The stakeholders were invited to express their opinion on the completeness and reliability of the data presented in the draft report prepared by the EFSA working group, in order to avoid any possibility of leaving out some important scientific evidence. Moreover, the interested parties were invited to comment on some crucial sections (stunning and killing methods, neurophysiologic aspects, education and training of sealers) and to further explain their comments/suggestions from the questionnaire previously distributed.

Many issues were raised and it was clarified that only those related to the animal welfare aspects of the seal killing and skinning were to be taken into account in the Scientific Report, without considering any management issue (ethical, social, economical, cultural) which were looked at in the framework of the COWI study.

2.6.2. Workshop organised by the Commission

A workshop with experts from sealing countries, animal welfare NGOs as well as fur trade and hunters associations was organised on 14th January 2008 with the objective to receive feed-back on the factual information under the country reporting exercise (national hunt management systems) conducted in the framework of the COWI study, i.e. information on legislation, enforcement and the socio-economic contexts in the sealing countries.

2.6.3. Bilateral meetings with stakeholders

Bilateral meetings with a whole range of stakeholders (e.g. sealing countries, animal welfare organisations, trade organisations, scientists) took place at political as well as at technical level.

2.6.4. Conference participation

The Commission also participated at the "International conference on Seals & Society Conference ", held from 15th until 19th October 2007 in Vaasa, Finland. Governmental representatives, scientists, representatives from international organisations dealing with marine resource management, environment and fisheries as well as traders and animal welfare groups from 15 different countries attended the Conference. It was a good opportunity for the Commission, on the one hand, to explain to the sealing countries the on-going Commission assessment process on the animal welfare aspects of seal hunting and on the other hand, to note their concerns.

2.7. Commission fact-finding mission to Canada to observe the 2007 annual seal hunt

Two Commission veterinarians travelled to Newfoundland between 9 and 16 April 2007 to observe the annual seal hunt following an invitation of the responsible Canadian Minister. Unfortunately, despite the investment and the efforts undertaken by the Commission, the mission failed to accomplish its objective and the Commission veterinarians were not put in a position to observe the actual hunting of the seals. No adequate arrangements seem to have been made by Canada to ensure access by them to the actual observation of the hunt. Adverse weather and ice conditions also played a role in preventing a successful observation.

2.8. Impact Assessment Board

The draft Impact Assessment was submitted to the Board on 6 May 2008 and discussed at the Board meeting of 21 May 2008. The Board issued its opinion on 23 May 2008. The Board recommended that the report should provide more analysis as to the effectiveness of the various options including i) assessing potential trade diversion resulting from import bans; ii) clarifying further the scale of the problem by better estimating the proportion of EU trade in seal products which results from seals killed in a non-acceptable way and iii) assessing more clearly the feasibility of introducing a monitoring system for the certification and labelling of seal products resulting from acceptable killing methods. The report should also provide a clear analysis of the content of the preferred policy package, its overall impact, and specific impacts on transit trade, Inuit activity and fish stocks. The recommendations of the Board have been incorporated into the present version of the report.

3. Problem definition

3.1. Animal Welfare Problems during the seal hunts relating to seals suffering avoidable pain, distress, fear and other forms of suffering

Seal hunts have occurred in various parts of the world throughout history, and the different stunning and killing methods used have been documented in various ways.

3.1.1. Description of the hunts

There are thirty-three existing species of pinnipeds (fur seals, sea lions, walrus and true seals). They occur mainly along the coasts of polar, sub-polar and temperate regions. At least fifteen species are hunted by humans for commercial purposes or to satisfy subsistence and cultural needs. However, the majority of animals killed belong to five species: harp seals, ringed seals, grey seals, hooded seals and Cape fur seals. The three largest seal hunts (Canada's commercial harp seal hunt – Total Allowable Catch (TAC) 270,000; West Greenland's harp seal hunt – unregulated, but landing c.a. 90,000 animals; and Namibia's Cape fur seal hunt TAC = 86,000) account for approximately 57% of the total number of seals (900,000) allowed to be killed or reportedly killed annual (uncorrected for struck and loss). The total population of seals of the hunted species is 15-16 million animals. (EFSA2007). Annex 1 provides a detailed overview of species and populations of seals that are killed and skinned.

3.1.2. Types of seal hunting

There are different types of seal hunting with different characteristics and motivations, both within and among range states. This leads to different seal hunt management systems. Within all systems improvements can be made. Table 3.1.2.1:

Table 3.1.2.1 Types of seal hunting, Characteristics and focus in seal hunt management systems

Types of seal hunting || Characteristics of the hunt || Focus in seal hunt management system

Commercial non-indigenous hunt || Industrialised hunt Large quotas and catches Organised Often supplementary income for fishermen or other workers || Provision of a basis for a viable industry Employment creation in sealing regions Sustainable use of the marine resources Hunting organisation

Personal non-indigenous hunt - individual small scale || Source of income and contributes to the subsistence of the hunter Dispersed || Sustainable use of the marine resources Hunting methods

Indigenous hunt || Hunt integrated part of the culture and the identity of the members of the society Source of income and contributes to the subsistence of the hunter One-man based activity Opportunistic Dispersed || Maintaining and protecting hunting traditions of indigenous societies Income creation in sealing regions Hunting tools

Recreational hunt || Small scale Activity supplementing primary occupation Comparable to other kinds of spare time activities/hunts Opportunistic Dispersed || Hunt is small scale often aims to reduce the seal population Contribute to pest control Samples from the catch contributes to research Sustainable use of the marine resources

Pest control* || Random or organised Minimise damage of seals on fishing gear Minimise damage to fish stocks || Limit population growth as to reduce damage to fishing gear and potential spreading of infection to other species

By-catch* || Random Seals caught in fishing gear || Invention and use of fishing gear that is seal proof hence reducing the number of seals caught in the gear Compensation to fisheries sector for damage inflicted by seals

*Included though it is not a hunt per se but man-induced killing of seals

Some range states have implemented comprehensive management 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 incorporate animal welfare concerns. Assessment summary sheets per sealing country (see Annex 2) provide an overview of national legislation and enforcement requirements in place and how animal welfare recommendations are carried out in practice.

According to the COWI study findings, the range states can roughly be grouped into three groups, even though it is to be noted that the type of seal hunting varies considerably between the range states, e.g. the EU countries not having any commercial hunting. Seal hunting is comprehensively regulated in Norway and it has the most developed management system. A second group is made up of Canada, Finland, Greenland, Namibia and Sweden - all of these range states have relatively well-developed legal 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 conclusions.

3.1.3. Killing methods

The use of rifles appears to have increased at the expense of hakapiks and other methods. The hakapik is currently used as a means of killing young harp and hooded seals (normally less than 3 – 4 months old) and it is considered effective when sufficient care is taken to apply the blows accurately to the head and to verify their results (EFSA2007).

Netting is usually prohibited for commercial hunting but is practised in traditional subsistence hunting.

Within the EU range states, only shooting is allowed and traps which capture the animals alive.

