EN    EN EN 
 
EN    EN  COMMISSION OF THE E UROPEAN COMMUNITIES 
Brussels, 23.7.2008 
SEC(2008) 2290 
  
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} 
{COM(2008) 2291} 
 
EN 2   EN 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 pr ejudice the final form of any decision to be 
taken by the Commission. 
TABLE OF CONTENTS 
1. Executive Summary ..................................................................................................... 5 
2. Procedural issues and consulta tion of interested parties.............................................. 7 
2.1. Overview.................................................................................................................. .... 7 
2.2. Inter-Service Steering Group ....................................................................................... 9 2.3. Independent scientific opinion of the Eu ropean Food Safety Authority (EFSA) on the 
animal welfare aspects of the k illing and skinning of seals......................................... 9 
2.4. The Assessment Study (hereafter re ferred 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 mi ssion 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 hun ts 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 
 
EN 3   EN 3.2.3. International perspectives........................................................................................... 20 
3.2.4. Community legislation............................................................................................... 20 3.2.4.1. Community Action Plan on the Protec tion 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 .......................................................................................................... 4 2 
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 th e 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 inte rnationally recognised organisation ............... 48 
6.6.3. EU information campaigns ........................................................................................ 49 6.6.4. “Sufficient information for action”? .......................................................................... 49 
 
EN 4   EN 7. Comparing the options ............................................................................................... 49 
7.1. Total prohibition of placing on the EU market of seal products................................ 49 7.2. Total prohibition of im ports 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 
 
EN 5   EN 1. E XECUTIVE SUMMARY  
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. 
In the framework of this analysis, regulat ory 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). 
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. 
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. 
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. 
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.e u/EFSA/efsa_locale-1178620753812_1178671319178.htm  
 
EN 6   EN 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.  
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. 
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. 
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. 
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. 
The EFSA scientific opinion cl early 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 
 
EN 7   EN skinned in a way that causes them avoida ble pain, distress and suffering, are denied 
access to the European market. 
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, 
transit through, or export from, the Community of all seal products from a given 
date. Trade in those products would howev er 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 po ssible by derogation to  the prohibitions 
otherwise in force would be clearly indica ted as coming from a country meeting the 
above-mentioned conditions. 
This would help to ensure that the genera l public is not conf ronted anymore with 
those seal products derived from seals ki lled 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 whic h do not cause avoidabl e pain, distress or 
other forms of suffering. In this way, the option would have a di rect impact on the 
application in practice of animal welfare friendly hunting techniques and thus protect 
the animals from unnecessary suffering. 
2. P
ROCEDURAL ISSUES AND CONSULTATION OF INTERESTED PARTIES  
2.1. Overview 
In response to concerns relating to the anim al welfare aspects of seal hunting, several 
EU Member States are considering, or ha ve 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 Eu rope adopted a recommendation on seal 
hunting inviting member and observer stat es 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 im mediately draft a regulation to ban the 
                                                 
3 Council of Europe, Parliamentary Assembly, Recommendation 1776 of 2006 on seal hunting see link: 
http://assembly.coe.int/Main.asp?link=/Documents/AdoptedText/ta06/EREC1776.htm   
 
EN 8   EN import, export and sale of a ll harp and hooded seal products  while ensuring that this 
measure would not have an impact on th e 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 appli cation of humane killing methods and 
sustainability of the hunting quotas. 
The Commission in its res ponse to the European Pa rliament on 16 January 2007 
recognised the high level of public concerns regarding the animal welfare aspects of 
seal hunting and in line with its commitme nt 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 warrant ed by the situation. Elements of the 
assessment are the EFSA scientific opi nion, and a study to support the Impact 
Assessment process carried out for the Co mmission 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 we re at that time no such concerns for 
the species targeted by the European Parliament s 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 Memb er States of skins of whitecoat pups 
of harp seals and of pups of hooded seal s and products derived therefrom, which 
was put in place following doubts on the popula tion status of these seal species; as 
well as  
• EU Wildlife Trade Regulations implemen ting the provisions of  the Convention on 
International Trade in Endangered Species (CITES) in the EU5 . The Convention's 
objective is to ensure that trade only take s 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 spec ies 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 trad e is not detrimental to the survival to 
the species. 
• Furthermore, Directive 92/43/EEC on the c onservation of natural habitats and of 
wild fauna and flora (Habitats Directive) pr otects all seal species occurring within 
EU. Grey seal (Halichoerus grypus), ri nged seal (Phoca hispida bottnica) and 
harbour seal (Phoca vitulina) are listed as  Annex V species which means that their 
                                                 
4 Council Directive 83/129/EEC [amended by Council Directive 89/370/EEC] prohibiting the 
importation into Member States of skins of whitecoat pups, of harp seals and of pups of hooded seals 
(blue-backs) and products derived therefrom 
5 EU Wildlife Trade Regulations implementing the prov ision of the Convention on International Trade in 
Endangered Species (CITES) in the EU: Council Regulation (EC) No. 338/97 of 9 December 1996 and 
Commission Regulation (EC) No. 865/2006 of 4 May 2006. 
 
EN 9   EN exploitation is allowed. However the Memb er States are under the obligation to 
maintain or restore these species at favourable conservation status. 
Consequently, this Commission overall im pact assessment focuses on the animal 
welfare aspect of seal hunting and trad e implications of any measures in all 
respective range states ("rang e states" are to be understood  as all territories where 
seals are present and are (or could be) hunte d, i.e. including EU Member States and 
Overseas Territories). The following countri es have been assessed in detail: Canada, 
Finland, Greenland, Namibia, Norway, Russia, Sweden and United Kingdom 
(Scotland).  
The proposal and this impact assessmen t 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 le d by DG Environment with the participation of the 
following Commission Directorates and Services: Enterprise, External Relations, Health and Consumer Protection, Trade, Se cretariat-General. Other services were 
also contacted but those pref erred 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 th e 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, eff ective and humane killing does not always happen."  
EFSA does not explicitly condemn the curren tly 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 review ed data (see also chapter 
6.6.4), the EFSA Risk Assessment proce ss was conducted in a qualitative way. 
Nevertheless, the general conclusions a nd 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 effec tively, 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 
 
EN 10   EN 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 c an be used to evaluate, with a high 
degree of certainty, the efficacy of th e various killing me thods employed in 
different seal hunts around the world on a quantitative basis. This is why the risk assessment had to take a qualitative approac h. 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 avoi dable 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 fo rce 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 th ey are inherently inhumane e.g. netting 
that traps seals underwater and causes death by suffocati on as well as harpooning 
seals through the snow. 
• Hunters should be trained and competent in the procedures they use, including 
killing methods, monitoring death, uncons ciousness and consciousness, and in 
rapid bleeding and skinning. 
• Independent monitoring of seal hunt s is recommended, thereby meaning 
independent of both industry/co mmercial interests and NGOs.  
• Hunts should be open to inspecti on 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 refer red to as "the COWI study") 
Building upon the EFSA scientific opinion, a study (commissioned by the 
Commission) by the co nsultancy firm COWI7 examined the regulatory frameworks 
for and the management practices  of the different seal hunts. 
                                                 
6 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.e u/EFSA/efsa_locale-1178620753812_1178671319178.htm  
 
EN 11   EN Legislative and enforcement provisions in a number of sealing countries, both within 
the European Community and beyond were a ssessed and best prac tices identified. 
The assessments were based on desk study research and information provided during the overall consultation proce ss - 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 fina l report was submitted to the Commission 
at the beginning of April 2008. 
The study shows that in many seal hunting countries, legi slation and guidelines for 
their implementation are in place, but ther e is evidence of problems with their 
implementation and effective enforcement. Th e study also points at the difficulty in 
establishing a clear link between trade measur es such as a trade ban and the way by 
which those measures would help to im prove the animal we lfare 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 Inte ractive-Policy Maki ng (IPM) tool. The 
consultation provided the possibility for EU  citizens as well as non-EU citizens to 
express their view on regulati on of seal hunting - as an in put 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 la rge 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 ba n. 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, ove r 50% of respondents in each single 
country - apart from Sweden and Namibia - prefer a ban, particularly respondents 
from Canada, UK and Russia, whereas the Nord ic range states show more diversified 
answers. In the EU 14.5% pr efer alternative measures while 6.1% see no need for 
further measures. 
The results show that many respondents ar e against seal hunting for reasons of 
principle - which again may be rooted in  a certain perception of the human-nature 
relation. However, the result s also show that for some  respondents the level of 
acceptability of seal hunting is influen ced by how the seal hunt is managed and 
undertaken - and for what reasons. Hence, th e results can also be used to develop a 
list of factors that - if fu lfilled - will tend towards increa sing the acceptability of seal 
hunting, namely:  
                                                                                                                                                        
 
7 COWI "Assessment of the potential impact of a ban of products derived from seal species", April 2008 
 
EN 12   EN • 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 en tire 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 accep table to the respondents. 
It is important to also hi ghlight 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 s eal 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 4
th 
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 po ssibility of leaving out some important 
scientific evidence. Moreover, the interested parties were invited to comment on some crucial sections (stunning and k illing methods, neurophysiologic aspects, 
education and training of seal ers) 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 k illing 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 associa tions was organised on 14
th January 2008 with the objective 
to receive feed-back on the factual information under the country reporting exercise (national hunt management systems) c onducted in the framework of the COWI 
study, i.e. information on legislation, enfo rcement and the socio-economic contexts 
in the sealing countries.  
 
EN 13   EN 2.6.3. Bilateral meetings with stakeholders 
Bilateral meetings with a whole range of st akeholders (e.g. seali ng countries, animal 
welfare organisations, trade organisations, scie ntists) took place at political as well as 
at technical level. 
2.6.4. Conference participation 
The Commission also participated at th e "International conference on Seals & 
Society Conference ", held from 15th until 19th October 2007 in Vaasa, Finland. 
Governmental representatives, scientis ts, representatives from international 
organisations dealing with marine resour ce 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 a nd on the other hand, to note their concerns. 
2.7. Commission fact-finding mission to Ca nada 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 follo wing an invitation of the responsible 
Canadian Minister. Unfortunately, despite the investment and th e 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 Ma y 2008. The Board issu ed its opinion on 23 
May 2008. The Board recommended that the re port should provide more analysis as 
to the effectiveness of the various opti ons including i) asse ssing potential trade 
diversion resulting from import bans; ii) cl arifying further the scale of the problem 
by better estimating the proportion of EU trad e 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 cer tification and labelling of seal products 
resulting from acceptable killing methods. The report should also provide a clear analysis of the content of the preferre d policy package, its overall impact, and 
specific impacts on transit trade, Inuit activity and fish stocks. The recommendations of the Board have been incorporated in to the present vers ion of the report. 
3. P
ROBLEM DEFINITION  
3.1. Animal Welfare Problems during the seal hunts relating to seals suffering 
avoidable pain, distress, fear a nd other forms of suffering  
Seal hunts have occurred in various parts of the wo rld throughout history, and the 
different stunning and killing methods used have been documented in various ways.  
 
EN 14   EN 3.1.1. Description of the hunts 
There are thirty-three existing species of pi nnipeds (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 se als, grey seals, hoode d seals and Cape fur 
seals. The three largest seal hunts (Can ada'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 Namibi a's Cape fur seal hunt TAC = 86,000) 
account for approximately 57% of the tota l number of seals (900,000) allowed to be 
killed or reportedly killed annual (uncor rected 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 sp ecies and populations of seals that are 
killed and skinned. 
3.1.2. Types of seal hunting 
There are different types of seal hunti ng with different characteristics and 
motivations, both within and among range st ates. This leads to different seal hunt 
management systems. Within all sy stems improvements can be made. Table 3.1.2.1:  
Table 3.1.2.1 Types of seal hunting, Char acteristics 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 regionsSustainable use of the marine resourcesHunting 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 
 
 
EN 15   EN 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 cat ch 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 an d animal welfare, whereas other range 
states' management systems are less we ll-developed and to a lesser degree 
incorporate animal welfare concerns. A ssessment summary sheets per sealing 
country (see Annex 2) provide an overview of national legislation and enforcement 
requirements in place and how animal welf are 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 comprehens ively 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 regardi ng enforcement and training require ments. A third group consists 
of Russia and the UK. For both of thes e, data are insufficient to make sound 
conclusions.  
3.1.3. Killing methods 
The use of rifles appears to have increas ed 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 ol d) 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. 
 
