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
Date: 2008-07-23
Institutions: European Commission
Subjects: export restriction, hides and furskins industry, marketing restriction, seal

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COMMISSION OF THE EUROPEAN COMMUNITIES 

Brussels, 24.7.2008 
SEC(2008) 2290/2 

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

COMMISSION STAFF WORKING DOCUMENT 

Accompanying document to the 

Proposal for a 

REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL 

concerning trade in seal products 

IMPACT ASSESSMENT  

ON THE POTENTIAL IMPACT OF A BAN OF PRODUCTS 
DERIVED FROM SEAL SPECIES 

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

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Agenda planning: 2008/ENV/013 

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

TABLE OF CONTENTS 

1. 

2. 

2.1. 

2.2. 

2.3. 

2.4. 

2.5. 

2.6. 

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

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

Overview ...................................................................................................................... 7 

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

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

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

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

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 ......................................................................... 12 

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

2.7. 

2.8. 

3. 

3.1. 

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

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

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

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

3.1.1.  Description of the hunts ............................................................................................. 13 

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 

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3.2.3. 

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

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

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

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

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

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

3.3. 

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

4. 

5. 

5.1. 

5.2. 

5.3. 

6. 

Objectives................................................................................................................... 22 

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

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

Legislative measures .................................................................................................. 24 

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

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

6.1. 

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

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

6.2. 

Baseline ...................................................................................................................... 30 

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

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

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

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

6.2.5. 

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

6.3. 

6.4. 

6.5. 

6.6. 

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

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

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

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

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

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

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

6.6.4. 

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

7. 

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

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7.1. 

7.2. 

7.3. 

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

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

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

7.3.1. 

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

8. 

8.1. 

8.2. 

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

Monitoring.................................................................................................................. 54 

Evaluation .................................................................................................................. 58 

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1. 

EXECUTIVE SUMMARY 

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

In the framework of this analysis, regulatory frameworks and management practices 
for seal hunting in the different range states were 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 all systems improvements can be made. Seals are hunted in 
substantially different contexts. Both the type and size of the hunt, and the regulatory 
environments  in  which  the  hunts  are  taking  place  are  different.  Some  range  states 
have  adopted  and  implemented  comprehensive  management  systems  aimed  at 
minimising the conflict between production and animal welfare, whereas other range 
states' management systems are less well-developed and indicate less concern about 
animal welfare. 

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

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

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

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Commission study outsourced to the consultancy firm COWI "Assessment of the potential impact of a 
ban of products derived from seal species", April 2008 
EFSA  independent  scientific  opinion  on  the  animal  welfare  aspects  of  methods  for  the  killing  and 
skinning of seals, Dec. 2007: 
http://www.efsa.europa.eu/EFSA/efsa_locale-1178620753812_1178671319178.htm 

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

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

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

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

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

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

The EFSA scientific opinion clearly indicates that there is reported evidence that, in 
practice, effective killing does not always happen - which is reinforced by the further 
assessment findings. There are therefore reasonable grounds to consider undertaking 
precautionary steps to ensure that products derived from seals, which are killed and 

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skinned in a way that causes them avoidable pain, distress and suffering, are denied 
access to the European market. 

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

•  protect  seals  from  acts  that  cause  them  avoidable  pain,  distress,  fear  and  other 

forms of suffering during the killing and skinning process 

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

of seals 

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

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

2. 

PROCEDURAL ISSUES AND CONSULTATION OF INTERESTED PARTIES 

2.1. 

Overview 

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

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

Furthermore,  the  European  Parliament  adopted  on  26th  September  2006  a  written 
declaration requesting the Commission to immediately draft a regulation to ban the 

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  

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import, export and sale of all harp and hooded seal products while ensuring that this 
measure  would  not  have  an  impact  on  the  traditional  Inuit  seal  hunting.  This 
Declaration with a high number of signatories (425) reflects the main issues of public 
concern,  i.e.  concerns  about  the  application  of  humane  killing  methods  and 
sustainability of the hunting quotas. 

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

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

•  Council  Directive  83/129/EEC4  as  amended  by  Council  Directive  89/370/EEC, 
prohibiting the importation into the EU Member States of skins of whitecoat pups 
of harp seals and of pups of hooded seals and products derived therefrom, which 
was put in place following doubts on the population status of these seal species; as 
well as  

•  EU Wildlife Trade Regulations implementing the provisions of the Convention on 
International Trade in Endangered Species (CITES) in the EU5 . The Convention's 
objective is to ensure that trade only takes place if it does not threaten the survival 
of  species  of  wild  fauna  and  flora.).  To  be  listed  under  CITES  would  be  the 
appropriate  response,  if  the  survival  of  these  seals  species  in  the  wild  should  be 
endangered  by  international  trade.  This  is  the  case  with  the  Namibian  Cape  fur 
seal,  which  is  the  only  seal  species  currently  listed  under  Appendix  II  of  the 
CITES Convention thereby ensuring that trade is not detrimental to the survival to 
the species. 

•  Furthermore, Directive 92/43/EEC on the conservation of natural habitats and of 
wild fauna and flora (Habitats Directive) protects all seal species occurring within 
EU.  Grey  seal  (Halichoerus  grypus),  ringed  seal  (Phoca  hispida  bottnica)  and 
harbour seal (Phoca vitulina) are listed as Annex V species which means that their 

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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 
EU Wildlife Trade Regulations implementing the provision 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. 

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exploitation  is  allowed.  However  the  Member  States  are  under  the  obligation  to 
maintain or restore these species at favourable conservation status. 

Consequently,  this  Commission  overall  impact  assessment  focuses  on  the  animal 
welfare  aspect  of  seal  hunting  and  trade  implications  of  any  measures  in  all 
respective  range  states  ("range  states"  are  to  be  understood  as  all  territories  where 
seals are present and are (or could be) hunted, i.e. including EU Member States and 
Overseas Territories). The following countries have been assessed in detail: Canada, 
Finland,  Greenland,  Namibia,  Norway,  Russia,  Sweden  and  United  Kingdom 
(Scotland).  

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

2.2. 

Inter-Service Steering Group 

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

2.3. 

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

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

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

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

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

Some of the main conclusions: 

•  Seals  are  sentient  mammals  that  can  experience  pain,  distress,  fear  and  other 

forms of suffering. 

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

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

Some of the main recommendations: 

•  Seals  should  be  killed  without  causing  avoidable  pain,  distress  or  other  form  of 

suffering. 

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

•  The  killing  methods  should  only  be  used  in  appropriate  conditions,  be  applied 
(stunning,  monitoring  of 

respect  a  3-steps  procedure 

adequately  and 
unconsciousness, bleeding) before skinning. 

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

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

•  Independent  monitoring  of  seal  hunts  is  recommended,  thereby  meaning 

independent of both industry/commercial interests and NGOs.  

•  Hunts should be open to inspection without undue interference. 

For further details, please refer to the full text of the scientific opinion published by EFSA on 
their website6. 

2.4. 

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

Building  upon  the  EFSA  scientific  opinion,  a  study  (commissioned  by  the 
Commission) by the consultancy firm COWI7 examined  the regulatory frameworks 
for and the management practices of the different seal hunts. 

Legislative and enforcement provisions in a number of sealing countries, both within 
the  European  Community  and  beyond  were  assessed  and  best  practices  identified. 

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EFSA  independent  scientific  opinion  on  the  animal  welfare  aspects  of  methods  for  the  killing  and 
skinning of seals, Dec. 2007: 
http://www.efsa.europa.eu/EFSA/efsa_locale-1178620753812_1178671319178.htm 
COWI "Assessment of the potential impact of a ban of products derived from seal species", April 2008 

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The assessments were based on desk study research and information provided during 
the overall consultation process - but the study team did not visit all the range states 
worldwide.  

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

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

2.5. 

Public consultation 

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

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

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

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

•  Motivation  of  hunt:  Seal  hunting  undertaken  for  subsistence  purposes  are  more 

acceptable than hunt for profit. 

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

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

•  Enforcement  and  monitoring:  Seal  hunting  is  more  acceptable  if  it  is  firmly 

monitored by an independent inspection authority. 

•  Struck and lost: Any seal hunting that lead to more than even a very low level of 

struck-and-lost is not acceptable to the respondents. 

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

2.6. 

Other consultations 

2.6.1.  EFSA stakeholder consultation 

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

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

2.6.2.  Workshop organised by the Commission 

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

2.6.3.  Bilateral meetings with stakeholders 

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

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2.6.4.  Conference participation 

representatives, 

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

representatives 

scientists, 

from 

2.7. 

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

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

2.8. 

Impact Assessment Board 

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

3. 

PROBLEM DEFINITION 

3.1. 

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

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

3.1.1.  Description of the hunts 

There are thirty-three existing species of pinnipeds (fur seals, sea lions, walrus and 
true  seals).  They  occur  mainly  along  the  coasts  of  polar,  sub-polar  and  temperate 
regions. At least fifteen species are hunted by humans for commercial purposes or to 

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satisfy  subsistence  and  cultural  needs.  However,  the  majority  of  animals  killed 
belong to five species: harp seals, ringed seals, grey seals, hooded seals and Cape fur 
seals.  The  three  largest  seal  hunts  (Canada's  commercial  harp  seal  hunt  –  Total 
Allowable Catch (TAC) 270,000; West Greenland's harp seal hunt – unregulated, but 
landing  c.a.  90,000  animals;  and  Namibia's  Cape  fur  seal  hunt  TAC  =  86,000) 
account for approximately 57% of the total number of seals (900,000) allowed to be 
killed  or  reportedly  killed  annual  (uncorrected  for  struck  and  loss).  The  total 
population  of  seals  of  the  hunted  species  is  15-16  million  animals.  (EFSA2007). 
Annex  1  provides  a  detailed  overview  of  species  and  populations  of  seals  that  are 
killed and skinned. 

