REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL on the application of Regulation (EC) No 1523/2007 banning the placing on the market and the import to, or export from, the Community of cat and dog fur, and products containing such fur
Date: 2013-06-13
Institutions: European Commission
Subjects: customs inspection, domestic animal, evaluation method, export (EU), export restriction, hides and furskins industry, import (EU), import restriction, marketing restriction, offence

EUROPEAN 
COMMISSION 

Brussels, 13.6.2013  
COM(2013) 412 final 

REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND 
THE COUNCIL 

on the application of Regulation (EC) No 1523/2007 banning the placing on the market 
and the import to, or export from, the Community of cat and dog fur, and products 
containing such fur 

(Text with EEA relevance) 

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REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND 
THE COUNCIL 

on the application of Regulation (EC) No 1523/2007 banning the placing on the market 
and the import to, or export from, the Community of cat and dog fur, and products 
containing such fur 

(Text with EEA relevance) 

1. 

BACKGROUND 
Regulation (EC) No 1523/20071 bans the placing on the market and the import to or 
export from the Union of cat and dog fur and products containing such fur. 

The  ban  was  adopted  in  order  to  address  the  concerns  of  European  citizens,  who 
consider  cats  and  dogs  as  pet  animals,  and  therefore  do  not  want  to  buy  products 
containing fur from cats or dogs. 

It harmonized the measures to prohibit cat and dog fur and products containing such 
fur at EU level since fifteen Member States2 had adopted national legislation in order 
to restrict the production and trade of cat and dog fur. 

Cat  and  dog  fur  is  not  easily  distinguishable  from  other  types  of  fur  or  synthetic 
material used to imitate fur. This is in particular the case when fur is used as lining or 
ornament  on  clothes (e.g. collar of a coat) or on toys or  accessories  (e.g. key rings 
with furry animals). 

The ban on cat and dog fur applies in the European Union since 31 December 2008. 

Article 7 of the Regulation states that "The Commission shall report to the European 
Parliament and the Council on the application of this Regulation, including customs 
activities  related  thereto,  no  later  than  31  December  2010".  This  report  is  the 
Commission's response to this request. 

The report aims to give an overview on the implementation of the ban on cat and dog 
fur in the EU during 2009 and 2010. The adoption of this report was delayed due to 
the need for the Member States to collect enough information on the implementation 
of  the  ban.  Some  data  were  received  only  at  the  beginning  of  2012  allowing  a  full 
analysis only during 2012. 

It describes the enforcement measures put in place by the Member States in order to 
prevent the placing on the market, the import to or export from the Union of cat and 
dog fur, and products containing such fur. 

In particular, the report provides an overview on the methods of analysis used by the 
Member States to identify the species of origin of fur and on the penalties applicable 
in  case  of  infringements.  The  report  highlights  the  main  implementing  issues 
signalled by stakeholders and Member States to the Commission. 

1 

2 

Regulation (EC) No 1523/2007 of 11 December 2007 banning the placing on the market and the import 
to,  or  export  from,  the  Community  of  cat  and  dog  fur,  and  products  containing  such  fur;  OJ  L  343, 
27.12.2007, p. 1. 
The Report is on the application of the Regulation for the period between 2009 and 2010. 

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Finally,  this  document  reports  the  impact  of  the  application  of  this  Regulation  as 
perceived by the main stakeholders. 

2. 

MEMBER STATES' OBLIGATIONS 
Member States are primarily responsible for the application of the ban3. 

In addition they are required to: 

– 

– 

inform  the  Commission  of  the  analytical  methods  they  use  to  identify  the 
species of origin of fur (Article 5 of the Regulation); 

lie down and notify to the Commission the rules on penalties applicable in case 
of infringements to the Regulation (Article 8 of the Regulation). 

3. 

METHODOLOGY 

In  order  to  produce  the  report,  the  Commission  used  the  following  sources  of 
information: 

– 

– 

– 

– 

The  replies  of  Member  States  to  a  questionnaire  sent  by  the  Commission  in 
2011 on the enforcement of the ban on cat and dog fur in 2009 and 20104. 

The information sent by Member States on the penalties applicable in case of 
infringements to the Regulation; 

Correspondence  from  stakeholders  or  Member  States  received  by  the 
Commission. 
The outcomes of a meeting5 organised on 18 January 2012 by the Commission 
to  discuss  the  implementation  of  the  ban  with  Member  States  representatives 
and main stakeholders6.  

4. 

IMPLEMENTATION OF THE BAN  

4.1. 