Table 3.1.3.1 - Methods used to kill seals and their geographic location (EFSA2007)

EFSA concluded that very little information is available on the extent of use of different hunting methods at different times of the year; the efficacy of each of these methods in the different environments; and their respective advantages and disadvantages in relation to animal welfare.

3.1.4. Underlying motives and forces

The overall assessment process conducted by the Commission over the last year has confirmed that there are indeed concerns about the animal welfare aspects of seal hunting. However, it is possible for animal welfare concerns to be minimised. Indeed, EFSA concluded that "it is possible to kill seals rapidly and effectively without causing them avoidable pain or distress. However, the Panel also reported evidence that, in practice, effective and humane killing does not always happen."

It is however clear that best practice is not always being followed and that as a result unnecessary and avoidable negative impacts on animal welfare occur. This is confirmed by the findings of the COWI Assessment Study[8]. Other studies (e.g. by NGOs, industry linked groups) also highlight serious deficiencies and concerns in the hunts, though some of these studies may be biased

One of the requests of the Impact Assessment Board was that this Impact Assessment has to be clear about the number of seals, which are killed in a non-acceptable way. The result of the assessment process however clearly shows that robust, scientifically peer reviewed data are scarce and that it is difficult to quantify. There is though clear evidence of that fact that seals within the varying commercial hunts may be killed in an appropriate manner. However, as noted by EFSA, this does not always happen but there is not enough peer-reviewed evidence to say how often this is the case.

One of the reasons for this lack of evidence is that even though in many seal hunting countries legislation and guidelines for their implementation are in place, there is evidence of problems with implementation and effective enforcement.

Those areas concern

I. Legislation

animal welfare principles – legislation does not enshrine these principles, or has not been developed with the principles in mind;

hunting tools - EFSA conclude that some methods should not be used to kill seals as they are inherently inhumane, e.g. trapping seals underwater that causes death by suffocation;

assuring death by monitoring – legislation does not contain requirements for monitoring and thereby does not oblige the hunter to assure that the seal is irrevocably unconscious before bleeding it out and before continuing to the next seal;

bleeding-out of animals shot or struck –bleeding out stunned animals to ensure death is frequently not carried out in some hunts;

Environmental factors - whilst other methods are not inherently inhumane, they may be practised in such a way as to unnecessarily have welfare implications. For example, shooting in poor environmental conditions (snowstorm, unstable platforms etc) is likely to result in a lower rate of clean shots;

Training of the hunters - some methods, e.g. shooting and hakapik, are only effective if applied properly by trained and competent hunters. In some countries training of sealers is mandatory and only hunters who pass a shooting proficiency test are allowed to kill seals. However, little information recorded by independent observers exists on the effectiveness of the training programmes;

II. Enforcement:

independent monitoring - the independency of inspectors of monitoring the hunt could be improved, even though the practical possibility of monitoring and inspecting the hunt has to be taken into account (environment where the hunt is undertaken / scope of the hunt);

ability of third party to monitor - most of the hunts are not open to third party monitoring or administrative / logistical barriers exist to obtain a licence;

reporting requirements - reporting requirements are more or less developed, however often not formalised;

sanctions and compliance - even though all sealing countries have prescribed maximum penalties for non-compliance in their legislation, the degree to which sanctions are put on hunters infringing the legislation are unclear.

It appears that there is room for improvement in many of the above-mentioned areas for almost all sealing countries by adhering to best practices which have been identified during the assessment process (further explained in chapter 4 – objectives).

Therefore, although it is not possible to say how many seals are killed in an inappropriate manner, there is evidence that the main commercial seal hunts would not satisfy best practice criteria.

3.1.5. Who is affected, in what ways, and to what extent

The general public expressed concerns about the killing and skinning of seals, with sectors requesting seal derived products to be banned on the EU market. These concerns are well documented through a large volume of correspondence and petitions and expressed clearly in the public consultation by internet (see 2.5 – public consultation).

Moreover, the animals themselves being a sentient species are of course affected by the lack of consideration for animal welfare and the use of inappropriate hunting methods.

Concerns for the Inuit people are currently taken into account by existing EU legislation (see 3.2.4.2). However, there are diverging opinions, also among sealing countries, on who Inuit are and what constitutes traditional hunting methods. It is nevertheless acknowledged that seal hunting, irrespective of the methods used, is a part of the cultural inheritance of certain people and certain regions.

The social dimension is also important in local communities within the EU where controlled hunting of seals and sustainable use of the hunted seals are ways to gain local people's (mainly fishermen) acceptance on seal conservation.

3.2. Trade in seal products and related measures in place

3.2.1. Level of trade

Trade data and trade flows are presented in detail in chapter 6.2.3 when describing the baseline for the trade impact analysis based on Eurostat data and national statistics mainly from the year 2006. It is the preferred approach to present the global picture of all trade elements in one chapter rather than to extract some of the specific elements to this chapter.

However, in summarizing some of the elements, it can be said that Denmark and Italy are by far the two largest EU importers of raw fur skin from seal for further processing/sales on the EU market. Denmark imports raw fur skins from Canada and Greenland, while Italy imports raw fur skins from Russia, Finland and the UK (Scotland) – where many of the skins of the latter two originate from outside the EU borders.

While the tanning in Denmark takes place in few locations, there are numerous small furrieries producing the final seal products. Most of these furrieries do, however, not only rely on the supply of seal skins. Similarly, Italy is among the world's leading producers of coats and other clothing items.

With regard to the import of tanned or dressed fur skin of seals, more EU Member States are engaged in this part of the trade. Although Denmark and Italy are the most important traders, Greece and the UK, but also Latvia are significant importers.

With regard to trade data from Canada, it is to be noted that more than 60% of the raw fur skins of seals are exported to Norway, while around a third to the EU – particular Germany (mainly transhipment in Frankfurt) and Finland. With reference to tanned or dressed fur skins, almost 60% are exported to the EU markets (Finland, Greece) while both the US and Turkey are the largest non-EU markets.

As regards Norway, imports of raw fur skins are much more important than exports. However, Norway has large export figures for tanned or dressed fur skins.

It is to be noted that the above description of trade data is not exclusive and only represents some of the more prominent findings.

3.2.2. EU Member States measures / WTO consultations

Several EU Member States are considering, or have already recently introduced, national legislative measures to ban the import and use of seal skins and seal products of certain or all seal species. Hindrances to intra-community trade resulting from a national measure imposing a trade ban may be justified on grounds of public morality, within however the limits set out by the Treaty and the case law of the Court. However, differences between such national measures could affect the functioning of the internal market and/or the public could be confused by the diversity of legal requirements. Hence, it seems to be appropriate to investigate the provision of harmonised rules across the Member States.

In response to the Belgian and Dutch measures, Canada has requested formal WTO consultation with the European Community pursuant to the WTO's Dispute Settlement Understanding. Consultations took place in Brussels on 14th November 2007.

3.2.3. International perspectives

The Commission assessment process in particular the adoption of the EFSA scientific opinion and the action undertaken by some EU Member States led to an intensification of the discussion between the Commission and sealing countries. Some of these countries have already introduced, or have the intention to introduce, measures to address and improve the animal welfare aspects of seal hunting.