3.1.2.  Types of seal hunting 

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

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

Types of seal 
hunting 

Commercial non-
indigenous  hunt  

Characteristics of the hunt 

Focus in seal hunt management 
system 

Industrialised hunt 
Large quotas and catches 
Organised  
Often supplementary income 
for fishermen or other workers 

Provision of a basis for a viable 
industry 
Employment creation in sealing regions
Sustainable use of the marine resources
Hunting organisation 

non-

Personal 
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 

Recreational 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  

Small scale 
Activity supplementing 
primary occupation 
Comparable to other kinds of 
spare time activities/hunts 
Opportunistic 
Dispersed  

Maintaining and protecting hunting 
traditions of indigenous societies 
Income creation in sealing regions 
Hunting tools 

Hunt is small scale often aims to reduce 
the seal population 
Contribute to pest control 
Samples from the catch contributes to 
research 
Sustainable use of the marine resources 

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Pest control* 

Random or organised 
Minimise damage of seals on 
fishing gear 
Minimise damage to fish 
stocks 

By-catch* 

Random  
Seals caught in fishing gear 

Limit population growth as to reduce 
damage to fishing gear and potential 
spreading of infection to other species 

Invention and use of fishing gear that is 
seal proof hence reducing the number 
of seals caught in the gear 
Compensation to fisheries sector for 
damage inflicted by seals 

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

Some range states have implemented comprehensive management systems aimed at 
minimising the conflict between production and animal welfare, whereas other range 
states'  management  systems  are  less  well-developed  and  to  a  lesser  degree 
incorporate  animal  welfare  concerns.  Assessment  summary  sheets  per  sealing 
country (see Annex 2) provide an overview of national legislation and enforcement 
requirements  in  place  and  how  animal  welfare  recommendations  are  carried  out  in 
practice. 

According to the COWI study findings, the range states can roughly be grouped into 
three  groups,  even  though  it  is  to  be  noted  that  the  type  of  seal  hunting  varies 
considerably  between  the  range  states,  e.g.  the  EU  countries  not  having  any 
commercial hunting. Seal hunting is comprehensively regulated in Norway and it has 
the  most  developed  management  system.  A  second  group  is  made  up  of  Canada, 
Finland, Greenland, Namibia and Sweden - all of these range states have relatively 
well-developed  legal  frameworks.  There  are,  however,  pronounced  insufficiencies 
particularly regarding enforcement and training requirements. A third group consists 
of  Russia  and  the  UK.  For  both  of  these,  data  are  insufficient  to  make  sound 
conclusions. 

3.1.3.  Killing methods 

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

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

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

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

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

3.1.4.  Underlying motives and forces 

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

It is however clear that best practice is not always being followed and that as a result 
unnecessary  and  avoidable  negative  impacts  on  animal  welfare  occur.  This  is 
confirmed  by  the  findings  of  the  COWI  Assessment  Study8.  Other  studies  (e.g.  by 

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) 

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NGOs, industry linked groups) also highlight serious deficiencies and concerns in the 
hunts, though some of these studies may be biased  

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

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

Those areas concern  

I. Legislation 

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

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

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

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

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

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

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II. Enforcement:  

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

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

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

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

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

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

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

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

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

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

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

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3.2. 

Trade in seal products and related measures in place 

3.2.1.  Level of trade 

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

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

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

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

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

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

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

3.2.2.  EU Member States measures / WTO consultations 

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

In response to the Belgian and Dutch measures, Canada has requested formal WTO 
consultation  with  the  European  Community  pursuant  to  the  WTO's  Dispute 

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Settlement  Understanding.  Consultations  took  place  in  Brussels  on  14th  November 
2007. 

3.2.3. 

International perspectives 

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

3.2.4.  Community legislation 

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

The  protection  of  wild  animals  is  covered  by  the  Community  Action  Plan  on  the 
Protection and Welfare of Animals9. This approach reflects the Protocol to the Treaty 
on the Protection of Animals defined as sentient beings. As agreed at the time of the 
adoption  of  the  Action  Plan  and  in  order  to  support  the  harmonisation  of  animal 
welfare  standards  adopted  in  the  EU  both  on  public  and  private  bases,  the 
Commission  has  launched  a  feasibility  study  to  create  a  European  Centre  for  the 
Protection and Welfare of Animals that could serve as reference body to support the 
measures that could be taken in the future to address the welfare concerns identified 
in  this  impact  assessment.  The  European  Centre  could  be  developed  in  a  way  to 
assist  the  Community  and  Member  States  in  the  management  of  animal  welfare 
issues  both  at  EU  and  International  level.  In  this  way  the  Community  would  be 
served in the future by EFSA in the role of risk assessors and possibly by the future 
reference centre for the support to the risk management. 

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

9 

Community Action Plan on the Protection and Welfare of Animals 2006-2010 {SEC(2006) 65} 

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3.2.4.2.  The "Seal pups directive"10  

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

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

3.2.4.3.  The "Habitats Directive"11 

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

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

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

3.2.5.  Possible evolution of the problem 

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

10 

11 

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 
Council Directive 92/43/EEC of 21 May 1992 on the conservation of natural habitats and of wild fauna 
and flora 

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

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

3.3. 

Subsidiarity/necessity test 

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

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

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

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

4. 

OBJECTIVES 

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

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

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The main overarching objectives are to: 

•  Protect  seals  from  acts  that  cause  them  avoidable  pain,  distress,  fear  and  other 

forms of suffering during the killing and skinning process 

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

of seals 

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

•  Ensure consistency and legal clarity in terms of the requirements for placing seal 

products on the EU market 

•  Promote and reward good sealing practices 

By means of: 

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

market 

•  Provide important information to consumers about the manner in which a seal was 

killed and skinned in a specific sealing country 

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

– 

– 

– 

On animal welfare principles: Animal welfare principles are highlighted in 
the applicable hunting legislation - whether this targets seal hunting specifically or 
hunting in general.  

On  hunting  tools:  The  characteristics  of  the  weapons  used  to  kill  seal  are 
specified.  It  is  made  explicit  in  the  legislation  which  weapons  are  allowed  for 
stunning  and/or  killing  pups  and  which  are  allowed  for  stunning  and/or  killing 
adult  seals.  The  requirements  to  the  weapons  are  made  in  accordance  with  the 
recommendations of the EFSA scientific opinion. 

On  assuring  death  by  monitoring:  Legislation  should  specifically  outline 
requirements for monitoring and thereby oblige the hunter to assure that the seal is 
irrevocably unconscious before bleeding it out and before continuing to the next 
seal. 

– 

On  bleeding-out  animals  shot  or  stunned:  Bleeding-out  of  all  animals  is 
required  directly  following  adequate  stunning  i.e.  before  proceeding  to  stun 
another seal. 

– 

On environmental factors: Requirements are specified as to secure that the 
seal  and/or  the  hunter  is  sufficiently  stable  and  that  the  target  can  be  properly 

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– 

– 

– 

– 

visualised. Other environmental factors, relevant for the hunt in question, are also 
regulated. 

On  training  of  hunters:  A  defined  level  of  knowledge  and  ability  of  the 
hunter  regarding  seal  biology,  hunting  methods  and  the  three  step  procedure, 
hereunder practical use of the hunting tools, e.g. shooting tests, are required. 

On independent monitoring: A system for monitoring and observation of the 
hunt,  securing  regular  supervision  of  the  hunt  and  that  secures  independency  of 
the inspectors is provided for. 

On  ability  of  third  party  to  monitor:  Third  party  monitoring  of  the  hunt  is 

possible, with a minimum of administrative or logistic barriers. 

On reporting  requirements: Clear requirements for reporting targeting both 
hunters  and  inspectors.  There  are  requirements  to  where  and  when  animals  are 
the  range  of  relevant 
killed  and  weapons  and  ammunition  used.  Also 
environmental factors (weather conditions, etc.) should be reported. 

– 

On sanctions and compliance: Statistical information on the hunt should be 

compiled and systemised. 

5. 

MAIN POLICY OPTIONS 

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

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

5.1. 

"No additional EU action"  

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

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

5.2. 

Legislative measures 

Table 5.2.1 presents the formulations of the legislative measures and their rationale - 
both  with  respect  to  effectiveness/efficiency  and  with  respect  to  achieving  the 
objectives  of  the  measure,  and  regarding  consistency  -  i.e.  the  extent  to  which  the 

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measures are likely to limit trade-offs across the economic, social and animal welfare 
domain. The measures are sorted so that they start with what immediately appears to 
be  the  most  wide-ranging.  However,  a  combination  of  the  first  two  measures  - 
prohibition of placing on the EU market and prohibition of imports/exports – may be 
the most comprehensive measure. 

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

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

Table 5.2.1  Legislative measures 

Formulation 

Effectiveness/efficiency 

Consistency 

Prohibition of 
placing on the EU 
market of skins of 
seals and products 
derived there from 

The measure is effective in the sense that it is 
without a doubt prohibited to hold any seal 
skins or seal products physically within the 
EU territory that are made available and 
destined for the first time for distribution or 
direct sale in the EU market. 