Controls in the Member States 

Member States had to set up systems of controls in order to implement the ban. This 
consisted  mainly  in  integrating  checks  for  the  ban  in  their  existing  systems  of 
controls and will be described in the following sections. 

The actions taken were more or less elaborate depending on the Member States; in 
particular,  actions  regarding  training  and  procedures  as  well  as  dissemination  of 
information were engaged by a limited number of Member States. 

Because most cat and dog fur and products containing such fur originate from third 
countries,  the  primary  objective  of  the  systems  of  controls  put  in  place  in  the 
Member States is to prevent the entry into the EU of illegal commercial imports of 
cat and dog fur from third countries. There is no evidence of production of cat and 
dog fur in the EU and the likelihood for export is therefore theoretical. 

3 
4 
5 

6 

The ban stands for "the ban on cat and dog fur". This is applicable for the rest of the text. 
All Member States replied except Greece.  
The agenda and presentations of the meeting are available at 
http://ec.europa.eu/food/animal/welfare/seminars/docs/agenda_implementation_ban_cat_dog_fur_en.pdf 
The list of organisations attending the meeting is available in annex to the report. 

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4.1.1.  National legislations banning cat and dog fur 

National legislations prohibiting cat and dog fur in place prior to the adoption of the 
Regulation  were  repealed  and/or  amended  in  the  Member  States  concerned.  The 
entry into force of the Regulation allowed therefore for harmonized rules at EU level 
on the ban. This simplifies the tasks of official staff performing the controls as well 
as for operators trading legal fur and fur products or imitations of fur. 

4.1.2.  Penalties applicable in case of infringements to the ban 

Member  States  are  responsible  for  laying  down  the  penalties  applicable  in  case  of 
infringements  to  the  provisions  of  the  Regulation.  The  penalties  shall  be  effective, 
proportionate and dissuasive. 

Most  Member  States  amended  their  national  legislations  in  order  to  introduce 
administrative  and/or  criminal  sanctions  in  case  of  infringements  to  the  ban.  Other 
Member States already had penalties laid down  in general  for importing or placing 
on  the  market  illegal  goods  that  would  apply  in  case  of  infringements  to  the 
Regulation. 

Administrative  sanctions  consist  mainly  in  fines  imposed  on  operators  and  they  do 
not exclude the possibility to use also criminal sanctions.  

Criminal sanctions require in general that the case is referred to a national court of 
justice.  As  illustrated  in  table  1,  the  level  of  penalties  applicable  is  quite  variable 
between Member States. 

Finally,  all  Member  States  have  the  legal  powers  to  seize  illegal  products  and  to 
request their destruction. 

Table 1: Summary of penalties applicable in Member States in case of 
infringements on the ban on cat and dog fur 

Penalties 

Administrative 
sanction 

Criminal sanction 

Range of penalties 
From 250 - 500 € up to 20 000 € 

Fines  from  1500  €  up  to  40  000  € 
Imprisonment  from  4  months  up  to 
3 years 

Source: Member States' replies to the questionnaire on implementation sent by the Commission 

4.1.3.  Competent Authorities responsible for the implementation of the ban  

Since the main objective of the controls was to prevent the entry into the Union of 
illegal  imports  of  cat  and  dog  fur  from  third  countries,  Customs  Authorities  or 
Customs  Authorities  and  Veterinary  Authorities  were 
the  main  Competent 
Authorities designated by the Member States as responsible for the implementation 
of the ban. 

Customs  Authorities  were  responsible  for  identifying  potential  illegal  commercial 
consignments  from  third  countries  suspected  of  containing  cat  and  dog  fur.  Their 
experience gained in other areas to prevent illegal imports was essential to identify 
consignments at risk. In case of suspicion, customs services will perform checks to 
confirm  the  suspicion.  Therefore,  the  control  procedure  on  importations  of  cat  and 
dog fur was integrated in the general customs procedures which already include risk 
based controls. Due to the low number of controls performed, the implementation of 
the ban is unlikely to have created a substantial burden for the Customs Authorities. 

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Where  Veterinary  Authorities  were  involved,  they  were  mostly  responsible  for  the 
physical  inspection  of  the  suspicious  consignments,  sampling  and  sending  samples 
for analysis where necessary.  

Where several competent authorities were involved, most Member States concerned 
have taken measures to ensure that they cooperate and exchange information. 

4.1.4.  Training and procedures 

At EU level, the Commission integrated control measures concerning the ban in the 
European online Customs Tariff Database called TARIC7. 

