EN    EN EN 
 
EN    EN  COMMISSION OF THE E UROPEAN COMMUNITIES 
Brussels, 23.7.2008 
SEC(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 
  
SUMMARY OF THE IMPACT ASSESSMENT  
  
ON THE POTENTIAL IMPACT OF A BAN OF PRODUCTS 
DERIVED FROM SEAL SPECIES 
{COM(2008) 469 final} 
{SEC(2008) 2290} 
 
EN 2   EN Executive Summary 
1. In line with its commitment to high an imal 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. 
2. In the framework of this analysis, regul atory frameworks and management practices 
for seal hunting in the different range states were analysed1 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). 
3. The assessment showed that the seal hunt  management systems differ between range 
states - and that within a ll systems improvements can be made. Seals are hunted in 
substantially different contexts . Both the type and size of  the hunt, and th e 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 an d animal welfare, whereas other range 
states' management systems are less well- developed and indicate  less concern about 
animal welfare. 
4. The EFSA scientific opinion indicates that s eals can be killed rapidly and effectively, 
without causing avoidable pa in, distress and suffering, us ing a variety of methods. 
However, there is reported evidence that in  practice effective k illing does not always 
happen and some animals are killed and sk inned in a way, which causes avoidable 
pain, distress and other form of suffering. 
5. 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 prohi bition of placing on th e 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. 
6. 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 transforma tion countries, while 
the social dimension touches mainly upon the conditions for the Inuit population. 
                                                
 
1 Commission study outsourced to the consultancy firm COWI "Assessment of the potential impact of a 
ban of products derived from seal species", April 2008 
2 EFSA independent scientific opinion on the anim al welfare aspects of methods for the killing and 
skinning of seals, Dec. 2007: http://www.efsa.europa.eu/EFSA/efsa_locale-
1178620753812_1178671319178.htm  
 
EN 3   EN 7. 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 a nd other seal products and impor ts of sealskins for further 
processing and exports can continue. The im pacts are assessed to be slightly more 
significant for non-EU range state. This is a re sult of the fact that the size of the seal 
hunts in these non-EU countries are much larger than in th e EU range states, and that 
the EU market - apart for Russia - is of some importance. This option would also 
deny consumers the choice to purcha se seal products in the EU.  
8. 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 cove r transit trade. The impacts would be 
slightly higher for the non-EU range states. Th is 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 a nd 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 sk ins 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. 
9. 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 ge neral. 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. 
10. Bi-/multilateral agreements  between the EU and one or more range states could be 
made, which could enlarge the geographical ar ea 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 es tablished standards as discussed above. 
11. Given the animal welfare concerns expre ssed by the public, nota bly by the European 
Parliament and Member States, stand- alone non-legislative measures are not 
considered sufficient to address the issue. 
 
EN 4   EN 12. The EFSA scientific opinion clearly indicates that there is reported evidence that, in 
practice, effective killing doe s not always happen - which is reinforced by the further 
assessment findings. There are therefore r easonable grounds to c onsider undertaking 
precautionary steps to ensure that products derived from seals, which are killed and skinned in a way that causes them avoida ble pain, distress and suffering, are denied 
access to the European market. 
13. The outcome of the assessment of impact s 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 pai n, 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 to 
transit through, or export fr om, the Community of all seal products. 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 estab lished aimed at ensuri ng that seal products 
whose trade would be possible by derogation to the prohibitions otherwise in force 
would be clearly indicated as coming fr om a country meeting the above-mentioned 
conditions. 
This preferred option would help to ensure that the general public is not confronted 
anymore with those seal products derive d 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.