However, (second-hand) seal products already 
sold once on the EU market are not covered. 
Furthermore, products that are imported, 
manufactured or stored within the EU 
territory but intended for export outside the 
EU are not covered. These exemptions might 
reduce the effectiveness of enforcement. 

The measure is considered efficient in the 
sense that it only requires expenditure for 
enforcement. 

This comprehensive 
measure will benefit the 
animal welfare concerns 
of the general public 
regarding seal hunting - 
at economic costs to the 
sealers, the seal product 
manufactures and the 
Inuit population. 

However, there is no 
incentive to improve the 
welfare of the hunted 
seal species (which is the 
main cause for concerns) 

Prohibition of 
imports into the 
Community of skins 
of seals and products 
derived there from 
(will in practice also 

The measure is effective in the sense that it is 
without a doubt prohibited for any seal skins 
or seal products to enter the customs territory 
of the Community (with exception of imports 
of non-commercial nature). Similarly, seal 
skins and seal products may not leave the 

similar to above 

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imply exports) 

customs territory. 

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 

Harmonised, 
mandatory labelling 
system 

Products which are not customs cleared are 
not covered. 

The measure is considered efficient in the 
sense that it only requires expenditure for 
enforcement. 

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. 

Such a labelling system (product-based) 
enabling consumers to distinguish between 
individual seal products on the basis of 
welfare considerations t allows selected seal 
skins and seal products from any range state, 
if they fulfil the labelling requirements (which 
can be based on the results of the EFSA 
opinion and the COWI study). 

The measure is considered similarly effective 
as the above measure - for the same reasons. 

However, it might be slightly less efficient 
than the above, as it does not contain any 
direct enforcement measure other than the 
provision and enforcement of labels. 

The trade-offs 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. 

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. 

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Bi-/multilateral 
agreement(s) with 
range state(s) 

Agreements between the EU and one or more 
states - and thus possibly defining those 
sealing countries exempted from the above 
legislative measures. 

Hence, effectiveness and efficiency will 
depend upon the actual content of an 
agreement. 

The trade-offs across the 
animal welfare, 
economic and social 
dimensions will depend 
upon the actual content 
of an agreement. 

5.3. 

Non-legislative measures 

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

Table 5.3.1  Non-legislative measures 

Formulation 

Effectiveness/efficiency 

Consistency 

Voluntary 
labelling systems 
/ development of 
voluntary 
standards 

An EU-administered voluntary labelling system 
(product-based) that seal hunters can subscribe to (if 
they fulfil the labelling requirements) is similar to 
the above-presented (see Table 5.2.1) harmonised, 
mandatory labelling system. However, such 
voluntary system might be less effective than the 
mandatory - merely because it is voluntary. 

The level of efficiency might be lower or higher, 
depending on the costs saved by not making the 
labelling system mandatory and possibly lower 
enforcement expenditure. 

A voluntary system 
might encourage a 
natural self-selection 
process regarding 
compliance and thus 
maintain the balance 
between the animal 
welfare, economic and 
social dimension - i.e. 
those who pursue the 
label might benefit 
more than it costs, and 
the welfare of the seals 
is enhanced. 

Development of 
guidelines by an 
internationally 
recognised 
organisation 

Best practices on seal hunting methods and seal 
hunt management systems recommended by an 
internationally recognised organisation. 

not possible to 
comment upon 

Such organisation still requires to be identified. . 

Hence, effectiveness and efficiency will depend 
upon the actual content of such guidelines. 

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 

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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. 

ANALYSIS OF IMPACTS 

6.1. 

General remarks  

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

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

6.1.1.  Coverage and type of impacts 

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

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

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

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

Type of Impact 

Likely impacts of EU policy measures 

Welfare dimension 

Welfare of seals 

In terms of welfare, the effectiveness of killing methods used for seals 
vary according to the methods used, the skill of the operators, and the 
environmental  conditions  (EFSA,  2007).  Hence,  policy  measures  that 
encourage  the  use  of  'best  practices'  -  e.g.  a  labelling  system  -  will 
improve the animal welfare aspects of seals. 

Policy  measures  -  such  as  prohibitions  of  market  access  for  seal 
products - might reduce the size of the hunting and thus the number of 
seals suffering. 

However,  animal  welfare  gains  will  be  reduced  by  the  extent  such 
policy measures imply that seal products are diverted to others markets 
- which might have lower requirements for animal welfare aspects. 

Economic dimension 

Trade 

Since seal hunting mostly takes place outside the Community territory, 
any  restrictions  to  market  access  in  the  Community  will  have  trade 
impacts. 

Trade  restrictions  on  seal  skins  will  directly  affect  the  seal  hunters 
while  they  indirectly  will  be  affected  by  reductions  in  the  trade  of 
manufactured seal products. Seal product manufacturers will obviously 
be affected by the latter restrictions. 

Furthermore,  importers  and  seal  product  manufacturers  on  the 
Community territory will experience income and production losses. 

Consumers' right may be reduced, if they can no longer purchase seal 
products on the EU market. 

However, trade losses for the exporters will be reduced if seal products 
are diverted to others markets and of course depend on how important 
the EU market is at present. 

Local economy  While  the  macroeconomic  impact  of  reducing  seal  hunting  might  be 
limited in the range states - there will be an impact on the incomes of 
the  individual  sealers  (although  state  subsidies  might  alleviate  this 
income loss) and the seal product manufacturers. 

These  activities  often  take  place  in  remote,  coastal  areas.  Hence,  the 
impacts  will  in  practice  depend  on  the  share  of  income  in  a  local 
economy  from  sealing  activities  -  and  whether  or  not  there  are  any 
other employment/income opportunities. 

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Social dimension 

Inuit population 

The  impact  on  the  Inuit  population  follows  the  impact  on  the  local 
economy. 

However, the impact might differ if the policy measures accept the use 
of  traditional  hunting  methods  and/or  allows  sales  of  seal  products 
made by the Inuit population. 

However,  policy  measures  that  have  adverse  impact  on  the  image  of 
seal  skins  and  other  seal  products  will  have  a  negative  impact  on  the 
Inuit population anyway. 

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

Geographical dimension 

Seal hunt 
management 
system specific 
impacts 

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

6.2. 

Baseline  

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

The socio-economic contexts analysed in the framework of the COWI assessment12 
of the national seal hunt management systems as well as information from additional 
data  sources  such  as  Eurostat  and  the  different  national  statistical  offices  provided 
the starting point for the presentations of this baseline. 

6.2.1.  Welfare of seals 

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

However,  as  also  mentioned  above,  animal  welfare  gains  will  not  arise  if  seals 
continue  to  be  hunted  in  the  same  way  as  they  are,  and  seals  products  are  simply 

12 

Assessment of the potential impact of a ban of products derived from seal species, April 2008, COWI 

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diverted to other markets. It is difficult to assess what action a commercial seal hunt 
will  undertake  when  faced  with  the  possibility  of  exclusion  from  the  EU  market. 
They will have to choose between improving animal welfare standards (which may 
not  be  a  costly  change),  or  the  economic  implications  of  exclusion  from  the  EU 
market (which seems to be the recipient of around a third of all existing global trade).  

6.2.2.  Environmental impacts 

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

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

Furthermore, the impact of any trade ban on seal products in the EU may not have a 
significant effect on total seal populations, at least in relation to other factors13. This 
should mean there is no significant impact on the fishing economies. 

6.2.3.  Trade 

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

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

It is important to emphasise that the Eurostat trade data presented below do not cover 
goods  in  transit.  They  exclude  extra-EU  trade  where  the  goods  are  placed  in  a 
customs warehouse (purely for storage) or given temporary admission inside the EU 

13 

The basis for this assumption is firstly the size of seal hunts. In a typical seal hunt, for example, maybe 
around  2-5%  of  the  seal  population  is  killed  in  commercial  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 populations but this may be for other factors, such as 
environmental or disease factors).  

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borders  for  trade  fairs,  temporary  exhibitions,  tests  etc.  as  well  as  intra-EU  trade 
where  the  goods  are  merely  passing  across  a  Member  State,  by  any  means  of 
transport, but are not stored there for any but transport reasons. This implies that the 
data for imports of seal products concern only products destined for the EU market 
and/or where further (substantial) processing takes place. 