3.2.4. Community legislation

3.2.4.1. Community Action Plan on the Protection and Welfare of Animals 2006-2010

The protection of wild animals is covered by the Community Action Plan on the Protection and Welfare of Animals[9]. This approach reflects the Protocol to the Treaty on the Protection of Animals defined as sentient beings. As agreed at the time of the adoption of the Action Plan and in order to support the harmonisation of animal welfare standards adopted in the EU both on public and private bases, the Commission has launched a feasibility study to create a European Centre for the Protection and Welfare of Animals that could serve as reference body to support the measures that could be taken in the future to address the welfare concerns identified in this impact assessment. The European Centre could be developed in a way to assist the Community and Member States in the management of animal welfare issues both at EU and International level. In this way the Community would be served in the future by EFSA in the role of risk assessors and possibly by the future reference centre for the support to the risk management.

Many Member States have already developed applied research centres or network working on animal welfare or animal protection (Sweden, Italy, The Netherlands, UK) but there is no formally established body in any Member States or in the EU mandated to deal with this. Therefore, any calculation of administrative costs to create this entity are difficult to estimate and will in any case depend on how much each Member State has already invested on this issue. Grouping functions to serve different purposes in the animal welfare and protection area will clearly reduce costs and facilitate the efficient implementation of the existing legislation in this area. Today straight requirements in the national and EU animal welfare legislation are in place that are demanding harmonised procedures in Europe to secure the welfare of the animals. The Commission feasibility study is going to deliver options for the creation of the Centre and is examining the most suitable tasks in relation to what already exists at present.

3.2.4.2. The "Seal pups directive"[10]

Existing Community legislation (Council Directive 83/129/EEC as amended by Council Directive 89/370/EEC) already prohibits the importation into the EU Member States of skins of whitecoat pups of harp seals and of pups of hooded seals and products derived therefrom. One of the reasons behind the adoption of the Directive were doubts on the population status of some seal species. This Directive does not apply to products resulting from traditional hunting by the Inuit people. According to the Directive, Member States have to take or maintain necessary measures to ensure that the listed seal pup products are not commercially imported into their territory.

It has to be noted that even though derogation was provided, the Inuit suffered in the 80's from the adverse impacts of this Directive on the image of seal products in general.

3.2.4.3. The "Habitats Directive"[11]

In the EU, all seal species present are protected by the Directive 92/43/EEC on the conservation of natural habitats and of wild fauna and flora, which protects endangered, rare and vulnerable species as well as their habitats through protection schemes provided by that Directive. Even though the main aim of the Directive with regard to the seal species occurring in the EU is to maintain or restore a favourable conservation status, its Article 15 prohibits the use of all indiscriminate means capable of causing local disappearance of, or serious disturbance to, populations of such species. The prohibited methods and means of capture and killing are listed in its Annex VI (a) and the prohibited forms of capture and killing from modes of transport are listed in Annex VI (b).

In addition the Article 14 of the Directive suggests that "regulation of the purchase, sale, offering for sale, keeping for sale or transport for sale of specimens" may be a measure to ensure that exploitation of Annex V species (species whose taking in the wild and exploitation may be subject t management measures) is compatible with it being maintained at a favourable conservation status.

Within EU the Member States are obliged to report every six years on the implementation of the measures taken under this Directive (the latest reporting period covered 2001-2006 and it has revealed information for the first time on the conservation status of all seal species listed under the Directive).

3.2.5. Possible evolution of the problem

If no action is taken at Community level, seal products will continue to be placed on the EU market without any reassurance to the consumer that the animal has been killed and skinned without causing avoidable pain, distress, fear and other forms of suffering.

More EU Member States might therefore undertake individual action in response to the animal welfare concerns expressed by many citizens. Such a situation will lead to a continued fragmentation of the EC's internal market.

Without any action at Community level, it will be difficult to ensure that the animal welfare aspects the killing and skinning of seals can effectively be addressed and that there would be an incentive for sealing countries to improve management methods in accordance with the best practices identified during the assessment process.

3.3. Subsidiarity/necessity test

The White Paper on European Governance, 2001, COM(2001)428 states that "Proposals must be prepared on the basis of an effective analysis whether it is appropriate to intervene at EU level and whether regulatory intervention is needed. If so, the analysis must also assess the potential economic, social and environmental impacts".

While there is also demand for measures at national level, in Europe, the public concern over the animal welfare impact of seal hunting is very high. The European Parliament, the Council of Europe as well as many stakeholders are demanding legislative measures at EU level. The concerns voiced by the public and legislators have to be taken seriously. These concerns are documented through a large volume of correspondence and petitions, and expressed clearly in the public consultation by internet.

Several Member States are also considering, or have already introduced, national legislative measures to ban the import and use of all skins and seal products. Differences between such national measures could affect the functioning of the internal market and/or the public could be confused by the diversity of legal requirements. Hence, it seems to be appropriate to investigate the provisos of harmonised rules across the Member States. Therefore, in case of a possible legislative measure, it appears, that Article 95 EC (internal market) as legal basis would be applicable. Article 133 however, also would be relevant in the context of the proposed measure, which also affects international trade.

The Protocol on the Protection and Welfare of Animals annexed to the EC Treaty by the Amsterdam Treaty sets out key fields of action in which the Community and Member States are to pay full regard to the welfare requirements of all animals in formulating and implementing policies. (see 3.2.4.1)

4. Objectives

The aim of this initiative is in line with the Commissions' strategic objectives and better regulation principles notably to provide effective and efficient measures, ensure a high level of legal certainty across the EU, and thus help to strengthen the Community's credibility in the eyes of its citizens.

In line with the Community Action Plan on the Protection and Welfare of Animals (which reflects the Protocol to the Treaty on the Protection of Animals defined as sentient beings) seals should be protected from acts that cause them avoidable pain, distress, fear and other forms of suffering.

The main overarching objectives are to:

· Protect seals from acts that cause them avoidable pain, distress, fear and other forms of suffering during the killing and skinning process

· Address the concerns of the general public with regard to the killing and skinning of seals

Taking these objectives into account, the following specific objectives have been established:

· Ensure consistency and legal clarity in terms of the requirements for placing seal products on the EU market

· Promote and reward good sealing practices

By means of:

· Laying down concrete rules concerning the placing of seal products on the EU market

· Provide important information to consumers about the manner in which a seal was killed and skinned in a specific sealing country

· Reference to the basic criteria (best practices) highlighted by the results of the overall Commission impact assessment process, which are essential to guarantee advancement in the future in the animal welfare area to step up standards. They are the following:

– On animal welfare principles: Animal welfare principles are highlighted in the applicable hunting legislation - whether this targets seal hunting specifically 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 accordance 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 continuing 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 properly visualised. Other environmental factors, relevant for the hunt in question, are also regulated.

– On training of hunters: A defined level of knowledge and ability of the hunter regarding seal biology, hunting methods and the three step procedure, 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 independency 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.

5. Main policy options

To address the areas of concern identified and described under chapter 3, different legislative and non-legislative policy options have been considered in the context of this impact assessment. Policy options that are not linked directly to the seal hunting management systems as well as those that could be linked to the management system analysis were looked at.

