Evaluation study to support the evaluation of the Zoos Directive (Council Directive 1999/22/EC) : final report.
Date: 2018-11-14
Institutions: Directorate-General for Environment
Subjects: EU programme, animal health, animal life, biodiversity, conservation of resources, directive (EU), national park, protection of animals, report, trade licence, veterinary inspection, wildlife, zoo

Evaluation study to support the evaluation 
of the Zoos Directive  
(Council Directive 1999/22/EC) 

Final Report 
August 2017

This  study  to  support  the  evaluation  of  Directive  1999/22/EC  (‘Zoos  Directive’)  has  been  prepared  by 
Milieu Ltd. and VetEffecT for the European Commission’s Directorate General Environment under Service 
Contract  number:  07.0202/2016/729791/ETU/ENV.B.3.  This  study  was  written  by  Nathy  Rass-Masson, 
Lucie Meura, Valentina Parziale, Athena Christofi, Virginie Rouas, Remco Schrijver and Philip McGowan.   

Milieu Ltd (Belgium), Chaussée de Charleroi, 112, B-1060 Brussels, tel: +32 (0)2 506 1000; e-mail : 
nathy.rassmasson@milieu.be ; web address: www.milieu.be.  

Disclaimer: The information and views set out in this study are those of the author(s) and do not 
necessarily  reflect  the  official  opinion  of  the  Commission.  The  Commission  does  not  guarantee 
the accuracy of the data included in this study. Neither the Commission nor any person acting on 
the  Commission’s  behalf  may  be  held  responsible  for  the  use  which  may  be  made  of  the 
information contained herein . 

EUROPEAN COMMISSION 

Directorate-General for Environment
Directorate D - unit D3 Nature Protection

European Commission 
B-1049 Brussels 

Evaluation study to support the 
evaluation of the Zoos Directive  
(Council Directive 1999/22/EC) 
Final Report, August 2017

 
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Evaluation study to support the evaluation of the Zoos Directive 
Final Report 

TABLE OF CONTENTS 

2.1 

3.1 

2.2 

LIST OF TABLES .............................................................................................................................. 5 
LIST OF FIGURES ............................................................................................................................ 8 
LIST OF BOXES ............................................................................................................................. 13 
LIST OF ABBREVIATIONS ............................................................................................................ 14 
ABSTRACT ................................................................................................................................... 15 
RÉSUMÉ ....................................................................................................................................... 15 
EXECUTIVE SUMMARY ............................................................................................................... 16 
NOTE DE SYNTHÈSE .................................................................................................................... 23 
INTRODUCTION ................................................................................................................... 30 
1 
1.1 
Purpose and scope of the study ......................................................................... 30 
1.2  Content of this report ............................................................................................ 30 
2  BACKGROUND TO THE DIRECTIVE ................................................................................... 32 
Baseline: the context of the Zoos Directive ...................................................... 32 
2.1.1 
Brief history of zoos .................................................................................. 32 
2.1.2  Context of adoption of the Zoos Directive ......................................... 34 
Functioning of the Zoos Directive ....................................................................... 36 
3  METHODOLOGY ................................................................................................................. 40 
Evaluation questions and criteria ....................................................................... 40 
Effectiveness ............................................................................................ 41 
3.1.1 
Efficiency .................................................................................................. 41 
3.1.2 
3.1.3 
Relevance ................................................................................................ 41 
3.1.4  Coherence ............................................................................................... 42 
3.1.5 
EU Added Value ...................................................................................... 42 
Evaluation Framework and its links to the Intervention logic ......................... 43 
Data collection ...................................................................................................... 44 
3.3.1 
Literature review and country fiches ................................................... 44 
3.3.2  Consultation strategy ............................................................................. 45 
3.4 
Data analysis methods ......................................................................................... 56 
3.5  Challenges, mitigation measures and robustness of the findings ................ 57 
3.5.1  Main challenges ...................................................................................... 57 
3.5.2  Mitigation measures and robustness of the findings ......................... 60 
IMPLEMENTATION OF THE ZOOS DIRECTIVE .................................................................... 61 
State of play: Implementation of the Directive in the Member States ........ 61 
4.1 
4.1.1 
Status of zoos in the EU ........................................................................... 61 
4.1.2  Market overview ..................................................................................... 63 
4.1.3 
Relevant stakeholders ............................................................................ 63 
4.1.4  Adoption of national law transposing the Zoos Directive ................ 64 
4.1.5  Competent authorities for transposition and implementation ....... 66 
4.1.6  National case law ................................................................................... 68 
State of Play: Infringements pursued at EU level .............................................. 68 
5  RESULTS: ANALYSIS AND DISCUSSION OF EVALUATION QUESTIONS ........................... 72 
Effectiveness ........................................................................................................... 72 
Effectiveness – EQ 1 ................................................................................ 72 
5.1.1 
Effectiveness – EQ 2 ............................................................................. 103 
5.1.2 

3.2 
3.3 

5.1 

4.2 

4 

 
 
 
 
5.5 

5.3 

5.2 

Effectiveness – EQ 3 ............................................................................. 116 
5.1.3 
5.1.4 
Effectiveness – EQ 4 ............................................................................. 131 
Efficiency ............................................................................................................... 133 
Efficiency – EQ 5 ................................................................................... 134 
5.2.1 
Efficiency – EQ 6 ................................................................................... 150 
5.2.2 
Efficiency- EQ 7 ..................................................................................... 152 
5.2.3 
5.2.4 
Efficiency – EQ 8 ................................................................................... 156 
Relevance ............................................................................................................ 157 
Relevance – EQ 9 ................................................................................. 158 
5.3.1 
Relevance – EQ 10 ............................................................................... 161 
5.3.2 
Relevance – EQ 11 ............................................................................... 168 
5.3.3 
5.4  Coherence ........................................................................................................... 175 
5.4.1  Coherence – EQ 12 ............................................................................. 175 
5.4.2  Coherence – EQ 13 ............................................................................. 182 
EU Added Value .................................................................................................. 184 
EU Added Value – EQ 14 .................................................................... 185 
5.5.1 
EU Added Value – EQ 15 .................................................................... 191 
5.5.2 
EU Added Value – EQ 16 .................................................................... 195 
5.5.3 
6  CONCLUSIONS ................................................................................................................. 201 
The Zoos Directive and its intervention logic .................................................. 201 
6.1 
6.2 
Limitations of the Analysis ................................................................................... 201 
6.3  Main Findings ........................................................................................................ 202 
Effectiveness ......................................................................................... 202 
6.3.1 
Efficiency ............................................................................................... 206 
6.3.2 
6.3.3 
Relevance ............................................................................................. 208 
6.3.4  Coherence ............................................................................................ 209 
EU added value ................................................................................... 211 
6.3.5 
ANNEX I – EVALUATION FRAMEWORK................................................................................. 214 
ANNEX II – COUNTRY FICHES ................................................................................................ 233 
ANNEX III – ADDITIONAL INFORMATION.............................................................................. 278 
ANNEX IV – BIBLIOGRAPHY ................................................................................................... 291 
ANNEX IVA – REFERENCE DATABASE ................................................................................... 300 
ANNEX V – GLOSSARY ........................................................................................................... 376 
ANNEX VI – TARGETED SURVEYS REPORT ............................................................................ 378 
ANNEXES VIA TO VIC – TARGETED SURVEYS QUESTIONNAIRES ....................................... 400 
ANNEX VII – INTERVIEWS REPORT ......................................................................................... 543 
ANNEX VIIA – INTERVIEW QUESTIONS .................................................................................. 562 
ANNEX VIII – PUBLIC CONSULTATION REPORT .................................................................... 566 
ANNEX VIIIA – PUBLIC CONSULTATION QUESTIONNAIRE .................................................. 637 
ANNEX IX – WORKSHOP REPORT .......................................................................................... 660 
ANNEX X – SYNOPSIS REPORT ............................................................................................... 732 

 
 
 
 
 
 
LIST OF TABLES 

Table 1: Legislation prior to the adoption of the Directive ................................................ 35 
Table 2: General regulatory framework prior to the adoption of the Directive ............ 36 
Table 3 Overview of evaluation criteria and questions ..................................................... 40 
Table 4: Overview of MSCAs responding to the questionnaire ........................................ 49 
Table 5: Overview of types of respondents to the high-level questionnaire .................. 49 
Table 6: Geographical distribution of federations and NGOs responding to the 
questionnaire ............................................................................................................................. 49 
Table 7: Geographical representation of zoos responding to the survey ...................... 51 
Table 8: Overview of stakeholders interviewed .................................................................. 52 
Table 9: EAZA membership and percentage of licensed zoos in the 28 EU Member 
States ........................................................................................................................................... 62 
Table 10: Adoption of transposing law in selected Member States: ‘old’ Member 
States’ (EU member before the entry into force of the Zoos Directive) .......................... 65 
Table 11: Adoption of transposing legislation in selected ‘new’ Member States (EU 
member since entry into force of the Zoos Directive) ........................................................ 66 
Table 12: Competent authorities for the implementation of the Zoos Directive in the 
14 selected Member States .................................................................................................... 67 
Table 13: EU infringement cases for non-compliance with the Zoos Directive .............. 69 
Table 14: Overview of the institutions, authorities and external bodies involved in 
inspections ................................................................................................................................. 75 
Table 15: Duration of licences and indicated frequency of inspections ........................ 76 
Table 16: Key features of the national inspection systems ................................................ 79 
Table 17: Penalties for breaches of zoo legislation in the 14 Member States ................ 84 
Table 18: Zoos licensed within, and after, four years of the entry into force of the 
legislation in 11 Member States (absolute numbers) .......................................................... 85 
Table 19: Number of zoos (licensed and unlicensed) and number of licensed zoos in 
14 Member States ..................................................................................................................... 87 
Table 20: Activities carried out by zoos ................................................................................. 98 
Table 21: Zoos with plans for the escape of animals and the intrusion of outside pests 
and vermin, by membership................................................................................................ 100 
Table 22: Overview of late transposition of the Directive ............................................... 120 
Table 23: Links between the Articles of the Directive and related activities, types of 
costs and stakeholders involved ......................................................................................... 136 
Table 24: CAs’ opinions on increased costs triggered by the Directive for licensing, 
inspection and monitoring ................................................................................................... 137 
Table 25: Number of zoos reporting one-off investments and, for those reporting some 
costs, estimates of the proportion attributable to the Directive (zero costs, i.e. zoos 
reporting no investments or none attributable to the Directive, are also included) . 139 
Table 26: Number of zoos reporting recurring expenditure and, for those reporting 
some costs, estimates of the proportion attributable to the Directive (zero costs, i.e. 
zoos reporting no investments or none attributable to the Directive, are also 
included) ................................................................................................................................. 140 
Table 27: Estimates of one-off investments and recurring zoo expenditure attributed 
by zoos to the Zoos Directive ............................................................................................... 141 
Table 28: Charges applied for the issuance of a licence in the 14 Member States .. 142 
Table 29: Reported difficulties in complying with and financing Article 3 requirements 
in order to obtain a licence for zoos of varying sizes ...................................................... 148 

 
 
 
Table 30: Number of zoos reporting major or moderate benefits associated with 
various items arising from the Directive (numbers in parentheses are percentages of 
zoos reporting benefits in each size category) ................................................................ 148 
Table 31: Zoos’ perceptions of whether or not the Directive implies disproportionate 
costs for investments and recurring administrative or other costs (number of replies = 
70) ............................................................................................................................................. 151 
Table 32: Number of zoos reporting disproportionate costs associated with licensing 
under the Directive for four categories of size of zoo (numbers in parentheses are 
percentages of zoos reporting disproportionate cost in each size category) ........... 151 
Table 33: Legislation prior to the adoption of the Zoos Directive .................................. 186 
Table 34: Effectiveness .......................................................................................................... 214 
Table 35: Efficiency ................................................................................................................ 222 
Table 36: Relevance .............................................................................................................. 226 
Table 37: Coherence ............................................................................................................ 228 
Table 38: EU Added Value ................................................................................................... 229 
Table 39: Overview of the definition of zoos in the 14 selected Member States........ 278 
Table 40: Existing definition of ‘animal of wild species’ provided by national law in the 
14 selected Member States ................................................................................................. 280 
Table 41: Comparison of requirements under Article 3 of the Directive and EAZA 
Standards ................................................................................................................................ 280 
Table 42: National requirements diverging and/or going beyond the Directive’s 
requirements ........................................................................................................................... 286 
Table 43: Overview of MSCAs responding to the questionnaire ................................... 381 
Table 44: Overview of types of respondents to the high-level questionnaire ............. 381 
Table 45: Geographical distribution of federations and NGOs responding to the 
questionnaire .......................................................................................................................... 382 
Table 46 Geographical representation of zoos responding to the survey .................. 383 
Table 47: Competent authorities ........................................................................................ 384 
Table 48: NGOs and zoos federations ................................................................................ 384 
Table 49: EU and international stakeholders ..................................................................... 386 
Table 50: Number of contacted zoos per Member State .............................................. 386 
Table 51: Zoos ......................................................................................................................... 386 
Table 52: Overview of interviewed stakeholders ............................................................. 543 
Table 53: Supplementary interviews ................................................................................... 546 
Table 54: Effectiveness .......................................................................................................... 547 
Table 55: Efficiency ................................................................................................................ 550 
Table 56: Relevance .............................................................................................................. 554 
Table 57: Coherence ............................................................................................................ 555 
Table 58: EU Added Value ................................................................................................... 556 
Table 59: Overall assessment – concluding question ...................................................... 557 
Table 60: Number of respondents to the public consultation, per Member States (in 
absolute numbers) ................................................................................................................. 572 
Table 61: Answer to question 20 of the public consultation “To what extent do you 
agree with the following statement?” - Share of respondents who replied “Totally 
agree” or “Somewhat agree”, per type of stakeholder. Percentages are calculated 
on the number of respondents that expressed an opinion (i.e. “Don’t know” is 
excluded) ................................................................................................................................ 580 
Table 62: Answer to question 20 of the public consultation “To what extent do you 
agree with the following statements?” - Share of respondents who flagged the reply 
options “Totally agree” or “Somewhat agree”, per Member State/non-EU Country. 