EN 16   EN Within the EU range states, only shooti ng is allowed and traps which capture the 
animals alive. 
Table 3.1.3.1 - Methods used to kill seal s and their geographic location (EFSA2007) 
 
EFSA concluded that very little informati on 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 respectiv e 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 seal s 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 impact s on animal welfare occur. This is 
 
EN 17   EN confirmed by the findings of the COWI Assessment Study8. Other studies (e.g. by 
NGOs, industry linked groups) also  highlight serious deficien cies and concerns in the 
hunts, though some of these studies may be biased  
One of the requests of the Impact Assessmen t Board was that this Impact Assessment 
has to be clear about the number of seal s, which are killed in a non-acceptable way. 
The result of the assessment process however clearly shows that robust, scientifically 
peer reviewed data are scar ce and that it is difficult to  quantify. There is though clear 
evidence of that fact that seals within the varying comme rcial 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 eviden ce is that even thou gh in many seal hunting 
countries legislation and guidelines for th eir implementation are in place, there is 
evidence of problems with implementa tion 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. trappi ng seals underwater th at causes death by 
suffocation; 
assuring death by monitoring – legislati on 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 co ntinuing to the next seal; 
bleeding-out of animals shot or struck –bl eeding out stunned animals to ensure death 
is frequently not carried out in some hunts; 
Environmental factors - whils t other methods are not inhe rently inhumane, they may 
be practised in such a way as to unneces sarily 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 c ountries training of 
sealers is mandatory and only hunters wh o pass a shooting proficiency test are 
allowed to kill seals. However, little info rmation recorded by independent observers 
exists on the effectiveness of the training programmes; 
                                                
 
8 There are also logistical difficulties inherent in assessing objectively the processes involved when these 
hunts are conducted under very different, remote, uncontrolled and unverifiable conditions. 
(EFSA2007) 
 
EN 18   EN II. Enforcement :  
independent monitoring - the independenc y of inspectors of  monitoring the hunt 
could be improved, even though the prac tical 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 requirement s are more or less developed, however 
often not formalised; 
sanctions and compliance - even though al l sealing countries have prescribed 
maximum penalties for non-compliance in th eir legislation, the degree to which 
sanctions are put on hunters infri nging the legislation are unclear. 
It appears that there is ro om for improvement in many of the above-mentioned areas 
for almost all sealing countries by adhe ring to best practices which have been 
identified during the assessment process (furth er explained in chap ter 4 – objectives).  
Therefore, although it is not possible to say how many seals are killed in an 
inappropriate manner, there is evidence th at 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 skinni ng of seals, with 
sectors requesting seal deri ved products to be banned on the EU market. These 
concerns are well documented through a large volume of correspondence and 
petitions and expressed clearl y in the public consultation by internet (see 2.5 – public 
consultation). 
Moreover, the animals themselves being a se ntient species are of course affected by 
the lack of consideration for animal we lfare 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 ar e diverging opinions, also among sealing 
countries, on who Inuit are and what cons titutes 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 a nd sustainable use of the hunted seals are ways to gain 
local people's (mainly fishermen)  acceptance on seal conservation. 
 
EN 19   EN 3.2. Trade in seal products a nd 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 analys is 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 ra ther 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 sk ins from Russia, Finland and the UK 
(Scotland) – where many of the skins of th e 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 s eal skins. Similarly, Italy is among the world's leading 
producers of coats and other clothing items. 
With regard to the import of tanned or dr essed fur skin of seals, more EU Member 
States are engaged in this part of the tr ade. 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 skin s 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 s eal skins and seal 
products of certain or all seal species. Hi ndrances to intra-comm unity 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 su ch 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 s eems to be appropriate to investigate the 
provision of harmonised rules across the Member States. 
In response to the Belgian and Dutch meas ures, Canada has requested formal WTO 
consultation with the European Community pursuant to the WTO's Dispute 
 
EN 20   EN Settlement Understanding. Consultations t ook place in Brussels on 14th November 
2007. 
3.2.3. Internationa l perspectives 
The Commission assessment process in particular the adoption of the EFSA 
scientific opinion and the ac tion undertaken by some EU Member States led to an 
intensification of the di scussion between the Commi ssion and sealing countries. 
Some of these countries have already intr oduced, or have the intention to introduce, 
measures to address and improve the an imal welfare aspects of seal hunting. 
3.2.4. Community legislation 
3.2.4.1. Community Action Plan on the Prot ection and Welfare of Animals 2006-2010 
The protection of wild anim als is covered by the Co mmunity Action Plan on the 
Protection and Welfare of Animals9. This approach reflects th e Protocol to the Treaty 
on the Protection of Animals defined as sentie nt beings. As agreed at the time of the 
adoption of the Action Plan and in orde r 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 co uld serve as refere nce 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 deve loped in a way to 
assist the Community and Member States in the management of animal welfare issues both at EU and Inte rnational 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 suppor t to the risk management. 
Many Member States have already develope d applied research centres or network 
working on animal welfare or animal pr otection (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, a ny 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 th e most suitable tasks in relation to what 
already exists at present. 
                                                
 
9 Community Action Plan on the Protection and Welfare of Animals 2006-2010 {SEC(2006) 65} 
 
EN 21   EN 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 proh ibits 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 ev en though derogation was provide d, the Inuit suffered in the 
80's from the adverse impacts of this Di rective 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 vulnerab le 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 mean s of capture and killing are listed in 
its Annex VI (a) and the prohibited form s of capture and killing from modes of 
transport are listed in Annex VI (b). 
In addition the Article 14 of the Directive suggests that "regulat ion 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 A nnex V species (species whose taking in the 
wild and exploitation may be subject t mana gement measures) is compatible with it 
being maintained at a favour able conservation status. 
Within EU the Member States are obliged to report every six years on the 
implementation of the measures taken unde r 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, se al products will continue to be placed on 
the EU market without any reassurance to the consumer that th e animal has been 
                                                
 
10 Council Directive 83/129/EEC [amended by Council Directive 89/370/EEC] prohibiting the 
importation into Member States of skins of whitecoat pups, of harp seals and of pups of hooded seals (blue-backs) and products derived therefrom 
11 Council Directive 92/43/EEC of 21 May 1992 on the conservation of natural habitats and of wild fauna 
and flora 
 
EN 22   EN 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 w ill be difficult to ensure that the animal 
welfare aspects the killing a nd skinning of seals can effectively be addressed and that 
there would be an incentive for sealing c ountries to improve management methods in 
accordance with the best pr actices identified during th e assessment process. 
3.3. Subsidiarity/necessity test 
The White Paper on European Gove rnance, 2001, COM(2001)428 states that 
"Proposals must be prepared on the basis of  an effective analys is whether it is 
appropriate to intervene at EU level and wh ether regulatory intervention is needed. If 
so, the analysis must also assess the pot ential 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 c oncerns voiced by the publ ic and legislators 
have to be taken seriously. These concer ns are documented through a large volume 
of correspondence and petitions, and expres sed clearly in the public consultation by 
internet. 
Several Member States are also consider ing, or have already introduced, national 
legislative measures to ban the import a nd use of all skins and seal products. 
Differences between such national measur es 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 appr opriate to investig ate 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, al so 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. O
BJECTIVES  
The aim of this initiative is in line w ith the Commissions' strategic objectives and 
better regulation principles notably to pr ovide 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. 
 
EN 23   EN In line with the Community Action Plan on the Protection and Welfare of Animals 
(which reflects the Protocol to the Treat y 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, th e following specific obj ectives 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 pr actices) highlighted by the results of the 
overall Commission impact assessment pro cess, 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 legisla tion - whether this targets se al hunting specifically or 
hunting in general.  
– On hunting tools:  The characteristics of the we apons used to kill seal are 
specified. It is made explicit in the le gislation which weapons are allowed for 
stunning and/or killing pups and which ar e allowed for stunning and/or killing 
adult seals. The requirements to the w eapons 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 con tinuing to the next 
seal. 
 
EN 24   EN – 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 stab le and that the target can be properly 
visualised. Other environmental factors, re levant 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 met hods and the three step procedure, 
hereunder practical use of the hunting t ools, e.g. shooting tests, are required. 
– On independent monitoring : A system for monitoring and observation of the 
hunt, securing regular supervis ion 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 admi nistrative or logistic barriers. 
– On reporting requirements : Clear requirements for reporting targeting both 
hunters and inspectors. There are require ments to where and when animals are 
killed and weapons and ammunition used. Also the range of relevant 
environmental factors (weather condi tions, etc.) should be reported. 
– On sanctions and compliance : Statistical information on the hunt should be 
compiled and systemised. 
5. M AIN POLICY OPTIONS  
To address the areas of concern identifie d 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 th e EFSA report. Continuous m onitoring could continue to 
have a comparable effect even though it mi ght 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 woul d lead to trade deflection and further 
fragmentation of the EC's internal market.  
 
EN 25   EN 5.2. Legislative measures 
Table 5.2.1 presents the formulations of the legislative measures and their rationale - 
both with respect to effectiveness/effici ency and with respect to achieving the 
objectives of the measure, and regarding c onsistency - i.e. the extent to which the 
measures are likely to limit trade-offs acro ss the economic, social and animal welfare 
domain. The measures are sorted so that th ey start with what immediately appears to 
be the most wide-ranging. However, a co mbination 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 possibl y 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 welf are impacts as trade could be shifted to 
countries with fewer requirements as to how the seal skins ha ve been obtained. 
Furthermore, they are regarded as efficien t in the sense that they only require EU 
expenditure for enforcement. However, th e 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 trad e-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 ar e 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 stor ed within the EU 
territory but intended for export outside the 
EU are not covered. These exemptions might reduce the effectivene ss 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 The measure is effective  in the sense that it is similar to above 
 
EN 26   EN imports into the 
Community of skins of seals and products derived there from (will in practice also imply exports) 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. 
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 produ cts 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. 
 
EN 27   EN 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 legi slative measures. However, it appears 
immediately that the formulations of the non-legislative measures are less precise, 
and thus the analysis of them and their im plementation 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 requi res 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. It is difficult to say 
how information campaigns will affect the trade-offs across the economic, social 
 
EN 28   EN 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. and animal welfare 
dimensions - since such campaigns might seek to make improvements with respect to all three dimensions.  
6. A NALYSIS 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 thir d countries, competent authorities, NGOs 
and other stakeholders aff ected 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 ar e 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 se lection 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 consider ed to be of concern, both in the range 
states and by the EU, e.g. those who derive th eir 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 delimite d to those of trade and local economy, 
while the social dimension concentrates on the conditions for the Inuit population. 
 
EN 29   EN 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 effectiv eness 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 th e size of the hunting a nd thus the number of 
seals suffering. 
However, animal welfare gains will be reduced by the extent such 
policy measures imply that seal produc ts 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 affe cted by reductions in the trade of 
manufactured seal products. Seal product manufacturers will obviously 
be affected by the latter restrictions. 
Furthermore, importers and s eal product manufacturers on the 
Community territory will experien ce 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 a nd of course depend on how important 
the EU market is at present. 
Local economy While the macroeconomic im pact of reducing seal hunting might be 
limited in the range states - there will be an impact on the incomes of the individual sealers (although stat e subsidies might alleviate this 
income loss) and the se al 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. 
 