The options were assessed against their relevance in respect of achieving the objectives identified in chapter 4.

5.1. "No additional EU action"

The current assessment process has already had some effect of its own since e.g. some countries are considering to or have already acted to improve the seal hunt situation on the basis of the EFSA report. Continuous monitoring could continue to have a comparable effect even though it might be difficult to implement in practice.

However, in the absence of further EU action, there is no indication that such effort would continue. In addition trade distortion issues would probably not be resolved by themselves. Indeed, it is likely that more Member states would decide in the absence of EU action to impose bans. This would lead to trade deflection and further fragmentation of the EC's internal market.

5.2. Legislative measures

Table 5.2.1 presents the formulations of the legislative measures and their rationale - both with respect to effectiveness/efficiency and with respect to achieving the objectives of the measure, and regarding consistency - i.e. the extent to which the measures are likely to limit trade-offs across the economic, social and animal welfare domain. The measures are sorted so that they start with what immediately appears to be the most wide-ranging. However, a combination of the first two measures - prohibition of placing on the EU market and prohibition of imports/exports – may be the most comprehensive measure.

While the two first measures are not linked to elements of seal hunt management systems, the third and fourth - and possibly also the fifth - could in their final formulations mention such elements.

The table shows that the strict regulatory measures such as total prohibitions of placing on the EU market or import/export bans are considered effective because there will be no or only little doubt about the coverage of the measures - although there might be indirect adverse animal welfare impacts as trade could be shifted to countries with fewer requirements as to how the seal skins have been obtained. Furthermore, they are regarded as efficient in the sense that they only require EU expenditure for enforcement. However, the trade-offs across the animal welfare, economic and social dimensions are likely to be fairly significant. The more targeted - or less strict - regulatory measures are in contrast considered to be less effective and efficient, but in contrast imply lower trade-offs across the animal welfare, economic and social dimensions.

Table 5.2.1 Legislative measures

Formulation || Effectiveness/efficiency || Consistency

Prohibition of placing on the EU market of skins of seals and products derived there from || The measure is effective in the sense that it is without a doubt prohibited to hold any seal skins or seal products physically within the EU territory that are made available and destined for the first time for distribution or direct sale in the EU market. However, (second-hand) seal products already sold once on the EU market are not covered. Furthermore, products that are imported, manufactured or stored within the EU territory but intended for export outside the EU are not covered. These exemptions might reduce the effectiveness of enforcement. The measure is considered efficient in the sense that it only requires expenditure for enforcement. || This comprehensive measure will benefit the animal welfare concerns of the general public regarding seal hunting - at economic costs to the sealers, the seal product manufactures and the Inuit population. However, there is no incentive to improve the welfare of the hunted seal species (which is the main cause for concerns)

Prohibition of imports into the Community of skins of seals and products derived there from (will in practice also imply exports) || The measure is effective in the sense that it is without a doubt prohibited for any seal skins or seal products to enter the customs territory of the Community (with exception of imports of non-commercial nature). Similarly, seal skins and seal products may not leave the customs territory. Products which are not customs cleared are not covered. The measure is considered efficient in the sense that it only requires expenditure for enforcement. || similar to above

Prohibition of placing on the EU market (and/or imports/exports) of skins of seals and products derived there from - if not taken through measures that meet established standards for the hunting of seals || The measure is similar to the above two measures - but excludes seal skins and seal products that stem from approved hunting methods. The measure is therefore likely to be less effective than the above two in the sense that it requires precise definitions/delimitations of approved hunting methods (which can be based on the results of the EFSA opinion and the COWI study) - and there might be unintended ways to show compliance with the established standards. The measure is also considered less efficient in the sense that it requires higher enforcement expenditure than the above two measures. || The trade-offs across the animal welfare, economic and social dimensions are probably lower than for the above two measures. The targeting will hurt the economy where it is supposed to hurt - but at the same time benefit 'best practice' seal hunting and therefore provides an incentive to improve the welfare of hunted seal species.

Harmonised, mandatory labelling system || Such a labelling system (product-based) enabling consumers to distinguish between individual seal products on the basis of welfare considerations t allows selected seal skins and seal products from any range state, if they fulfil the labelling requirements (which can be based on the results of the EFSA opinion and the COWI study). The measure is considered similarly effective as the above measure - for the same reasons. However, it might be slightly less efficient than the above, as it does not contain any direct enforcement measure other than the provision and enforcement of labels. || The trade-offs are similar to for the above measures. However, the economic and social dimension might benefit from a price mark-up on the consumer market and at the same time help to increase the image of seal hunting in general.

Bi-/multilateral agreement(s) with range state(s) || Agreements between the EU and one or more states - and thus possibly defining those sealing countries exempted from the above legislative measures. Hence, effectiveness and efficiency will depend upon the actual content of an agreement. || The trade-offs across the animal welfare, economic and social dimensions will depend upon the actual content of an agreement.

5.3. Non-legislative measures

Table 5.3.1 presents then the formulations of possible non-legislative measures in a similar way to the above mentioned legislative measures. However, it appears immediately that the formulations of the non-legislative measures are less precise, and thus the analysis of them and their implementation in practice might be less easy to handle. This feature is also reflected in the table with respect to the difficulties in explaining the effectiveness, efficiency and consistency of the measures.

Table 5.3.1 Non-legislative measures

Formulation || Effectiveness/efficiency || Consistency

Voluntary labelling systems / development of voluntary standards || An EU-administered voluntary labelling system (product-based) that seal hunters can subscribe to (if they fulfil the labelling requirements) is similar to the above-presented (see Table 5.2.1) harmonised, mandatory labelling system. However, such voluntary system might be less effective than the mandatory - merely because it is voluntary. The level of efficiency might be lower or higher, depending on the costs saved by not making the labelling system mandatory and possibly lower enforcement expenditure. || A voluntary system might encourage a natural self-selection process regarding compliance and thus maintain the balance between the animal welfare, economic and social dimension - i.e. those who pursue the label might benefit more than it costs, and the welfare of the seals is enhanced.

Development of guidelines by an internationally recognised organisation || Best practices on seal hunting methods and seal hunt management systems recommended by an internationally recognised organisation. Such organisation still requires to be identified. . Hence, effectiveness and efficiency will depend upon the actual content of such guidelines. || not possible to comment upon

Information campaigns || An EU information campaign targeted at consumers can, for example, benefit from the results of the public consultation carried out within the present study. An EU information campaign targeted at seal hunters and producers can, for example, benefit from the above mentioned guidelines. The effectiveness and efficiency will depend on the actual information campaign - although the costs involved might be quantifiable from experiences with other similar information campaigns. || It is difficult to say how information campaigns will affect the trade-offs across the economic, social and animal welfare dimensions - since such campaigns might seek to make improvements with respect to all three dimensions.

6. Analysis of impacts

6.1. General remarks

This Impact Assessment combines quantitative and qualitative approaches to ensure that adequate consideration is given to a broad range of direct and indirect economic, social and animal welfare impacts. It is important to emphasise that the quality of the information differs between elements, and for some of these between range states. Furthermore, what can be quantified and qualified depends on the availability of information.