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

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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 

43021941 

43021949 

43023051 

43023055 

43031010 

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) 

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 

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) 

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

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

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

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

EN 

33 

   EN 

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

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

between  EU-27 

Canada 

Finland  UK  

(Scotland) 

Green-
land 

Namibia  Norway  Russia 

Sweden 

Import to EU-27 from: 

43017010 

0 

0 

0 

0 

43017090 

191389 

931888 

337817 

1313000 

43021941 

21849 

0 

0 

0 

0 

0 

0 

0 

0 

659 

186081 

2192 

43021949 

461238 

7582 

299325 

60131 

67079 

176794 

43023051 

0 

43023055 

45563 

0 

0 

1742 

178239 

43031010 

0 

162 

88150 

0 

39599 

6312 

0 

0 

0 

0 

113657 

0 

0 

0 

0 

0 

0 

Total 

720039 

939632 

905273 

1419042 

67079 

293302 

186081 

Export from EU-27 to: 

43017010 

43017090 

43021941 

0 

0 

0 

0 

1251 

551435 

2389 

19608 

0 

0 

0 

0 

43021949 

24627 

677193 

2193682 

1458 

43023051 

43023055 

43031010 

0 

0 

1062 

0 

0 

0 

0 

269327 

909209 

0 

2182 

0 

Total 

26940 

1228628 

3374607 

23248 

Import minus export 

43017010 

0 

0 

0 

0 

43017090 

190138 

380453 

335428 

1293392 

43021941 

21849 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

14108 

195500 

0 

109774 

1947 

2505755 

0 

0 

0 

23282 

36411 

297931 

52466 

3132242 

0 

0 

-13449 

-9419 

2192 

-109774 

0 

0 

0 

4443 

0 

0 

1620 

6063 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

43021949 

436611 

-669611 

-1894357 

58673 

67079 

174847 

-2505755 

4443 

43023051 

43023055 

43031010 

0 

45563 

-1062 

0 

0 

1742 

-91088 

162 

-821059 

0 

37417 

6312 

0 

0 

0 

0 

0 

113657 

-23282 

-36411 

-297931 

Total 

693099 

-288996 

-2469334 

1395794 

67079 

240836 

-2946161 

0 

0 

1620 

6063 

Source: Eurostat external trade database 

EN 

34 

   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 fur skins. Although articles of apparel and 
clothing accessories made of the fur skin of whitecoat pups of harp seal or blueback 
pups  of  hooded  seal  (excl.  gloves  made  of  leather  and  fur  skin,  footwear  and 
headgear  and  parts  thereof)  and  possibly  other  items  seem  not  as  fully  covered 
compared  with  the  trade  figures  in  Euro  -  the  table  is  considered  useful  for 
comparisons with other seal product data using such units. 

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

  Canada 

Finland 

UK  
(Scotland) 

Green-
land 

Namibia 

Norway 

Russia 

Sweden 

0 

0 

5064 

54184 

0 

0 

0 

0 

12 

15 

1900 

13729 

3526 

0 

4490 

50 

3423 

0 

0 

600 

0 

6635 

0 

3421 

0 

0 

0 

0 

605 

0 

0 

168 

0 

15 

0 

13 

0 

0 

43017010 

43017090 

43021941 

43021949 

43023051 

43023055 

43031010 

43017010 

43017090 

43021941 

43021949 

43023051 

43023055 

43031010 

43017010 

43017090 

43021941 

43021949 

43023051 

43023055 

43031010 

0 

3558 

200 

6868 

0 

227 

0 

0 

10 

0 

712 

0 

0 

0 

0 

3548 

200 

6156 

0 

227 

0 

0 

9131 

0 

260 

0 

0 

0 

0 

1062 

0 

35 

0 

0 

0 

0 

8069 

0 

225 

0 

0 

0 

Import to EU-27 from: 
0 

0 

1407 

0 

0 

0 

0 

0 

0 

0 

88 

0 

0 

0 

Export from EU-27 to: 
0 

0 

Import minus export 
0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

2409 

0 

0 

25 

0 

0 

0 

200 

0 

-13 

15 

194 

17425 

1745 

735 

0 

267 

0 

-338 

-735 

0 

0 

0 

0 

0 

0 

0 

0 

88 

0 

0 

0 

4464 

54016 

0 

0 

-2145 

1885 

13729 

3332 

-17425 

50 

2 

0 

0 

592 

0 

0 

0 

0 

0 

2409 

-200 

0 

-267 

0 

Source: Eurostat external trade database 

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

Table 6.2.3.4 shows that Denmark and Italy by far are the two largest EU importers 
of  raw  fur  skin  from  seal  for  further  processing/sales  on  the  EU  market  -  and  they 
share the market. Denmark imports raw fur skins directly coming from Canada and 

EN 

35 

   EN 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Greenland (that are not categorised as goods in transit), while Italy imports raw fur 
skins  from  Russia,  Finland  and  the  UK  (Scotland)  -  where  many  of  the  skins  from 
the latter two originates from outside the EU borders. Greece also has a small share 
of the skins coming from the two latter range states, i.e. Scotland and Finland, which 
is imported for further processing. 

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

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

Canada 

Finland 

0 

191389 

0 

0 

0 

UK  
(Scotland) 
0 

Green-
land 

114 

0 

0 

1312886 

0 

0 

0 

0 

0 

60089 

32433 

0 

280 

871799 

281132 

0 

23972 

0 

0 

0 

0 

0 

191389 

931888 

337817 

1313000 

Namibia 

Norway 

Russia 

Sweden 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

659 

0 

0 

0 

0 

0 

0 

0 

0 

0 

186081 

0 

659 

186081 

0 

0 

0 

0 

0 

0 

0 

0 

Austria 

Denmark 

Finland 

Greece 

Ireland 

Italy 

Poland 

EU-27 

Source: 

Eurostat external trade database. 

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

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

EN 

36 

   EN 

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

UK  
(Scotland) 
0 

Green-
land 

Namibia 

Norway 

Russia 

Sweden 

Canada 

Finland 

0 

0 

275610 

0 

0 

0 

0 

0 

0 

0 

1436 

0 

0 

0 

0 

0 

139714 

45563 

0 

0 

0 

0 

0 

0 

0 

0 

Bulgaria 

Germany 

Denmark 

Estonia 

Spain 

Finland 

UK 

Greece 

Ireland 

Italy 

Latvia 

Poland 

Portugal 

Sweden 

EU-27 

0 

0 

89336 

0 

0 

947 

0 

0 

0 

0 

0 

0 

0 

74820 

0 

0 

50751 

0 

0 

31414 

186177 

0 

0 

14343 

0 

0 

0 

0 

0 

0 

0 

53001 

0 

14078 

0 

0 

0 

0 

6742 

0 

98 

10998 

1879 

726 

233190 

0 

0 

0 

0 

0 

29856 

9154 

0 

9447 

528650 

7582 

479306 

99730 

67079 

292643 

67763 

6146 

121801 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

2213 

0 

576 

0 

0 

1654 

0 

0 

4443 

Eurostat external trade database.   

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

The  description  of  the  baseline  for  the  trade  impact  analysis  has  until  now 
concentrated on the situation in 2006. However, the situation has not been stable in 
the  period  1999  to  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 sufficient to describe the situation for the EU-
27 Member States - hereunder the range states: Finland, UK and Sweden, they do not 
fully  cover  the  trade  of  the  non-EU  range  states:  Canada,  Greenland,  Namibia, 
Norway and Russia. In particular, the exclusion in the Eurostat trade data of goods 

14 

Eurostat trade data for 2007 are still incomplete. 

EN 

37 

   EN 

 
                                                 
that  are  placed  in  a  customs  warehouse  (purely  for  storage)  or  given  temporary 
admission  for  trade  fairs,  temporary  exhibitions,  tests  etc.  is  to  some  extent 
inconsistent  with  the  statistics  kept  by  some  of  these  exporters  since  they  actually 
consider these EU traders as importers of their goods. On the other hand, further EU 
restrictions on such transit trade might not be that severe - depending on how easily 
this  part  of  the  trade  can  be  shifted  to  a  non-EU  country.  However,  there  could  be 
some  impacts  on  transport  companies,  EU  sea-  and  airport  for  which,  however,  it 
was not possible to provide data. 

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

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

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

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

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

EN 

38 

   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 

Belgium 

Czech Rep. 

Germany 

Denmark 

Spain 

Finland 

France 

UK 

Greece 

Hungary 

Italy 

Latvia 

Poland 

Portugal 

Sweden 

EU-27 

Norway 

Namibia 

Greenland 

Russia 

0 

0 

0 

2091143 

222556 

0 

950 

870 

32860 

1711744 

371763 

100682 

2964716 

8744547 

0 

0 

273418 

634873 

14529 

6206711 

0 

0 

0 

0 

0 

0 

293018 

615194 

228528 

360614 

18140 

15364 

5292944 

19609276 

10042654 

0 

0 

0 

104690 

18032 

11014 

1531820 

1665556 

834367 

2918163 

136274 

4136882 

13988 

0 

0 

39586 

3716 

32599 

0 

0 

5150 

183856 

0 

0 

0 

0 

0 

12120 

294362 

20912 

0 

2128 

12980 

36020 

45270 

33126 

28862 

248630 

Other range states 

10042654 

China 

Hong Kong 

South Korea 

US 

931452 

125105 

2486 

0 

EN 

39 

   EN 

 
Turkey 

Other 

Total 

EU-27 share 

Other range state share 

0 

0 

3825504 

409378 

16394641 

33535400 

32.3% 

61.3% 

58.5% 

5.0% 

0 

105411 

791681 

37.2% 

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 

43023000  -  Tanned  or  dressed  fur  skins, 
assembled 

347320 

Source: 

Statistics Norway 

.. 

.. 

15433012 

8026126 

.. 

.. 