 
 
 
Percentages and, in brackets, absolute number of total respondents per Member 
State excluding “No opinion” .............................................................................................. 583 
Table 63: Answers to question 21 of the public consultation “Do you think the 
following activities are sufficiently promoted in zoos across the EU?” per share of 
respondents who replied ‘yes’. Percentages are calculated on the number of 
respondents that expressed an opinion (i.e. “No opinion/don’t know” is excluded).
 .................................................................................................................................................. 589 
Table 64: Answer to question 21 of the public consultation- Share of respondents who 
think that the activities listed in Question 21 are sufficiently promoted, per Member 
States/non-EU countries, and per activity. Percentages and, in brackets, absolute 
number of total respondents per Member State excluding “No opinion”. ................ 591 
Table 65: Answer to question 25 of the public consultation “To what extent do you 
consider that the Directive has brought the following benefits?” (% on total 
respondents) ........................................................................................................................... 597 
Table 66: Analysis of the open comments to question 26 of the public consultation 
(“To what extent do you consider that the Directive has brought the following 
benefits? – If Other, please specify”) and identification of repeated comments ..... 598 
Table 67: Answer to question 25 of the public consultation “To what extent do you 
consider that the Directive has brought the following benefits?” - Share of 
respondents who flagged the reply options “Significant Benefits” or “Crucial 
Benefits”, per type of stakeholder. Percentages and, in brackets, absolute number of 
total respondents per stakeholder excluding “No opinion” .......................................... 599 
Table 68: Answer to question 25 of the public consultation “To what extent do you 
consider that the Directive has brought the following benefits?” - Share of 
respondents who flagged the reply options “Significant Benefits” or “Crucial 
Benefits”, per Member State/non-EU Country. Percentages and, in brackets, absolute 
number of total respondents per Member State excluding “No opinion”.................. 602 
Table 69: Answer to question 27 of the public consultation “In your view, how do the 
costs of implementation of the Zoos Directive compare with the benefits brought 
about from their implementation” (% and absolute numbers of respondents), per 
Member State/Non-EU country ........................................................................................... 607 
Table 70: Answers provided to Question 23 of the public consultation ‘Please specify 
other’ – Absolute numbers and percentage on the total number of answers to 
Question 23 (n=488) clearly influenced by public campaigns ..................................... 610 
Table 71: Answers to question 22 of the public consultation “How important do you 
think EU-wide rules on zoos are on the following matters?” (per share of respondents 
who think that it is important or very important to have EU-wide rules on the following 
matters, per type of stakeholder). Percentages are calculated on the number of 
respondents that expressed an opinion (i.e. “No opinion/don’t know” is excluded).
 .................................................................................................................................................. 612 
Table 72: Answers to question 22 of the public consultation, per share of respondents 
who think that it is important or very important to have EU-wide rules on the points 
listed in question 22, per Member State). Percentages and, in brackets, absolute 
number of total respondents per Member State excluding “No opinion”.................. 615 
Table 73: Answer to Question 28m of the public consultation “Is the Zoos Directive 
consistent with and mutually supportive of the following legal and non-legal 
interventions or do you see significant gaps or overlaps? ‘Other’” in number of 
respondents, and percentage of respondents to Question 28m. ................................ 620 
Table 74: Answers provided to Question 29 of the public consultation ‘Please specify 
other’ – Absolute numbers and percentage on the total number of answers to 
Question 29 (n=400) clearly influenced by public campaigns ..................................... 620 

 
 
 
Table 75: Answers to question 29 of the public consultation ‘Please specify other’ – 
Categories and proportion of isolated answers ............................................................... 620 
Table 76: Answer to question 28 of the public consultation- Share of respondents who 
think that there are gaps between the Zoos Directive and the following instruments. 
Percentages and, in brackets, absolute number of total respondents per Member 
State excluding “No opinion” .............................................................................................. 623 
Table 77: Answer to question 28 of the public consultation- Share of respondents who 
think that there are overlaps between the Zoos Directive and the following 
instruments. Percentages are calculated on the number of respondents that 
expressed an opinion (i.e. “No opinion/don’t know” is excluded). ............................. 624 
Table 78: Activities that would take place or not in the absence of EU rules, 
according to answers to question 24 of the public consultation ................................. 629 
Table 79: Answers to question 24 of the public consultation “In your opinion, would 
the following activities take place without EU legislation on zoos?” (per share of 
respondents who think that it is likely or certain that the following activities would take 
place without EU rules, per country). Percentages are calculated on the number of 
respondents that expressed an opinion (i.e. “No opinion/don’t know” is excluded).
 .................................................................................................................................................. 632 
Table 80 – Agenda of the Workshop .................................................................................. 661 
Table 81 – Contacts with workshop participants ............................................................. 662 

LIST OF FIGURES 

Figure 1: Brief history of the evolution of the zoo ................................................................. 33 
Figure 2: Evolution of the zoo concept ................................................................................. 33 
Figure 3: Intervention logic of the Zoos Directive ................................................................ 38 
Figure 4: Evaluation logic of the Zoos Directive. ................................................................. 43 
Figure 5: Timeframe for the consultation processes ........................................................... 45 
Figure 6: Distribution of survey responses by membership, number of employees and 
type of entity, in absolute numbers ....................................................................................... 50 
Figure 7: Types of respondents ............................................................................................... 56 
Figure 8: Number of licensed zoos in selected Member States in 2015 .......................... 62 
Figure 9: NGOs and associations of zoos or zoo professionals in selected Member 
States ........................................................................................................................................... 64 
Figure 10: Stakeholder opinions of the effectiveness, proportionality and 
dissuasiveness of penalties (absolute number of replies per each stakeholder 
category, total number of respondents = 111) ................................................................... 85 
Figure 11: Opinion of zoos on the national licensing and inspection systems, in terms 
of: adequacy of the national licensing and inspection systems, knowledge training of 
inspectors, and human and financial resources (absolute numbers, total number of 
respondents = 70) (data referred to zoos in 14 Member States) ...................................... 90 
Figure 12: Opinion of federations/NGOs/experts on the national licensing and 
inspection systems, in terms of: adequacy of the national licensing and inspection 
systems, knowledge training of inspectors, and human and financial resources 
(absolute numbers, total number of respondents = 26) (data referred to 
federations/NGOs/experts in 14 Member States) ............................................................... 91 
Figure 13: Opinion of MSCAs on the national licensing and inspection systems, in 
terms of: knowledge training of inspectors, and human and financial resources 
(absolute numbers, total number of respondents = 15) .................................................... 91 

 
 
 
 
 
Figure 14: Number of zoos surveyed with a written conservation strategy, by 
membership ............................................................................................................................... 94 
Figure 15: Number of zoos surveyed with a written conservation strategy, by number 
of employees ............................................................................................................................. 94 
Figure 16: Overview of participation in research projects, training and exchange of 
information ................................................................................................................................. 95 
Figure 17: Number of zoos surveyed with a written education strategy, by 
membership ............................................................................................................................... 97 
Figure 18: Number of zoos surveyed with a written education strategy, by size of zoo
 ..................................................................................................................................................... 97 
Figure 19: Zoos’ capabilities in the field of animal husbandry .......................................... 99 
Figure 20: Main features of zoos’ record-keeping systems, number of answers per 
option (based on the answer provided by 68 zoos) ....................................................... 101 
Figure 21: Survey results on zoos’ participation in research projects 2003-2016 (number 
of projects) .............................................................................................................................. 104 
Figure 22: Survey results on the number of publications benefiting conservation 2003-
2016 .......................................................................................................................................... 106 
Figure 23: Survey results on zoos’ estimations of the percentage of species they keep 
that are on the global IUCN red list .................................................................................... 108 
Figure 24: Stakeholder opinions on the extent of the benefits associated with the Zoos 
Directive (results from the targeted questionnaires addressed to MSCAs, zoos and 
zoos’ federations, NGOs and experts. Number of replies = 111) .................................. 144 
Figure 25: MSCAs opinions on the extent of the benefits associated with the Zoos 
Directive (Number of replies = 15) ...................................................................................... 145 
Figure 26: Zoos’ opinions on the extent of the benefits associated with the Zoos 
Directive (Number of replies = 70) ...................................................................................... 145 
Figure 27: Opinion of zoos’ federations, NGOs and experts on the extent of the 
benefits associated with the Zoos Directive (Number of replies = 26) ......................... 146 
Figure 28: Stakeholders considering the protection of threatened species to be 
relevant, in absolute numbers ............................................................................................. 159 
Figure 29: Stakeholder perceptions of the relevance of public awareness of 
biodiversity conservation issues ........................................................................................... 160 
Figure 30: Development of global biodiversity and conservation objectives ............ 162 
Figure 31: Stakeholder perceptions of the contribution of the Directive to Aichi Target 
1 ................................................................................................................................................ 165 
Figure 32: Stakeholder perceptions of the contribution of the Directive to the 
protection of threatened species ....................................................................................... 166 
Figure 33: Timeline of approach to conservation ............................................................ 168 
Figure 34: Number of stakeholders considering the protection of threatened species 
to be relevant ......................................................................................................................... 173 
Figure 35: Stakeholder perceptions of technical progress in relation to strengthening 
links between in situ and ex situ conservation .................................................................. 173 
Figure 36: Online responses to the question ‘Do you think that the EU intervention has 
contributed to make zoos adopt or implement the Article 3 conservation measures 
more efficiently or more quickly as compared to national law or non-legal 
initiatives?’ (Total number of respondents = 111) ............................................................ 188 
Figure 37: Zoos’ online responses to question 108 ‘In your zoo, to what extent has the 
Zoos Directive contributed to implementing new conservation measures or improving 
the existing ones?’ (in %, out of 70 responding zoos in total; 37 EAZA members; 16 
other zoos’ federations; six no zoos’ federations; 11 undetermined) ........................... 189 

 
 
 
Figure 38: Online responses to the question ‘In your opinion, has the role of zoos in the 
conservation of biodiversity been strengthened over the last 15 years? Can this be 
attributed to the Zoos Directive?’ ....................................................................................... 189 
Figure 39: Answers to question 22 of the public consultation ‘How important do you 
think EU-wide rules on zoos are on the following matters?’ (in absolute numbers of 
respondents) ........................................................................................................................... 194 
Figure 40: Online responses to the question ‘In your opinion, could the same 
objectives be partly or entirely achieved with the relevant existing international 
conventions, programmes or other instruments?’ ........................................................... 196 
Figure 41: Online responses to the question ‘Do you think an EU legislative act is 
necessary to ensure that zoos implement Article 3 measures?’ ................................... 198 
Figure 42: Answers to question 24 of the public consultation ‘In your opinion, would 
the following activities take place without EU legislation on zoos?’ (in absolute 
numbers of respondents) ..................................................................................................... 199 
Figure 43: Distribution of the zoos having replied the survey by membership,number of 
employees and type of entity (in absolute numbers) ..................................................... 382 
Figure 44: Types of respondents to the public consultation (in shares of total number 
of respondents, n=2297) ....................................................................................................... 571 
Figure 45: Answers to the public consultation, level at which organisation operate (in 
absolute numbers) ................................................................................................................. 572 
Figure 46: Main field of activity of respondents to the public consultation (in absolute 
numbers) ................................................................................................................................. 573 
Figure 47: Main field of interest of respondents to the public consultation (in absolute 
numbers) ................................................................................................................................. 573 
Figure 48: Respondents’ memberships in organisations relevant to the topic of the 
public consultation (in absolute numbers) ........................................................................ 574 
Figure 49: Familiarity with the Zoos Directive of respondents to the public consultation 
(in absolute numbers) ........................................................................................................... 574 
Figure 50: Answers to question 17 of the public consultation “How familiar are you 
with the Directive?” (in absolute number of respondents, per type of stakeholder) 574 
Figure 51: Respondents’ reasons for visiting a zoo per type of stakeholder ................ 575 
Figure 52: Answers to question 18 of the public consultation “What are your main 
reasons for visiting a zoo?” in absolute number of respondents ................................... 575 
Figure 53: Answer to question 20 of the public consultation “To what extent do you 
agree with the following statements?” in absolute number of respondents .............. 578 
Figure 54: Answer to question 20 of the public consultation “To what extent do you 
agree with the following statement?” per share of respondents who agree to the 
statements proposed, per type of stakeholders. Percentages are calculated on the 
number of respondents that expressed an opinion (i.e. “Don’t know” is excluded)  580 
Figure 55: Answer to question 20 of the public consultation- Share of respondents 
who agreed with the statements of Question 20, on average across Questions 20a to 
20l ............................................................................................................................................. 582 
Figure 56: Answer to question 20 of the public consultation “To what extent do you 
agree with the following statements?” - Share of respondents who flagged the reply 
options “Totally agree” or “Somewhat agree”, per respondents visiting zoos or not. 
Percentages are calculated on the number of respondents that expressed an 
opinion (i.e. “No opinion” is excluded) .............................................................................. 585 
Figure 57: Answer to question 21 of the public consultation “Do you think the 
following activities are sufficiently promoted in zoos across the EU?” in absolute 
number of respondents ........................................................................................................ 587 

 
 
 
Figure 58: Answer to question 21 of the public consultation “Do you think the 
following activities are sufficiently promoted in zoos across the EU?” in percentage of 
respondents ............................................................................................................................ 587 
Figure 59: Answers to question 21 of the public consultation “Do you think the 
following activities are sufficiently promoted in zoos across the EU?” per share of 
respondents who replied ‘yes’. Percentages are calculated on the number of 
respondents that expressed an opinion (i.e. “No opinion/don’t know” is excluded).
 .................................................................................................................................................. 588 
Figure 60: Answer to question 21 of the public consultation- Share of respondents 
who think that the activities listed in Question 21 are sufficiently promoted, on 
average across Questions 21a to 21h, per Member State/non-EU country. .............. 590 
Figure 61: Answer to question 21 of the public consultation - Share of respondents 
who think that the activities listed in Question 21 are sufficiently promoted, 
depending on whether they visit zoos or not. Percentages are calculated on the 
number of respondents that expressed an opinion (i.e. “No opinion” is excluded) . 593 
Figure 62: Answer to question 25 of the public consultation “To what extent do you 
consider that the Directive has brought the following benefits?”, in absolute numbers 
of respondents ....................................................................................................................... 596 
Figure 63: Answer to question 25 of the public consultation “To what extent do you 
consider that the Directive has brought the following benefits?” - Share of 
respondents who flagged the reply options “Significant Benefits” or “Crucial 
Benefits”, per respondents visiting zoos or not. Percentages are calculated on the 
number of respondents that expressed an opinion (i.e. “No opinion” is excluded) . 604 
Figure 64: Answer to question 27 of the public consultation “In your view, how do the 
costs of implementation of the Zoos Directive compare with the benefits brought 
about from their implementation” in absolute numbers of respondents) ................... 605 
Figure 65: Answer to question 27 of the public consultation “In your view, how do the 
costs of implementation of the Zoos Directive compare with the benefits brought 
about from their implementation”, in absolute numbers of respondents, per type of 
stakeholder ............................................................................................................................. 606 
Figure 66: Answer to question 27 of the public consultation “In your view, how do the 
costs of implementation of the Zoos Directive compare with the benefits brought 
about from their implementation”, in absolute numbers of respondents, per 
respondents visiting zoos or not ........................................................................................... 608 
Figure 67: Answers to question 22 of the public consultation “How important do you 
think EU-wide rules on zoos are on the following matters?” in absolute number of 
respondents ............................................................................................................................ 610 
Figure 68: Answers to question 22 of the public consultation “How important do you 
think EU-wide rules on zoos are on the following matters?” per share of respondents 
who think that it is important or very important to have EU-wide rules on the following 
matters, per type of stakeholder. Percentages are calculated on the number of 
respondents that expressed an opinion (i.e. “No opinion/don’t know” is excluded).
 .................................................................................................................................................. 611 
Figure 69: Answers to question 22 of the public consultation “How important do you 
think EU-wide rules on zoos are on the following matters? c. Captive breeding (i.e. 
breeding of animals outside their natural habitats) of threatened species in Europe 
and globally” (in absolute number of respondents, per type of stakeholder). 
Percentages are calculated on the number of respondents that expressed an 
opinion (i.e. “No opinion/don’t know” is excluded). ....................................................... 613 
Figure 70: Answers to question 22 of the public consultation “How important do you 
think EU-wide rules on zoos are on the following matters?” as averaged shares of 