EN 30   EN Social dimension  
Inuit population The impact on the Inuit popul ation 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 importa nt in local communities within the 
EU where controlled hunting of seal s 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 prohibitio n of placing on the EU market or a 
labelling system - punish certain s ubstandard 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, tr ade, local economy, and the I nuit population - in comparison 
with a baseline, in the present impact asse ssment 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 assessment12 
of the national seal hunt management system s as well as information from additional 
data sources such as Eurostat and the diffe rent national statistical offices provided 
the starting point for the pres entations 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 assessmen t of the seal hunt management systems 
clearly indicate that all sy stems would need improvements to increase the level of 
welfare (see chapter 3.1.2). The assumed imp acts on the welfare are to a large extent 
embedded in the formulations of the measures. 
                                                
 
12 Assessment of the potential impact of a ban of products derived from seal species, April 2008, COWI 
 
EN 31   EN 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 possibil ity of exclusion from the EU market. 
They will have to choose between improvi ng 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 ex isting 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 w ill 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 popul ation and fish stocks in the 
same area. Marine ecosystems are comple x and dynamic and seals are only one of 
many factors affecting them. Seals eat a wide  range of fish and ma rine invertebrates, 
many of which are not commercially fish ed and some of which are themselves 
predators of commercially fished species. As such, seals may even be positive for fish stocks, and are certainly unlik ely 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 relatio n to other factors
13. This 
should mean there is no significan t 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 an alysis is the Eurost at external trade 
database. Table 6.2.3.1 shows the seal pr oducts covered in this database.  
The coverage reflects the present prohibiti on 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 sa le 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. 
                                                
 
13 The basis for this assumption is firstly the size of s eal hunts. In a typical seal  hunt, for example, maybe 
around 2-5% of the seal population is killed in co mmercial hunting each year. It is unclear whether 
killing seals on such a scale has an impact on the seal population though there are claims that this is the 
case (there is some evidence of changes in seal popul ations but this may be for other factors, such as 
environmental or disease factors).  
 
EN 32   EN It is important  to emphasise that the Eurostat tr ade data presented below do not cover 
goods in transit. They excl ude 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 exhibiti ons, 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 bu t transport reasons. This implies that the 
data for imports of seal products concern only products destined for the EU market 
and/or where further (substan tial) processing takes place. 
The trade data can therefore be said to a ppropriately represent the importance of seal 
products trade for the EU Member State ec onomies. 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 (mai nly Frankfurt) and Fi nnish traders; who 
furthermore are important seen from the Canadian export viewpoint. Hence, the Canadian export-to-EU data pr esented later in this chap ter differ greatly from the 
Eurostat trade data. 
 
EN 33   EN 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, a nd 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 add ition 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 acce ssories made of the fur skin of 
whitecoat pups of harp seal or blueback pups of hooded seal (excl. gloves made of leather and fur ski n, 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 ei ght 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 th e EU market - for Finland and the UK 
(Scotland), while the trade fi gures for Sweden are insignificant. It must here again 
emphasised that, for example, Canadian seal skins 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 Finl and is registered as transit trade. This 
kind of registration helps, however, by comb ining these data with other trade flows 
and trade data to distinguish tr ansit trade from other trade. 
 
EN 34   EN While there is limited export out of EU- 27 to Canada, Greenland and Norway, there 
is a significant export to Russia in particul ar of tanned or dressed fur skins of seal, 
whole, with or without head s, tails or paws, not assemb led (excl. white coat pups of 
harp seal or blueback pups of hooded se al). 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 
 
EN 35   EN 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 fu r 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 pr oduct 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 th e trade between EU-27 as a whole and the 
eight range states differ between range st ates, the following two tables look into 
which of the EU-27 Member States - apar t from Finland, UK (Scotland) and Sweden 
- are likely to be affected by an EU measur e that puts restrict ions 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 proc essing/sales on the EU market - and they 
share the market. Denmark imports raw fur skins directly comi ng from Canada and 
 
EN 36   EN Greenland (that are not categor ised as goods in transit), while Italy imports raw fur 
skins from Russia, Finland and the UK (S cotland) - where many of the skins from 
the latter two originates from outside the EU borders. Greece al so has a small share 
of the skins coming from the two latter range stat es, 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 fo r 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 a nd 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 ta kes in a sizeable part of such fur skins 
from Canada. 
 
EN 37   EN 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 situati on has not been stable in 
the period 1999 to 200614 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 suffi cient 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 ra nge states: Canada, Greenland, Namibia, 
Norway and Russia. In particular, the excl usion in the Eurostat  trade data of goods 
                                                
 
14 Eurostat trade data for 2007 are still incomplete. 
 
EN 38   EN that are placed in a customs warehouse ( purely for storage) or given temporary 
admission for trade fairs, temporary exhibi tions, 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 tr ansit trade might not be that severe - de pending 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 ra nge 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 seal s are specifically avai lable, 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 ar ound a third to the EU  - in particular 
Germany (mainly transhipment in Frankfur t) and Finland. As me ntioned earlier the 
exports to these two EU Member States ar e not registered as imports by Eurostat 
since this part is considered as trans it i.e. the goods are pl aced in a customs 
warehouse (purely for storag e) or given temporary ad mission for trade fairs, 
temporary exhibitions, tests etc. The remain ing 6.5% of the exports  go primarily to 
China - hereunder Hong Kong. 
Furthermore, almost 60% of tanned or dre ssed fur skins go to EU markets - mainly 
whole, not assembled skins, while the expor t 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 impor tant 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 contra st, 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 sealskin s) show sensitiveness to further 
regulations for the more pro cessed section of products. 
 
EN 39   EN 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 6206 711 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 
 
EN 40   EN 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 ar ound 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 th is export into perspective shows that it amounts to 
around 1.7% of total Greenlandic exports - th at 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 Enda ngered Species of Wild Fauna and Flora 
 
EN 41   EN (CITES). Appendix II lists species that ar e 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 regist ered by Italy (see Table 6.2.3.4), since they 
originate from outside th e EU, mainly Canada.  
 
EN 42   EN 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 clot hing 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 EU policy measures - while excluding th e activities of the traders of transit 
goods. However, for Finland and Sweden only a limited share of this export is sold to 
other EU Member States. In regards to UK,  it is surprising that the UK has export of 
raw seal skins as neither commercia l nor recreational hunt is legal. 
For the last range state covered by this study, Russia , it has not been to obtain 
additional trade data from national Ru ssian sources. Such lack of Russian 
information is also reflected in the respect ive description of the range state seal hunt 
management system (see Annex 2). Any a ssessment of the trade impacts of policy 
measures for Russia will have to re ly on other available information. 
6.2.4. Local Economy 
In general, the impacts on local economies can mainly be derived from the impacts 
on trade. The local-economy focus is thus on how this impact will be felt by certain 
groups of the society - i.e. from  a distributional impact viewpoint. 
 
EN 43   EN The assessment of the local economy is limited by the fact that there is no 
unambiguous definition of local economy  - although for the seal hunt issue the 
interest is centred on small coastal communities. Furthermore, to reach at widely-accepted analyses for such local economies, it would have been beneficial to base the 
analyses on official data
.  
However, there is only little local economy information available to investigate when 
addressing a baseline for this assessment. Furthermore, such information is not fully comparable between the range states – and for some range states, particularly Namibia and Russia, the information could not be obtained. Table 6.2.4.1 shows the extent to which there are local economie s that depend on seal hunting, the general 
economic/employment situation in such econo mies compared with the rest of the 
countries, and whether there ar e alternative income  sources to substitute any declines 
in incomes for sealing. With re spect to the latter , the level of subsidies (if any) to 
sealing (communities) should also be consider ed - i.e. whether they will be increased 
to compensate for any income declines; alt hough this is an  issue of the range states 
regional income redistribution policies. The table indicates that local-economy 
concerns predominantly are found in Canada and Greenland. 
Table 6.2.4.1 Seal product dependent local ec onomy characteristics in range states 
 Canada Finland Green-land Namibia Norway Russia Sweden UK  
(Scotlan
d) 
Income from 
sealing 15-35% of 
local  
economy insignifica
nt 50% of 
households 
hold  
licences  only 3 to 5 
vessels 
participate  insignificant, 
only 50 
hunters Insignifi
cant 
Unemploym
ent 30pp 
above 
national 
level        
Alternative 
income  tourism 24% of 
hunters 
have 
additional 
occ. eco-
tourism tourism sales go 
to non-EU  tourism 
Source: COWI study, co untry assessments 
The information in the above table can be regarded as too scarce for a local economy 
assessment. 
6.2.5. Inuit population 
As emphasised before, there are diverging opinions on who the Inuit are and what 
constitutes a traditional hunting method.  
The impact on the Inuit population from any policy measures will be broadly in line 
with the impact on the local economy, where Inuit hunting is for commercial reasons. However, in some areas the majority of Inuit hunting seems to be for subsistence 
reasons, with no seal products subsequen tly entering onto the market. Although, the 
impact might differ if the policy measur es accept the use of traditional hunting 
methods and/or allows sales of seal products made by the Inuit population. However, the experience from the EU ban on certai n seal products from 1983, which excluded 
 
EN 44   EN this part of the hunt, is that policy measur es that have adverse impacts on the image 
of seal skins and other seal products wi ll have a negative impact on the Inuit 
population anyway. 
6.3. Impact of prohibition of placing on the EU market of skins of seals and 
products derived therefrom 
This measure would ban the distribution or direct sale in the EU market of such 
products y within the EU te rritory. Hence, the measur e would not cover goods in 
transit - such as the large transhipments of seal skins taking place through Germany 
(mainly Frankfurt). Furthermore, products th at are manufactured in  the EU territory 
but intended for export outside the EU are not covered. 
Table 6.3.1 shows that a total prohibition of placing on the EU market is assessed to 
have minor economic impacts on the EU Member States. This assumes, however, that transhipments of sealsk ins and other seal products, a nd imports of sealskins for 
further processing and exports continue. The sealing in Finland and Sweden is 
anyway mostly characterised as having cultu ral and recreational roles in the coastal 
communities, rather than being trade orient ed. Furthermore, in the UK (Scotland) the 
hunt is targeted at the killing of seals in the vicinity of fi shing, rather than for the use 
of the skin. However, the UK does process s ealskins where more than a third of this 
produce is sold on the EU market. 
Table Error! No text of specified style in document. .1 Impacts of prohibition of 
placing on the EU market of skins of se als and products derived therefrom - EU 
Member States 
Finland Sweden UK  
(Scotland)  Other EU 
Minor  - for sealers 
and seal product manufactures since 
only a small share is 
sold on EU markets. Minor
 - for sealers 
and seal product manufactures since 
only a small share is 
sold on EU markets. Medium
 - since more 
than a third of seal product exports go to 
other EU Member 
States; but no impact 
on local communities. Minor
 - although some impact for a few 
manufactures of fur of sealskin in Denmark, Italy and Greece i.e. with respect to the sales 
on the EU market, since they still can import 
sealskins for manufacturing and sales to 
non-EU countries. 
Source: COWI assessments 
Table 6.3.2 shows that the impacts are asse ssed to be slightly higher for non-EU 
range state. This is a result of  the fact that the size of th e seal hunts in these countries 
is much larger than in EU range states, and that the EU market - apart from for 
Russia - is of some importance. The assessm ent does not take into account the signal 
value, i.e. image effect that an EU ban will have on the use of product of seal 
products - hereunder price levels if  the products go out of fashion. 
 
EN 45   EN Table Error! No text of specified style in document. .2 Impacts of prohibition of 
placing on the EU market of skins of se als and products derived therefrom - non-EU 
range states 
Canada Greenland Namibia Norway Russia 
Medium  - since a 
large share of exports to EU is for 
re-export outside the 
EU, but the 
significant amount 
that ends up in Italy 
via Finland will be 
affected to the extent 
the Italian produce is 
sold on the EU 
market. Medium
 - since a 
fourth of exports are designated EU 
markets - and so 
local sealing 
communities will be 
affected. Medium
 - since a fifth 
of exports are designated EU 
markets - and so 
local sealing 
communities will be 
affected. Medium
 - covering no 
impact regarding raw sealskin exports and 
thus sealers in the 
local communities, 
while there is a 
significant export of 
tanned or dresses 
skins to the EU. Minor
 - since few 
seal Russian sealskins are 
assessed to end up 
on the EU market. 
Source: COWI assessments 
A prohibition of market access for seal pr oducts may initially reduce demand for seal 
products, thus impacting on the size of the hunt and thus the number of seals 
suffering. It would thus increase animal we lfare of seals - the 2006 declaration from 
the European Parliament actually focuses on the regulation of import, export and sale 
of products from harp and hooded seals only. Table 6.3.3 indicates that a limitation 
to these two species will eliminate la rgely the negative economic impacts for 
Namibia and somewhat relieve impacts for Greenland. In contrast, the measure will 
fully affect the Canadian and Norwegian hunts. 
Table Error! No text of specified style in document. .3 Number of seals caught in 
2006 
 Canada Finland 
(2005)  Green-
land 
(2005)  Namibia Norway 
(2004)  Russia Sweden UK(1)  
(Scotland)  
Harp and 
hooded seals 354744 0 94447 0 15295 na 0 not 
relevant 
Total seals   355521 514 184220 83100 15597  na 100 not 
relevant 
Share of harp 
and hooded 99.8% 0.0% 51.3% 0.0% 98.1%  na 0.0% not 
relevant 
Source: COWI assessments 
Note: (1) The hunt is targeted at the killing of seals in the vicinity of fishing, rather than for the use of 
the skin. 
As mentioned several times already, the a ssessment of the seal hunt management 
systems (see Annex 2) - together with th e results of the EFSA opinion - identified 
'best practices' of the hunt (see chapter 4) that can be used for establishing standards 
for the hunting of seals. Precise references  to practices have, however, still to be 
developed. Since the above assessed prohibition of placing on the EU market mainly have an impact on the non-EU range stat es, such limited measure will only make a 
real difference if it addresses elements  of the hunt in these range states. 
 