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

Table 6.2.3.8 Greenlandic exports, 2006 

Export, DKr 

Raw fur skins whole - seal 

36949000 

Products of seal skin 

Total 

903000 

37852000 

Source: 

Statistics Greenland 

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

EN 

40 

   EN 

 
 
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 

Denmark 

Greece 

Italy 

Poland 

EU-27 

Norway 

Canada 

336 

150 

13550 

300 

1 

14337 

15177 

6510 

Other range states 

21687 

Hong Kong 

Turkey 

Total 

EU-27 share 

14684 

17813 

68521 

20.9% 

Other range state share 

31.7% 

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

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

EN 

41 

   EN 

 
 
Table 6.2.3.10 

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

43017010  Raw fur skins - whitecoat pups of harp seal or blueback pups 

of hooded seals 

43017090  Raw fur skins - other seals 

43021941 

Tanned or dressed fur skins - whitecoat pups of harp seal or 

blueback pups of hooded seals - not assembled 

43021949 

Tanned or dressed fur skins - other seals - not assembled 

43023051 

Tanned or dressed fur skins - whitecoat pups of harp seal or 

blueback pups of hooded seals - assembled 

43023055 

Tanned or dressed fur skins - other seals - assembled 

43031010 

Articles of apparel and clothing accessories - whitecoat pups 

of harp seal or blueback pups of hooded seals 

Total 

Share of exports to EU 

43021949 

Tanned or dressed fur skins - other seals - not assembled 

Total 

Source: Eurostat external trade database 

Finland 

UK  

Sweden 

(Scotland) 

0 

0 

0 

0 

0 

3052 

12098 

0 

0 

72238 

298995 

80 

0 

0 

0 

24469 

0 

0 

6016 

0 

9379 

78254 

326516 

21557 

2.5% 

38.1% 

100.0% 

2.3% 

34.8% 

0.4% 

The figures therefore represent the export of nationally produced goods threatened by 
new  EU  policy  measures  -  while  excluding  the  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 commercial 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  Russian  sources.  Such  lack  of  Russian 
information is also reflected in the respective description of the range state seal hunt 
management  system  (see  Annex  2).  Any  assessment  of  the  trade  impacts  of  policy 
measures for Russia will have to rely 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. 

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 

EN 

42 

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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  economies  that  depend  on  seal  hunting,  the  general 
economic/employment  situation  in  such  economies  compared  with  the  rest  of  the 
countries, and whether there are alternative income sources to substitute any declines 
in  incomes  for  sealing.  With  respect  to  the  latter,  the  level  of  subsidies  (if  any)  to 
sealing (communities) should also be considered - i.e. whether they will be increased 
to compensate for any income declines; although 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 economy characteristics in range states 

Canada 

Finland 

Green-land  Namibia  Norway 

Russia 

Sweden 

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 

UK  
(Scotlan
d) 
Insignifi
cant 

30pp 
above 
national 
level 

Unemploym

ent 

Alternative 
income 

tourism 

24% of 
hunters 
have 
additional 
occ. 

eco-
tourism 

tourism 

sales go 
to non-EU 

tourism 

Source: COWI study, country 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 subsequently entering onto the market. Although, 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, 
the experience from the EU ban on certain seal products from 1983, which excluded 
this part of the hunt, is that policy measures that have adverse impacts on the image 
of  seal  skins  and  other  seal  products  will  have  a  negative  impact  on  the  Inuit 
population anyway. 

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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  territory.  Hence,  the  measure  would  not  cover  goods  in 
transit - such as the large transhipments of seal skins taking place through Germany 
(mainly Frankfurt). Furthermore, products that 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 sealskins and other seal products, and imports of sealskins for 
further  processing  and  exports  continue.  The  sealing  in  Finland  and  Sweden  is 
anyway mostly characterised as having cultural and recreational roles in the coastal 
communities, rather than being trade oriented. Furthermore, in the UK (Scotland) the 
hunt is targeted at the killing of seals in the vicinity of fishing, rather than for the use 
of the skin. However, the UK does process sealskins 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  seals  and  products  derived  therefrom  -  EU 
Member States 

Finland 

Sweden 

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. 

UK  
(Scotland) 
Medium - since more 
than a third of seal 
product exports go to 
other EU Member 
States; but no impact 
on local communities. 

Other EU 

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  assessed  to  be  slightly  higher  for  non-EU 
range state. This is a result of the fact that the size of the 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 assessment 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. 

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44 

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Table Error! No text of specified style in document..2 
Impacts  of  prohibition  of 
placing on the EU market of skins of seals and products derived therefrom - non-EU 
range states 

Canada 
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. 

Greenland 
Medium - since a 
fourth of exports are 
designated EU 
markets - and so 
local sealing 
communities will be 
affected. 

Namibia 
Medium - since a fifth 
of exports are 
designated EU 
markets - and so 
local sealing 
communities will be 
affected. 

Russia 
Minor - since few 
seal Russian 
sealskins are 
assessed to end up 
on the EU market. 

Norway 
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. 

Source: COWI assessments 

A prohibition of market access for seal products 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 welfare 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  largely  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 

354744 

0 

94447 

0 

15295 

na 

0 

hooded seals 

Total seals  

355521 

514 

184220 

83100 

15597 

 na 

100 

Share of harp 

99.8% 

0.0% 

51.3% 

0.0% 

98.1% 

 na 

0.0% 

and hooded 

Source: COWI assessments 

not 

relevant 

not 

relevant 

not 

relevant 

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  assessment  of  the  seal  hunt  management 
systems  (see  Annex  2)  -  together  with  the  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 states, such limited measure will only make a 
real difference if it addresses elements of the hunt in these range states. 

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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  measure  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 exhibitions, tests etc. However, banning imports 
on  the  basis  of  public  morality  might  not  go  well  together  with  allowing  such 
transhipments. Hence, the assessment looks also 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, although 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 comprehensive measure - will 
have additional impact. 

Table  6.4.1  Impacts  of  prohibition  of  imports  (and  exports)  into  the  Community  of 
skins of seals and products derived therefrom - EU Member States 

Finland 

Sweden 

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. 

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 

Source: COWI assessments. 

UK  
(Scotland) 
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. 

if extended to transit: 
No difference to 
above - since the 
limited transit trade 
seems to be for the 
EU market. 

Other EU 

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 - 
primarily in Germany (Frankfurt), not only for 
the EU market, will cease.  

Similar  to  the  prohibition  of  placing  on  the  EU  market,  Table  6.4.2  shows  that  the 
impacts  are  assessed  to  be  slightly  higher  for  non-EU  range  state.  This  is  again 
merely  a  result  of  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. However, if the ban is extended to transit trade Canada will in particular 
suffer unless this trade can be shifted away from Germany and Finland to outside the 
EU  e.g.  Norway.  Hence,  Norway  may  actually  strengthen  its  position  as  a  transit 
trader. 

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46 

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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. 
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 

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. 

if extended to transit: 
No difference to 
above 

if extended to transit: 
No difference to 
above 

Medium - since the 
Russian market take 
in a large share of 
EU exports. 

if extended to transit: 
No difference to 
above 

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. 
if extended to transit: 
Positive impact - 
since the position as 
transit trader might 
be strengthened e.g. 
more Canadian 
skins. 

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  context  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 contribute to an improvement of the welfare of 
seals at killing. However, as mentioned above 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 market and at the same time could help to 
enhance  the  image  of  seal  hunting  in  general.  If  the  system  is  voluntary  and  not 
linked  to  a  legislative  measure,  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 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 labelling 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  reasons  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 some mandatory and enforceable standards. 

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47 

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6.6. 

Impact of other measures 

6.6.1.  Bi-/multilateral agreements between the 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 products, 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 other 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  that,  via  agreements,  are  not  subject  to 
restrictions.  Greenland  could  be  the  largest  beneficiary,  while  Namibia  and  Russia 
are likely to experience the worst economic impact of such agreements. 

Table Error! No text of specified style in document..1.1  Impacts 
bilateral 
agreements with non-EU range states - excluding them from prohibitions of imports 
or placing on the EU market 

of 

Canada 

Greenland 

Namibia 

Norway 

Russia 

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.  

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. 

Source: COWI assessments 

6.6.2.  Development of guidelines by an internationally recognised organisation 

Guidelines developed and adopted by an internationally recognised organisation, but 
unrelated to a mandatory system, would have a similar effect as a voluntary labelling 
system. Such guidelines could comprise best practices on seal hunting methods and 
seal  hunt  management  systems  -  and  in  this  context  build  upon  the  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  recognised'  and  which  would 
cover all seal hunts. 

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48 

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6.6.3.  EU 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,  while  a 
campaign targeted at seal hunters and producers can, for example, benefit from the 
above  mentioned  guidelines.  It  is,  however,  difficult  to  say  how  information 
campaigns will affect over a longer period of time the 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 reviewed data. EFSA therefore 
had  to  take  a  qualitative  approach  when  conducting  its  risk  assessment  on  adverse 
welfare effects of seals during the killing and skinning process. Nevertheless, it was 
possible  for  EFSA  to  use  the  output  of  that  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  information  received  during  the  assessment 
process differs between the elements (welfare of seals, trade, local economy, and the 
Inuit  population)  and  for  some  of  these  between  range  states.  This  is  in  particular 
relevant  for  the  lack  of  data  to  analyse  the  consequences  for  local  economies 
dependent on sealing. 

Given  the  above  and  considering  the  animal  welfare  concerns  expressed  by  the 
public, the EP and Member States and identified by EFSA, non-legislative measures 
such as information campaigns and voluntary labelling schemes will not be sufficient 
to address the issue.  

7. 