 
 
 
respondents who think that it is important or very important to have EU-wide rules on 
the points listed in question 22, per Member State, percentages are calculated on 
the number of respondents that expressed an opinion (i.e. “No opinion/don’t know” 
is excluded)............................................................................................................................. 613 
Figure 71: Answers to question 22 of the public consultation “How important do you 
think EU-wide rules on zoos are on the following matters?” per share of respondents 
who think that it is important or very important to have EU-wide rules on the points 
listed in question 22, depending on whether respondents visit zoos or not (question 18 
of the public consultation). Percentages are calculated on the number of 
respondents that expressed an opinion (i.e. “No opinion/don’t know” is excluded).
 .................................................................................................................................................. 616 
Figure 72: Answers to question 22 of the public consultation “How important do you 
think EU-wide rules on zoos are on the following matters? c.  Captive breeding (i.e. 
breeding of animals outside their natural habitats) of threatened species in Europe 
and globally” per share of respondents who think that it is important or very 
important to have EU-wide rules on the points listed in question 22, depending on 
whether respondents visit zoos or not (question 18 of the public consultation) ........ 616 
Figure 73: Answers to question 28 of the public consultation “Is the Zoos Directive 
consistent with and mutually supportive of the following legal and non-legal 
interventions or do you see significant gaps or overlaps?” in absolute number of 
respondents ............................................................................................................................ 619 
Figure 74: Answer to question 28 of the public consultation- Share of respondents 
who think that there are gaps between the Zoos Directive and the following 
instruments, per type of stakeholders. Percentages are calculated on the number of 
respondents that expressed an opinion (i.e. “No opinion/don’t know” is excluded).
 .................................................................................................................................................. 621 
Figure 75: Answer to question 28 of the public consultation- Share of respondents 
who think that there are overlaps between the Zoos Directive and the following 
instruments, per type of stakeholders. Percentages are calculated on the number of 
respondents that expressed an opinion (i.e. “No opinion/don’t know” is excluded).
 .................................................................................................................................................. 622 
Figure 76: Answer to question 28 of the public consultation- Share of respondents 
who think that there are gaps between the Zoos Directive and the following 
instruments, depending on whether they visit zoos or not. Percentages are 
calculated on the number of respondents that expressed an opinion (i.e. “No 
opinion/don’t know” is excluded). ..................................................................................... 626 
Figure 77: Answers to question 24 of the public consultation “In your opinion, would 
the following activities take place without EU legislation on zoos?” in absolute 
number of respondents. (“No opinion/don’t know” is excluded). ............................... 629 
Figure 78: Answers to question 24 of the public consultation “In your opinion, would 
the following activities take place without EU legislation on zoos?”  per share of 
respondents who think that it is likely or certain to have EU-wide rules on the following 
matters, per type of stakeholder. Percentages are calculated on the number of 
respondents that expressed an opinion (i.e. “No opinion/don’t know” is excluded).
 .................................................................................................................................................. 630 
Figure 79: Answers to question 24 of the public consultation “In your opinion, would 
the following activities take place without EU legislation on zoos?” per share of 
respondents who think that it is likely or certain that the following activities would take 
place without EU rules, depending on whether respondents visit zoos or not (question 
18 of the public consultation). Percentages are calculated on the number of 

 
 
 
respondents that expressed an opinion (i.e. “No opinion/don’t know” is excluded).
 .................................................................................................................................................. 633 
Figure 80: Stakeholders’ opinions on the significance of benefits associated with the 
Zoos Directive (results from the targeted questionnaires addressed to MSCAs, zoos 
and zoos’ federations, NGOs and experts. Number of replies = 111) .......................... 739 
Figure 81: Stakeholders’s opinions on the relevance of the protection of threatened 
species (results from the targeted questionnaires addressed to MSCAs, zoos and 
zoos’ federations, NGOs and experts. Number of replies = 108) .................................. 740 
Figure 82: Stakeholders’ perceptions that the EU intervention has contributed to 
make zoos adopt or implement the Article 3 conservation measures more efficiently 
or more quickly as compared to national law or non-legal initiatives (results from the 
targeted questionnaires addressed to MSCAs and zoos’ federations, NGOs and 
experts. Number of replies = 41) .......................................................................................... 741 
Figure 83: Answers of the public consultation to ‘‘How important do you think EU-
wide rules on zoos are on the following matters?’ .......................................................... 742 

LIST OF BOXES 

Box 1: Example of case law at national level - France ...................................................... 68 
Box 2: Irish inspection system ................................................................................................... 82 
Box 3: Examples of training for zoo inspectors organised in the Member States .......... 89 
Box 4: Promotion of Article 3, first indent, measures, results of the public consultation
 ..................................................................................................................................................... 96 
Box 5: Promotion of Article 3, second indent, measures, results of the public 
consultation ............................................................................................................................... 98 
Box 6: Promotion of Article 3, third indent, measures, results of the public consultation
 ..................................................................................................................................................... 99 
Box 7: Promotion of Article 3, fourth indent, measures, results of the public 
consultation ............................................................................................................................ 100 
Box 8: Promotion of Article 3, fifth indent, measures results of the public consultation
 .................................................................................................................................................. 101 
Box 9: Impact of financial support to in situ conservation programmes ..................... 109 
Box 10: Examples of participation of zoos in LIFE funded projects ................................ 115 
Box 11: Categorisation of zoos in Austria ........................................................................... 118 
Box 12: Example of successful contribution to conservation by joint efforts of zoos and 
academia ............................................................................................................................... 128 
Box 13: Dutch inspection system ......................................................................................... 154 
Box 14: Steps in assessing the relevance of ex situ management for conservation 
purposes .................................................................................................................................. 170 
Box 15: Common inspection systems ................................................................................. 180 
Box 16: More stringent requirements - France .................................................................. 192 

 
 
 
 
 
 
LIST OF ABBREVIATIONS 

Approved Bodies, Institutes and Centres 
ABICS  
Asociación Ibérica de Zoos y Acuarios (Spanish Zoo Federation) 
AIZA 
Associacao Portuguesa de Zoos e Aquaria (Portuguese Zoo Federation) 
APZA   
Business as usual 
BAU 
British and Irish Association of Zoos and Aquariums 
BIAZA  
Competent Authority 
CA 
Convention on Biological Diversity 
CBD 
Conservation Breeding Specialist Group (IUCN) 
CBSG   
Convention on International Trade in Endangered Species of Wild Flora and Fauna 
CITES   
Court of Justice of the European Union 
CJEU 
Convention on Migratory Species 
CMS 
Danish Association of Zoos and Aquaria 
DAZA   
DG ENV 
Environment Directorate-General European Commission 
DG SANTE  Directorate-General for Health and Food Safety European Commission  
EAAM  
EAZA   
EEP 
EQ 
ESB 
EU 
FAO 
FTE 
IAS 
ISMZP  
IUCN 
JZAR 
MDG 
MEA 
MoU 
MS 
MSCA   
NGO 
NIMs 
NVD 
REFIT   
SDG 
SSC 
UIZA 
UK 
UN 
VdZ 
WAZA  
WWF 
WZACS  
Zoos Directive  Council Directive 1999/22/EC of 29 March 1999 relating to the keeping of wild ani-
mals in zoos 

European Association for Aquatic Mammals 
European Association of Zoos and Aquaria 
European Endangered Species Programme (EAZA) 
Evaluation Question 
European Stud Books 
European Union 
Food and Agriculture Organization of the United Nations 
Full Time Equivalent 
Invasive Alien Species 
Irish Standards of Modern Zoo Practice 
International Union for the Conservation of Nature 
Journal of Zoo and Aquarium Research 
Millennium Sustainable Development Goals 
Multilateral Environmental Agreement 
Memorandum of Understanding 
Member States of the European Union 
Member State Competent Authorities 
Non-Governmental Organisation 
National Implementation Measures 
Nederlandse Vereniging van Dierentuinen (Dutch Zoo Federation) 
Commission's Regulatory Fitness Check and Performance 
Sustainable Development Goals 
Species Survival Commission (IUCN) 
Unione Italiana Giardini Zoologici e Acquari (Italian Zoo Federation) 
United Kingdom 
United Nations 
Verband der Zoologischen Gärten (German Zoo Federation) 
World Association of Zoos and Aquariums 
World Wildlife Fund 
World Zoo and Aquarium Conservation Strategy 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
ABSTRACT 

This evaluation study supports the evaluation of Directive 1999/22/EC of 29 March 1999 relating to 
the keeping of wild animals in zoos (‘Zoos Directive’) as part of the Commission's Regulatory Fitness 
Check  and  Performance  (REFIT)  programme.  The  REFIT  programme  assesses  European  Union 
(‘EU’) law to ensure it is ‘fit for purpose’. This assessment is based on five evaluation criteria: effec-
tiveness, efficiency, relevance, coherence and EU added value. The evidence for this exercise is partly 
gathered through the present study, based on desk research and several stakeholders’ consultations. 

The Zoos Directive was adopted in 1999 and is force since 2002. Its main aim is to fulfil the obliga-
tions deriving from the Convention on Biological Diversity to adopt measures for ex situ conservation 
‘by providing for the adoption of measures by Member States for the licensing and inspection of zoos 
in the EU’. The setting up of adequate licensing and inspection systems by the national authorities and 
the implementation of conservation measures by zoos are expected to result in a strengthened role for 
zoos in biodiversity conservation, increased knowledge and public awareness in relation to the conser-
vation of biodiversity and, ultimately, in the protection of wild species and prevention of biodiversity 
loss. 

RÉSUMÉ 

Cette étude d’évaluation soutient l’évaluation de la directive 1999/22/CE du 29 mars 1999 relative à la 
détention d’animaux sauvages dans un environnement zoologique (‘Directive Zoos’) dans le cadre du 
programme  de  la  Commission  pour  une  réglementation  affûtée  et  performante  (REFIT).  Le  pro-
gramme REFIT évalue le droit de l’Union Européenne (UE) pour s’assurer que celui-ci réponde à ses 
besoins.  Cette  évaluation  est  basée  sur  cinq  critères  d’évaluation :  l’efficacité,  l’efficience,  la  perti-
nence, la cohérence et la valeur ajoutée de la directive. La base factuelle pour cet exercice est fournie 
en partie par la présente étude, sur base d’une analyse bibliographique et de plusieurs consultations de 
parties prenantes. 

La Directive Zoos fut adoptée en 1999 et est en vigueur depuis 2002. Son but premier est de satisfaire 
aux obligations dérivant de la Convention sur la Diversité Biologique d’adopter des mesures de con-
servation  ex-situ  ‘en  prévoyant  l’adoption  par  les  États  membres  de  mesures  d’octroi  de  licences  et 
d’inspection  des  jardins  zoologiques’.  L’instauration  de  systèmes  adéquats  d’octroi  de  permis  et 
d’inspection par les autorités nationales ainsi que la mise en œuvre des mesures de conservation par 
les  zoos  doivent  résulter  dans  un  rôle  renforcé  des  zoos  dans  la  conservation  de  la  biodiversité,  une 
plus grande connaissance et conscience du public en la matière et, enfin, dans la protection des espèces 
sauvages et la prévention du déclin de la diversité biologique. 

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EXECUTIVE SUMMARY  

The Supporting Study 

The purpose of the supporting study is to support the evaluation of Directive 1999/22/EC of 29 March 
1999 relating to the keeping of wild animals in zoos (‘Zoos Directive’) as part of the Commission's 
Regulatory  Fitness  Check  and  Performance  (REFIT)  programme.  With  REFIT,  the  Commission  is 
acting to make European Union (EU) law ‘fit for purpose’, i.e. to simplify and reduce regulatory costs 
while maintaining benefits.  

Milieu Ltd. and VetEffecT were awarded in June 2016 the contract to carry out the supporting study to 
support the Commission in their evaluation of the Zoos Directive. Based on the Commission Evalua-
tion Roadmap, setting out the scope and terms of reference of the Zoos Directive evaluation, the pur-
pose  of  this  study  was  to  assess  the  Directive  based  on  the  five  criteria  of  relevance,  effectiveness, 
efficiency, coherence and EU added value of the Directive, together with 16 related ‘evaluation ques-
tions’. The study provides an evidence-based judgement to support the REFIT evaluation carried out 
by the Commission to inform future decisions relating to EU biodiversity policy and ex situ conserva-
tion. 

The Zoos Directive 

The  Zoos  Directive  was  adopted  on  29  March  1999  and  came  into  force  in  2002.  It  was  adopted 
against  the  backdrop  of  an  increasing  interest  in  conservation  and  protection  of  biodiversity,  which 
was reflected during the Earth Summit of 1992 and in the adoption of the 1992 Convention on Biolog-
ical Diversity (CBD). During the same period, the 1993 World Strategy for Conservation in Zoos and 
Aquaria reflected the evolution of zoos from their role as living museums to one of modern conserva-
tion centres, where education, research, and captive breeding and reintroduction programmes are un-
dertaken, over and above purely recreational activities. At European level, at the time, a comprehen-
sive and consistent approach to ex situ conservation was generally missing. Notable gaps were the lack 
of a widely used definition of ‘zoo’, limited information on the number of zoos in existence, few zoos 
meeting  the  standards  required  by  international  guidelines  in  the  areas  of  animal  husbandry,  species 
conservation  and  public  education,  and  a  considerable  number  of  zoos  not  meeting  any  acceptable 
standards.  Equally,  there  was  little  consideration  of  the  conservation  activities  or  potential  of  zoos. 
Only five of the 12 Member States (i.e. Belgium, Denmark, France, Spain, and the UK) had relevant 
legislation on the subject. 

In July 1991, the European Commission  adopted a draft Directive, laying down  minimum standards 
for the keeping of animals in zoos. The stated objective of this proposal was to ensure that minimum 
harmonised standards for the keeping of wild animals would be observed by all zoos in the Communi-
ty. Such harmonisation was deemed necessary to facilitate the application of Community nature con-
servation laws and to protect the public.  