The analysis is based upon the COWI study, the EFSA scientific opinion and results of consultations and data provided by third countries, competent authorities, NGOs and other stakeholders affected such as the Inuit.

6.1.1. Coverage and type of impacts

Table 6.1.1.1 provides information about the likely impacts across the three main policy dimensions: animal welfare, economic and social. The table also emphasises a geographical dimension of the impacts of the measures; partly because some range states are EU member states and other are not; and partly because some measures might depend on the used seal hunting methods and might thus directly affect the range states differently.

The starting point for the selection of impacts is that the analysed policy measures are considered to have little impact at the macro level - for example on the national GDP or total employment situation - in the range states (and the non-range states). At the micro level, however, the impacts will be felt by certain groups of the society - and these groups of the society are considered to be of concern, both in the range states and by the EU, e.g. those who derive their income directly or indirectly from seal hunting.

As explained in chapter 2.1, the issue is not a conservation issue. Therefore, the assessment is limited to discussing the impacts of animal welfare aspects for seals and is to a large extent built upon the EFSA 2007 scientific opinion (EFSA, 2007). The central economic impacts are delimited to those of trade and local economy, while the social dimension concentrates on the conditions for the Inuit population.

Table 6.1.1.1 Type of impact and likely impacts of EU policy measures

Type of Impact || Likely impacts of EU policy measures

Welfare dimension

Welfare of seals || In terms of welfare, the effectiveness of killing methods used for seals vary according to the methods used, the skill of the operators, and the environmental conditions (EFSA, 2007). Hence, policy measures that encourage the use of 'best practices' - e.g. a labelling system - will improve the animal welfare aspects of seals. Policy measures - such as prohibitions of market access for seal products - might reduce the size of the hunting and thus the number of seals suffering. However, animal welfare gains will be reduced by the extent such policy measures imply that seal products are diverted to others markets - which might have lower requirements for animal welfare aspects.

Economic dimension

Trade || Since seal hunting mostly takes place outside the Community territory, any restrictions to market access in the Community will have trade impacts. Trade restrictions on seal skins will directly affect the seal hunters while they indirectly will be affected by reductions in the trade of manufactured seal products. Seal product manufacturers will obviously be affected by the latter restrictions. Furthermore, importers and seal product manufacturers on the Community territory will experience income and production losses. Consumers' right may be reduced, if they can no longer purchase seal products on the EU market. However, trade losses for the exporters will be reduced if seal products are diverted to others markets and of course depend on how important the EU market is at present.

Local economy || While the macroeconomic impact of reducing seal hunting might be limited in the range states - there will be an impact on the incomes of the individual sealers (although state subsidies might alleviate this income loss) and the seal product manufacturers. These activities often take place in remote, coastal areas. Hence, the impacts will in practice depend on the share of income in a local economy from sealing activities - and whether or not there are any other employment/income opportunities.

Social dimension

Inuit population || The impact on the Inuit population follows the impact on the local economy. However, the impact might differ if the policy measures accept the use of traditional hunting methods and/or allows sales of seal products made by the Inuit population. However, policy measures that have adverse impact on the image of seal skins and other seal products will have a negative impact on the Inuit population anyway. The social dimension is also important in local communities within the EU where controlled hunting of seals and sustainable use of the hunted seals are ways to gain local people's (mainly fishermen) acceptance on seal conservation.

Geographical dimension

Seal hunt management system specific impacts || If policy measures - e.g. a prohibition of placing on the EU market or a labelling system - punish certain substandard aspects of the seal hunt management systems, or relate to certain seal species, the impact on the different range states will differ.

6.2. Baseline

The impacts of EU measures are assessed as changes in the conditions - with respects to the welfare of seals, trade, local economy, and the Inuit population - in comparison with a baseline, in the present impact assessment year 2008, even though most of the recently available information about the different elements is from the year 2006.

The socio-economic contexts analysed in the framework of the COWI assessment[12] of the national seal hunt management systems as well as information from additional data sources such as Eurostat and the different national statistical offices provided the starting point for the presentations of this baseline.

6.2.1. Welfare of seals

This type of impact is included in table 6.1.1.1, but it does not as such have a well-specified baseline - i.e. a measurable level of seal welfare. It is not possible to quantify the level of suffering of the animal or the number of seals killed in a particular way. The results of the assessment of the seal hunt management systems clearly indicate that all systems would need improvements to increase the level of welfare (see chapter 3.1.2). The assumed impacts on the welfare are to a large extent embedded in the formulations of the measures.

However, as also mentioned above, animal welfare gains will not arise if seals continue to be hunted in the same way as they are, and seals products are simply diverted to other markets. It is difficult to assess what action a commercial seal hunt will undertake when faced with the possibility of exclusion from the EU market. They will have to choose between improving animal welfare standards (which may not be a costly change), or the economic implications of exclusion from the EU market (which seems to be the recipient of around a third of all existing global trade).

6.2.2. Environmental impacts

If the number of seals being killed is reduced this may have an impact on the respective seal population and consequently on the population of fish on which they rely for food. One of the arguments put forward by fishermen for killing seals is that it safeguards fisheries i.e. that there will be a double whammy, whereby communities lose income from sealing and income from fishing because the increased number of seals reduces fishing opportunities. This is, however, much disputed.

It is difficult to establish a direct link between a seal population and fish stocks in the same area. Marine ecosystems are complex and dynamic and seals are only one of many factors affecting them. Seals eat a wide range of fish and marine invertebrates, many of which are not commercially fished and some of which are themselves predators of commercially fished species. As such, seals may even be positive for fish stocks, and are certainly unlikely to have a significant impact.

Furthermore, the impact of any trade ban on seal products in the EU may not have a significant effect on total seal populations, at least in relation to other factors[13]. This should mean there is no significant impact on the fishing economies.

6.2.3. Trade

The potential EU measures would directly affect the trade flows across the EU border and also between the EU Member States. For this reason, the trade picture is painted in some detail in this chapter so that changes in those flows can be understood. The central data set for the analysis is the Eurostat external trade database. Table 6.2.3.1 shows the seal products covered in this database.

The coverage reflects the present prohibition of the importation into the EU Member States of skins of whitecoat pups of harp seals and of pups of hooded seals. In this context, it must be remembered that the 2006 declaration from the European Parliament also focuses on the regulation of import, export and sale of all products from harp and hooded seals - and not only the pups. However, this distinction of harp and hooded seals is not available in the other trade data sets used in the analysis - and any such distinction in the impact analysis must be based on available data of seal catches by species.

It is important to emphasise that the Eurostat trade data presented below do not cover goods in transit. They exclude extra-EU trade where the goods are placed in a customs warehouse (purely for storage) or given temporary admission inside the EU borders for trade fairs, temporary exhibitions, tests etc. as well as intra-EU trade where the goods are merely passing across a Member State, by any means of transport, but are not stored there for any but transport reasons. This implies that the data for imports of seal products concern only products destined for the EU market and/or where further (substantial) processing takes place.