COMPARING THE OPTIONS 

The EFSA scientific opinion clearly indicates that there is reported evidence that, in 
practice, effective killing does not always happen - which is reinforced by the COWI 
study  findings.  There  are  therefore  reasonable  grounds  to  consider  undertaking 
precautionary steps to ensure that products derived from seals, which are killed and 
skinned in a way that causes them avoidable pain, distress and suffering, are denied 
access to the European market. Based on the assessment, it appears that the impact of 
non-legislative  measures  on  sealing  countries  to  implement  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  therefore  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  product  on  the  EU  market  including  those 
originating from within the EU. This measure would provide for a harmonization of 

EN 

49 

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the EU internal market, but would cause problems to some of the EU Member States 
where seal hunting is taking place and products are offered to a limited extent on the 
local market.  

This option is assessed to have minor trade impacts on the EU Member States. This 
assumes,  however,  that  transhipments  of  sealskins  and  other  seal  products  and 
imports of sealskins for further processing and exports continue. The trade impacts 
are assessed to be slightly higher 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  negative  trade  impacts 
for Namibia and somewhat relieve the ones 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 seal 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  accordance  with  trade  statistics  received  by 
Canada, seal products for a total value 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  considered  in  transit,  i.e.  the  goods  are  placed  in  a  customs 
warehouse for storage until reshipment, or given temporary admission for trade fairs, 
temporary  exhibitions,  tests,  etc.  With  regard  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  transit  trade.  According  to  EUROSTAT,  the 
total  imports  to  the  EU-27  from  Finland  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 size 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 Finland to outside the 
EU  e.g.  Norway.  Hence,  Norway  may  actually  strengthen  its  position  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  skins  directly  coming  from  Canada  and 
Greenland (that are not categorised as goods in transit), while Italy imports raw fur 
skins  from  Russia,  Finland  and  the  UK  (Scotland)  -  where  many  of  the  skins  from 
the latter two  originates from  outside  the EU borders.  Greece also  has  a  noticeable 
share of the skins coming from the two latter range states. 

EN 

50 

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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  welfare  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  pain,  distress,  fear  and  other 

forms of suffering during the killing and skinning process 

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

of seals 

This  should  be  done  through  prohibiting  the  placing  on  the  market  and  the  import, 
transit  through,  or  export  from,  the  Community  of  all  seal  products  from  a  given 
date. The prohibitions shall not apply to seal products resulting from traditional hunts 
conducted  by  Inuit  communities  for  subsistence  purposes.  By  way  of  derogation 
from the above, such a prohibition would allow the placing on the market for those 
seal products derived from seals taken in those countries that can demonstrate that: 

•  adequate legislative and enforcement provisions are in place seeking to ensure that 
seals are killed and skinned without causing avoidable pain, distress and any other 
form of suffering and 

•  high  animal  welfare  standards  respecting  the  basic  criteria  highlighted  by  the 
results of the Commission's impact assessment process are applied and that their 
application is properly enforced and monitored. 

The  measure  would  also  establish  the  requirement  (country-based  label  or  marking 
coupled with a certification scheme to be put in place in the sealing countries) that 
seal  products  whose  trade  would  be  possible  by  derogation  to  the  prohibitions 
otherwise  in  force,  would  be  clearly  marked/labelled  as  coming  from  a  country 
meeting the above-mentioned conditions. 

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

7.3.1. 

Impacts of preferred policy package 

Impact on world trade 

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51 

   EN 

As  explained  above,  trade  statistics  are  not  necessarily  complete.  Nevertheless,  we 
can say that: 

Canada  (almost  certainly  the  biggest  exporter),  exports  around  40%  of  its  raw  fur 
seal skins by value to the EU and around half of all seal products 

A quarter of Greenland's exports go to the EU market 

A fifth of Namibia's exports go to the EU market 

So, very roughly, around a third of world trade currently 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  (Canada,  Russia,  Asia  etc).  However,  it  is 
improbable that such demand would completely 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  would  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 trade would have the most significant 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  country  might  be  strengthened.  A  ban  on 
transit  would  ensure  that  seal  products  do  not  transit  through  the  Community  and 
would therefore render a ban on intra-Community 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 possible 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 scientific 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  the  ice  at  present.  In  practice  though,  it  would  seem 

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reasonable to say that financial costs would 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  further  processing/sales  on  the  EU  market, 
would  suffer  a  medium  sized  impact  from  a  lack  of  raw  fur  supply.  Denmark 
imports the raw furs kins directly coming 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  exclusively  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 about a tenth of the seals caught in Canada 
for  a  mixture  of  commercial  and  subsistence  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  results  in  earnings  by  the  community  of 
around 1mill Canadian $ a year (about €650,000).  

Impact on fish stocks 

There is no clear evidence for an impact on the fish stocks (see chapter 6.2.2). 

WTO compatibility 

An  import  ban  can  be  justified  on  the  basis  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 morals (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 arbitrary or unjustifiable discrimination. The proposed measure 
is  not  discriminatory  as  the  various  prohibitions  to  be  provided  for  will  apply  to 
intra-Community trade as well as to imports and exports. 

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8. 

MONITORING AND EVALUATION 

8.1.  Monitoring 

The  monitoring would  be done by the Commission and Member States. The future 
European Centre for the Protection and Welfare 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  any  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 will enable the evaluations of the extent 
to  which  the  envisaged  measures  have  contributed  to  improve  the  welfare  of  seals 
during  the  killing  process  and  to  which  extent  the  concerns  of  some  citizens  have 
been addressed. The monitoring of impact of the measures on the welfare aspects of 
seal  killing  in  third  countries  would  need  to  be  defined  in  the  framework  of 
negotiations. 

The  efficiency  of  the  legislative  measure  will  be  measured  in  reference  to  the  'best 
practices'  highlighted  by  the  results  of  the  overall  Commission  impact  assessment 
process.  This  should  be  possible  but  would  imply  additional  costs.  It  should  be 
recognised that commercial hunts are already subject to some degree of monitoring 
and inspection. The effectiveness and adequacy of current arrangements is disputed, 
but at the very least it provides a solid base on which adequate procedures could be 
built. 

The  'best  practices'  identified  through  the  assessment  process  are  listed  below 
together with some examples of current practices 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  demonstrate  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 animals do not suffer unnecessarily. 

•  Hunting tools: The characteristics of the weapons used to kill seal are specified. It 
is made explicit in the legislation which weapons are allowed for stunning and/or 
killing  pups  and  which  are  allowed  for  stunning  and/or  killing  adult  seals.  The 
requirements to the weapons are made in accordance with the recommendations 
of the EFSA scientific opinion. 

Countries have various degrees of description of the tools that shall be used to hunt 
seals. According to the EFSA opinion, some tools are more likely to reduce animal 

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welfare than others. First of all, the hakapik 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 Namibian club is even lighter and without a 
spike. Moreover, the club or hakapik should 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. Second, regarding rifles and 
ammunition, all countries except 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 oblige the hunter to assure that the seal 
is irrevocably unconscious before bleeding it out and before continuing to the next 
seal. 

Canada is the only country where it is required by law to undertake a blinking test as 
to  confirm  that  the  seal  is  dead  before  proceeding  to  strike  another  seal  (MMR 
§28.3). Monitoring that the seal and assuring that 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) states 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  described.  Norway  is  the  only  country  with  an 
explicit  requirement  to  bled-out  all  seals  right  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 the other range states require bleeding out, 
although the government in some states say that 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 environmental factors, relevant for the hunt in question, are also 
regulated. 

The Swedish EPA Decision on controlled hunting 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 prescribes a condition securing that shooting is 
taken  place  from  a  stable  foundation.  The  Norwegian  legislation  prescribes  that 
hunting seal that is in the water is prohibited (2003-02-11-151 §6). Several countries 
have  restrictions  on  hunting  in  artificial  light,  e.g.  Norway  and  Finland.  The 
difference in environmental conditions, both regarding weather and hunting location 
and climate influences what and which factors need to be addressed. 

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•  Training  of  hunters:  A  defined  level  of  knowledge  and  ability  of  the  hunter 
regarding seal biology, hunting methods and the three step procedure, hereunder 
practical use of the hunting tools, e.g. shooting tests are required. 

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  Greenland  young  sealers  learn  from  more 
experienced ones. In principle this hands-on training is just as good or might even be 
better than formally organised training. The challenge is to secure that good practices 
are passed on and not bad practices. 

Norway is the country with the most extensive training requirements of all the range 
states  in  the  study  with  mandatory  seal  hunt  training  courses  every  year  for  the 
captain  of  the  sealing  vessel  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 extensive exam to get a hunting card. The test is 
general and a course targeting seal hunt is voluntary. The curriculum is though rather 
extensive and detailed. Many stakeholders have during the process pointed to the fact 
that  seal  hunt  is  a  dangerous  and  advanced  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  monitoring  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 evaluated on the affiliation of the inspectors to 
the regulating authority. Observation by marshals, police and coast guard can thus be 
considered  to  be  more  independent  than  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 the inspector with the local community is 
likely to reduce independency of the inspector. 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 there 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 specifically 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  have  provisions  on  third  party  monitoring. 
Several  countries  do  though  state  that  observers  are  welcome,  but  that  there  are 

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practical  challenges  due  to  the  nature  of  the  hunt  e.g.  Greenland  and  Finland.  This 
indicates that there is room for improvement in all countries included in this study. 

•  Reporting requirements: Clear requirements for reporting targeting both hunters 
and inspectors. There are requirements to where and when animals are killed and 
weapons and ammunition used. Also the range of relevant environmental factors 
(weather conditions, etc.) should be reported. 