EN 46   EN 6.4. Impact of prohibition of imports into  the Community of skins of seals and 
products derived therefrom 
The second measure would prohibit any seal  skins or seal products from third 
countries entering 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. 
In principle, such formulation of a meas ure does not cover goods in transit - i.e. 
which are placed in a customs warehouse ( purely for storage) or given temporary 
admission for trade fairs, temporary exhibi tions, tests etc. However, banning imports 
on the basis of public morality might not  go well together with allowing such 
transhipments. Hence, the assessment looks al so into the impact of extending such a 
ban to transit trade. 
Table 6.4.1 shows that a total prohibition of imports and exports will have medium 
economic impacts on EU Member States, a lthough the impacts may be significant for 
Finland and Germany if such ban is extended to r transit trade. Apart from this, the impacts of this measure are not expected  to differ much from the impacts of a 
prohibition of placing on the EU market. However, a combination of the two 
measures – which must be recognized to be the most comprehe nsive measure - will 
have additional impact. 
Table 6.4.1 Impacts of prohibi tion of imports (and exports) into the Community of 
skins of seals and products derived therefrom - EU Member States 
Finland Sweden UK  
(Scotland)  Other EU 
Medium  - although 
the trade in Finnish product is small and 
exported to outside 
the EU, the trade of 
Canadian skins e.g. 
for the Italian market 
will partly cease. 
 Minor
 - for sealers 
and seal product manufactures, 
although most 
Swedish products are 
exported to outside 
the EU. Medium
 - since more 
than 60% of seal product exports go 
outside the EU; and 
the UK also has a 
trade in non-UK skins 
for the Italian market, 
and some to Greece 
and Poland. 
 Medium
 - impact for a few manufactures of 
fur of sealskin in Denmark, Italy and Greece i.e. they will have to reduce production or 
shift to other types of skin. 
if extended to transit: 
Significant  - since the 
large transit trade, not only for the EU 
market, will cease.  if extended to transit: 
No difference to 
above  if extended to transit: 
No difference to 
above  - since the 
limited transit trade 
seems to be for the 
EU market. if extended to transit: 
Significant  - since the large transit trade - 
primarily in Germany (Frankfurt), not only for the EU market, will cease.  
Source: COWI assessments . 
Similar to the prohibition of placing on the EU  market, Table 6.4.2  shows that the 
impacts are assessed to be slightly highe r for non-EU range state. This is again 
merely a result of that the si zes of the seal hunt in thes e countries are 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 away  from Germany and Fi nland to outside the 
EU e.g. Norway. Hence, Norway may actuall y strengthen its pos ition as a transit 
trader. 
 
EN 47   EN Table Error! No text of specified style in document. .2 Impacts of prohibition of 
imports (and exports) into the Community of skins of seals and products derived 
therefrom - non-EU range states 
Canada Greenland Namibia Norway Russia 
Medium  - since a 
large share of 
exports to EU is for 
re-export outside the 
EU, but the 
significant amount 
that ends up in Italy 
via Finland will be 
affected. Medium  - since a 
fourth of exports are 
designated EU 
markets - and so 
local sealing 
communities will be 
affected. Medium  - since a fifth 
of exports are 
designated EU 
markets - and so 
local sealing 
communities will be 
affected. Medium  - covering no 
impact regarding raw 
sealskin exports and 
thus sealers in the 
local communities, 
while there is a 
significant export of 
tanned or dresses 
skins to the EU. Medium  - since the 
Russian market take 
in a large share of 
EU exports. 
if extended to transit: 
Significant  - since the 
large transit trade, 
not only for the EU 
market, will cease - 
unless it can be 
shifted to a non-EU 
country e.g. Norway if extended to transit: 
No difference to 
above  if extended to transit: 
No difference to 
above  if extended to transit: 
Positive impact  - 
since the position as 
transit trader might 
be strengthened e.g. 
more Canadian 
skins. if extended to transit: 
No difference to 
above  
Source: COWI assessments 
6.5. Impact of a labelling system 
The third measure can both be legislative or non-legislative - i.e. a harmonised, 
mandatory or voluntary labelling system (product-based) linked to the development 
of voluntary standards. In the present co ntext any such label should refer to the 
animal welfare aspect of the seal hunt and thus to some established standards for the 
hunting of seals. This could directly contri bute to an improvement of the welfare of 
seals at killing. However, as mentioned a bove regarding the possibility of a limited 
ban on placing on the EU market of seal  products - precise references to the 
identified 'best practices' of such hunt have still to be developed. 
As described in Chapter 5, benefits from  a stand-alone labelling system might 
include a price mark-up on the consumer mark et and at the same time could help to 
enhance the image of seal hunting in gene ral. If the system is voluntary and not 
linked to a legislative measure, it might encourage a natural se lf-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 
The impact will be best if it is a widespread  international labelling system rather than 
a specific EU system. If well designed, a labe lling scheme could create an incentive 
to sealers to improve their hunting practices and thus improve the welfare of seals at 
killing. 
It has to be noted however that the results of the public  consultation show that many 
respondents are against seal hunting for r easons of principle and it is therefore 
unlikely that a labelling system would be acceptable for the majority of the 
respondents as long as it is not linked to so me mandatory and enforceable standards. 
 
EN 48   EN 6.6. Impact of other measures 
6.6.1. Bi-/multilateral agreements between th e EU and one or more range states 
Bi-/multilateral agreements between the EU and one or more range states could be 
developed. They would limit trade in such  products from sealing countries, which 
enter into such agreements, to those produc ts, which comply with some established 
standards as discussed above. 
Table 6.6.1.1 provides a rough assessment of the impacts on non-EU range states of 
bilateral agreements with the EU. In othe r words, how would the single range state 
be affected if the prohibitions only regard  the other range states? This result will of 
course be slightly different if more range states are exempted from such prohibitions 
via a multilateral agreement - i.e. no change to  the present situation if all range states 
are covered by the multilateral agreement.  The assessment points to minor positive 
economic impacts for the range states th at, via agreements, are not subject to 
restrictions. Greenland could be the larg est beneficiary, while Namibia and Russia 
are likely to experience the worst eco nomic impact of such agreements. 
Table Error! No text of specified style in document. .1.1 Impacts of bilateral 
agreements with non-EU range states - excl uding them from prohibitions of imports 
or placing on the EU market 
Canada Greenland Namibia Norway Russia 
Minor  positive impact 
of shifting a part of 
the trade away from 
Asian markets to a 
higher-priced EU 
market, which suffers 
from the falling 
supply from the other 
range states. 
The positive impact 
will be somewhat offset by a decline in 
the exports of raw fur 
skins to Norway that 
were destined for 
further processing 
and sales on the EU 
market. Medium
 positive 
impact from selling a 
larger part of the raw 
fur skins to a higher-
priced EU market, 
which suffers from 
the falling supply 
from the other range 
states. Minor  positive impact 
in the niche EU 
markets for cape fur 
seal skins. However, 
it is likely that the EU 
market will 
completely change if 
all of Canadian, 
Greenlandic, and 
Norwegian produce are excluded; and so 
the assessment is 
very uncertain. Minor
 since 
Norwegian 
processors of raw 
seal skins see an 
increase in the EU 
market share of 
processed seal skins. 
However, these 
producers are likely to suffer from the 
non-available supply 
of Canadian raw fur 
skins. 
 Minor
 positive impact 
since the EU market 
is not central for 
Russia. Furthermore, 
it is likely that the EU 
market will 
completely change if 
all of Canadian, 
Greenlandic, and 
Norwegian produce are excluded; and so 
the assessment is 
very uncertain.  
Source: COWI assessments 
6.6.2. Development of guidelines by an internationally recognised organisation 
Guidelines developed and adopted by an in ternationally recognised organisation, but 
unrelated to a mandatory system, would have  a similar effect as a voluntary labelling 
system. Such guidelines could comprise be st practices on seal hunting methods and 
seal hunt management systems - and in th is context build upon th e results of this 
study and the EFSA opinion. However, it is difficult to point out at this stage an 
organisation that could be labelled 'internationally re cognised' and which would 
cover all seal hunts. 
 
EN 49   EN 6.6.3. EU information campaigns 
An EU information campaign targeted at consumers can, for example, benefit from 
the results of the public c onsultation carried out within the pr esent study, while a 
campaign targeted at seal hunters and produ cers can, for example, benefit from the 
above mentioned guidelines. It is, howev er, difficult to say how information 
campaigns will affect over a l onger period of time th e practices of the hunt as well as 
the development of the markets. 
6.6.4. “Sufficient information for action”? 
Policy decisions will have to be taken on limited information. EFSA stated clearly 
that there was a scarcity of robust, scientifically peer re viewed data. EFSA therefore 
had to take a qualitative a pproach when conducting its risk assessment on adverse 
welfare effects of seals duri ng the killing and sk inning process. Nevertheless, it was 
possible for EFSA to use the output of th at risk assessment exercise to rank the 
problems and to designate areas of concern, as well as guidance for future research. 
The assessments of the impacts of policy measures are also connected with much 
uncertainty, because the quality of the in formation received during the assessment 
process differs between the elements (welfare  of seals, trade, local economy, and the 
Inuit population) and for some of these betw een range states. This is in particular 
relevant for the lack of data to anal yse the consequences for local economies 
dependent on sealing. 
Given the above and considering the anim al welfare concerns  expressed by the 
public, the EP and Member States and iden tified by EFSA, non-le gislative measures 
such as information campaigns and voluntary labelling schemes will not be sufficient to address the issue.  
7. C
OMPARING THE OPTIONS  
The EFSA scientific opinion cl early indicates that there is  reported evidence that, in 
practice, effective killing does not always happen - which is reinforced by the COWI 
study findings. There are therefore reas onable grounds to consider 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. Based on the assessment, it appears that the impact of non-legislative measures on s ealing countries to implemen t best practices might be 
limited. Recent developments, such as efforts by some sealing countries to improve their systems already by introducing measures  in line with the EFSA scientific 
opinion adopted in December 2007, would not have happened if non-legislative 
measures would have been seen to be privileged. 
The following section of the report therefor e considers further legislative options 
initially identified.  
7.1. Total prohibition of placing on the EU market of seal products  
This option would not allow any seal pr oduct on the EU market including those 
originating from within the EU. This m easure would provide for a harmonization of 
 
EN 50   EN the EU internal market, but would cause prob lems to some of the EU Member States 
where seal hunting is taking place and produc ts are offered to a limited extent on the 
local market.  
This option is assessed to have minor trad e impacts on the EU Member States. This 
assumes, however, that transhipments of  sealskins and other seal products and 
imports of sealskins for further processi ng and exports continue. The trade impacts 
are assessed to be slightly hi gher for non-EU range state. This  is the result of the fact 
that the sizes of the seal hunt  in these countries are much larger than in  the EU range 
states, and that the EU market – apart for Russia - is of some importance. A focus in 
the regulation on harp and hooded seals only  will eliminate nega tive trade impacts 
for Namibia and somewhat relieve the one s for Greenland. In contrast, the measure 
will almost fully affect the Canadian and Norwegian hunts. 
Such a ban would also affect  those consumers that buy s eal products offered on local 
markets in the respective EU range states. 
With regard to the killing practices, this option on its own  would have limited or no 
impact on the animal welfare dimension in the sealing countries, but as set out in 
paragraph 7.3, it is considered effective as part of a broader set of measures. 
7.2. Total prohibition of imports and exports  
This option will have medium trade impacts on the EU Member States, although the 
economic impacts may be significant for Finland and Germany, if such ban is extended to also cover transit trade. In acco rdance with trade statistics received by 
Canada, seal products for a total va lue of about 3,842,473 Can$ (= 2,477,562 €) are 
exported to Germany. Those goods are not registered as imports by EUROSTAT 
data and are therefore consid ered in transit, i.e. the goods are pl aced in a customs 
warehouse for storage until reshipment, or given temporary admission for trade fairs, temporary exhibitions, tests, etc. With re gard to Finland, seal products for a total 
value of about Can$ 11,709,263 (= 7,550,081 €) are exported from Canada to Finland, whereby most of it passes in tran sit trade. According to EUROSTAT, the 
total imports to the EU-27 from Finla nd amount to 939,632 € and the actual total 
exports from the EU-27 to Finland to 1,228,628 €. 
Economic impacts are assessed to be higher for non-EU range states. This is again a 
result of the fact that the si ze of the seal hunts in these 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 away  from Germany and Fi nland to outside the 
EU e.g. Norway. Hence, Norway may actuall y strengthen its pos ition as a transit 
trader. 
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 raw fur skin s directly coming from Canada and 
Greenland (that are not categor ised as goods in transit), while Italy imports raw fur 
skins from Russia, Finland and the UK (S cotland) - where many of the skins from 
the latter two originates from outside the EU borders. Greece also has a noticeable 
share of the skins coming from  the two latter range states. 
 