TARIC is a multilingual database available online to officials and business operators 
in which in particular measures relating to measures on import and export restrictions 
are integrated. In 2009, a list of products and Combined Nomenclature (CN) codes8 
of  goods  suspected  of  containing  cat  and  dog  fur  was  defined  at  EU  level  and 
integrated into TARIC.  

Several Member States mentioned the usefulness of TARIC to help them to identify 
potential illegal consignments. However, one Member State considered that the list 
of goods and CN codes suspected of containing cat and dog fur was too exhaustive. 

When officials performing controls on imports or exports of fur enters a product or 
CN code belonging to the list mentioned above into TARIC, the database will show 
that it is necessary to check whether the business operator ticked a box in its customs 
declaration  stating  that  the  fur  imported  or  exported  are  not  from  cats  and  dogs  as 
mentioned by Regulation (EC) No 1523/2007. 

In  addition  to  TARIC,  some  Member  States  issued  guidelines  and  information  to 
their  official  staff  on  the  implementation  of  the  ban.  These  included  practical 
information for performing controls, as well as information on the provisions of the 
Regulation  and  national  law.  An  example  of  such  documents  is  available  at  the 
following link: 

https://findok.bmf.gv.at/findok/targetSearchSubmit.do;jsessionid=9605F10870FC60
5A9F5E848516744BF5 

4.1.5.  Methods of analysis to identify the species of origin of fur 

Member  States  used  the  following  methods  of  analysis  to  identify  the  species  of 
origin of fur:  

– 

Visual identification, 

–  Microscopic hair identification, 

– 

– 

DNA analysis (Polymerase Chain Reaction, PCR), 

Species 
spectrometry. 

Identification  of  Animals 

(SIAM)  by  MALDI–TOF  mass 

The  list  of  the  methods  and  laboratories  used  in  each  Member  State  is  provided  in 
Annex I to the report. 

7 

8 

TARIC database is accessible on line at the following link: 
http://ec.europa.eu/taxation_customs/customs/customs_duties/tariff_aspects/customs_tariff/index_en.htm 
When declared to customs in the Union, goods must generally be classified according to the Combined 
nomenclature or CN. Imported and exported goods have to be declared stating under which subheading 
of the nomenclature they fall. 

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Member States used mostly microscopy, DNA analysis and species Identification of 
Animals by MALDI – TOF mass spectrometry. Each of these methods has its pros 
and cons depending on the type of samples taken, the level of identification required, 
the repeatability and the costs involved. 

Microscopic hair identification can determine whether the sample contains animal 
or synthetic fur. 

DNA analysis can identify whether the sample is not from a domestic cat or dog and 
the  species  of  origin  of  the  fur  provided  the  relevant  species-specific  primers  are 
available;  DNA  analysis  can  differentiate  samples  of  domestic  dog  fur  from  fox, 
coyote, jackal and raccoon dog fur. However, DNA analysis cannot differentiate fur 
of domestic cats from fur obtained from hybrids of domestic and Bengal cats. To be 
successful, DNA analysis requires a minimum amount and quality of isolated DNA 
which may be difficult to obtain sometimes when the sample is coming from treated 
fur (e.g dyed). 

Species  identification of animals by MALDI-TOF mass spectrometry has a larger 
spectrum of species of origin that can be identified compared to DNA analysis and 
can detect the species of origin of the fur even on treated fur. 

Further details on the different methods of analysis were provided at the stakeholders 
and Member States meeting organized by the Commission on 18 January 2012 and 
are available at the following link:  

http://ec.europa.eu/food/animal/welfare/seminars/docs/methods_analysis_identifying
_species_origin_fur_en.pdf 

The range of costs of the methods of analysis used to identify cat and dog fur is given 
in the table below. 

Table 2: Costs of methods of analysis to identify the species 
of origin of fur 

Method 

Microscopy 

Species identification 
of Animals (SIAM) by 
MALDI – TOF mass 
spectrometry 

DNA analysis 

Costs 

30 – 60 € 

150 – 250 € 

150 – 1075 € 

Source: Member States' replies to the questionnaire on implementation sent by the Commission 

Most  Member  States  designate  a  laboratory  on  their  territory  where  samples  for 
detection of cat and dog fur can be sent by their official staff. Several Member States 
chose or consider subcontracting samples to a laboratory located in another Member 
State, due to the current lack of expertise of their laboratories and the small number 
of samples to be analysed. 