All  countries,  except  Namibia,  have  reporting  requirements  that  are  more  or  less 
developed, both for hunters and the monitoring 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-compliance the inspector must fill in an 
infringement report with detailed 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  infringing  the  legislation  are  subject  to 
sanctions is unclear and depends on several 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 reporting system and number of cases of non-
compliance must be seen relative to each other 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 are not commercially 
imported into their territory. Even though the stated reasons for the adoption of the 
Directive  were  different  (existing  worries  about  the  population  status  of  harp  and 
hooded  seals)  it  might  be  used  as  a  precedent  the  Member  States  might  be  able  to 
build on. Costs for the existing system have 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 

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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. Furthermore, 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  value  of  fur  products,  it  would  probably  be  a 
small percentage of costs. 

In  2007,  the  International  Fur  Trade  Federation  launched  a  new  international 
labelling  programme  whereby  the  so-called  "Origin  Assured  label"  informs 
consumers that the fur or fur products come from a country where national or local 
regulations or standards governing fur productions 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  results  are  consistent  with  the  objectives 
set.  The  evaluation  results  should  be  used  for  the  decision-making  needs  on  the 
future of and any amendments to the regulatory framework, if appropriate.  

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ANNEX 1 

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61 

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Assessment sheets of seal hunt management systems16 

ANNEX 2 

1. 

2. 

3. 

4. 

5. 

6. 

7. 

8. 

Canada 

Finland 

Greenland 

Namibia 

Norway 

Russia 

Sweden 

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 

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Table 1 

Assessment Summary Sheet, Canada 

Are national legislation requirements in place?(i) 
Yes 

No 

Canada 
Legislation 

Animal 
principles 

welfare  

Hunting tools 

X 

X 

Assuring  death  by 
monitoring(ii) 
Bleeding-out 
of  
animals  shot  or 
struck(ii) 
Environmental 
factors 
Training  of 
hunters 

the 

Enforcement 

Independent  
monitoring 

X 

third 

of 

Ability 
party to monitor 
Reporting  
requirements 

Comment 
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. 
Inconclusive - as the conditions to get a Yes is only partially there. Characteristics of the tools 
allowed  are  prescribed  in  §28  (1)  of  the  Marine  Mammal  Regulations  (SOR/93-56).  This  is 
applicable for personal and commercial use. However, §28 is only applicable in sealing areas 4 
to 33, i.e. the areas for commercial hunting. Outside these areas, i.e. areas 1 to 3 covering the 
Arctic areas, there are no restrictions. 
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). 
No  requirements  in  the  applicable  legislation,  however  it  is  incorporated  as  a  licence 
requirement and non-compliance may thus be sanctioned. 

X 

No requirements in the applicable legislation. 

Inconclusive.  Training  takes  form  of  apprenticeship  -  i.e.  learning  from  experienced  hunters. 
There  are  no  requirements  to  any  specific  skills  being  taught  or  curriculum  to  be  studied 
according to the Seal Licensing Policy for Eastern Canada Section 33, and the 1995 Canadian 
Firearms Act. 

Are national enforcement requirements in place?(i) 
Yes 

No 

Comment 
Inconclusive - without further analysis the independency of inspectors. Monitoring 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.  
Seal  Fishery  Observation  Licenses  may  be  issued  by  the  Minister  if  such  issuance  does  not 
cause disruption to a seal fishery according to Section 32 (1)-(2), MMR (SOR/93-56). 
Inconclusive  -  although  inspections  by  DFO  fishery  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 documentation, documenting their seal hunt (Section 39.1 
(2) of the Fisheries (General) Regulations and Section 61 of the Fisheries Act). However, there 
are no requirements to report on environmental factors. 
Data from the reporting of inspectors and sealers are gathered. 

X 

and 

Sanctions 
compliance 
Are animal welfare recommendations carried out in practice?(ii) 
Legislation in practice (implementation and application) 
The  Canadian  hunt  is  highly  disputed  and  there  are  different  opinions  on  the  degree  to  which  the  legislation  is  complied  with.  The 
competitive  nature  of  the  hunt  may  lead  to  hunters  taking  shortcuts  that  may  reduce  animal  welfare.  Without  further  information  it 
cannot be concluded to which degree the legislation is complied with. However, as bleeding-out is not required by legislation but is as 
of 2008 a part of the licence requirement, and so administrative sanctions might be the consequence if these are not complied with. 
Enforcement in practice 
Enforcement is challenged by the characteristics of the hunt, with a large number of relatively small boats operating in a challenging 
environment.  That  said,  i.a.  IVWG  (2005)  stated  that  the  independence  of  the  enforcement  and  loyalties  of  inspectors  can  be 
questioned.  The  DFO  has,  however,  increased  focus  on  enforcement  since  2005  and  increases  the  number  of  inspectors.  NGOs 
stress  that  there  are  administrative  barriers  to  get  an  observers  licence  in  spite  of  the  procedure  being  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 foremost the 
commercial  hunt  which  is  the  largest  -  landing  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 income in the fisheries off season. Most 
seals  are  killed  from  late-March  to  mid-April.  The  Inuit  hunt  is  further  north  in  Canada  and  is  both  for  subsistence  and  commercial 
purposes as Inuit also sell their products 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 accordance with animal welfare 
recommendations for seal hunt. No - implies that legislation/enforcement requirements 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. 

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Finland 
Legislation 

Animal  welfare  
principles 

Hunting tools 

X 

Assuring  death 
by monitoring(ii) 

Bleeding-out  of  
animals  shot  or 
struck(ii) 
Environmental 
factors 
Training  of  the 
hunters 

Enforcement 

Independent  
monitoring 

Table 2 

Assessment Summary Sheet, Finland 

Are national legislation requirements in place?(i) 
Yes  No 
X 

Comment 
Law on animal protection is applicable to all animals (§§3, 12 and 32 are particularly 
applicable  here).  The  Hunting  Act  stresses  that  hunting  must  be  not  "cause 
unnecessary suffering". 
A range of tools are prohibited and the only legal method to catch and kill a seal is by 
trap,  for  the  capture  of  animals  alive,  or  by  shooting.  There  are  specifications  for 
ammunition and weapons allowed. 
Not required by the applicable legislation. 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. 
Not required by the applicable legislation. 

X 

X 

Inconclusive  -  as  hunting  is  not  legal  in  artificial  lighting  unless  it  is  to  put  down  an 
already wounded animal. No other provisions on environmental factors.  
Inconclusive - although hunters must pass a rather extensive test to get the required 
hunting  card.  There  is  moreover  a  voluntary  course  targeting  seal  hunt  (with  80% 
participation of seal hunters). However, there are no requirements on shooting tests 
for seal hunters. 

Are national enforcement requirements in place?(i) 
Yes  No 

Comment 
Inconclusive - although an extensive organisation for monitoring exits both within the 
Ministry of Forestry and Agriculture, hereunder the Game Management Districts and 
organisations. Also the police, frontier guard, the customs authorities participate in the 
monitoring and inspecting the hunt. Their independence are, however, uncertain. 
Not applicable - as the Finnish hunt is not large scale. 

-  

-  

X 

X 

and 

third 

Hunters  are  required  to  report  on  their  catch.  The  coast  guard  must  report  on 
"important circumstances" hereunder the hunt. 
Information on infringements and suspected infringements are gathered by the police. 

Ability  of 
party to monitor 
Reporting  
requirements 
Sanctions 
compliance 
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 herds or alone. The hunter shoots 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 wound. 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 only 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 internal 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 incidents 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 integrated 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/enforcement requirements are in place and contain provision in accordance with 
animal welfare recommendations for seal hunt. No - implies that legislation/enforcement requirements 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. 

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Greenland 
Legislation 

Animal  welfare  
principles 
Hunting tools 

Assuring  death 
by monitoring(ii) 
Bleeding-out  of  
animals  shot  or 
struck(ii) 
Environmental 
factors 
Training  of  the 
hunters 
Enforcement 

Independent  
monitoring 

X 

X 

X 

X 

X 

X 

Ability of third 
party to monitor 
Reporting  
requirements 

Sanctions and 
compliance 

X 

Table 3 

Assessment Summary Sheet, Greenland 

Are national legislation requirements in place?(i) 
Yes  No 
X 

Comment 
Legislation emphasises that killing must be as fast and painless as possible (29/2003 
§13). 
Netting, which is not considered an appropriate method (EFSA Journal p 92), is 
allowed. However, the legislation also provides for shooting of seals - a method which 
is in accordance with animal welfare recommendations.  
Not required by the applicable legislation. 

Not required by the applicable legislation. 

Not required by the applicable legislation. 

Not required by the applicable legislation. 

Are national enforcement requirements in place?(i) 
Yes  No 

Comment 
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 Agriculture, who is the responsible authority 
for the hunt. Also police and GLK observe the hunt. 
There is no restriction on third party monitoring (but also no explicit provision on third 
party monitoring in existing legislation). 
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 observations, recommendations, confiscations and 
censuses. Reporting on environmental factors or struck and lost is, however, not 
required. 
The Department is in the process of developing 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 being 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 used 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 hunters, this is traditionally 
carried out by experienced hunters passing 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 the areas where hunting is undertaken. The 
officers inspect the hunt during the trip and report on this. GLK (Island Commander Greenland) and the police also 
inspect the hunt. GLK has a specific role in controlling foreign vessels in Greenlandic waters. In practice, NAMMCO is 
part of the enforcement by observing the hunt. According 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 same legislation and requirements. 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 plays an important role for many communities. 
Notes 
 (i) 

Yes - implies that legislation/enforcement requirements are in place and contain provision in accordance with 
animal welfare recommendations for seal hunt. No - implies that legislation/enforcement requirements 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. 

