Commission staff working document - Accompanying document to the Proposal for a Regulation of the European Parliament and of the Council concerning trade in seal products - Summary of the impact assessment on the potential impact of a ban of products derived from seal species {COM(2008) 469 final} {SEC(2008) 2290}
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, 23.7.2008 
SEC(2008) 2291 

COMMISSION STAFF WORKING DOCUMENT 

Accompanying document to the 

Proposal for a 

REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL 

concerning trade in seal products 

SUMMARY OF THE IMPACT ASSESSMENT  

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

{COM(2008) 469 final} 
{SEC(2008) 2290} 

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Executive Summary 

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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. 

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 
http://www.efsa.europa.eu/EFSA/efsa_locale-
1178620753812_1178671319178.htm 

2007: 

seals, 

Dec. 

of 

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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. 

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12. 

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

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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 to 
transit through, or export from, the Community of all seal products. Trade in those 
products  would  however  be  possible  when  certain  conditions,  which  concern  the 
manner  and  method  whereby  seals  are  killed  and  skinned,  are  met.  Information 
requirements would also need to be 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 preferred option 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. 

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