The trade data can therefore be said to appropriately represent the importance of seal products trade for the EU Member State economies. That said, EU firms doing trade in seal furs will claim the many jobs also are dependent on the not-accounted transit of seal products, for example German (mainly Frankfurt) and Finnish traders; who furthermore are important seen from the Canadian export viewpoint. Hence, the Canadian export-to-EU data presented later in this chapter differ greatly from the Eurostat trade data.

Table 6.2.3.1 Seal products covered in Eurostat trade database

Code || Title

43017010 || Raw fur skins of whitecoat pups of harp seal or blueback pups of hooded seals, whole, with or without heads, tails or paws

43017090 || Raw fur skins of seal, whole, with or without heads, tails or paws (excl. those of whitecoat pups of harp seal or blueback pups of hooded seals)

43021941 || Tanned or dressed fur skins of whitecoat pups of harp seal or blueback pups of hooded seal, whole, with or without heads, tails or paws, not assembled

43021949 || Tanned or dressed fur skins of seal, whole, with or without heads, tails or paws, not assembled (excl. whitecoat pups of harp seal or blueback pups of hooded seal)

43023051 || Tanned or dressed whole fur skins of whitecoat pups of harp seal or blueback pups of hooded seal, and pieces or cuttings thereof, assembled, without the addition of other materials (excl. ''dropped'' fur skins, clothing, clothing accessories and other fur skin articles)

43023055 || Tanned or dressed whole fur skins of seal, and pieces or cuttings thereof, assembled, without the addition of other materials (excl. of whitecoat pups of harp seal or blueback pups of hooded seal, and ''dropped'' fur skins, clothing, clothing accessories and other fur skin articles)

43031010 || Articles of apparel and clothing accessories made of the fur skin of whitecoat pups of harp seal or blueback pups of hooded seal (excl. gloves made of leather and fur skin, footwear and headgear and parts thereof)

Table 6.2.3.2 provides an account of the latest data for a whole year - i.e. 2006 - for the imports in Euro to EU-27 from the eight range states covered by this study, and the exports the other way. The table shows that imports (excluding transit - see above) from non-EU range states mainly come from Greenland and Canada, while the import from Namibia is fairly limited. Intra-EU trade is comparable in size regarding the sales of seal skins on the EU market - for Finland and the UK (Scotland), while the trade figures for Sweden are insignificant. It must here again emphasised that, for example, Canadian sealskins destined for the Italian market but actually entering Finland - are registered as import from Finland by Italy (not transit), while the import from Canada by Finland is registered as transit trade. This kind of registration helps, however, by combining these data with other trade flows and trade data to distinguish transit trade from other trade.

While there is limited export out of EU-27 to Canada, Greenland and Norway, there is a significant export to Russia in particular of tanned or dressed fur skins of seal, whole, with or without heads, tails or paws, not assembled (excl. whitecoat pups of harp seal or blueback pups of hooded seal). Hence, the trade balance (excluding transit - see above) with Russia is much in favour of EU-27.

Table Error! No text of specified style in document..3.2 Trade between EU-27 Member states and 8 range states, Euro, 2006

|| Canada || Finland || UK (Scotland) || Green-land || Namibia || Norway || Russia || Sweden

Import to EU-27 from:

43017010 || 0 || 0 || 0 || 0 || 0 || 0 || 0 || 0

43017090 || 191389 || 931888 || 337817 || 1313000 || 0 || 659 || 186081 || 0

43021941 || 21849 || 0 || 0 || 0 || 0 || 2192 || 0 || 0

43021949 || 461238 || 7582 || 299325 || 60131 || 67079 || 176794 || 0 || 4443

43023051 || 0 || 0 || 1742 || 0 || 0 || 0 || 0 || 0

43023055 || 45563 || 0 || 178239 || 39599 || 0 || 113657 || 0 || 0

43031010 || 0 || 162 || 88150 || 6312 || 0 || 0 || 0 || 1620

Total || 720039 || 939632 || 905273 || 1419042 || 67079 || 293302 || 186081 || 6063

|| || || || || || || ||

Export from EU-27 to:

43017010 || 0 || 0 || 0 || 0 || 0 || 0 || 0 || 0

43017090 || 1251 || 551435 || 2389 || 19608 || 0 || 14108 || 195500 || 0

43021941 || 0 || 0 || 0 || 0 || 0 || 0 || 109774 || 0

43021949 || 24627 || 677193 || 2193682 || 1458 || 0 || 1947 || 2505755 || 0

43023051 || 0 || 0 || 0 || 0 || 0 || 0 || 0 || 0

43023055 || 0 || 0 || 269327 || 2182 || 0 || 0 || 23282 || 0

43031010 || 1062 || 0 || 909209 || 0 || 0 || 36411 || 297931 || 0

Total || 26940 || 1228628 || 3374607 || 23248 || 0 || 52466 || 3132242 || 0

|| || || || || || || ||

Import minus export

43017010 || 0 || 0 || 0 || 0 || 0 || 0 || 0 || 0

43017090 || 190138 || 380453 || 335428 || 1293392 || 0 || -13449 || -9419 || 0

43021941 || 21849 || 0 || 0 || 0 || 0 || 2192 || -109774 || 0

43021949 || 436611 || -669611 || -1894357 || 58673 || 67079 || 174847 || -2505755 || 4443

43023051 || 0 || 0 || 1742 || 0 || 0 || 0 || 0 || 0

43023055 || 45563 || 0 || -91088 || 37417 || 0 || 113657 || -23282 || 0

43031010 || -1062 || 162 || -821059 || 6312 || 0 || -36411 || -297931 || 1620

Total || 693099 || -288996 || -2469334 || 1395794 || 67079 || 240836 || -2946161 || 6063

Source: Eurostat external trade database

Table 6.2.3.3 provides a similar account of the 2006 trade situation, but where the figures are in units - e.g. number of raw fur skins. Although articles of apparel and clothing accessories made of the fur skin of whitecoat pups of harp seal or blueback pups of hooded seal (excl. gloves made of leather and fur skin, footwear and headgear and parts thereof) and possibly other items seem not as fully covered compared with the trade figures in Euro - the table is considered useful for comparisons with other seal product data using such units.

Table 6.2.3.3 Trade between EU-27 Member states and 8 range states, Units, 2006

|| Canada || Finland || UK (Scotland) || Green-land || Namibia || Norway || Russia || Sweden

Import to EU-27 from:

43017010 || 0 || 0 || 0 || 0 || 0 || 0 || 0 || 0

43017090 || 3558 || 9131 || 5064 || 54184 || 0 || 12 || 1407 || 0

43021941 || 200 || 0 || 0 || 0 || 0 || 15 || 0 || 0

43021949 || 6868 || 260 || 4490 || 1900 || 13729 || 3526 || 0 || 88

43023051 || 0 || 0 || 50 || 0 || 0 || 0 || 0 || 0

43023055 || 227 || 0 || 3423 || 605 || 0 || 2409 || 0 || 0

43031010 || 0 || 0 || 0 || 0 || 0 || 0 || 0 || 0

|| || || || || || || ||

Export from EU-27 to:

43017010 || 0 || 0 || 0 || 0 || 0 || 0 || 0 || 0

43017090 || 10 || 1062 || 600 || 168 || 0 || 25 || 1745 || 0

43021941 || 0 || 0 || 0 || 0 || 0 || 0 || 735 || 0

43021949 || 712 || 35 || 6635 || 15 || 0 || 194 || 17425 || 0

43023051 || 0 || 0 || 0 || 0 || 0 || 0 || 0 || 0

43023055 || 0 || 0 || 3421 || 13 || 0 || 0 || 267 || 0

43031010 || 0 || 0 || 0 || 0 || 0 || 200 || 0 || 0

|| || || || || || || ||

Import minus export

43017010 || 0 || 0 || 0 || 0 || 0 || 0 || 0 || 0

43017090 || 3548 || 8069 || 4464 || 54016 || 0 || -13 || -338 || 0

43021941 || 200 || 0 || 0 || 0 || 0 || 15 || -735 || 0

43021949 || 6156 || 225 || -2145 || 1885 || 13729 || 3332 || -17425 || 88

43023051 || 0 || 0 || 50 || 0 || 0 || 0 || 0 || 0

43023055 || 227 || 0 || 2 || 592 || 0 || 2409 || -267 || 0

43031010 || 0 || 0 || 0 || 0 || 0 || -200 || 0 || 0

Source: Eurostat external trade database

While the above two tables show that the trade between EU-27 as a whole and the eight range states differ between range states, the following two tables look into which of the EU-27 Member States - apart from Finland, UK (Scotland) and Sweden - are likely to be affected by an EU measure that puts restrictions on imports of products derived from seal species.

Table 6.2.3.4 shows that Denmark and Italy by far are the two largest EU importers of raw fur skin from seal for further processing/sales on the EU market - and they share the market. Denmark imports raw fur skins directly coming from Canada and Greenland (that are not categorised as goods in transit), while Italy imports raw fur skins from Russia, Finland and the UK (Scotland) - where many of the skins from the latter two originates from outside the EU borders. Greece also has a small share of the skins coming from the two latter range states, i.e. Scotland and Finland, which is imported for further processing.

While the tanning in Denmark takes place in few locations, there are numerous small furrieries producing the final seal products for the markets. Most of these furrieries do not, however, only rely on the supply of seal skins. Similarly, Italy is among the world's leading producers of coats and other clothing items made from seal skin; but the producers are many and also use other types of skin.

Table 6.2.3.4 Import of raw fur skin to EU-27 Member states from 8 range states, Euro, 2006

|| Canada || Finland || UK (Scotland) || Green-land || Namibia || Norway || Russia || Sweden

Austria || 0 || 0 || 0 || 114 || 0 || 0 || 0 || 0

Denmark || 191389 || 0 || 0 || 1312886 || 0 || 0 || 0 || 0

Finland || 0 || 0 || 0 || 0 || 0 || 659 || 0 || 0

Greece || 0 || 60089 || 32433 || 0 || 0 || 0 || 0 || 0

Ireland || 0 || 0 || 280 || 0 || 0 || 0 || 0 || 0

Italy || 0 || 871799 || 281132 || 0 || 0 || 0 || 186081 || 0

Poland || 0 || 0 || 23972 || 0 || 0 || 0 || 0 || 0

EU-27 || 191389 || 931888 || 337817 || 1313000 || 0 || 659 || 186081 || 0

Source: Eurostat external trade database.

Note: Sum of codes 43017010 and 4317090 (see Table 6.2.3.1). Only EU Member states with import of raw fur skin presented in the table.

The picture is somewhat different when it comes to the import of tanned or dressed fur skin of seals. Table 6.2.3.5 shows that more EU Member States are engaged in this part of the trade. Although Denmark and Italy remain important traders, Greece and the UK, but also Latvia are significant importers. Greece deals, for example, with the largest part of the imports coming from Namibia, while the UK is the main trading partner here with Norway. Latvia takes in a sizeable part of such fur skins from Canada.

Table 6.2.3.5 Import of tanned or dressed fur skin to EU-27 Member states from 8 range states, Euro, 2006

|| Canada || Finland || UK (Scotland) || Green-land || Namibia || Norway || Russia || Sweden

Bulgaria || 0 || 0 || 0 || 0 || 0 || 6742 || 0 || 0

Germany || 0 || 0 || 74820 || 0 || 0 || 0 || 0 || 0

Denmark || 275610 || 0 || 0 || 89336 || 0 || 98 || 0 || 0

Estonia || 0 || 1436 || 0 || 0 || 0 || 10998 || 0 || 0

Spain || 0 || 0 || 50751 || 0 || 0 || 1879 || 0 || 0

Finland || 0 || 0 || 0 || 947 || 0 || 726 || 0 || 0

UK || 0 || 0 || 0 || 0 || 0 || 233190 || 0 || 2213

Greece || 67763 || 6146 || 121801 || 0 || 53001 || 0 || 0 || 0

Ireland || 0 || 0 || 31414 || 0 || 0 || 0 || 0 || 576

Italy || 0 || 0 || 186177 || 0 || 14078 || 0 || 0 || 0

Latvia || 139714 || 0 || 0 || 0 || 0 || 0 || 0 || 0

Poland || 45563 || 0 || 0 || 0 || 0 || 0 || 0 || 1654

Portugal || 0 || 0 || 14343 || 0 || 0 || 29856 || 0 || 0

Sweden || 0 || 0 || 0 || 9447 || 0 || 9154 || 0 || 0

EU-27 || 528650 || 7582 || 479306 || 99730 || 67079 || 292643 || 0 || 4443

Source: Eurostat external trade database. Note: Sum of codes 43021941, 43021949, 43023051 and 43023051 (see Table 6.2.3.1). Only EU Member states with import of tanned or dressed fur skin presented in the table.

The description of the baseline for the trade impact analysis has until now concentrated on the situation in 2006. However, the situation has not been stable in the period 1999 to 2006[14] for which Eurostat supplies data. Hence, the possible fluctuations in trade figures - which can be due to good or bad hunts and other factors - must be kept in mind when trying to access the impacts on trade from potential EU policy measures.

While the trade data from Eurostat are sufficient to describe the situation for the EU-27 Member States - hereunder the range states: Finland, UK and Sweden, they do not fully cover the trade of the non-EU range states: Canada, Greenland, Namibia, Norway and Russia. In particular, the exclusion in the Eurostat trade data of goods that are placed in a customs warehouse (purely for storage) or given temporary admission for trade fairs, temporary exhibitions, tests etc. is to some extent inconsistent with the statistics kept by some of these exporters since they actually consider these EU traders as importers of their goods. On the other hand, further EU restrictions on such transit trade might not be that severe - depending on how easily this part of the trade can be shifted to a non-EU country. However, there could be some impacts on transport companies, EU sea- and airport for which, however, it was not possible to provide data.

To ensure the most recent picture, as seen from the different range states' viewpoint, the data used in the following are to the extent possible based on national sources - i.e. the national statistical offices.

Table 6.2.3.6 below shows Canadian export figures provided by Statistics Canada. While the exports of raw fur skins of seals are specifically available, the tanned or dressed fur skins are contained in a group of not-elsewhere-specified fur skins. However, the data are considered sufficient for an indication of relevance of the EU to Canada for its exports.