EN 51   EN Such a ban would affect the rights of the consumers who are willing to buy seal 
products and would therefore affect  consumers' right to chose. 
In addition, as far as the animal welf are dimension is concerned, this option on its 
own would  probably have limited or  no impact on the killing practices, in particular 
in non-EU countries. However, it could be combined with other measures. 
7.3. Conclusion and preferred policy package 
With reference to the outcome of the above  assessment of impacts in relation to the 
animal welfare, economic and social dimension, 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, 
transit through, or export from, the Community of all seal products from a given 
date. The prohibitions shall not apply to s eal products resulting from traditional hunts 
conducted by Inuit communities for subsis tence purposes. By wa y of derogation 
from the above, such a prohibition would a llow the placing on the market for those 
seal products derived from seals taken in those countries that can demonstrate that: 
• adequate legislative and enforcement provisi ons are in place seeking to ensure that 
seals are killed and skinned without causi ng avoidable pain, dist ress and any other 
form of suffering and 
• high animal welfare standards respecting the basic criteria highlighted by the 
results of the Commission's impact assessm ent process are applied and that their 
application is properly enforced and monitored. 
The measure would also establish the requi rement (country-based label or marking 
coupled with a certification scheme to be put in place in the s ealing countries) that 
seal products whose trade would be po ssible by derogation to  the prohibitions 
otherwise in force, would be clearly ma rked/labelled as coming from a country 
meeting the above-mentioned conditions. 
This would help to ensure that the genera l public is not conf ronted anymore with 
those seal products derived from seals ki lled 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 whic h do not cause avoidabl e pain, distress or 
other forms of suffering. In this way, the option would have a direct impact can be 
made on the application in practice of an imal welfare friendly hunting techniques 
and thus protect the animal s from unnecessary suffering. 
7.3.1. Impacts of preferred policy package 
Impact on world trade 
 
EN 52   EN As explained above, trade statistics are no t necessarily complete . Nevertheless, we 
can say that: 
Canada (almost certainly the biggest expor ter), exports around 40% of its raw fur 
seal skins by value to the EU a nd around half of all seal products 
A quarter of Greenland's exports go to the EU market A fifth of Namibia's expo rts go to the EU market 
So, very roughly, aroun d a third of world trade curren tly ends up or passes through 
the EU market. The impact of an EU trade ban would therefore be significant. Some 
of this trade would be diverted in case of  a ban. Transit trade could be diverted very 
easily (see below). However, the significant portion of trade that is consumed in the EU would be less susceptible to diversion.  
The fall in demand would lead to a fall in world market prices. This could lead to 
increased demand from other markets (Canad a ,  R u s s i a ,  A s i a  e t c ) .  H o w e v e r ,  i t  i s  
improbable that such demand would comple tely replace European demand. As such, 
the market will contract to some extent and – as supply and demand interplay – fewer seals would be killed. This would obviously translate into  a reduction in seals killed 
in an inappropriate manner.  
Impact on animal welfare 
Any reduction in number of seals killed w ould translate into an improvement in 
animal welfare. The impact on animal welfare of seals that are killed (i.e. continue to 
be killed) will depend on whether commercial sealers improve the animal welfare of their practices. They will have an economic incentive to do so because of the size of 
the EU market (as set out above and in Section 6.2.1).  
Impact on transit trade 
A prohibition of transit trad e would have the most signi ficant effect on Finland and 
Germany (Frankfort airport) because their large transit trade would have to stop. 
Canada would have to shift their transit trade away from Frankfort and Finland to 
non-EU countries, eg direct trade with Asia or via Norway. In the latter case, Norway 
would gain since its position as transit c ountry might be strengthened. A ban on 
transit would ensure that seal products do not trans it through the Community and 
would therefore render a ban on intra-Communi ty trade more effective. (see chapter 
7.2) 
Possibility to avoid a trade ban 
As is made clear above, trade by derogation to a ban would be pos sible if a sealing 
country meets certain conditions, which concern the manner and method whereby seals are killed and skinned and which have  been identified in the Commission 
assessment process based on the scie ntific opinion adopted by EFSA. 
It is unclear what the costs of doing so would be; in part because it is not always 
clear what happens on th e ice at present. In pr actice though, it would seem 
 
EN 53   EN reasonable to say that financial costs woul d not be prohibitive. Furthermore, it may 
take longer to kill each seal, creating an additional cost. 
Economic impact in Europe 
• Transit operators  would lose. 
• The fur processing industry  in Denmark and Italy, which are the two largest EU 
importers of fur skins from seals for fu rther processing/sales on the EU market, 
would suffer a medium sized impact fr om a lack of raw fur supply. Denmark 
imports the raw furs kins directly co ming from Canada (€191,389) and Greenland 
(€1,312,886) (that are not categorised as good s in transit), while Italy mainly 
imports raw fur skins from Russia (€186,081) Finland (€871,799) and from the UK (Scotland) (€281,132) – where many of th e skins of the latter two originate 
from mainly Canada (transit trade not registered in EUROSTAT database). 
According to Canadian trade statistics, about Can$ 11,709,263 (= €7,550,081) are exported to Finland and about Can$ 634,873 (= €408,090) to the UK. Greece also 
has a small share of the skins coming from Finland and the UK for further processing by their industry, but mostly imports from Namibia (n° of skins 
according to CITES trade database: 13,550).   It is to be noted, however, that most of  the fur processing industry producing final 
seal products for the markets does not ex clusively focus on seal products and 
therefore does not fully rely on the supply of seal skins.  
Impact on the Inuit 
The Inuit currently are estimated to catch a bout a tenth of the seals caught in Canada 
for a mixture of commercial and subsisten ce purposes. That would translate into 
approximately 30,000 seals a year. Of these,  only about a fifth (6000) is exported 
though not necessarily to the EU. This re sults in earnings by the community of 
around 1mill Canadian $ a year (about €650,000).  
Impact on fish stocks 
There is no clear evidence fo r an impact on the fish stocks (see chapter 6.2.2). 
WTO compatibility 
An import ban can be justified on the basi s of the general exceptions contained in 
Article XX of the General Agreement on Trade and Tariffs (GATT), more 
specifically by invoking Article XX (a) under which the adoption or enforcement by 
any contracting party of measures necessary  to protect public mo rals (i.e "standards 
of right or wrong conduct maintained by or on behalf of a community or a nation") is 
allowed provided that such measures are not applied in a manner which would 
constitute a means of arbitr ary or unjustifiable discrimination. The proposed measure 
is not discriminatory as the various prohi bitions to be provided for will apply to 
intra-Community trade as well as to imports and exports. 
 
EN 54   EN 8. M ONITORING AND EVALUATION  
8.1. Monitoring 
The monitoring would be done by the Comm ission and Member States. The future 
European Centre for the Protection and We lfare of Animals could – once established 
and in operation be considered to serve as  reference body. It could then assist the 
Commission in the implementation of a ny labelling and marking requirements, 
whose basis features would be established in the legislative measure (see chapter 
3.2.4.1). 
Reporting mechanisms will be foreseen that wi ll enable the evaluations of the extent 
to which the envisaged measures have cont ributed to improve the welfare of seals 
during the killing process and to which extent the concer ns of some citizens have 
been addressed. The monitoring of impact of  the measures on the welfare aspects of 
seal killing in third countries would n eed to be defined in the framework of 
negotiations. 
The efficiency of the legislative measure wi ll be measured in reference to the 'best 
practices' highlighted by th e results of the overall Commission impact assessment 
process. This should be possible but woul d imply additional costs. It should be 
recognised that commercial hunts are already subject to some degr ee of monitoring 
and inspection. The effectiveness and adequ acy of current arrangements is disputed, 
but at the very least it provides a solid ba se on which adequate procedures could be 
built. 
The 'best practices' identified through th e assessment process are listed below 
together with some examples of current pr actices in place in seal hunting countries: 
• Animal welfare principles : Animal welfare principles  are highlighted in the 
applicable hunting legislation - whether this targets seal  hunting specifically or 
hunting in general. 
Many countries have animal welfare provisions in their respective laws on animal 
protection and this is used actively in  some countries e.g. Finland. However 
explicitly stating animal welfare principles clearly emphasises the importance of killing animals under conditions minimising their pain. 
The Norwegian regulation on the execution of seal hunt (2003-02-11-151) clearly 
stipulates that the hunters shall demons trate utmost care and use hunting methods 
that prevent all unnecessary pain (§1). It also  stresses that hurt animals shall be killed 
as soon as possible. Also §7, on the killing process, stresses that animals shall be 
killed in a way that anim als do not suffer unnecessarily. 
• Hunting tools:
 The characteristics of the weapons us ed to kill seal are specified. It 
is made explicit in the le gislation which weapons are allowed for stunning and/or 
killing pups and which are allowed for st unning and/or killi ng adult seals. The 
requirements to the weapons are made in accordance with the recommendations 
of the EFSA scientific opinion. 
 
EN 55   EN Countries have various degrees of descripti on of the tools that shall be used to hunt 
seals. According to the EFSA opinion, some  tools are more likely to reduce animal 
welfare than others. First of all, the hakapi k required in the hunt in Norway is heavier 
than the hakapik required in the Canadian  hunt, and this reduces the risk of not 
killing the animal in the first blow. The Na mibian club is even lighter and without a 
spike. Moreover, the club or hakapik shoul d only be used on pups where the skull is 
still relatively thin (EFSA, 2007). Using club or hakapik to  stun or kill adult seals is 
prohibited in all countries, except Greenland or Canada. Se cond, regarding rifles and 
ammunition, all countries ex cept for Greenland and UK/Scotland have requirements 
to the arm and ammunition used to kill seals. 
• Assuring death by monitoring:  Legislation should specifically outline 
requirements for monitoring and thereby oblig e the hunter to assu re that the seal 
is irrevocably unconscious before bleeding it out and before continuing to the next seal. 
Canada is the only country wher e it is required by law to undertake a blin king test as 
to confirm that the seal is dead before  proceeding to strike  another seal (MMR 
§28.3). Monitoring that the seal and assuring th at it is irrevocably unconscious is a 
clear recommendation from both the EFSA opinion (EFSA, 2007) and the IVWG (2005). 
• 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. 
The Norwegian legislation (2003-02-11-151 §7) st ates that the animal shall be bled-
out right after being hit with hakapik or slagkrok (a hook only allowed on pups). The 
procedure for bleeding-out is also descri bed. Norway is the only country with an 
explicit requirement to bled-out all seals ri ght after they are hit. In the Namibian 
regulation relating to the exploitation of  marine resources (241/2001) it is only 
required that pups are bled-out. None of th e other range states require bleeding out, 
although the government in some states say th at this is done in practise for practical 
reasons, e.g. in Greenland and Finland. 
• 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 environmenta l factors, relevant for the hunt in question, are also 
regulated. 
The Swedish EPA Decision on controlled hun ting of grey seals for 2007, adopted on 
11 April 2007 states that if the weather is calm (wind speed <3m/s) the hunt can take 
place from ice or from boat anchored to ice, from a shooting tower or other construction built or anchored to the bottom of the sea. Otherwise hunt must take place from land. Hence the legislation prescr ibes a condition securing that shooting is 
taken place from a stable foundation. The Norwegian legislati on prescribes that 
hunting seal that is in the water is prohi bited (2003-02-11-151 §6) . Several countries 
have restrictions on hunting in artific ial light, e.g. Norway and Finland. The 
difference in environmental conditions, both regarding weather and hunting location 
and climate influences what and wh ich factors need to be addressed. 
 