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Table 4 

Assessment Summary Sheet, Namibia 

Namibia 
Legislation 

Animal welfare  
principles 
Hunting tools 

Assuring death 
by monitoring(ii) 
Bleeding-out of  
animals shot or 
struck(ii) 
Environmental 
factors 
Training of the 
hunters 
Enforcement 

Independent  
monitoring 

Ability of third 
party to monitor 

Are national legislation requirements in place?(i) 
Yes  No 

Comment 
Not required by the applicable legislation. 

X 

X 

X 

The weapons used to shoot adult seals are defined as "capable of killing and adult 
seal instantaneously by penetrating the brain 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. 
Required for both pups and adult males (241/2001 §20. 3c and §20.4b). 

Inconclusive - as bleeding out is required for pups only (241/2001 §20.3d). Bleeding 
out is not required for adult animals. 

X 

Not included in the relevant legislation. 

Inconclusive - because requirements are unclear regarding the training required by 
the licence conditions. 
Are national enforcement requirements in place?(i) 
Yes  No 

Comment 
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 inspectors are required to be independent 
is unclear. 
Inconclusive - because third party monitoring is not regulated in the legislative acts. 
However, according to the licence requirement "Observers of the Wildlife Society of 
Namibia are allowed access to the harvests as observers to recommend possible 
improvements" (MFMR, 2008). 
There are no reporting requirements prescribed in the relevant legislation. 

X 

Inconclusive - because information is insufficient for concluding. 

Reporting  
requirements 
Sanctions and 
compliance 
Are animal welfare recommendations carried out in practice?(ii) 
Legislation in practice (implementation and application) 
Reports indicate that the procedures prescribed in the legislation are not always adhered to. The herding process is 
believed to cause considerable distress for the animals (EFSA, 2007). According to EFSA (2007, p. 94) both non-
targeted and targeted animals may sustain injuries before they are killed or escape during the pup hunt.  
Enforcement in practice 
The hunt is to be observed by governmental inspectors. However, the EFSA opinion reports that there are very few 
inspectors present during the hunt, and that the inspectors lack training and knowledge 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 hunt, following Canada and Greenland. The characteristics of the 
Namibian hunt are somewhat different from the other seal hunts. It is the only commercial hunt in the southern 
hemisphere and is conducted on the beach of the Namibian coast. The hunt is seasonal 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/enforcement requirements are in place and contain provision in accordance with 
animal welfare recommendations for seal hunt. No - implies that legislation/enforcement requirements 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. 

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Table 5 

Assessment Summary Sheet, Norway 

Are national legislation requirements in place?(i) 
Yes  No 
X 

Norway 
Legislation 

Animal welfare  
principles 

Hunting tools 

X 

Assuring death 
by monitoring(ii) 

X 

Bleeding-out of  
animals shot or 
struck(ii) 
Environmental 
factors 

Training of the 
hunters 

X 

Enforcement 

Independent  
monitoring 

Ability of third 
party to monitor 
Reporting  
requirements 

X 

Comment 
Clearly stated in the regulation on the execution of seal hunt, both in §1, which 
corresponds to §2 of the Act on animal protection, and in §7 regulating the killing 
procedures (2003-02-11-151). 
Requirements to weapons used both for adults and pups. These are in line with 
recommendations of the EFSA opinion. The legislation prohibits netting and traps 
(2003-02-11-151 §11).  
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 shall be struck with the spike of the hakapik 
into the brain. 
Bleeding-out is required instantly after 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). 
Inconclusive - since requirements for environmental factors are not clearly outlined in 
the legislation. However, §6.2 stipulates a general prohibition of shooting seals under 
conditions where the seal cannot be clubbed 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. 
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). 

Comment 
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. 
Inconclusive - although there are very strict requirements to monitor the seal hunt, but 
it appears to be difficult to get an observers licence.  
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 the hunt (1986-06-03-40 §9 and J-53-2007 §13). 
The logbook contains information on special circumstances e.g. the weather 
conditions. 
Inconclusive - since the information on level/number of sanctions and non-compliance 
is unstructured. 

Are national enforcement requirements in place?(i) 
Yes  No 
X 

Sanctions and 
compliance 
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 follow the legislation and the procedures 
prescribed. Adults are shot and pups are clubbed; and if the procedures 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 observes 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 mainly 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/enforcement requirements are in place and contain provision in accordance with 
animal welfare recommendations for seal hunt. No - implies that legislation/enforcement requirements 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. 

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Table 6 

Assessment Summary Sheet, Russia 

Are national legislation requirements in place?(i) 
Yes  No 

Comment 
Inconclusive - due to lack of knowledge. However, in the legislation analysed no 
provisions on animal welfare are identified. 
Netting is allowed and is a frequently used hunting method. There is insufficient 
information on other hunting weapons used. 
Lack of information in order to conclude. 

Russia 
Legislation 

Animal welfare  
principles 
Hunting tools 

Assuring death 
by monitoring(ii) 
Bleeding-out of  
animals shot or 
struck(ii) 
Environmental 
factors 
Training of the 
hunters 
Enforcement 

X 

- 

- 

- 

- 

- 

- 

- 

- 

Lack of information in order to conclude. 

Lack of information in order to conclude. 

Lack of information in order to conclude. 

Are national enforcement requirements in place?(i) 
Yes  No 
- 

Comment 
Lack of information in order to conclude. 

- 

- 

- 

- 

- 

- 

- 

Lack of information in order to conclude. 

Lack of information in order to conclude. 

Lack of information in order to conclude. 

Independent  
monitoring 
Ability of third 
party to monitor 
Reporting  
requirements 
Sanctions and 
compliance 
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 quotas allowing for catches of around 100,000 per year. Russia 
has commercial hunt as well as hunt carried out by a number 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/enforcement requirements are in place and contain provision in accordance with 
animal welfare recommendations for seal hunt. No - implies that legislation/enforcement requirements 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. 

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Sweden 
Legislation 

Animal welfare  
principles 
Hunting tools 

Assuring death 
by monitoring(ii) 
Bleeding-out of  
animals shot or 
struck(ii) 
Environmental 
factors 

Training of the 
hunters 

Enforcement 

Independent  
monitoring 

Table 7 

Assessment Summary Sheet, Sweden 

Are national legislation requirements in place?(i) 
Yes  No 
X 

Comment 
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. 
The applicable weapons are clearly prescribed (§§14 and 16 of NFS 2002:18) and 
are in accordance with international best practises.  
There is no requirement to monitoring in the legislation.  

There is no requirement to bleeding-out the seal in the legislation. 

X 

X 

X 

Inconclusive - although the may only take place from land unless certain 
environmental criteria are fulfilled e.g. concerning 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). 
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 Swedish EPA Decision on controlled hunting 
of grey seals for 2007.  
Are national enforcement requirements in place?(i) 
Yes  No 

Comment 
Inconclusive - as the hunting Inspectors are appointed 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.  
Not applicable as the Swedish hunt is not large scale. 

- 

- 

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. 
Inconclusive - as there is no available statistics on reported cases of seal hunt 
infringements. 

Ability of third 
party to monitor 
Reporting  
requirements 
Sanctions and 
compliance 
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 voluntary 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 distances 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 commercial purposes, e.g. to restaurants. 
Notes 
 (i) 

Yes - implies that legislation/enforcement requirements are in place and contain provision in accordance with 
animal welfare recommendations for seal hunt. No - implies that legislation/enforcement requirements 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. 

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Table 8 

Assessment Summary Sheet, United Kingdom (Scotland) 

United Kingdom (Scotland) 
Legislation 

Are national legislation requirements in place?(i) 
Yes  No 

Comment 
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. 
Killing seals is only allowed using a rifle "having a muzzle energy of not less than 600 
foot pounds and a bullet weighing not less than 45 grains" (1970 c.30 §1). Netting is 
not allowed. 
No requirements in the legislation. 

Animal welfare  
principles 

Hunting tools 

X 

Assuring death 
by monitoring(ii) 
Bleeding-out of  
animals shot or 
struck(ii) 
Environmental 
factors 
Training of the 
hunters 
Enforcement 

X 

X 

X 

X 

X 

No requirements in the legislation. 

No requirements in the legislation. 

No requirements in the legislation. 

Are national enforcement requirements in place?(i) 
Yes  No 
X 

Comment 
Responsibility of the police (1970 C.30 §4). 

- 

- 

X 

X 

There is no statistical data on how many seals are killed nor under which conditions 
(the Marine Directorate, 2007). 

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). 
There are no requirements in the Act to report on killings of seals. 

Independent  
monitoring 
Ability of third 
party to monitor 
Reporting  
requirements 
Sanctions and 
compliance 
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 number 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 neither commercial nor recreational seal hunt. However, killing 
seals is allowed under certain circumstances, such as for research 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 NGOs warning about population levels and animal welfare 
considerations. 
Notes 
 (i) 

Yes - implies that legislation/enforcement requirements are in place and contain provision in accordance with 
animal welfare recommendations for seal hunt. No - implies that legislation/enforcement requirements 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. 

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