The Directive was finally adopted on 29 March 1999 with the main aim of  fulfilling the obligations 
deriving from the CBD to adopt measures for ex situ conservation. The objectives of the Directive are 
to protect wild fauna and to conserve biodiversity by providing for the adoption of measures by Mem-
ber  States  for  the  licensing  and  inspection  of  zoos  in  the  EU.  In  order  to  achieve  these  objectives, 
while simultaneously recognising that zoos are not a homogeneous set of establishments all with the 
same purpose, the Directive focuses on the role of Member States’ authorities in putting in place sys-
tems  for  inspection  and  licensing  of  zoos  to  ensure  that  zoos  implement  the  conservation  measures 
listed in Article 3. The setting up of adequate licensing and inspection systems and the implementation 
of conservation measures by zoos are expected to strengthen the role of zoos in biodiversity conserva-
tion,  increase  knowledge  and  public  awareness  of  biodiversity  conservation,  and,  ultimately,  help  to 
protect wild species and prevent biodiversity loss.  

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Evaluation Study to support the evaluation of the Zoos Directive/ 16 

 
 
 
 
 
 
 
 
 
 
Methodology and challenges 

The study gathered all available evidence to answer 16 evaluation questions. To this end, it included a 
literature  review,  targeted  surveys  aimed  at  key  stakeholder  groups  (i.e.  Member  States  competent 
authorities  (MSCAs),  zoo  operators,  NGOs  and  zoos’  federations),  in-depth  interviews  and  a  public 
consultation. The targeted surveys and interviews, as well as part of the literature review, focused on 
the 14 Member States  selected as representative case studies (Belgium, Bulgaria, Cyprus, the Czech 
Republic, Denmark, France, Ireland, Italy, Germany, Lithuania, the Netherlands, Poland, Portugal and 
Spain). This in-depth research on the 14 Member States was complemented by the public consultation 
and a general literature review, in order to broaden the scope and geographical coverage of the  sup-
porting study to all Member States1. Finally, a workshop was held with key stakeholders from all EU 
Member States to validate the findings of the study.  

Several challenges were encountered in relation to: (i) the availability and quality of information and 
data;  (ii)  the  limited  possibility,  in  some  cases,  for  triangulating  sources  and  opinions,  and;  (iii)  the 
quality  of  stakeholder  input.  Member  States  are  not  required  to  report  on  the  implementation  of  the 
Zoos Directive and no mechanisms exist at EU level for the systematic monitoring of its implementa-
tion. The information available at the beginning of the study was thus limited, and considerable effort 
was required to collect basic elements of information. The information used for the study was mainly 
gathered through desk research in each of the 14 Member States and through answers to the question-
naires addressed to MSCAs and other stakeholders (zoos’ federations, NGOs, experts and zoos). How-
ever, in  many cases, it was not possible to obtain  reliable and/or comparable  data. This affected  the 
triangulation of data, particularly for: (i) contextual elements on zoos and performance of the national 
licensing and inspection systems; (ii) research projects and other conservation measures implemented 
by zoos; and (iii) costs and benefits triggered by the Zoos Directive. Two main groups of stakeholders 
closely  followed  the  supporting  study,  zoos’  federations  (such  as  the  European  Association  of  Zoos 
and Aquaria) and NGOs involved in animal welfare (such as Born Free). The influence of these inter-
est  groups  was  visible  in  the  results  of  the  consultations  launched  as  part  of  the  supporting  study. 
These challenges were addressed –to the extent possible – by gathering an extensive collection of pri-
mary data, including literature review, targeted questionnaires addressed to different stakeholder cate-
gories, and additional interviews. 

Effectiveness 

This criterion analyses the extent to which the Directive’s general objective (to protect wild fauna and 
conserve biodiversity by strengthening the role of zoos in the conservation of biodiversity) and specif-
ic objectives (to ensure that zoos implement Article 3 conservation measures and that closures of zoos 
are appropriately handled) have been achieved.  

Compared to the baseline situation (when only five out of 12 Member States had a legislation in place, 
and conservation activities  received little consideration  among zoos), the Zoos Directive represented 
an  important  instrument,  which  prompted  the  establishment  of  legislative  frameworks  and  licencing 
and inspection systems in all Member States. Despite initial delays and issues in the transposition and 
implementation of the EU legislation,  progress has been  made towards achieving the specific objec-
tives of the Zoos Directive: Member States have set up the legislative and practical conditions (includ-
ing adequate licensing and inspection systems) to ensure that zoos implement conservation measures 
and that cases of non-compliance are handled; in parallel, data collected among a sample of 70 zoos, 
although not representative, suggests that many zoos are engaged in conservation activities (as defined 
in Article 3 of the Zoos Directive), at different degrees and in accordance with their capacity. Different 

1 Targeted surveys received answers from the CAs of the 14 selected Member States, 13 NGOs, 13 zoos’ federations, 70 zoos and one expert. 
In-depth interviews were carried out with 44 stakeholders (13 MSCAs, eight zoos’ federations, six NGOs, nine zoo operators and eight EU 
and international stakeholders). The public consultation received 2,297 answers (1,944 from individuals, 148 from zoo operators, 21 from 
business or business representatives, seven from public authorities, 38 from NGOs, 34 from other associations and 105 ‘other’).     

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factors have been reported during consultation with stakeholders, as having contributed to this positive 
evolution, including actions undertaken by: 
  The European Commission, through the launch of several infringements procedures, the publica-
tion of the Good Practices Document and the availability of funding opportunities for zoos (e.g. 
LIFE and ERASMUS).  

  Member  States,  by  providing  additional  requirements  in  their  transposing  legislation,  issuing 

 

guidance documents and organising training and workshops. 
International, EU and national zoos’ and aquarium federations, which are very active in support-
ing the implementation of the Zoos Directive, through their membership requirements, standards, 
training, breeding programmes, workshops and conferences and public awareness-raising activi-
ties.  

  NGOs, who play an important role in monitoring the implementation  of the Directive’s require-

ments and alerting authorities to issues, informing the public and raising awareness.  

  Zoos, which put into place the changes observed and pay increasing attention to conservation of 

biodiversity. 

  Other actors, such as academics and veterinarians (with e.g. research relying on ex situ manage-

ment), or the media (through public awareness activities). 

However, important implementation and enforcement issues remain and hinder the full achievement of 
the objectives and expected results of the Zoos Directive. The main issues identified include:  

 

Inconsistent application of the requirements on conservation measures, due to the differences in 
the national licensing and inspection systems, and the criteria applied to assess zoos’ compliance 
with requirements.  

  Lack of resources and capacity for inspections by MSCAs: zoo inspectors are often responsible 
for  a  range  of  different  duties  (e.g.  animals  used  for  scientific  purposes,  compliance  with  other 
legislation dealing with invasive alien species and CITES). Their skills are usually broad and not 
necessarily focused on wild fauna and species-specific issues. 

  Unlicensed  zoos,  or  zoos  that  do  not  meet  the  requirements  yet  continue  to  operate,  on  which 

stakeholders have raised concerns. 

These  issues  limit  the  effectiveness  of  the  licensing  and  inspection  systems  across  the  EU  and  raise 
concerns about the proper enforcement of the legislation at national level and the consistent implemen-
tation of conservation measures across all EU zoos.  

Finally, the overall impact of the Directive on the protection of wild fauna and conservation of biodi-
versity  (i.e.  the  achievement  of  the  general  objective)  is  difficult  to  assess.  For  example,  the  overall 
contribution of zoos to biodiversity conservation through research, training, captive breeding or rein-
troductions cannot be measured precisely. This issue is debated within the scientific community. Ex-
isting evidence is not conclusive. By contrast, the Zoos Directive clearly represents an essential condi-
tion  for  the  achievement  of  the  general  objectives  set  at  European  and  global  level  (particularly  the 
CBD) in relation to the protection of wild fauna and conservation of biodiversity.  

Efficiency 

Efficiency compares the inputs of a certain activity with the outputs and results produced. This criteri-
on addresses the range of regulatory costs implied by the implementation of the Directive and assesses 
whether these costs are reasonable and proportionate to the benefits. It also identifies the factors driv-
ing costs and examines if unnecessary burdens result from the Directive’s implementation.  

The  lack  of  literature  and  of  independent  assessments  on  the  topic,  as  well  as  the  paucity  of  infor-
mation provided by stakeholders did not allow to carry out a quantitative assessment. It als resulted in 
difficulties attributing costs and benefits directly to the Zoos Directive (rather than to other factors). 
Despite these limitations, evidence suggests that, by introducing a licensing and inspection system, the 
Zoos Directive has resulted in an increase in costs for both MSCAs and zoos, for the enforcement of 

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Evaluation Study to support the evaluation of the Zoos Directive/ 18 

 
 
 
 
 
 
 
 
 
 
the legislation and the application of the requirements related to conservation measures, respectively. 
The extent of increased costs appears limited.  

For Member State authorities, new or additional costs (compared to the situation before the entry into 
force of the Zoos Directive) are borne in relation to the treatment of licence applications, and for the 
preparation, execution and follow-up of inspections. The magnitude of these costs varies widely across 
Member States depending on the organisation of the licensing and inspection system (frequency of the 
inspections, number of inspectors involved in each on-site visit, existence of a pre-inspection phase). 
Resources  allocated  to  the  implementation  of  the  Directive  are  difficult  to  quantify,  in  view  of  the 
broader  range  of  responsibilities  of  zoo  inspectors  (i.e.  the  enforcement  of  other  legislative  acts). 
Where  estimates  have  been  provided,  the  resources  fully  dedicated  to  the  enforcement  of  the  Zoos 
Directive  appear  limited.  While  MSCAs  agreed  that  the  increase  in  costs  was  directly  related  to  the 
performance of the inspections, only half reported an increase in training costs. These data support the 
issues raised by stakeholders, including MSCAs, about the lack of appropriate knowledge of zoo in-
spectors and the need for better, targeted training activities.  

For zoos, the information collected through the targeted consultation is extremely fragmented. A sig-
nificant number of zoos in the sample (between 20 and 31 zoos out of 70) reported an increase in re-
curring expenditures related to Article 3 conservation measures and investment across different fields: 
renovation  of  the  enclosures;  provision  of  information  on  exhibited  animals;  improved  standards  of 
animal husbandry and enclosures; systems to prevent escape and record-keeping/animal identification 
systems. When estimates are provided, the amount spent can be significant (ranging from hundreds to 
millions of Euro), especially where investments related to the renovation of enclosures. However, only 
a  minority  of  zoos  stated  that  they  considered  these  costs  as  (fully  or  partly)  attributable  to  the  Di-
rective. The same pattern appears for recurring expenditure, where some zoos report a wide range of 
expenses (from tens to hundreds of thousands of Euro) but do not see these as attributable to the Di-
rective. In general terms, zoos reported a difficulty in disentangling the costs borne as a direct conse-
quence of the Directive from those expenses that would have occurred anyway, i.e. in the absence of 
the Directive and as part of the evolution of their role towards that of ‘modern zoos’. Overall evidence 
suggests that the Zoos Directive has triggered only part of the increase in costs recorded.  

In relation to the administrative burden, efforts of zoos  in relation to licensing and inspection proce-
dures have increased (i.e. preparing an application for the licence, preparatory work for the inspection, 
sending documents to authorities, completing pre-inspection questionnaires, taking part in the visit of 
the  MSCAs,  providing  answers  to  the  inspection  report).  Administrative  costs  appear  to  be  strictly 
related to the requirements for obtaining the licence, and are only considered by zoos as unnecessary 
or disproportionate to the benefits in very few cases.  

According to all categories of consulted stakeholders, the Zoos Directive has brought benefits by con-
tributing  to:  public  education  and  knowledge  on  biodiversity;  improved  accommodation  of  animals 
and  standards  for  animal  husbandry;  efforts  for  ex  situ  conservation;  and  higher  engagement  of  the 
public and stakeholders in biodiversity protection. It remains difficult to establish the extent to which 
these benefits can be attributed directly to the implementation of the Zoos Directive, and the extent to 
which other factors (the evolution of zoos as institutions, and the change in expectations of the general 
public) have played a role.  

Overall, costs were considered proportionate  and necessary for MSCAs and zoos, despite the uncer-
tainty about the extent of costs and benefits that can be attributed to the Directive. No significant dif-
ferences  emerged  between  zoos  of  different  sizes,  without  strong  evidence  that  smaller  zoos  have 
faced higher difficulties in adapting to the legislation.  

The qualitative information gathered suggests that the issues hindering the proper and efficient func-
tioning of the licensing and inspection system are mainly associated with the resources and capacity of 
national  inspectorates,  rather  than  with  specific  requirements  of  the  national  legislation  (such  as  the 
frequency of inspections). Possibilities thus exist to enhance the efficiency of the Zoos Directive, such 

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as improved guidance, involvement of external experts in the inspection process, and removal of pos-
sible duplication of controls carried out under different legislative acts (i.e. under Regulation (EC) No 
338/97 on the protection of species of wild fauna and flora by regulating trade therein, and Directive 
92/65/EEC on animal health requirements for trade in and imports into the EU). 

Relevance 

The relevance analysis relies on a comparison of the current needs and objectives with those defined at 
the time of adoption of the Directive. The Zoos Directive was adopted in 1999 and has been in force 
since 2002 without further amendments. The purpose of the analysis was to identify any disparity be-
tween the objectives of the Directive and the current (legal, policy and scientific) situation.  

Scientific  evidence  shows  that  the  status  of  conservation  (both  in terms  of  species  and  habitats)  has 
deteriorated over the last two decades. At the same time, understanding of the importance of the pro-
tection  of  threatened  species  and  public  awareness  of  biodiversity  conservation  has  improved.  Con-
cretely, the need to protect biodiversity is significantly greater now than at the time of the adoption of 
the Directive. This evolution is reflected  in the  changes in policy  objectives at EU and international 
level (e.g. Aichi targets under the CBD, UN Sustainable Development Goals). In light of these chang-
es, the view that the Directive’s objectives remain relevant is supported by all groups of stakeholders 
surveyed  (authorities,  zoos  and  federations/NGOs).  However,  the  evolution  of  international  instru-
ments from general aspirations to focused targets has resulted in more specific objectives for the con-
servation of biodiversity, to which ex situ management can contribute. While these more specific ob-
jectives and indicators underline the importance of the implementation of the Zoos Directive's provi-
sions, they also illustrate a general need to be more explicit about where ex situ management is most 
needed and could have the biggest impact in achieving conservation objectives.  