First and foremost, the table shows that in 2006 more than 60% of the raw fur skins of seal was exported to Norway, while around a third to the EU - in particular Germany (mainly transhipment in Frankfurt) and Finland. As mentioned earlier the exports to these two EU Member States are not registered as imports by Eurostat since this part is considered as transit i.e. the goods are placed in a customs warehouse (purely for storage) or given temporary admission for trade fairs, temporary exhibitions, tests etc. The remaining 6.5% of the exports go primarily to China - hereunder Hong Kong.

Furthermore, almost 60% of tanned or dressed fur skins go to EU markets - mainly whole, not assembled skins, while the export of assembled pieces or cuttings of fur skins is limited. Finland followed by Greece are the main EU importers, while both the US and Turkey are the largest non-EU markets - although these markets are mainly considered to be for other fur skins than from seals.

Table 6.2.3.7 repeats the already described picture for Norway - i.e. that imports of raw fur skins of seal are much more important than exports. Norway exported only 373 fur skins of seal (amounting to around Euro 7,000) of which 12 where registered as EU import (see Table 6.2.3.3). In contrast, the import of sealskins amounted in 2006 to 107,604 skins. Hence, further restrictions of imports of raw fur skins of seals to the EU will only have limited direct implications for Norway. However, the large export figures for tanned or dressed fur skins, whole, not assembled, not mink, sheep, coyote (code 43021909, which include sealskins) show sensitiveness to further regulations for the more processed section of products.

Table 6.2.3.6 Canadian exports, Can$, 2006

|| 430170 - Raw fur skins whole - seal || 430219 - Tanned or dressed fur skins, whole, not assembled, || 430230 - Tanned or dressed fur skins - assembled pieces or cuttings

Austria || 0 || 950 || 13988

Belgium || 0 || 870 || 0

Czech Rep. || 0 || 32860 || 0

Germany || 2091143 || 1711744 || 39586

Denmark || 222556 || 371763 || 3716

Spain || 0 || 100682 || 32599

Finland || 2964716 || 8744547 || 0

France || 0 || 273418 || 0

UK || 0 || 634873 || 5150

Greece || 14529 || 6206711 || 183856

Hungary || 0 || 293018 || 0

Italy || 0 || 615194 || 0

Latvia || 0 || 228528 || 0

Poland || 0 || 360614 || 0

Portugal || 0 || 18140 || 0

Sweden || 0 || 15364 || 12120

EU-27 || 5292944 || 19609276 || 294362

Norway || 10042654 || 104690 || 20912

Namibia || 0 || 18032 || 0

Greenland || 0 || 11014 || 2128

Russia || 0 || 1531820 || 12980

Other range states || 10042654 || 1665556 || 36020

China || 931452 || 834367 || 45270

Hong Kong || 125105 || 2918163 || 33126

South Korea || 2486 || 136274 || 28862

US || 0 || 4136882 || 248630

Turkey || 0 || 3825504 || 0

Other || 0 || 409378 || 105411

Total || 16394641 || 33535400 || 791681

EU-27 share || 32.3% || 58.5% || 37.2%

Other range state share || 61.3% || 5.0% || 4.5%

Source: Statistics Canada.

Note: only those countries are presented to which Canada exported seal products

Table 6.2.3.7 Norwegian exports and imports, 2006

|| Export, NOK || Export, skins || Import, NOK || Import, skins

43017000 - Raw fur skins whole - seal || 57200 || 373 || 49141040 || 107604

43021909 - Tanned or dressed fur skins, whole, not assembled, not mink, sheep, coyote || 107089127 || .. || 15433012 || ..

43023000 - Tanned or dressed fur skins, assembled || 347320 || .. || 8026126 || ..

Source: Statistics Norway

Table 6.2.3.8 indicates that around a fourth of Greenland's export goes to the EU market - i.e. an export of raw fur skins of seal of around Euro 5 million compared with a registered EU import of Euro 1.3 million - excluding goods in transit (Table 6.2.3.2). Putting the size of this export into perspective shows that it amounts to around 1.7% of total Greenlandic exports - that are dominated by the prawn industry with around 53%.

Table 6.2.3.8 Greenlandic exports, 2006

|| Export, DKr

Raw fur skins whole - seal || 36949000

Products of seal skin || 903000

Total || 37852000

Source: Statistics Greenland

There do not seem to be any immediately available Namibian national data sources that can shed further light on the Namibian exports of seal products. However, the cape fur seal (at least until recently) is considered an Appendix II species by the Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES). Appendix II lists species that are not necessarily now threatened with extinction but that may become so unless trade is closely controlled.

Table 6.2.3.9 shows the Namibia exports of cape fur seal skin for 2006 - measured as imports to different countries where Namibia stands as the direct exporter or as the origin of the seal skins imported. The table shows (like Table 6.2.3.5) that Greece is by far the most important EU market for Namibia. However, Turkey, Norway and Hong Kong were in 2006 even more important markets.

Table 6.2.3.9 Namibian exports, no of skins, 2006

|| Number of cape fur seal skins

Germany || 336

Denmark || 150

Greece || 13550

Italy || 300

Poland || 1

EU-27 || 14337

Norway || 15177

Canada || 6510

Other range states || 21687

Hong Kong || 14684

Turkey || 17813

Total || 68521

EU-27 share || 20.9%

Other range state share || 31.7%

Source: CITES trade statistics derived from the CITES Trade Database, UNEP World Conservation Monitoring Centre, Cambridge, UK

Table 6.2.3.10 finally shows the exports from the three EU range states, Finland, UK (Scotland) and Sweden in 2006 - i.e. the exports registered by these member states as not being transit trade. Hence, the data do, for example, not comprise the sales of raw fur skins to Italy from Finland - as registered by Italy (see Table 6.2.3.4), since they originate from outside the EU, mainly Canada.

Table 6.2.3.10 Exports by Finland, UK (Scotland) and Sweden, Euro, 2006

|| || Finland || UK (Scotland) || Sweden

43017010 || Raw fur skins - whitecoat pups of harp seal or blueback pups of hooded seals || 0 || 0 || 0

43017090 || Raw fur skins - other seals || 0 || 3052 || 12098

43021941 || Tanned or dressed fur skins - whitecoat pups of harp seal or blueback pups of hooded seals - not assembled || 0 || 0 || 0

43021949 || Tanned or dressed fur skins - other seals - not assembled || 72238 || 298995 || 80

43023051 || Tanned or dressed fur skins - whitecoat pups of harp seal or blueback pups of hooded seals - assembled || 0 || 0 || 0

43023055 || Tanned or dressed fur skins - other seals - assembled || 0 || 24469 || 0

43031010 || Articles of apparel and clothing accessories - whitecoat pups of harp seal or blueback pups of hooded seals || 6016 || 0 || 9379

Total || || 78254 || 326516 || 21557

|| Share of exports to EU || || ||

43021949 || Tanned or dressed fur skins - other seals - not assembled || 2.5% || 38.1% || 100.0%

Total || || 2.3% || 34.8% || 0.4%

Source: Eurostat external trade database

The figures therefore represent the export of nationally produced goods threatened by new