EN 56   EN • Training of hunters : A defined level of knowle dge 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. 
In Canada there is no required theoretical training or curriculum to be completed. 
Sealers learn from the more experienced sealers and they must hold an assistant 
sealers licence for two years. In Gr eenland young sealers learn from more 
experienced ones. In principl e this hands-on training is ju st as good or might even be 
better than formally organised training. The ch allenge is to secure  that good practices 
are passed on and not bad practices. 
Norway is the country with the most extens ive training requirements of all the range 
states in the study with mandatory seal hunt training courses every year for the 
captain of the sealing ve ssel and every second year for the hunters on board. The 
legislation moreover prescribes that passing a test is required both for shooting and in 
the use of hakapik. Finland has an extensiv e exam to get a hunti ng card. The test is 
general and a course targeting seal hunt is voluntary. The curriculum is though rather 
extensive and detailed. Many stakeholders ha ve during the process pointed to the fact 
that seal hunt is a dangerous and adva nced form of hunting, which emphasise the 
importance of proper training. 
• 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. 
The practical possibility of  monitoring and inspecting the hunt differs according to 
the environment where the hunt is undertaken  as well as the scope of the hunt. The 
Namibian legislation prescribes a monito ring scheme requiring that an inspector 
overseeing the hunt must be satisfied that  the seal is dead (241/2001 §20). Norway 
has a developed system for monitoring and requires an inspector on every sealing 
vessel. Independency of monitoring is evalua ted on the affiliation of the inspectors to 
the regulating authority. Observation by mars hals, police and coast guard can thus be 
considered to be more independent th an inspectors employed by the regulating 
authority, e.g. the Directorate of Fisheries in  Norway or the Department of Fisheries 
and Oceans in Canada. The affiliation of th e inspector with the local community is 
likely to reduce independency of the inspec tor. In Norway, the inspectors are hired 
for the specific task of inspecting the hunt and are requested to be independent. The 
optimal monitoring system meets both these requirements, and ther e is clearly room 
for improvements in the field of independent monitoring. 
• Ability of third party to monitor : Third party monitoring of the hunt is possible, 
with a minimum of administrative or logistic barriers. 
Canada is the only country that specifica lly allows for third party monitoring. NGOs 
do though report cases of administrative difficulties regarding getting such licence. Under the Norwegian legislation vessels can be ordered to have observers on board 
during the hunt. It is though a requirement that inspectors and observers are trained 
veterinaries, which clearly is a restraint to  the opportunity for third party to monitor 
the hunt. None of the other countries ha ve provisions on third party monitoring. 
Several countries do though state that obser vers are welcome, but that there are 
 
EN 57   EN practical challenges due to the nature of the hunt e.g. Greenland and Finland. This 
indicates that there is room for improveme nt in all countries included in this study. 
• Reporting requirements : Clear requirements for re porting 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. 
All countries, except Namibia, have repor ting requirements that are more or less 
developed, both for hunters and the monitori ng authorities. In most countries, hunters 
are required to report on where and when the seal was killed. Only Norway has a formalised process for the inspector to report - with a form that must be filled-in with 
information on whether requirements to weapons and ammunitions are complied with, whether the ship logbook is kept as  required and if there has been any 
infringements of legislation. In cases of non-comp liance the inspector must fill in an 
infringement report with detail ed descriptions of the breach. 
• Sanctions and compliance
: Statistical information on the hunt should be compiled 
and systemised. 
All countries assessed have prescribed maximum penalties for non-compliance in the 
legislation. The degree to which hunters in fringing the legislation are subject to 
sanctions is unclear and depends on severa l factors. Knowledge about infringements 
is pivotal for enforcement and for this dimension to have real value it must be connected to both monitoring and reporting requirements. None of the countries 
currently gather statistical data based on the reports and there is clearly room for 
improvements in all countries. The number  of actual court cases cannot be seen 
isolated. Frequency of monitoring, the re porting system and number of cases of non-
compliance must be seen relative to each ot her in order to get an understanding of the 
range of infringements. 
Monitoring of trade
 
The market for seal products is a fairly well defined market with a fairly small 
number of people involved. The cost of  monitoring imports should therefore be 
relatively small, and be met as part of normal business by Member States' customs. 
The 'Seal pups directive'15 already obliges EU Member States to take or maintain 
necessary measures to ensure  that the listed seal pup products ar e not commercially 
imported into their territory . Even though the stated reas ons for the adoption of the 
Directive were different (existing worries about the population st atus of harp and 
hooded seals) it might be used as a preceden t the Member States might be able to 
build on. Costs for the existing system ha ve never been reported as a problem. 
                                                 
15 Council Directive 83/129/EEC [amended by Council Directive 89/370/EEC] prohibiting the 
importation into Member States of skins of whitecoat pups, of harp seals and of pups of hooded seals 
(blue-backs) and products derived therefrom 
 
EN 58   EN Costs for information requirements ( certification / labelling / marking)  
The information presented in the Impact Assessment is the best available data. 
Detailed information and cost estimates are not available. Nevertheless, costs are not expected to be significant as range states  would be certified, in accordance with the 
legislative measure, on country basis. Furt hermore, trade appears to be handled by a 
relatively small number of firms. Labels and markings would need to be affixed by 
the economic operators engaged in the trade and costs would probably be passed on to the end-consumer. Given the high valu e of fur products, it would probably be a 
small percentage of costs. 
In 2007, the International Fur Trade Fe deration launched a new international 
labelling programme whereby the so-cal led "Origin Assured label" informs 
consumers that the fur or fur products come  from a country where national or local 
regulations or standards governing fur productio ns are in force. This initiative could 
be an example to further built on. 
8.2. Evaluation 
An evaluation of the new initiative should be undertaken within 5 years of its 
adoption assessing the extent to which its re sults are consistent with the objectives 
set. The evaluation results should be us ed for the decision-making needs on the 
future of and any amendments to the regulatory framework, if appropriate.  
 
EN 59   EN  ANNEX 1 
 
 
EN 60   EN 
 
 
EN 61   EN 
 
 
EN 62   EN 
 
 
EN 63   EN 
 
 
EN 64   EN 
 
 
EN 65   EN 
 
 
EN 66   EN 
 
 
EN 67   EN  ANNEX 2 
Assessment sheets of seal hunt management systems16 
1. Canada 
2. Finland 3. Greenland 4. Namibia 5. Norway 6. Russia 7. Sweden 8. United Kingdom (Scotland) 
                                                
 
16 Extracted from the COWI study "Assessment of the potential impact of a ban of products derived from 
seal species", April 2008 
 
EN 68   EN Table 1 Assessment Summary Sheet, Canada 
Canada  
Legislation Are national legislation requirements in place?(i) 
 Yes No Comment 
Animal welfare  
principles   Inconclusive  - although there are principles and statements on animal welfare mentioned in §§7-
10 of the Marine Mammal Regulations (SOR/93-56), particularly §8 stating that it shall be killed 
quickly - but there is no reference to avoiding unnecessary pain or distress. 
Hunting tools 
   Inconclusive  - as the conditions to get a Yes is only pa rtially there. Characteristics of the tools 
allowed are prescribed in §28 (1) of the Mari ne Mammal Regulations (SOR/93-56). This is 
applicable for personal and commercial use. Howeve r, §28 is only applicable in sealing areas 4 
to 33, i.e. the areas for commercial hunting. Outs ide these areas, i.e. areas 1 to 3 covering the 
Arctic areas, there are no restrictions. 
Assuring death by monitoring
(ii) X  A blinking test is required to confirm that the seal is death according to Sections 28 (2)-(4) and 
Section 29 of the Marine Mammal Regulations (SOR/93-56). 
Bleeding-out of  animals shot or struck
(ii) X  No requirements in the applicable legislati on, however it is incorporated as a licence 
requirement and non-compliance may thus be sanctioned. 
Environmental factors  X No requirements in the applicable legislation. 
Training of the 
hunters   Inconclusive . Training takes form of apprenticeship - i.e. learning from experienced hunters. 
There are no requirements to any specific sk ills being taught or curriculum to be studied 
according to the Seal Licensing Policy for Ea stern Canada Section 33, and the 1995 Canadian 
Firearms Act. 
Enforcement Are national enforcement requirements in place?(i) 
 Yes No Comment 
Independent  monitoring   Inconclusive
 - without further analysis the independency of inspectors. Moni toring is undertaken 
by fisheries officers from DFO and by at-sea fisheries observers  - designated according to 5 (1)-
(2) of the Fisheries Act and §39 (1) and §1 of the Fisheries Regulations.  
Ability of third 
party to monitor X  Seal Fishery Observation Lic enses may be issued by the Minister if such issuance does not 
cause disruption to a seal fishery accordi ng to Section 32 (1)-(2), MMR (SOR/93-56). 
Reporting  
requirements   Inconclusive  - although inspections by DFO fish ery officers are recorded daily.  At-sea fishery 
observers shall transmit collected information to DFO.  Seal hunters are required to keep 
records, log books and other relevant documentat ion, documenting their seal hunt (Section 39.1 
(2) of the Fisheries (General) Regulations and Se ction 61 of the Fisheries Act). However, there 
are no requirements to report on environmental factors. 
Sanctions and compliance X  Data from the reporting of in spectors and sealers are gathered. 
Are animal welfare recommendations carried out in practice?(ii) 
Legislation in practice (imp lementation and application) 
The Canadian hunt is highly disputed and there are different opi nions on the degree to which the legislation is complied with. The 
competitive nature of the hunt may lead to hunters taking shortcut s that may reduce animal welfare. Without further information  it 
cannot be concluded to which degree the legi slation is complied with. However, as bl eeding-out is not required by legislation b ut is as 
of 2008 a part of the licence requirement, and so administrative  sanctions might be the consequenc e if these are not complied w ith. 
Enforcement in practice 
Enforcement is challenged by the characteri stics of the hunt, with a large number of relatively small boats operating in a chal lenging 
environment. That said, i.a. IVWG (2005) stated that the i ndependence of the enforcement and loyalties of inspectors can be 
questioned. The DFO has, however, increased focus on enforcement  since 2005 and increases the num ber of inspectors. NGOs 
stress that there are administrative barrier s to get an observers licence in spite of the procedure bei ng rather simple and 
straightforward according to the legislation. 
Contextual factors of importance for understanding legislation and enforcement 
There are three kinds of hunt in Canada: commercial hunt, personal  use hunt and Inuit hunt. This study targets first and foremo st the 
commercial hunt which is the largest - landi ng 200,000-300,000 seals a year. The commercial hunt mainly takes place in coastal 
communities in Newfoundland and Labrador, where professional fishermen supplement their in come in the fisheries off season. Mos t 
seals are killed from late-March to mid- April. The Inuit hunt is further north in Canada and is both for subsistence and commer cial 
purposes as Inuit also sell their pr oducts on the commercial market. This hunt is mainly for ringed seals. 
Notes 
 (i)Yes - implies that legislation/enforcement requirements are in place and contain provision in ac cordance with animal welfare 
recommendations for seal hunt. No - implies that legislation/enfor cement requirements are not in place or not in accordance wit h 
animal welfare recommendations for seal hunt. No X - if the information available is inconclusive. 
(ii)This assessment by the study team is solely based on writt en information obtained - hence not on observations of the hunt in 
practice. Furthermore, the description is not claimed to be complete. 
 