There has been a wide range of scientific and technical developments in the field of biodiversity con-
servation  since  1999,  in  particular  in  terms  of  population  management,  identification  of  species  in 
need of conservation action, and identification of the actions needed for threatened species. More spe-
cifically,  considerable  progress  has  been  made  since  the  adoption  of  the  Directive  in  relation  to  the 
interaction between in situ and ex situ conservation. Due to its broad scope and formulation, the Di-
rective does not contain  any outdated requirements in  relation to these developments. The results of 
stakeholders’  consultations  support  this  conclusion.  The  vast  majority  of  stakeholders  responding  to 
the targeted surveys (82%) considered the Directive appropriate in light of subsequent technical and 
scientific  developments.  The  stakeholders  consulted  nevertheless  also  indicated  that  the  interaction 
between in situ and ex situ conservation could be significantly enhanced. 

Coherence 

Evaluating  the  coherence  of  an  EU  act  involves  looking  at  the  wider  policy  and  legal  framework  in 
relation to a policy field. It evaluates how well the different interventions work together, by providing 
evidence of synergies and complementarities that could reinforce the achievement of common objec-
tives,  while  also  analysing  inconsistencies  and  overlapping  obligations  that  could  lead  to  inefficien-
cies.  The interactions of the Zoos Directive with other acts in the areas of biodiversity conservation 
and animal health have been analysed in this context. The evaluation of coherence also sought to ex-
amine  the  extent  to  which  the  Directive  has  supported  the  EU  internal  market  and  the  creation  of  a 
level playing field for zoos across the EU.  

The  primary  objective  of  the  Directive  is  the  conservation  of  biodiversity  through  establishing  the 
conservation role of zoos. The Zoos Directive  thus fits within a wide net of laws and policies at EU 
and national level aimed at the conservation of biodiversity. The legal analysis revealed no inconsist-
encies between the Zoos Directive and other relevant instruments. On the contrary, there are examples 
of positive interactions that strengthen the achievement of common objectives. Biodiversity conserva-
tion is not only the primary objective of the Zoos Directive, but also of the Nature Directives, the EU 
Wildlife  Trade  Regulation  and  Regulation  (EU)  1143/2014  on  invasive  alien  species  (IAS  Regula-

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tion). Taken together, these instruments establish a comprehensive system for biodiversity conserva-
tion in the EU, and contribute to the compliance of the Union with its obligations under the CBD. At 
the same time, there is scope for further synergies to reinforce the effectiveness of the legal framework 
applicable to zoos and their contribution to biodiversity conservation, for instance, through reintroduc-
tion programmes for native species or the organisation of joint inspection procedures. 

Certain stakeholders pointed to inconsistencies between the Zoos Directive and Regulation (EC) No. 
1739/2005 on the movement of circus animals (Circus Regulation), as well as with the IAS Regula-
tion.  However,  the  legal  analysis  found  no  coherence  issues.  With  respect  to  the  Circus  Regulation, 
there is no interaction between the two acts, given the clear exclusion of circuses from the scope of the 
Zoos Directive. For the IAS Regulation, even though zoos are required to ban the keeping and breed-
ing  of  IAS,  this  is  fully  in  line  with  the  biodiversity  conservation  objectives  embodied  in  the  Zoos 
Directive and the IAS Regulation, in view of the particularly negative impact that a spread of invasive 
alien  species  may  have  on  local  biodiversity.  While  it  is  acknowledged  that  zoos  are  not  the  main 
pathways for invasive alien species, there is evidence that they can still function as such, thereby justi-
fying the strict approach taken by the IAS Regulation.  

Finally, the information gathered indicates that the Zoos Directive has made a positive contribution to 
the establishment of a level playing field for zoos across the EU.  Prior to its adoption, there was no 
regulation for zoos in some Member States, yet all zoos must now comply with the minimum require-
ments imposed by the Directive. However, evidence suggests that there are significant discrepancies in 
the obligations imposed on zoos, as well as in the enforcement of the Directive, in the different Mem-
ber States. This suggests that a true level playing field has not yet been achieved. 

EU Added Value 

The  criterion  of  EU  Added  Value  examines,  from  a  qualitative  perspective,  the  extent  to  which  the 
Zoos Directive has contributed to strengthening the role of zoos and  promoting the adoption of con-
servation measures in a way that could not have been achieved by Member States on their own and/or 
by other stakeholders. It also assesses if there is a need for continued EU action. 

The Zoos Directive has played an important role in placing binding rules on all European zoos and, as 
such, it prompted the adoption of conservation measures  through the compulsory requirements of li-
censing.  Without  an  EU  Directive,  this  overall  result  would  probably  not  have  been  achieved  under 
national legislation, through participation in international agreements or the membership requirements 
of zoos’ federations. As already indicated, before the adoption of the Zoos Directive, national legisla-
tion regulating zoo affairs was absent in most Member States. Where national rules were in place, they 
included  requirements  for  licensing  and  inspection,  but  mainly  in  relation  to  conditions  for  animal 
accommodation and animal welfare, excluding objectives on biodiversity conservation. Standards and 
guidelines were provided by zoos’ federations (such as EAZA) prior to the adoption of the Directive, 
but these had a limited impact due to their coverage (17% of licensed zoos are members of EAZA), 
scope (before the adoption of the Directive, EAZA standards covered exclusively accommodation and 
care of animals) and non-binding nature. The Zoos Directive and external factors (e.g., work done by 
zoos’ federations, individual ambitions of zoo owners, general change of attitude towards biodiversity 
conservation and protection) exerted a mutually reinforcing effect on strengthening the role of all zoos 
in the conservation of biodiversity. According to a majority of MSCAs, NGOs and zoos, the Directive 
prompted  more efficient and faster implementation of conservation measures, especially in zoos that 
are not members of a federation.   

All  stakeholders  recognised  a  continuing  need  for  EU  intervention.  As  previously  mentioned,  im-
portant  differences  still  exist  across  Member  States  in  terms  of  implementation  and  enforcement, 
which have led to discrepancies in the obligations applying to zoos. This affects the level playing field 
between zoo operators in the different Member States and impairs the proper protection of biodiversity 
sought by the Directive. In parallel, whereas existing international conventions (CBD and CITES) and 
non-legislative instruments (standards and guidelines of zoos’ federations) enhance the role of zoos in 

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conservation, they do not enable the full achievement of the objectives set in the Zoos Directive. First-
ly, the Zoos Directive is instrumental in the practical implementation of the CBD and CITES, and in 
particular to fulfill the EU’s obligation as a party to the CBD. Secondly, standards and guidelines de-
fined by zoos’ federations can contribute only to a limited extent to the protection of biodiversity by 
EU zoos. These instruments lack one of the key features of the Zoos Directive: a legally binding value 
that enables enforcement across all EU zoos. As such, the Directive remains important for ensuring the 
implementation of conservation measures by zoos.   

The  need  for  continued  EU  action  in  the  field  of  ex  situ  management  is  deemed  important  by  more 
than 80% of the respondents to the public consultation. While zoos and public authorities agreed that 
most of the activities currently promoted by zoos would continue in the absence of the Directive, other 
stakeholder categories, including individuals and NGOs, were less assertive. On average, less than half 
of the respondents believe that all activities would be continued. Concerns were  raised by NGOs on 
the political message of abandoning EU legislation on zoos. One of the key concerns was that an ab-
sence of EU legislation on zoos would trigger repeals of national legislation  and budget cuts for en-
forcement. 

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NOTE DE SYNTHÈSE 

L’étude de soutien 

Dans le cadre du programme pour une réglementation affûtée et performante (REFIT) de la Commis-
sion, l’étude de soutien a pour objectif d’assister l’évaluation de la directive 1999/22/CE du 29 mars 
1999 relative à la détention d’animaux sauvages dans un environnement zoologique (ci-après la ‘Di-
rective Zoos’). Avec le REFIT, la Commission veille à ce que le droit de l’Union Européenne (UE) 
réponde à ses besoins, à simplifier et à réduire les charges réglementaires tout en maintenant les béné-
fices.  

Le  contrat  pour  effectuer  l’étude  de  soutien  a  été  attribué  à  Milieu  Ltd  et  VetEffecT  en  juin  2016. 
Fondé sur la feuille de route d’évaluation de la Commission fixant la portée et les termes de références 
de l’évaluation de la Directive Zoos, l’objectif de cette étude est d’évaluer la pertinence, l’efficacité, 
l’efficience, la cohérence et la valeur ajoutée de la directive autour de ces cinq ‘critères d’évaluation’ 
ainsi  que  seize  ‘questions  d’évaluation’.  Elle  fournit  une  base  factuelle  pour  assister  la  Commission 
dans l’évaluation REFIT qui guidera, parmi d’autres, la politique future de l’UE en matière de biodi-
versité et de conservation ex-situ. 

La Directive Zoos 

La Directive Zoos, adoptée le 29 mars 1999, est entrée en vigueur en 2002. Elle fut adoptée sur fond 
d’un intérêt croissant pour la conservation et la protection de la biodiversité, reflété durant le Sommet 
de la Terre de 1992 et par l’adoption de la Convention de 1992 sur la Diversité Biologique (CDB). À 
la  même  période,  la  Stratégie  Mondiale  pour  la  Conservation  dans  les  Zoos  et  Aquariums  de  1993 
illustrait  l’évolution  des  zoos  depuis  leur  rôle  de  musées  vivants  vers  celui  de  centres  modernes  de 
conservation, dédiés, au-delà d’activités purement récréatives, à l’éducation, la recherche, l’élevage en 
captivité  et  les  programmes  de  réintroduction  sont  entrepris.  Au  niveau  européen,    à  l’époque,.  une 
approche  complète  et  cohérente  de  la  conservation  ex  situ  était  généralement  absente  Des  manque-
ments, tels l’absence d’une définition commune du terme ‘zoo’, l’information limitée sur le nombre de 
zoos, le nombre restreint de zoos satisfaisant les normes exigées par les lignes directrices internatio-
nales en matière de conditions d’élevage, de conservation des espèces et d’éducation du public, ainsi 
que  le  nombre  considérable  de  zoos  ne  respectant  aucune  norme  acceptable,  étaient  également  vi-
sibles. Par ailleurs, peu d’attention était portée aux activités et au potentiel de conservation des zoos. 
Seuls  cinq  sur  douze  Etats  membres  (i.e.  Belgique,  Danemark,  France,  Espagne  et  Royaume-Uni) 
disposaient de législation pertinente en la matière. 

En juillet 1991, la Commission Européenne adopta un projet de directive, établissant les normes mi-
nimales  pour  la  détention  d’animaux  dans  les  zoos.  L’objectif  explicite  de  cette  proposition  était  de 
garantir que des standards harmonisés minimaux soient respectés par tous les zoos de la Communauté 
pour  la  détention  d’animaux  sauvages.  Une  telle  harmonisation  était  considérée  nécessaire  afin  de 
faciliter l’application de la législation communautaire en matière de conservation de la nature et pour 
protéger le public.  

La directive fut finalement adoptée le 29 mars 1999 avec l’objectif principal de remplir les obligations 
dérivant de la CDB d’adopter des mesures pour la conservation ex situ. Les objectifs de la directive 
sont donc ‘de protéger la faune sauvage et de préserver la biodiversité en prévoyant l’adoption par les 
États  membres  de  mesures  d’octroi  de  licences  et  d’inspection  des  jardins  zoologiques’  de  l’Union 
Européenne. Pour atteindre ces objectifs, tout en reconnaissant que les zoos ont différents buts et ne 
sont pas un ensemble homogène d’établissements, la directive se concentre sur le rôle des autorités des 
Etats membres pour instaurer des systèmes d’octroi des permis et d’inspection des zoos afin d’assurer 
que ceux-ci mettent en œuvre les mesures de conservation prévues à l’article 3. L’instauration de sys-
tèmes adéquats d’octroi de permis et d’inspection ainsi que la mise en œuvre des mesures de conserva-
tion par les zoos doivent résulter dans un rôle renforcé des zoos dans la conservation de la biodiversité, 

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une  plus  grande  connaissance  et  conscience  du  public  en  la  matière  et,  enfin, dans  la  protection  des 
espèces sauvages et la prévention du déclin de la diversité biologique. 

Méthodologie et défis 

L’étude  rassemble  les  informations  disponibles  pour  répondre  aux  seize  questions.  Elle  inclut  une 
analyse  bibliographique,  des  enquêtes  ciblées  envers  certains  groupes  de  parties  prenantes  (autorités 
compétentes des Etats membres, exploitants de zoo, ONG et fédérations de zoos), des entretiens ap-
profondis  et  une  enquête  publique.  Les  enquêtes  ciblées  et  les  entretiens,  ainsi  qu’une  partie  de 
l’analyse bibliographique, se sont concentrés sur  14 Etats  membres (Allemagne, Belgique,  Bulgarie, 
Chypre,  Danemark,  Espagne,  France,  Irlande,  Italie,  Lituanie,  Pays-Bas,  Pologne,  Portugal  et  Répu-
blique  Tchèque).  Afin  d’élargir  le  champ  et  la  portée  géographique  de  l’étude  à  tous  les  Etats 
membres,  cette  recherche  approfondie  a  été  complétée  par  une  consultation  publique  et  une  analyse 
bibliographique générale2. 

Plusieurs défis, liés à : (i) la disponibilité et la qualité des données ; (ii) la possibilité, parfois limitée, 
de  trianguler les  différentes  sources  et  opinions,  et ;  (iii)  la  qualité  des  informations  fournies  par  les 
parties  prenantes,  ont  émaillé  le  projet.  En  particulier,  les  Etats  membres  n’ont  pas  d’obligation  de 
rendre compte de la mise en œuvre de la Directive Zoos et aucun mécanisme pour la surveillance sys-
tématique  de  sa  mise  en  œuvre  n’existe  au  niveau  européen.  L’information  disponible  en  début 
d’étude était, par conséquent, limitée. Des efforts importants ont été nécessaire pour réunir des infor-
mations élémentaires. Les informations utilisées pour cette étude ont principalement été collectée via 
une recherche documentaire dans les 14 Etats membres et via les réponses aux questionnaires adressés 
aux autorités et autres parties prenantes (fédérations de zoos, ONG, experts et zoos). Cependant, dans 
de nombreux cas, il n’a pas  été possible d’obtenir des données fiables  et/ou comparable,  et donc  de 
trianguler les données, en particulier sur : (i) les éléments contextuels sur les zoos et la performance 
des systèmes nationaux d’octroi de permis et d’inspection ; (ii) les projets de recherche et autres me-
sures de conservation mises en œuvre par les zoos ; et (iii) les coûts et bénéfices induits par la direc-
tive. Par ailleurs, deux groupes d’intérêt ont prêté une attention particulière à l’étude : d’une part, les 
fédérations de zoos (telle que l’European Association of Zoos and Aquaria) et, d’autre part, les ONG 
actives en matière de bien-être animal (telle que Born Free). L’influence de ces groupes d’intérêts s’est 
reflétée dans les résultats des consultations effectuées dans le cadre de l’étude. Ces limitations ont été 
compensées  autant  que  possible  par  l’obtention  de  données  brutes,  par  l’analyse  bibliographique,  et 
par  les  enquêtes  ciblées  adressées  aux  différentes  parties  prenantes  et  autres  entretiens  supplémen-
taires. En outre, un séminaire, auquel ont participé les parties prenantes de tous les Etats-Membres, a 
permis de valider les résultats de l’étude.  