4.1.6.  Dissemination of information 

As  mentioned  earlier,  the  customs  tariff  database  TARIC  is  available  on  line  to 
business  operators.  Through  TARIC,  business  operators  can  have  access  to  the 
Regulation  and  be  informed  that  in  order  to  import  or  export  fur  they  will  have  to 
state  in  their  customs  declaration  stating  that  the  goods  they  intend  to  import  or 
export do not contain cat and dog fur. 

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In  addition,  several  Member  States  provided  information  to  the  potential  business 
operators  concerned,  importers  and  retailers,  and  to  consumers.  Letters  of 
information  were  published  in  the  official  journal  or  in  the  official  website  of  the 
Member States. 

4.2. 

Results of the controls 

Member States focussed their control activities on imports. In addition, these controls 
were completed within the Union by checks carried out mainly in retail shops. 

Where necessary, samples were taken for analysis to confirm the presence of cat and 
dog fur. Illegal products were seized and destroyed when identified. Sanctions were 
pronounced in case of infringements. 

A  summary  of  the  checks  performed  by  the  Member  States  and  their  outcomes  is 
provided in the tables below. The Member States did not provide specific data on the 
quantity of cat and dog fur found and the sanctions applied. 

Table 3: Controls performed for preventing commercial illegal imports 
of cat and dog fur 

Number imported 
commercial 
consignments 
checked 

Number imported 
commercial 
consignments 
sampled for 
analysis 

Number 
consignments 
not accepted 
for import 

Number 
consign-
ments 
seized 

Number 
imported 
consignments 
destroyed 

9687 

25275 

0 

5 

1 

2 

0 

67 

0 

0 

Source: Member States' replies to the questionnaire on implementation sent by the Commission 

Table 4: Control performed for illegal placing of cat and dog fur 
on EU market 

Number of 
controls 
performed 
in shops 
and 
retailers 

Number of 
consign-
ments 
sampled for 
analysis 

Number of 
commercial 
consignments 
seized in 
shops and 
retailers9 

Number of 
commercial 
consignments 
destroyed from 
shops and 
retailers10 

Number of 
targeted 
checks on 
internet 
selling 
websites 

Number of 
targeted 
checks on 
packages 
sent by -
mail 

119 

169 

46 

52 

66 

40 

56 

28 

0 

0 

0 

0 

Source: Member States' replies to the questionnaire on implementation sent by the Commission 

Year 

2009 

2010 

Year 

2009 

2010 

9 

10 

Consignments seized were not necessarily sampled for analysis since non-compliance may have been 
detected for other reasons than positive results from analysis. 
Consignments  destroyed  were  not  necessarily  sampled  for  analysis  since  non-compliance  may  have 
been detected for other reasons than positive results from analysis. 

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Table 5: Number of samples analysed 

Member State 

Number of Samples analysed 

Austria 

Czech Republic 

Germany 

Denmark 

Finland 

France 

Italy 

UK 

Total 

2009 

1 

0 

1 

0 

2010 

10 

1 

15 for 2009 and 2010 together 

2 

46 (of which 17 non 
complied11) 

20 (all samples complied) 

0 

20 

119 

3 

Source: Member States' replies to the questionnaire on implementation sent by the Commission 

The number of controls increased in 2010 compared to 2009 as well as the number of 
samples  taken  and  sent  for  analysis.  2009  was  the  first  year  when  the  Regulation 
came  into  force  and  the  level  implementation  increased  in  2010  as  by  that  time 
Member States had taken measures to organise the checks. 

From the information sent by the Member States, goods identified by Member States 
as  potentially  containing  cat  and  dog  fur  were  mainly  jackets  and  coats,  scarves, 
neckerchiefs, key rings and skin. 

5. 

IMPLEMENTATION ISSUES 

Some  stakeholders  considered  that,  not  enough  official  controls  were  performed 
regarding the placing on the EU market of cat and dog fur and in particular on sales 
on the Internet. 

The  issue  of  labelling  requirements  was  also  discussed  in  the  frame  of  the  future 
application  of  Regulation  (EC)  No  1007/201112  with  regards  labeling  of  clothes 
containing a small part of fur as obliged by Member States.  

Regulation (EC) No 1007/2011 requires indicating the presence of non-textile parts 
of animal origin on the labelling or marking of textile products containing such parts, 
in  order  to  enable  consumers  to  make  informed  choices.  The  labelling  or  marking 
should not be misleading. 

11 
12 

Non-compliance means positive results to the presence of cat or dog fur. 
Regulation (EU) No 1007/2011 of the European Parliament and of the Council of 27 September 2011 
on textile fibre names and related labelling and marking of the fibre composition of textile products (OJ 
L 272, 18.10.2011, p. 1–64). 