EN 69   EN Table 2 Assessment Summary Sheet, Finland 
Finland  
Legislation Are national legislation requirements in place?(i) 
 Yes No Comment 
Animal welfare  
principles X  Law on animal protection is applicable to all animals (§§3, 12 and 32 are particularly 
applicable here). The Hunting Act st resses that hunting must be not "cause 
unnecessary suffering". 
Hunting tools 
 X  A range of tools are prohibited and the only legal method to catch and kill a seal is by 
trap, for the capture of anim als alive, or by shooting. There are specifications for 
ammunition and weapons allowed. 
Assuring death by monitoring(ii)  X Not required by the applicable legislati on. However, the required rifle and ammunition 
do lead to immediate and obvious death of the seal as the skull is destroyed when the 
seal is shot in the neck or head. 
Bleeding-out of  
animals shot or 
struck(ii)  X Not required by the applicable legislation. 
Environmental 
factors   Inconclusive  - as hunting is not legal in artificial lighting unless it is to put down an 
already wounded animal. No other pr ovisions on environmental factors.  
Training of the 
hunters   Inconclusive  - although hunters must pass a rather  extensive test to get the required 
hunting card. There is moreover a voluntar y course targeting seal hunt (with 80% 
participation of seal hunters). However, there are no requirements on shooting tests 
for seal hunters. 
Enforcement Are national enforcement requirements in place?(i) 
 Yes No Comment 
Independent  monitoring   Inconclusive
 - although an extensive organisation for monitoring exits both within the 
Ministry of Forestry and Agriculture, her eunder the Game Management Districts and 
organisations. Also the police, frontier guar d, the customs authorities participate in the 
monitoring and inspecting the hunt. Their independence are, however, uncertain. 
Ability of third party to monitor -  -  Not applicable
 - as the Finnish hunt is not large scale. 
Reporting  
requirements X  Hunters are required to report on thei r catch. The coast guard must report on 
"important circumstances" hereunder the hunt. 
Sanctions and 
compliance X  Information on infringements and suspected infringements are gathered by the police. 
Are animal welfare recommendations carried out in practice?(ii) 
Legislation in practice (implementation and application) 
The hunt takes place in the spring when seals are on ice in her ds or alone. The hunter shoot s the seal in the head at a 
distance of 10-150 metres. When the seal is shot in the head or upper neck with the required ammunition, it is likely that 
the seal is immediately dead because of its impact power and the large ensuing wou nd. This does of course require the 
shots are placed correctly. The animal is in practice bled-out in  order to secure the quality of the meat and skin which is 
used for food and manufacture, but this is not required by  legislation. The hunt is onl y undertaken in stable weather 
conditions due to the character of  the hunt and the danger that bad weather poses to the hunter.  
Enforcement in practice 
Inspection and control of the hunt is  undertaken both by game wardens and by  the hunters themselves. Within the 
hunting community there is a strict inte rnal code of conduct and hunters breaching this are not allowed to take part in 
the hunting club or are reported to the authorities. Most of the reported inci dents received by the authorities are 
reported by fellow hunters.  
Contextual factors of importance for understanding legislation and enforcement 
The seal hunt in Finland is small scale and is undertaken as a recreational activity. It is a part of the coastal culture of 
Finland and there are long traditions for hunting as an integrat ed part of society, particularly in the small communities. 
The hunt of seals is, however, also important for protecting  fisheries - where costs are inflicted due to damages by 
seals.  
Notes 
 (i) Yes - implies that legislation/enforce ment requirements are in place and c ontain provision in accordance with 
animal welfare recommendations for seal hunt. No - implies that  legislation/enforcement requ irements are not in place 
or not in accordance with animal welfare recommendations  for seal hunt. No X - if the information available is 
inconclusive. 
(ii) This assessment by the study team is solely based on written information obtained - hence not on 
observations of the hunt in practice. Furthermore, the description is not claimed to be complete. 
 
EN 70   EN Table 3 Assessment Summary Sheet, Greenland 
Greenland  
Legislation Are national legislation requirements in place?(i) 
 Yes No Comment 
Animal welfare  
principles X  Legislation emphasises that killing must be as fast and painless as possible (29/2003 
§13). 
Hunting tools 
  X Netting, which is not considered an ap propriate method (EFSA Journal p 92), is 
allowed. However, the legislation also prov ides for shooting of seals - a method which 
is in accordance with animal welfare recommendations.  
Assuring death 
by monitoring(ii)  X Not required by the applicable legislation. 
Bleeding-out of  
animals shot or 
struck(ii)  X Not required by the applicable legislation. 
Environmental 
factors  X Not required by the applicable legislation. 
Training of the 
hunters  X Not required by the applicable legislation. 
Enforcement Are national enforcement requirements in place?(i) 
 Yes No Comment 
Independent  
monitoring   Inconclusive  - although wildlife officers monitor the hunt. However, they are not 
necessarily independent of commercial and NGO interests. They are employed by the 
Department for Fisheries, Hunting and Agri culture, who is the responsible authority 
for the hunt. Also police and GLK observe the hunt. 
Ability of third 
party to monitor X  There is no restriction on third party monito ring (but also no explicit provision on third 
party monitoring in existing legislation). 
Reporting  requirements   Inconclusive
 - although the legislation prescribes requirements for reporting both from 
the hunters and inspectors. The hunters report what species is hunted when and 
where. Inspectors shall report observa tions, recommendations, confiscations and 
censuses. Reporting on environmental fact ors or struck and lost is, however, not 
required. 
Sanctions and 
compliance  X The Department is in the process of dev eloping a system in order to specify how 
many infringements regard seal hunt, but the system does as of March 2008 not 
exist. 
Are animal welfare recommendations carried out in practice?(ii) 
Legislation in practice (implementation and application) 
Netting is legal and the only hunting method considered bei ng possible in some regions during the winter months and 
firm ice periods. 16% of the seals killed from 1995-2005 were  caught by net. Most seals are shot and although not 
prescribed by legislation, in practise the seals are often bled -out in order to secure the quality of the meat, blubber and 
skins and also for safety reasons on board the dinghies us ed during the hunt. The character of the hunt makes it less 
likely that hunting is undertaken under adverse environmental conditions - such as bad weather and ice conditions - 
due to the possible danger the weather poses to the hunter. Regarding training of the hunt ers, this is traditionally 
carried out by experienced hunters passi ng on their knowledge to new hunters.  
Enforcement in practice 
Enforcement of the rules on seal hunt in Greenland is a logistic challenge due to the dispersed and opportunistic 
character of the hunt. According to information obtained from  responsible authorities, enforcement is carried out by 
wildlife officers making control visits i. a. in the form of daytrips out into t he areas where hunting is undertaken. The 
officers inspect the hunt during the trip and report on th is. GLK (Island Commander Greenland) and the police also 
inspect the hunt. GLK has a specific role in controlling fo reign vessels in Greenlandic waters. In practice, NAMMCO is 
part of the enforcement by observing the hunt. Accordi ng to the NAMMCO secretariat hunt is observed on average 
once every year between June and September (either land based or from a whaling vessel).  
Contextual factors of importance for understanding legislation and enforcement 
Seal hunt is an integrated part of the society and is both for commercial gain and subsistence hereunder both food for 
human consumption and feed for sled dogs. The skins, meat  and blubber are used. The hunt is carried out both as full-
time and as recreational hunt. Both hunts are bound by the sa me legislation and requirem ents. The character of the 
commercial hunt is different from the commercial hunts in other range states - being more  dispersed and opportunistic. 
Economically, income from seal products play s an important role for many communities. 
Notes 
 (i) Yes - implies that legislation/enforce ment requirements are in place and c ontain provision in accordance with 
animal welfare recommendations for seal hunt. No - implies that  legislation/enforcement requ irements are not in place 
or not in accordance with animal welfare recommendations  for seal hunt. No X - if the information available is 
inconclusive. 
(ii) This assessment by the study team is solely based on written information obtained - hence not on 
observations of the hunt in practice. Furthermore , the description is not claimed to be complete. 
 
EN 71   EN Table 4 Assessment Summary Sheet, Namibia 
Namibia  
Legislation Are national legislation requirements in place?(i) 
 Yes No Comment 
Animal welfare  
principles  X Not required by the applicable legislation. 
Hunting tools 
 X  The weapons used to shoot adult seals ar e defined as "capable of killing and adult 
seal instantaneously by penetrating the br ain case and destroying the brain without 
exiting […]" (241/2001 §1. The requirements to  the clubs and rifles are described in 
the definitions  of 241/2001. 
Assuring death 
by monitoring(ii) X  Required for both pups and adult ma les (241/2001 §20. 3c and §20.4b). 
Bleeding-out of  
animals shot or 
struck(ii)   Inconclusive  - as bleeding out is required for pups only (241/2001 §20.3d). Bleeding 
out is not required for adult animals. 
Environmental factors  X Not included in the relevant legislation. 
Training of the 
hunters   Inconclusive  - because requirements are unclear regarding the training required by 
the licence conditions. 
Enforcement Are national enforcement requirements in place?(i) 
 Yes No Comment 
Independent  monitoring   Inconclusive
 - although monitoring is required both in the Marine Act and in the 
regulations relating to the exploitation of marine resources (27/2000 §7 and 241/2001 
§20.1). However, the degree to which the ins pectors are required to be independent 
is unclear. 
Ability of third 
party to monitor   Inconclusive  - because third party monitoring is not regulated in the legislative acts. 
However, according to the licence requirem ent "Observers of t he Wildlife Society of 
Namibia are allowed access to the harvests as observers to recommend possible 
improvements" (MFMR, 2008). 
Reporting  requirements  X There are no reporting requirements pre scribed in the relevant legislation. 
Sanctions and 
compliance   Inconclusive  - because information is insufficient for concluding. 
Are animal welfare recommendations carried out in practice?(ii) 
Legislation in practice (implementation and application) 
Reports indicate that the procedures pr escribed in the legislation are not always adhered to. The herding process is 
believed to cause considerable distress for the animal s (EFSA, 2007). According to EFSA (2007, p. 94) both non-
targeted and targeted animals may sustain injuries bef ore they are killed or escape during the pup hunt.  
Enforcement in practice 
The hunt is to be observed by governmental inspectors. Ho wever, the EFSA opinion reports that there are very few 
inspectors present during the hunt, and t hat the inspectors lack training and kn owledge of the legislation and hunting 
practises. Ability of third party to monitor is limited. 
Contextual factors of importance for understanding legislation and enforcement 
The Namibian hunt is currently the third largest seal hun t, following Canada and Greenland. The characteristics of the 
Namibian hunt are somewhat different from the other se al hunts. It is the only commercial hunt in the southern 
hemisphere and is conducted on the beach of the Namibian coast. The hunt is seas onal and hunters, or harvesters, are 
employed on a seasonal basis by two private concessionaires. Seal products are mainly driven by commercial interests 
and products are exported to international markets. 
Notes 
 (i) Yes - implies that legislation/enforce ment requirements are in place and c ontain provision in accordance with 
animal welfare recommendations for seal hunt. No - implies that  legislation/enforcement requ irements are not in place 
or not in accordance with animal welfare recommendations  for seal hunt. No X - if the information available is 
inconclusive. 
(ii) This assessment by the study team is solely based on written information obtained - hence not on 
observations of the hunt in practice. Furthermore, the description is not claimed to be complete. 
 