Efficacité 

Ce critère analyse la mesure dans laquelle l’objectif général de la directive - de protéger la faune sau-
vage et de  conserver la biodiversité par le renforcement du rôle des zoos dans  la conservation de la 
biodiversité - et ses objectifs spécifiques - de garantir que les zoos mettent en œuvre les mesures de 
conservation prévues à l’article 3 et que les fermetures des zoos soient gérées de façon appropriée  - 
ont été atteints. 

Dans  ce  contexte  où  seuls  cinq  sur  douze  Etats  membres  avaient  une  législation  en  place,  et  où  les 
activités de conservation recevaient peu d’attention au niveau des zoos, la Directive Zoos constitue un 
instrument  important,  qui  déclencha  la  mise  en  place  de  cadres  législatifs  ainsi  que  des  systèmes 
d’octroi de licences et d’inspections dans tous les Etats membres. 

2 Les enquêtes ciblées reçurent des réponses des autorités compétentes des 14 Etats membres sélectionnés, 13 ONG, 13 fédérations de zoos, 
70 zoos et un expert. Des entretiens approfondis furent conduits avec 44 parties (13 MSCAs, 8 fédérations de zoos, 6 ONG, 9 exploitants de 
zoos ainsi que 8 parties au niveaux EU et international). La consultation publique reçut 2297 réponses (1944 réponses de citoyens, 148 
d’exploitants de zoos, 21 d’entreprises ou représentants d’entreprises, 7 d’autorités publiques, 38 d’ONG, 34 d’autres associations et 105 
« autres »). 

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Malgré des retards initiaux et des problèmes dans la transposition et la mise en œuvre de la législation 
européenne au  niveau  national, des progrès ont été fait vers l’atteinte des objectifs spécifiques de  la 
Directive Zoos : les Etats membres ont mis en place les conditions juridiques et pratiques (y compris 
des  systèmes adéquats d’octroi de permis et d’inspection, pour garantir que les zoos adoptent des me-
sures de conservation et que les cas de non-conformité soient traités ; en parallèle, les données collec-
tées au sein d’un échantillon de 70 zoos, bien que non représentatif, suggère que de nombreux zoos 
sont engagés dans des activités de conservation (telles que définies dans l’article 3), à différents degrés 
et selon leurs capacités. 

Différents  facteurs  ont  été  décrits  durant  les  consultations  avec  les  parties  prenantes  comme  ayant 
contribué à cette évolution positive, y compris les actions menées par : 

  La Commission Européenne, via l’introduction de plusieurs procédures en manquement, la publi-
cation d’un ‘Good Practices Document’ et les opportunités de financement des zoos (ex. LIFE et 
ERASMUS) ; 

  Les Etats membres, par l’adoption d’exigences supplémentaires dans leurs législations nationales, 
la publication de lignes directrices ainsi que l’organisation de formations et autres évènements ; 
  Les  fédérations  internationales,  européennes  et  nationales  de  zoos  et  d’aquariums,  très  actives 
dans  le  soutien  de  la  mise  en  œuvre  de  la  Directive  Zoo,  par  le  biais  de  leurs  conditions 
d’affiliation,  leurs  normes,  leurs  formations,  leurs  programmes  d’élevage,  leurs  évènements  et 
conférences ainsi que leurs activités de sensibilisation du public ; 

  Les ONG, qui jouent un rôle important dans la surveillance de la mise en œuvre de la directive, 
pour alerter les autorités de manquements éventuels, ainsi que dans l’information et la sensibilisa-
tion du public ; 

  Les zoos, qui mettent en place les ajustements nécessaires et portent une attention croissante à la 

conservation de la biodiversité dans leur démarche ; 

  D’autres acteurs, tels qu’universitaires et vétérinaires (pour, par exemple, la recherche et les acti-

vités ex situ), ou les médias (via des activités d’information du public). 

Des  problèmes  importants  de  mise  en  œuvre  et  d’exécution  subsistent  cependant  et  freinent 
l’accomplissement  des  objectifs  et  résultats  attendus  par  la  Directive.  Les  problèmes  principaux  in-
cluent : 

  L’application  incohérente  des  mesures  de  conservation,  due  en  partie  aux  différences  entre  les 
systèmes  nationaux  d’octroi  de  permis  et  d’inspection,  et  les  critères  appliqués  pour  évaluer  la 
conformité des zoos. 

  Le manque de ressources et de capacité des autorités pour mener les inspections. Les inspecteurs 
en charge des zoos sont souvent également responsables du contrôle dans le cade d’autres législa-
tions (p.ex. sur les animaux utilisés à des fins scientifiques, sur les espèces invasives et CITES). 
Leurs  compétences  sont  généralement  étendues  et  non  concentrées  sur  la  faune  sauvage  et  les 
questions propres à ces espèces. 

  Des zoos non agréés, ou des zoos qui ne répondent pas aux exigences légales mais qui continuent 

d’opérer, régulièrement mis en évidence par les divers acteurs sociaux. 

Ces problèmes limitent l’efficacité des systèmes d’octroi de permis et d’inspection à travers l’UE et 
soulèvent des questions quant à l’exécution appropriée de la législation au niveau national et la mise 
en œuvre cohérente de mesures de conservation parmi tous les zoos de l’UE. 

Au final, l’impact de la directive sur la protection de la faune sauvage et la conservation de la biodi-
versité (càd l’objectif général de la directive) est difficile à évaluer. La contribution générale des zoos 
à  la  conservation  de  la  biodiversité  au  travers  de  la  recherche,  de  la  formation,  des  programmes 
d’élevage ou de réintroduction, ne peut, par exemple, pas être mesurée précisément. La question  est 
débattue au sein de la communauté scientifique, mais les preuves existantes ne sont pas concluantes. 
En revanche, la Directive Zoos représente clairement une condition essentielle pour l’atteinte des ob-

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jectifs fixés aux niveaux européen et mondial (en particulier la CDB) de protection de la faune sau-
vage et de conservation de la biodiversité. 

Efficience 

L’efficience compare les ressources mises à disposition pour une certaine activité liée à une directive 
avec ses résultats. Ce critère prend en compte les charges réglementaires induites par la mise en œuvre 
de la directive et détermine si ces coûts sont raisonnables et proportionnés par rapport aux bénéfices. 
Les origines de ces coûts, ainsi que les charges accrues inutilement, si elles existent, sont également 
examinées. 
L’absence  de  littérature  et  d’évaluations  indépendantes  sur  le  sujet,  de  même  que  le  peu 
d’informations fournies par les parties prenantes n’ont pas permis de réaliser une évaluation quantita-
tive. Cela a également résulté dans des difficultés pour attribuer les coûts et bénéfices directement à la 
Directive Zoos (et pas à d’autres facteurs). 

Malgré  ces  limitations,  il  semblerait  que,  en  introduisant  un  système  d’octroi  de  licences  et 
d’inspection, la Directive Zoos a mené à une augmentation des coûts pour les autorités (mise en œuvre 
de la législation) et pour les zoos (mesures de conservation). L’augmentation des coûts semble malgré 
tout limitée.  

Pour les autorités, des coûts nouveaux ou additionnels, comparés à la situation antérieure à l’entrée en 
vigueur de la Directive Zoos, sont dus aux traitements des demandes de permis, ainsi qu’à la prépara-
tion, l’exécution et le suivi des inspections. L’ampleur de ces coûts varie substantiellement  entre les 
différents  Etats  membres  en  fonction  de  l’organisation  de  leurs  systèmes  d’octroi  de  permis  et 
d’inspection  (fréquence  d’inspection,  nombre  d’inspecteur  par  visite,  existence  d’une  phase  de  pré-
inspection). Les ressources allouées à la mise en œuvre de la directive sont difficiles à quantifier, étant 
donné le nombre important d’autres responsabilités des personnes en charge de l’inspection des zoos 
(c’est-à-dire l’exécution d’autres législations). Quand des estimations ont été fournies, les ressources 
entièrement dédiées à la mise en œuvre de la Directive Zoos semblent limitées. Quand bien même les 
autorités reconnaissent que l’augmentation des coûts est directement liée à la performance des inspec-
tions,  seulement  la  moitié  d’entre  elles  mentionnent  une  augmentation  des  coûts  de  formation.  Ces 
données renforcent les doutes levés par les parties prenantes, y compris les autorités, quant à l’absence 
de connaissances appropriées des inspecteurs de zoos, et le besoin de formations de meilleure qualité 
et plus ciblées. 

Pour  les  zoos,  les  opinions  collectées  via  la  consultation  ciblée  sont  extrêmement  partagées.  Un 
nombre important de zoos de l’échantillon (entre 20 et 31 zoos sur 70) déclare une augmentation des 
dépenses courantes liées aux mesures de conservation de l’article 3 et aux investissements dans diffé-
rents  domaines  :  la  rénovation  des  enclos ;  l’exposition  d’information  sur  les  espèces  exhibées ;  les 
normes plus élevées d’élevage et d’hébergement des animaux ; les systèmes instaurés pour éviter que 
les animaux ne s’échappent ; et  ceux pour la tenue des registres/d’identification des animaux. Quand 
des estimations ont été fournies, les sommes investies peuvent être considérables (entre des centaines 
et des millions d’Euros), spécialement lorsque ceux-ci sont liés à la rénovation des enclos. Cependant, 
seule une minorité de zoos exprima qu’ils considèrent ces coûts comme (pleinement ou partiellement) 
attribuable à la directive. La même logique apparaît pour les dépenses courantes : si des zoos ont dé-
claré  une  série  importante  de  dépenses  (entre  des  centaines  et  des  milliers  d’Euros),  ils  ne  les  attri-
buent pas à la directive. Dans l’ensemble, les zoos ont exprimé des difficultés à distinguer les coûts 
supportés comme conséquence directe de la directive de ceux qui seraient survenus indépendamment 
de l’existence de celle-ci, c’est-à-dire dans le cadre de l’évolution de leur rôle vers celui de ‘zoos mo-
dernes’.  De  façon  générale,  il  semblerait  que  la  Directive  Zoos  n’a  causé  qu’une  partie  de 
l’augmentation enregistrée des coûts.  

En ce qui concerne la charge administrative, les efforts des zoos liés à l’octroi de permis et les inspec-

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tions  (la  préparation  de  la  demande  de  permis,  le  travail  préparatoire  pour  l’inspection,  l’envoi  des 
documents  aux  autorités,  la  complétion  des  questionnaires  pré-inspection,  la  participation  à  la  visite 
des MSCAs, les réponses aux rapports d’inspection) ont augmenté. Les coûts administratifs apparais-
sent strictement liés aux exigences d’obtention du permis et sont considérés par une faible minorité de 
zoos comme inutiles ou disproportionnés par rapport aux bénéfices. 

Selon les parties prenantes consultées, toutes catégories confondues, la Directive Zoos a engendré des 
bénéfices  par  sa  contribution  à  l’éducation  et  l’information  du  public  sur  la  biodiversité,  à 
l’amélioration  des  conditions  des  animaux  et  des  normes  d’élevage,  aux  efforts  en  conservation  ex 
situ, et dans l’engagement plus élevé du public et des acteurs sociaux dans la protection de la biodiver-
sité. Il reste difficile d’établir dans quelle mesure ces bénéfices peuvent être directement attribués à la 
mise en œuvre de la Directive Zoos, et non à d’autres facteurs, comme l’évolution globale des zoos en 
tant qu’institutions de conservation ou l’évolution des attentes du public. 

Dans  l’ensemble,  les  coûts  sont  considérés  par  les  autorités  et  les  zoos  comme  étant  nécessaires  et 
proportionnés,  malgré  l’incertitude  liée  à  l’attribution  des  coûts  et  bénéfices  à  la  directive.  Aucune 
différence significative n’émerge entre les zoos de différentes tailles, et il n’y a pas de preuve solide 
que les zoos plus petits feraient face à des difficultés plus importantes pour s’adapter à la législation. 

L’information collectée suggère que les obstacles au fonctionnement efficace des systèmes d’octroi de 
permis et d’inspection sont surtout liés aux ressources et capacités des inspectorats nationaux, plutôt 
qu’aux  exigences  spécifiques  de  la  législation  nationale  –  tel  que  la  fréquence  des  inspections.  Des 
possibilités existent donc pour améliorer l’efficience de la Directive Zoos, comme l’amélioration des 
directives  données  pour  les  inspections,  l’implication  d’experts  externes  dans  les  inspections  et 
l’élimination  des  duplications  potentielles  avec  les  contrôles  effectués  sous  d’autres  législations  - 
comme le Règlement (CE) 338/97 relatif à la protection des espèces de faune et flore sauvages par le 
contrôle de leur commerce, et la Directive 92/65/CEE sur les conditions de police sanitaire régissant 
les échanges et les importations d’animaux au sein de l’UE. 

Pertinence 

L’analyse de la pertinence repose sur une comparaison des besoins et objectifs actuels avec ceux défi-
nis lors de l’adoption de la directive. La Directive Zoos fut adoptée en 1999 et est en vigueur depuis 
2002, et n’a pas subi de modifications. L’objectif de cette analyse était donc d’identifier toute disparité 
entre  les  objectifs  définis  dans  la  directive  et  la  situation  actuelle  sur  le  plan  juridique,  politique  et 
scientifique. 

L’analyse bibliographique démontre que le statut de conservation des espèces et habitats s’est détério-
ré au cours des deux dernières décennies. En parallèle, l’importance de la protection des espèces me-
nacées est devenue de plus en plus évidente, y compris aux yeux du public. Concrètement, le besoin de 
protéger la biodiversité est  substantiellement plus important maintenant qu’au moment de l’adoption 
de la directive. Cette évolution est reflétée dans les objectifs politiques aux niveaux européen et inter-
national, par exemple les objectifs d’Aichi pour la CDB et les objectifs de l’ONU pour le développe-
ment  durable.  À  la  lumière  de  ces  changements,  tous  les  acteurs  sociaux  consultés  (autorités,  zoos, 
fédérations et ONG) soutiennent l’opinion selon laquelle les objectifs de la directive restent pertinents. 
L’évolution des instruments internationaux, d’aspirations générales à des objectifs précis, a induit la 
mise en place d’objectifs plus spécifiques pour la conservation de la biodiversité à laquelle la conser-
vation  ex  situ  peut  contribuer.  Alors  que  ces  objectifs  (et  indicateurs)  plus  spécifiques  soulignent 
l’importance  de  la  mise  en  œuvre  de  la  Directive  Zoos,  ils  mettent  également  en  lumière  le  besoin 
d’expliciter les domaines dans lesquels la conservation ex situ est la plus nécessaire et pourrait avoir le 
plus grand impact pour atteindre les objectifs de conservation fixés au niveau global. 