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6. 

IMPACT OF THE REGULATION 

Main stakeholders highlighted the positive impact of the Regulation. The ban on cat 
and  dog  fur  is  now  in  place  in  all  Member  States.  The  Regulation  harmonises  the 
rules and simplifies therefore the work of business operators importing or placing on 
the EU market fur or articles with part of fur. In addition, according to the European 
Fur Breeders Association, the ban did not have a negative impact on fur trade. 

Based  on  stakeholders'  opinion,  it  could  be  assumed  that  the  ban  and  the  controls 
performed in the Member States ensure that the risk for European consumers to be 
placed in a situation where they could buy cat and dog fur is very limited. 

7. 

CONCLUSION 

Member  States  set  up  a  system  of  controls  in  order  to  implement  the  ban.  They 
mainly integrated checks for the ban in their existing systems of controls by taking 
the following actions: 

– 

– 

– 

– 

– 

The  modification  of  national  legislations  in  order  to  repeal  previous  national 
measures prohibiting cat and dog fur and to introduce penalties; 

The designation of the competent authorities and officials responsible; 

The designation of the methods of analysis and laboratories performing them in 
order to identify whether the fur comes from a domestic dog or cat in case of 
suspicion; 

The  training  and  elaboration  of  procedures  in  order  to  inform  officials 
performing the controls; 

The dissemination of information to business operators and general public. 

The  primary  objective  of  the  systems  of  controls  is  to  prevent  the  entry  into  the 
Union of illegal commercial imports of cat and dog fur from third countries because 
most of it originate from there.  

In  2009  and  2010,  Member  States'  controls  were  therefore  mainly  focussed  on 
preventing illegal imports. Direct involvement of Customs authorities and the use of 
the Commission database TARIC by business operators and Member States allow for 
a harmonized implementation of the ban regarding illegal imports. 

Overall  the  application  of  the  Regulation  had  a  positive  impact  as  it  simplifies  the 
work  of  business  operators  since  it  has  replaced  several  national  bans  applied  with 
different  procedures.  In  addition,  according  to  stakeholders'  opinion,  the  ban 
contributed to limit the risk that European consumers may be exposed to buying cat 
and dog fur or products containing such fur. 

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ANNEX I: Methods of identification of cat and dog fur used in Member States 

No 

Member State 

Method applicable 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

Austria 

Belgium 

Bulgaria 

Cyprus 

Czech Republic 

Denmark 

Estonia 

Finland 

France 

Germany 

Greece 

Hungary 

Ireland 

Italy 

Latvia 

Lithuania 

17 

Luxembourg 

18  Malta 

Microscopic  hair  identification  +  DNA  analysis  has  been 
considered 

No information available in the reply to the questionnaire 

Microscopic hair identification + MALDI-TOF 

MALDI-TOF 

DNA analysis 

DNA analysis 

Visual identification + Microscopic hair identification 

Microscopic hair identification 

Microscopic hair identification + DNA analysis 

DNA analysis + MALDI-TOF 

No reply to the questionnaire 

Microscopic hair identification + DNA analysis 

MALDI-TOF 

Visual  identification  +  Microscopic  hair  identification  +  DNA 
analysis + MALDI-TOF 

Microscopic hair identification 

identification  +  DNA  analysis  under 

Microscopic  hair 
consideration 

MALDI-TOF 

DNA analysis 

19 

20 

21 

22 

23 

24 

25 

26 

27 

The Netherlands 

Microscopic hair identification + MALDI-TOF 

Poland  

Portugal 

Romania 

Slovakia 

Slovenia 

Spain  

Sweden 

Visual identification + DNA analysis 

Subcontracted Laboratory in abroad is under consideration 

MALDI-TOF 

Microscopic hair identification + DNA analysis + MALDI-TOF 

Microscopic hair identification + DNA analysis 

Microscopic hair identification + DNA analysis 

DNA analysis + MALDI-TOF 

The United Kingdom 

DNA analysis 

Source: Member States' replies to the questionnaire on implementation sent by the Commission 

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ANNEX II: List of stakeholders consulted 

Name of Organisation 

AEDT - The European Association of Fashion Retailers 

COTANCE 

GAIA 

HSI Humane Society International  

IFTF, International Fur Trade Federation 

European Fur Breeders Association 

Euroleather 

UNIC (Unione Nazionale Industria Conciaria) 

Fondation Brigitte Bardot 

IFAW, International Fund for Animal Welfare 

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