EN 72   EN Table 5 Assessment Summary Sheet, Norway 
Norway  
Legislation Are national legislation requirements in place?(i) 
 Yes No Comment 
Animal welfare  
principles X  Clearly stated in the regulation on the execution of seal hunt, both in §1, which 
corresponds to §2 of the Act on animal prot ection, and in §7 regulating the killing 
procedures (2003-02-11-151). 
Hunting tools 
 X  Requirements to weapons used both for adults and pups. These are in line with 
recommendations of the EFSA opinion. The l egislation prohibits netting and traps 
(2003-02-11-151 §11).  
Assuring death 
by monitoring(ii)   Inconclusive  - since his is not required by the legislation, but if the procedure for 
killing seals is followed, the animal will obviously be dead (2003-02-11-151 §7). As soon as possible after a seal is shot it s hall be struck with the spike of the hakapik 
into the brain. 
Bleeding-out of  
animals shot or 
struck(ii) X  Bleeding-out is required instantly afte r the animal is struck with the hakapik or 
slagkrok (only allowed on pups). Techniques to bleed-out the animal are also outlined 
(§7 2003-02-11-151). 
Environmental 
factors   Inconclusive  - since requirements for environmental  factors are not clearly outlined in 
the legislation. However, §6. 2 stipulates a general prohib ition of shooting seals under 
conditions where the seal cannot be cl ubbed and bleed-out on the ice afterwards. 
§11f states that it is not permitted to hunt in artificial lighting, and §6 states that it is 
forbidden to shot a seal in water. 
Training of the hunters X  Seal hunt courses are mandatory every second year for the hunting crew and every 
year for the captain of the vessel. Separate shooting tests and a test in use of hakapik 
also exist (2003-02-11-151 §3). 
Enforcement Are national enforcement requirements in place?(i) 
 Yes No Comment 
Independent  monitoring X  It is required to have a seal hunt inspector on board every sealing vessel. The 
inspector is a trained veterinary that is hired for this explicit task by the Directorate of 
Fisheries. Monitoring can thus be categorised as independent. 
Ability of third 
party to monitor   Inconclusive  - although there are very strict requirements to monitor the seal hunt, but 
it appears to be difficult to get an observers licence.  
Reporting  requirements X  Both inspectors and vessels are required to report to the Directorate of Fisheries. 
Inspectors have a standardised form to fill out. The vessels shall keep a logbook to be 
submitted to the Directorate after t he hunt (1986-06-03-40 §9 and J-53-2007 §13). 
The logbook contains information on s pecial circumstances e.g. the weather 
conditions. 
Sanctions and 
compliance   Inconclusive  - since the information on level/number of sanctions and non-compliance 
is unstructured. 
Are animal welfare recommendations carried out in practice?(ii) 
Legislation in practice (implementation and application) 
The fact that there is an inspector on board the vessel induces the hunters to fo llow the legislation and the procedures 
prescribed. Adults are shot and pups are clubbed; and if the proc edures are followed, the animal will obviously be dead 
before being bleeding-out. 
Enforcement in practice 
Norway has one of the strictest systems for enforcement of  seal hunt, requiring an inspector to be present on every 
vessel. The inspector is observing the hunt and responsible  for controlling that all requirements are complied with, 
regarding training, equipment and killing methods. NAMMCO obs erves the seal hunt, though mainly from the shores. 
Contextual factors of importance for understanding legislation and enforcement 
Using the marine resources is a vital part of the culture of  the coastal communities in Norway. The country has two 
forms of hunt - the commercial and the recreational hunt. The two hunts are different in character and the legislation 
and context of the hunts differ greatly. This study focus main ly on the commercial hunt. The commercial seal hunt is 
industrialised and is carried out from a small number of vessels within a short period of time in the spring/early summer. 
Notes 
 (i) Yes - implies that legislation/enforce ment requirements are in place and c ontain provision in accordance with 
animal welfare recommendations for seal hunt. No - implies that  legislation/enforcement requ irements are not in place 
or not in accordance with animal welfare recommendations  for seal hunt. No X - if the information available is 
inconclusive. 
(ii) This assessment by the study team is solely based on written information obtained - hence not on 
observations of the hunt in practice. Furthermore, the description is not claimed to be complete. 
 
EN 73   EN Table 6 Assessment Summary Sheet, Russia 
Russia  
Legislation Are national legislation requirements in place?(i) 
 Yes No Comment 
Animal welfare  
principles   Inconclusive  - due to lack of knowledge. However, in the legislation analysed no 
provisions on animal welfare are identified. 
Hunting tools 
  X Netting is allowed and is a frequently used hunting method. There is insufficient 
information on other hunting weapons used. 
Assuring death 
by monitoring(ii) - - Lack of information  in order to conclude. 
Bleeding-out of  
animals shot or 
struck(ii) - - Lack of information  in order to conclude. 
Environmental 
factors - - Lack of information  in order to conclude. 
Training of the 
hunters - - Lack of information  in order to conclude. 
Enforcement Are national enforcement requirements in place?(i) 
 Yes No Comment 
Independent  
monitoring - - Lack of information  in order to conclude. 
Ability of third 
party to monitor - - Lack of information  in order to conclude. 
Reporting  
requirements - - Lack of information  in order to conclude. 
Sanctions and 
compliance - - Lack of information  in order to conclude. 
Are animal welfare recommendations carried out in practice?(ii) 
Legislation in practice (implementation and application) 
There is not sufficient information to assess the practices of the hunt in Russia. NGOs have though pointed to animal 
welfare being compromised e.g. by using traps and cages for catching, transporting and keeping live seals.  
Enforcement in practice 
Lack of information. 
Contextual factors of importance for understanding legislation and enforcement 
The Russian hunt is one of the largest seal hunts with quot as allowing for catches of around 100,000 per year. Russia 
has commercial hunt as well as hunt carried out by a numbe r of aboriginal communities. Further analysis is needed to 
provide thorough description of the context. Russia has an increasing market for fur products and is increasingly 
importing seal products. 
Notes 
 (i) Yes - implies that legislation/enforce ment requirements are in place and c ontain provision in accordance with 
animal welfare recommendations for seal hunt. No - implies that  legislation/enforcement requ irements are not in place 
or not in accordance with animal welfare recommendations  for seal hunt. No X - if the information available is 
inconclusive. 
(ii) This assessment by the study team is solely based on written information obtained - hence not on 
observations of the hunt in practice. Furthermore, the description is not claimed to be complete. 
 
EN 74   EN Table 7 Assessment Summary Sheet, Sweden 
Sweden  
Legislation Are national legislation requirements in place?(i) 
 Yes No Comment 
Animal welfare  
principles X  Provisions in both the Hunting Act §§ 5, 27-28 and 30-31 as well as the Decision on 
controlled hunting of grey seals for 2007, adopted on 11 April 2007. 
Hunting tools 
 X  The applicable weapons are clearly prescribed (§§14 and 16 of NFS 2002:18) and 
are in accordance with international best practises.  
Assuring death 
by monitoring(ii)  X There is no requirement to monitoring in the legislation.  
Bleeding-out of  
animals shot or 
struck(ii)  X There is no requirement to bleedi ng-out the seal in the legislation. 
Environmental 
factors   Inconclusive  - although the may only take place from land unless certain 
environmental criteria are fulfilled e.g. co ncerning wind. If these conditions are met 
hunt may also be undertaken from e.g.  the ice (The Swedish EPA Decision on 
controlled hunting of grey seals for 2007, 11 April 2007). 
Training of the hunters   Inconclusive
 - although requirements to training in order to be eligible for a firearms 
licence. Commercial fishermen - permitted to hunt from boat - must be trained in seal-
hunting by hunting associations in Sweden  and in Finland (NFS 2005:4, § 4 of the 
Weapon Ordinance (1996:70), and the Swedi sh EPA Decision on controlled hunting 
of grey seals for 2007.  
Enforcement Are national enforcement requirements in place?(i) 
 Yes No Comment 
Independent  monitoring   Inconclusive
 - as the hunting Inspectors are app ointed by the County Administrative 
Board and is regulated by Article 42 of the Hunting Act (1987:259)) and Article 53 of 
the Hunting Ordinance (1987: 905) and the RPSFS 2000:28.  
Ability of third 
party to monitor - - Not applicable as the Swedish hunt is not large scale. 
Reporting  
requirements X  Both the hunter and the inspectors are required to report according to The Swedish 
EPA Decision on controlled hunting of grey seals for 2007, adopted on 11 April 2007. 
Sanctions and 
compliance   Inconclusive  - as there is no available statis tics on reported cases of seal hunt 
infringements. 
Are animal welfare recommendations carried out in practice?(ii) 
Legislation in practice (implementation and application) 
There is no requirements for monitoring or bleeding-out the animal. However, if the animal is shot in the head with the 
required ammunition, studies indicate that the seal will obviously be dead. A volunt ary course is offered to seal hunters 
providing training and which is finalised with an exam.  
Enforcement in practice 
Enforcement is challenged by the large geographic distance s relative to the number of hunters. There is no other 
information on the practical aspects of the enforcement. 
Contextual factors of importance for understanding legislation and enforcement 
The Swedish seal hunt is rather limited with only about 100 seals killed per year. The seal hunt is undertaken by 
professional fishermen or as a recreational activity on the same basis as other recreational hunts. The seal is used 
either by the hunter or sold for co mmercial purposes, e.g. to restaurants. 
Notes 
 (i) Yes - implies that legislation/enforce ment requirements are in place and c ontain provision in accordance with 
animal welfare recommendations for seal hunt. No - implies that  legislation/enforcement requ irements are not in place 
or not in accordance with animal welfare recommendations  for seal hunt. No X - if the information available is 
inconclusive. 
(ii) This assessment by the study team is solely based on written information obtained - hence not on 
observations of the hunt in practice. Furthermore, the description is not claimed to be complete. 
 
EN 75   EN Table 8 Assessment Summary Sheet, United Kingdom (Scotland) 
United Kingdom (Scotland) 
Legislation Are national legislation requirements in place?(i) 
 Yes No Comment 
Animal welfare  
principles  X It is prohibited to kill, injure or take seals in the closed season (1970 c.30 §2). There 
are, however, no animal welfare principles  for when seals are killed in general or 
under §§9 and 10. 
Hunting tools 
 X  Killing seals is only allowed using a rifle "having a muzzle energy of not less than 600 
foot pounds and a bullet weighing not le ss than 45 grains" (1970 c.30 §1). Netting is 
not allowed. 
Assuring death 
by monitoring(ii)  X No requirements in the legislation. 
Bleeding-out of  
animals shot or 
struck(ii)  X No requirements in the legislation. 
Environmental 
factors  X No requirements in the legislation. 
Training of the 
hunters  X No requirements in the legislation. 
Enforcement Are national enforcement requirements in place?(i) 
 Yes No Comment 
Independent  
monitoring X  Responsibility of the police (1970 C.30 §4). 
Ability of third 
party to monitor - - Not applicable  - as there is no hunt for seals in  Scotland, only killing of seals under 
conditions set out in the Act (1970 C.30). 
Reporting  requirements  X There are no requirements in the Act to report on killings of seals. 
Sanctions and 
compliance  X There is no statistical data on how many  seals are killed nor under which conditions 
(the Marine Directorate, 2007). 
Are animal welfare recommendations carried out in practice?(ii) 
Legislation in practice (implementation and application) There seem to be loopholes in the Act, making killing of seals possible with little chance of sanctions. The Act aims to 
protect seals, nevertheless NGOs indicate that a large num ber of seals are killed every year, over 3,500. Scottish 
authorities do though stress that the kill is limited and that the seal population is growing. 
Enforcement in practice 
According to Scottish NGOs, there is little or no enforcement  of the Act. It has been in place for almost 30 years and 
only two cases have been taken to court, one of which ended in conviction. According to NGOs, people informing the 
police of infringements are in danger of loosing their jobs, indicating that there is a strong culture for not talking about 
possible infringements. 
Contextual factors of importance for understanding legislation and enforcement 
There is a general prohibition on seal hunt and there is neit her commercial nor recreational seal hunt. However, killing 
seals is allowed under certain circumstances, such as for resear ch purposes or if the seal poses a threat to the fisheries 
equipment. The government of Scotland has no data on the number of seals killed under these exemptions, and the 
economic damage caused on the fisheries sector by seals. Killing of seals is debated in Scotland. On the one side is 
the fishermen pressuring for a cull and on the other side N GOs warning about population levels and animal welfare 
considerations. 
Notes 
 (i) Yes - implies that legislation/enforce ment requirements are in place and c ontain provision in accordance with 
animal welfare recommendations for seal hunt. No - implies that  legislation/enforcement requ irements are not in place 
or not in accordance with animal welfare recommendations  for seal hunt. No X - if the information available is 
inconclusive. 
(ii) This assessment by the study team is solely based on written information obtained - hence not on 
observations of the hunt in practice. Furthermore, the description is not claimed to be complete.