Depuis 1999, de nombreux développements scientifiques et techniques ont eu lieu dans le domaine de 
la conservation de la biodiversité, en particulier en termes de gestion des populations, d’identification 
des  espèces  menacées,  et  d’identification  des  actions  nécessaires  pour  ces  espèces.    Plus  spécifique-

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ment, des progrès considérables ont été faits depuis l’adoption de la directive quant aux interactions 
entre la conservation in situ et ex situ. De par son champ d’application et sa formulation larges, la di-
rective ne contient pas de conditions obsolètes au vu de ces développements. Les résultats des consul-
tations  des  parties  prenantes  confirment  ce  point.  La  vaste  majorité  (82%)  des  participants  aux  en-
quêtes ciblées considère la directive adaptée aux développement techniques et scientifiques. Ils indi-
quent néanmoins que les interactions entre la conservation ex situ et in situ pourraient être significati-
vement améliorée. 

Cohérence 

Evaluer la cohérence d’un acte législatif européen implique d’examiner le cadre politique et législatif 
général. Il s’agit d’évaluer comment différentes interventions réglementaires interagissent, en fournis-
sant  des  preuves  de  synergies  et  de  complémentarité  qui  pourraient  renforcer  l’atteinte  d’objectifs 
communs,  tout  en  analysant  les  éventuelles  incohérences  et  superpositions  qui  peuvent  nuire  à  son 
efficacité. Les interactions de la directive avec d’autres actes dans les domaines de la conservation de 
la biodiversité et de la santé animale ont été analysées dans ce contexte. L’évaluation de la cohérence 
examine aussi la mesure dans laquelle la directive soutient le marché interne et la création de condi-
tions de concurrences équitables dans l’UE. 

L’objectif premier de la directive est la conservation de la biodiversité à travers la promotion d’un rôle 
renforcé de conservation des zoos. La Directive Zoos appartient donc à un ensemble de lois et poli-
tiques aux niveaux européen et national visant la conservation de la biodiversité. L’analyse juridique 
n’a  révélé  aucune  incohérence  entre  la  directive  et  les  autres  actes  pertinents.  Au  contraire,  des 
exemples d’interactions positives, qui renforcent l’atteinte d’objectifs communs, existent. La conser-
vation de la biodiversité est l’objectif principal non seulement de la Directive Zoos, mais également 
des Directives Nature, du Règlement relatif à la protection des espèces de faune et flore sauvages par 
le contrôle de leur commerce et du Règlement (UE) 1143/2014 relatif aux espèces exotiques envahis-
santes (Règlement EEE). Ensemble, ces instruments œuvrent à un système complet pour la conserva-
tion de la biodiversité dans l’UE, et contribuent à la conformité de l’Union avec ses obligations sous la 
CDB.  En  même  temps,  de  plus  amples  synergies  sont  possibles  pour  renforcer  l’efficacité  du  cadre 
juridique applicable aux zoos et leur contribution à la conservation de la biodiversité, par exemple, via 
des  programmes  de  réintroduction  d’espèces  indigènes  ou  l’organisation  de  procédures  d’inspection 
conjointes. 

Certains  acteurs  sociaux  soulignent  des  incohérences  entre  la  Directive  Zoos  et  le  Règlement  (CE) 
1739/2005 sur le mouvement des animaux de cirque (Règlement Cirque), ainsi qu’avec le Règlement 
EEE. L’analyse juridique n’a toutefois pas identifié d’incohérence. En ce qui concerne le Règlement 
Cirque,  les  deux  actes  n’interagissent  pas :  les  cirques  sont  explicitement  exclus  du  champ 
d’application de la Directive Zoos. Quant au Règlement EEE, même si les zoos doivent bannir la cap-
tivité et l’élevage d’EEE, cela est tout à fait en accord avec les objectifs de conservation de la biodi-
versité des deux actes, eu égard à l’impact particulièrement négatif qu’une EEE pourrait avoir sur la 
biodiversité  locale.  Même  s’il  est  vrai  que  les  zoos  ne  sont  pas  un  vecteur  majeur  d’introduction 
d’EEE, des cas existent, et justifient l’approche stricte prise par le règlement EEE. 

Finalement,  l’information  collectée  indique  que  la  Directive  Zoos  a  contribué  positivement  à 
l’établissement de conditions de concurrence équitable pour les zoos dans l’UE. Avant son adoption, 
certains Etats membres n’avaient pas de législation sur les zoos. Désormais, tous les zoos doivent res-
pecter les conditions minimales imposées par la directive. Des différences majeures subsistent toute-
fois quant aux obligations imposées aux zoos, ainsi que dans l’exécution de la directive dans les Etats 
membres.  Ceci  suggère  que  des  conditions  de  concurrence  réellement  équitable  ne  sont  pas  encore 
atteintes. 

Valeur ajoutée de l’UE 

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Le critère de la valeur ajoutée de l’UE pousse à examiner, d’un point de vue qualitatif, la mesure dans 
laquelle la Directive Zoos a contribué au renforcement du rôle des zoos et à la promotion de l’adoption 
de  mesures de conservation  d’une façon  qui n’aurait pas pu être atteinte par l’action seule des Etats 
membres et/ou d’autres acteurs sociaux. Il comprend également une analyse du besoin de la continuité 
d’une action au niveau de l’UE. 

La Directive Zoos a joué un rôle important dans l’établissement de règles contraignantes pour tous les 
zoos  européens,  et  en  tant  que  telle,  a  poussé  à  l’adoption  de  mesures  de  conservation  à  travers  les 
exigences liées à l’octroi de permis.  En l’absence d’une directive, ce résultat général n’aurait proba-
blement pas été atteint par les législations nationales, par la participation dans des accords internatio-
naux ou par les exigences d’affiliation des fédérations de zoos. Comme indiqué précédemment, avant 
l’adoption de la Directive Zoos, la plupart des Etats membres n’avaient pas de législation sur les acti-
vités des zoos. Quand des dispositions nationales existaient, celles-ci incluaient des exigences pour les 
permis  et  les  inspections,  principalement  en  termes  de  condition  d’hébergement  des  animaux  et  de 
bien-être animal, et non des mesures de conservation. Des normes et lignes directrices furent propo-
sées  par  des  fédérations  de  zoos  (comme  EAZA)  avant  l’adoption  de  la  directive,  celles-ci  avaient 
toutefois  un  impact  limité  de  par  leur  champ  d’application  (17%  des  zoos  agréés  sont  membres 
d’EAZA),  leur  nature  (avant  l’adoption  de  la  directive,  les  normes  EAZA  couvraient  exclusivement 
l’hébergement et le soin des animaux) et leur caractère non contraignant. La Directive Zoos et d’autres 
facteurs (p.ex. le travail des fédérations de zoos, les ambitions individuelles des gérants des zoos, le 
changement  général  d’attitude  à  l’égard  de  la  conservation  et  protection  de  la  biodiversité)  ont  réci-
proquement renforcé le rôle de tous les zoos dans la conservation de la biodiversité. Selon une majori-
té d’autorités compétentes, d’ONG et de zoos, la Directive a déclenché une mise en œuvre plus effi-
cace et plus rapide des mesures de conservation, en particulier parmi les zoos qui ne sont pas membres 
d’une fédération. 

Tous les acteurs sociaux reconnaissent le besoin persistent d’une intervention de l’UE. Comme men-
tionné précédemment, d’importantes différences subsistent entre les Etats membres en termes de mise 
en œuvre de la directive. Celles-ci mènent à des divergences dans les obligations applicables aux zoos 
qui affectent la création de conditions de concurrence équitable entre les exploitants de zoos de diffé-
rents Etats membres et limitent la protection de la biodiversité recherchée par la directive. En paral-
lèle,  tandis  que  des  conventions  internationales  (CDB  et  CITES)  et  des  instruments  non  juridiques 
(normes  et  lignes  directrices  de  fédérations)  promeuvent  le  rôle  des  zoos  dans  la  conservation,  elles 
n’assurent  pas  l’atteinte  complète  des  objectifs  de  la  directive.  Premièrement,  la  Directive  Zoos  est 
indispensable à la mise en œuvre pratique de la CDB et de CITES, en particulier pour remplir les obli-
gations de l’UE en tant que partie à la CDB. Deuxièmement, les normes et lignes directrices définies 
par les fédérations ne peuvent contribuer que de façon limitée à la protection de la biodiversité par les 
zoos européens. Ces instruments ne disposent pas d’une des caractéristiques clefs de la directive : une 
valeur juridiquement contraignante qui permet une application à tous les zoos européens. Par consé-
quent, la directive reste importante pour assurer la mise en œuvre de mesure de conservation par les 
zoos. 

Le besoin continu d’une action de l’UE dans le domaine de la gestion ex situ est considéré important 
par  plus de  80%  des  participants  à  la  consultation  publique.  Tandis  que  les  zoos  et  les  autorités  pu-
bliques considèrent que la plupart des activités actuellement conduites par les zoos continueraient en 
l’absence  d’une  directive,  les  autres  catégories  de  participants,  y  compris  les  individus  et  les  ONG, 
sont moins catégoriques : en moyenne, moins de la moitié considère que toutes les activités continue-
raient sans la directive. Les ONG émettent également des doutes quant au message politique envoyé si 
une législation européenne sur les zoos était abandonnée. Une des inquiétudes les plus prégnantes est 
que l’absence de législation européenne engendrerait un abandon progressif des législations nationales 
et des coupes budgétaires affectant les inspections et autres mesures de contrôle. 

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1 

INTRODUCTION 

1.1  PURPOSE AND SCOPE OF THE STUDY 

The purpose of this study is to support the evaluation of Directive 1999/22/EC of 29 March 1999 relat-
ing to the keeping of wild animals in zoos (‘Zoos Directive’) as part of the Commission's Regulatory 
Fitness Check and Performance (REFIT) programme. As per the Technical Specifications, the study 
aims to ‘assist the European Commission in the evaluation of the Zoos Directive. This entails compil-
ing, assessing and synthesising evidence for the evaluation’.  

With REFIT, the Commission is taking action to make European Union (EU) law ‘fit for purpose’, i.e. 
to simplify and reduce regulatory costs while maintaining benefits. It ensures that EU legislation is of 
the highest quality and delivers its benefits with the least burden, through a system of impact assess-
ments, retrospective evaluations and stakeholder consultations. The ultimate objective of such an exer-
cise is to promote better legislation which is more responsive to existing and future challenges, as well 
as to improve its implementation.  

As a rule, evaluation is defined as an evidence-based judgement of the extent to which an intervention 
has been: 

 

 

 

 

effective and efficient, 
relevant given the needs and its objectives, 
coherent both internally and with other EU policy interventions and 
and has achieved EU added value. 

Accordingly, the present supporting study assesses the effectiveness, efficiency, coherence, relevance 
and added value of the Zoos Directive.  

It provides evidence-based critical analysis of the Directive’s performance, particularly in relation to 
the implementation of Article 3 on conservation measures. It maps the differences in the level of im-
plementation  across  Member  States,  and  identifies  good  practices  and  issues  at  national  level.  The 
study also measures – to the extent possible – the magnitude of costs, in particular in terms of adminis-
trative burden, and the benefits of having a EU Directive on zoos.  

The assessment worked in collaboration with zoos that are registered or officially recognised as zoos 
according to the definition of the Competent Authorities (CAs). As agreed with the Commission, the 
analysis of implementation at national level focused on 14 selected Member States (Belgium, Bulgar-
ia,  Cyprus,  Czech  Republic,  Denmark,  France,  Germany,  Italy,  Ireland,  Lithuania,  the  Netherlands, 
Poland, Portugal and Spain)3.  

1.2  CONTENT OF THIS REPORT 

This draft final report is structured as follows:  

 

 

 

 

Section 1 is an introduction to the main purpose and context of the report. 
Section  2  provides  the  background  to  the  Directive,  with  information  on  the  baseline  of  the 
Directive (i.e. the context of its adoption), and its functioning. 
Section 3 gives an overview of the methodology used for the analysis, including the evaluation 
logic  and  framework,  data  collection  tools  and  analytical  methods.  This  section  also  provides  a 
summary of the challenges encountered in the implementation of the project,  and the mitigation 
measures applied.  
Section 4 presents the current state of play of implementation, at both national and EU level.  

3 See Section 3.3.2.1 for information on the selection process. 

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 

 

Section  5  details  the  results  of  the  analysis  by  evaluation  criterion  and  evaluation  question.  It 
compiles, assesses and synthesises the evidence gathered for the study. 
Section  6  provides  a  set  of  overall  conclusions  on  the  effectiveness,  efficiency,  relevance, 
coherence  and  EU  added  value  of  the  Directive  by  identifying  weaknesses  and  strengths  in 
relation to each of these criteria.  

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2  BACKGROUND TO THE DIRECTIVE 

2.1  BASELINE: THE CONTEXT OF THE ZOOS DIRECTIVE 

The EU Zoos Directive came into force on 29 March 1999. Set against a background of EU Directives 
concerned with nature conservation and the 1992 global Convention on Biological Diversity (CBD), it 
was intended to encourage zoos to provide stronger support for biodiversity conservation. Zoos are not 
a homogeneous set of establishments, all with the same purpose; they may seek to attract visitors, to 
provide entertainment, to serve conservation interests, or some combination of these. In other words, 
not all zoos have the same priorities. 

Understanding the impact of the Directive in the 17 years since it came into force requires considera-
tion of the context within which it was adopted. This section establishes that context by:   

  Briefly outlining the history of zoos;  
 

Presenting the adoption process of the Zoos Directive. 

The elements presented below in particular provide some key points of information to help measuring 
the progress made since the adoption of the Directive: 

  The 20th century saw an important evolution in the perception of the role of zoos. The Directive 
was adopted in a context where more progressive zoos aimed at pursuing conservation, research 
and education.  

  At international level, this evolution was reflected in the adoption in 1993 of the World Strategy 

for Conservation in Zoos and Aquaria. 

  At European level, the European Survey of Zoological Collections carried out by Zoo Check in 
1988  remains  the  primary  source  of  information  on  the  state  and  status  of  zoos  across  the  EU 
prior to the adoption of the Directive. The Survey found that there was no widely used definition 
of zoo and that the information on the number of zoos was limited (1012 were inventoried during 
the  Survey).  It  also  found  that  a  few  zoos  broadly  met  ‘the  standards  required  by  international 
guidelines  of  modern  zoo  practice  in  the  areas  of  animal  husbandry,  species  conservation  and 
public education’, but that a considerable number did not meet any acceptable standards.  

  At  national  level,  prior  to  the  adoption  of  the  Directive,  five  out  of  the  then  12  Member  States 
(Belgium,  Denamrk,  France,  Spain  and  the  United  Kingdom)  had  adopted  legislation  on  zoos. 
The  other  seven  countries  had  no  legislation  specifically  targeting  zoos,  although  a  general 
regulatory framework on animal welfare or imports of animals could regulate their activities. 

2.1.1  Brief history of zoos 

In their history of zoos, Tribe and Booth (2003) consider zoos to be the oldest form of wildlife tour-
ism. Ancient Egyptian, Greek, Roman and Chinese societies are known to have kept animals for en-
joyment or as a form of status symbol. What sets zoos apart from such personal collections is that they 
are open to the public for at least part of the year to display some of the individuals in their collections. 
The  first  ‘modern  zoos’  are  considered  to  have  started  some  200  years  ago  when  they  were  first 
opened to the public (IUCN/CBSG 1993). 

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Figure 1: Brief history of the evolution of the zoo 

• First ‘modern zoos’. In addition to public exhibition, they supported scientific research and education 
[bearing in mind what research and education was at that time – naming species and displaying weird 
and wonderful animals]. 

Late 18th and  
early 19th 
centuries 

• Recognition that the perception of zoos was increasingly bad. They were considered not to have 
changed with the times, to be poorly managed and as a result did not reflect what the public wanted to, 
or where prepared to see. 

1960s 

• Recognition that many people who visited zoos were concerned about conservation and animal welfare. 
It was understood that the survival of zoos depended on addressing these concerns.  

• Shift towards pursuing conservation, research, education and recreation 

Mid-late 1900s 

Late 1900s 

Source: Adapted from Tribe and Booth 2003 
The  closing  decades  of  the  20th  century  saw  the  development  of  a  philosophy  that  shaped  the  more 
progressive zoos4, namely  the pursuit of  conservation, research  and  education.  This was  reflected  in 
the fact that ex situ breeding programmes began around 1995. Clearly, however, zoos must still raise 
sufficient  finance  to  be  viable,  and  must  remain  attractive  to  visitors  who  would  pay  entrance  fees. 
Recreation was therefore acknowledged as the fourth aim of enlightened zoos. The Wildfowl and Wet-
lands  Trust,  for  example,  added  recreation  to  its  aims  in  1982,  alongside  the  conservation,  research 
and education aims defined by Sir Peter Scott when the trust was established as the Severn Wildfowl 
Trust in 1946 (Kear 1990).  

Figure 2: Evolution of the zoo concept 

Source: IUDZG/CBSG (IUCN/SSC) 1993, © Chicago Zoological Society 

At the same time, attitudes towards the exhibition of animals have also changed and these have led to 
what  have  been  called  first,  second  and  third  generation  exhibits  (Moss,  Esson  and  Francis  2010), 

4 See also the concept of EU ‘progressive zoos’ used in the EU and Europe’s Zoos (John Reagan Associates Ltd 2007). 

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defined as follows: 
  First  generation  exhibits,  in  which  animals  usually  kept  singly:  bare,  featureless  and  either 

 

barred completely or using deep pits for animal containment. 
Second  generation  exhibits  may  still  be  fairly  austere,  with  modest  attempts  to  include  ‘cage’ 
furniture.  They  are  typically  constructed  of  inorganic  materials  such  as  concrete  and  are  often 
surrounded  by  a  water-filled  moat.  They  are  designed,  at  least  in  part,  with  the  welfare  of  the 
animal in mind.  

  Third generation exhibits, in which animals are kept in species-appropriate group numbers and 
in areas planted and themed to resemble their native ecosystem. The barriers between visitors and 
animals are normally concealed. Often, the term ‘immersive’ or ‘immersion’ is used to describe 
such third generation exhibits. 

2.1.2 

 Context of adoption of the Zoos Directive 

2.1.2.1 

International context  

The changes in attitudes towards conservation and the protection of biodiversity gave rise to the 1992 
Earth Summit. In 1993, the International Union of Directors of Zoological Gardens (now  the World 
Association of Zoos and Aquariums, WAZA), together with the International Union for the Conserva-
tion  of  Nature  (IUCN),  including  its  Conservation  Breeding  Specialist  Group  (CBSG),  and  WWF 
published  its  ‘World  Strategy  for  Conservation  in  Zoos  and  Aquaria’  (WSCZA)  which  outlined 
the common  conservation objectives and practices that zoos should follow. It noted the evolution of 
zoos from their role as living museums to one of modern conservation centres, where education, re-
search,  and  captive  breeding  and  reintroduction  programmes  are  undertaken,  over  and  above  purely 
recreational activities. 

2.1.2.2  European context  

One  of  the  other  key  drivers  behind  the  adoption  of  the  Zoos  Directive  was  the  then  progressive 
legislative framework applicable in the UK. The UK Zoo Licensing Act of 1981 laid down minimum 
requirements  for  zoos,  including  licensing  requirements.  It  stimulated  the  interest  of  a  non-profit 
organisation, UK  Charity Zoo  Check  (which later became  the Born  Free Foundation), to  investigate 
the  protection  of  wild  animals  in  European  zoos  compared  to  the  protection  guaranteed  under  the 
British  legislation5.  The  European  Commission  co-funded  the  European  Survey  of  Zoological 
Collections (‘Survey of Zoological Collections’) (Travers and Straton 1988) carried out by Zoo Check 
five years prior to the 1992 Earth Summit. This work took place during a 12-month period, with the 
final  report  submitted  to  the  Commission  in  August  1988.  This  remains  the  primary  source  of 
information on the state and status of zoos across the EU (which then comprised 12 Member States6), 
prior to the adoption of the Directive. The science of conservation biology was very new at that time, 
having only emerged in the mid-1980s (see Section 5.3.3.1), and there were as yet very few scientific 
papers  that  considered  the  conservation  performance  and  potential  of  zoos.  The  same  applies  to 
analyses of other issues related to zoos, such as education, awareness-raising and  animal husbandry. 
No information was provided on these issues in a systematic manner across Europe.  

In the absence of a systematic understanding of zoos in the EU, the Survey of Zoological Collections 
sought to: a) provide a definition of zoos; b) assess how many existed; and c) comment on the legisla-
tion in force in Member States. There was no widely used definition of a zoo and the Survey listed the 
variety of different collections of animals that were open to the public. These included zoological gar-
dens or parks, menageries, wildlife parks, and safari parks, as well as more specialised exhibits such as 
monkey  sanctuaries,  deer  parks,  sealaria,  aviaries,  bird  gardens,  hawk  conservancies,  wildfowl  re-
serves, vivaria, crocodile farms, aquariums and butterfly houses. The report provides a description of 
each of these and other ‘types’ of collections.  

5 Interview with NGO.  
6 Belgium, Denmark, France, Germany, Greece, Ireland, Italy, Luxembourg, the Netherlands, Portugal, Spain and the UK.  

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There was similarly limited information on the number of zoos in existence. The Survey of Zoologi-
cal Collections reported that the 1987 issue of the International Zoo Yearbook, published by the Zoo-
logical Society of London, listed 218 zoos, whereas they themselves identified 1,012, including some 
that had closed during their survey. The report then went on to make brief comments on conditions in 
the  zoos  that  they  visited,  highlighting  enclosure  size,  design,  furnishings  and  facilities,  social  re-
quirements and environmental suitability7. Overall, the Survey of Zoological Collections found that a 
few zoos broadly met ‘the standards required by international guidelines of modern zoo practice in the 
areas of animal husbandry, species conservation and public education’, but that a considerable number 
did not meet any acceptable standards (Travers and Straton 1988).  

The Survey of Zoological Collections report compiled information on zoos in 12 European countries 
for the first time and provided an assessment of husbandry standards8. There was little significant con-
sideration of the conservation activities or potential of zoos. The receipt of this report by the Com-
mission stimulated the drafting of a Directive concerned with minimum standards of animal husbandry 
in zoos (Johnson 2015).  

Over time, the Commission welcomed the  support of EAZA in developing both the husbandry and 
the conservation elements of the Directive. A key driver for the mainstream zoological establishments 
was the diversity of establishments that kept animals and exhibited them to the public, including those 
for whom such activities were incidental to their main business (e.g. restaurants and petrol stations). 
EAZA was understandably keen to end poor practices and improve the standards of weaker zoos9.  

2.1.2.3  The Directive 

In July 1991, the European Commission adopted a draft Directive laying down minimum standards for 
the keeping of animals in zoos. The stated objective of this proposal was to ensure that minimum har-
monised standards for the keeping of wild animals would be observed by all zoos in the Community. 
Such harmonisation was deemed necessary to facilitate the application of Community nature conserva-
tion laws and to protect the public. 

This proposal recognised a threefold role for zoos in society: 

  Contributing to efforts to conserve threatened or endangered species. 
  Carrying out scientific research on species that are difficult to observe and study in their natural 

habitat. 

  Educating the public on the environment and ecology. 

After some debate on the nature of Community intervention in that area, in particular the added value 
and efficiency of a Directive (European Council 1992), the European Parliament examined the situa-
tion of zoos and their regulation across the European Community (European Parliament 1993). At the 
time, five out of the 12 Member States had relevant legislation on the subject (see Table 1 below).  

Table 1: Legislation prior to the adoption of the Directive 

Country 

1993 Legislation 

Main provisions 

Belgium 

Law  of  14  August  1986 
on  the  protection  and 
well-being of animals  

Belgian  legislation  requires  licences  for  zoos,  animal  parks 
and  private  collections.  It  outlines  conditions  for  the 
accommodation of wild animals.  

Denmark 

Act  on  Animal  Welfare 
(1967); 

Danish legislation requires zoos to hold authorisations issued 
information 
by  the  police  authority  on  the  basis  of 

7 The report gives different figures of the number of zoos visited (232 stated in the Foreword, 217 given in the Section 1 summary). 
8 Interview with expert.  
9 Interview with expert.  

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(submitted  by  the  applicant)  on  the  conditions  of  animal 
accommodation and inspections. 

Zoos are regulated under the general legislation on nature 
protection,  complemented  by  10  regulations  concerning 
the  conditions  for  keeping  wild  animals,  the  licensing 
system and inspection of zoos. 

Zoological  collections  must  be  authorised  and  registered 
by the Provinces 

Act on State subsidies to 
zoological 
gardens 
(1977,  amended in 1980, 
1983, 1985) 

France 

Law  of  10  July  1976  on 
the protection of nature 

Spain 

on 

Decree  1119/1975  of  24 
the 
April 
1975 
authorisation 
and 
registration  of  zoological 
centres,  establishments 
to  practice  horse-riding, 
centres 
the 
enhancement  and  care 
of  companion  animals 
and other similar centres 

for 

UK  

Zoo Licensing Act (1981) 

British  legislation  established  a  comprehensive  licensing 
and inspection system for zoos. The government produced 
a  list  of  authorised  inspectors  and  detailed  guidelines  for 
the accommodation and care of animals in zoos. 

Source: (European Parliament 1993) 

The other seven countries had no legislation specifically targeting zoos, although a general regulatory 
framework on animal welfare or imports of animals could regulate their activities. The 1993 European 
Parliament report stated that the frameworks summarised in Table 2 below were in place in those sev-
en countries. 

Table 2: General regulatory framework prior to the adoption of the Directive 

Country 
Germany 

Greece 

1993 National regulatory frameworks 
Legislation  on  animal  welfare,  conservation  of  nature,  protection  of  species  and 
veterinary imports, as well as CITES.  
Guidelines for granting subsidies to zoos. 
Animal welfare and import laws. 
Zoos are generally under the control of the local mayor and nearly all are financed 
by the municipality. 
Animal welfare and import licensing.  
None. 
None (No zoos). 
General legislation on animal welfare, veterinary inspection and imports. 
Animal welfare and imports laws. 

Ireland 
Italy 
Luxembourg 
Netherlands 
Portugal 
Source: (European Parliament 1993) 

The  1991  Proposal  was  withdrawn  and  replaced  in  1995  by  a  draft  Recommendation  (European 
Commission 1995) which included detailed guidelines for the accommodation and care of animals in 
zoos. 

The  Commission’s  Economic  and  Social  Committee’s  opinion  of  July  1996 on  the  Proposal  recom-
mended adopting a Directive instead of a Recommendation, stating that action would only be effective 
if legislation was adopted at Community level. Finally, the current Zoos Directive was adopted after a 
long process on 29 March 1999. 

2.2  FUNCTIONING OF THE ZOOS DIRECTIVE 

The review, assessment and evaluation of the Zoos Directive should correspond directly to the objec-
tives,  inputs  and  outputs  required  to  implement  the  legislation.  This  ‘intervention  logic’  guided  the 

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evaluation methodology and process and is illustrated in the following figure (Figure 3). 

The Directive’s overall aim is to fulfil the obligations deriving from the 1992 CBD to adopt measures 
for ex situ conservation. The Directive thus seeks ‘to protect wild fauna and to conserve biodiversity 
by providing for the adoption of measures by Member States for the licensing and inspection of zoos’ 
in the EU.  

Activities and inputs designed to achieve the objectives focus on the role of Member States’ authori-
ties, which are responsible for implementing the Directive at national level through the setting up of 
systems for inspection and licensing of zoos.  

Outputs are the measures and services that immediately result from the activities undertaken (i.e. the 
measures adopted for licensing and inspections of zoos, and closure and penalties for breaches of the 
legislation). These outputs should achieve certain results (increased participation of zoos in measures 
to conserve biodiversity), and contribute to longer-term impacts at the EU level, towards the ultimate 
goal of protecting wild fauna and preserving biodiversity.  

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Figure 3: Intervention logic of the Zoos Directive  

Needs 

 Many species kept in EU zoos are threatened by extinction, contributing to global biodiversity 




loss 
The CBD requires that Parties adopt measures for ex situ conservation 
Knowledge and public awareness of conservation of biodiversity are insufficient in view of 
Aichi Target 1 

Objectives 

General objectives 
Protect wild fauna and conserve biodiversity by strengthening the role of zoos in the conservation of 
biodiversity 

Specific objectives 

A. Ensure that zoos participate in research, and/or training and/or exchange of information on 

species conservation and/or in captive breeding, repopulation or reintroduction of species into 
the wild 

B. Ensure that zoos promote public education and awareness of conservation of biodiversity, in 
particular by providing information about the species exhibited in zoos and their natural habi-
tats 

C. Ensure that zoos accommodate their animals under conditions which satisfy their species' 

biological and conservation requirements and maintain high standards of animal husbandry 

D. Ensure that zoos prevent escape of animals and intrusion of outside pests and vermin 
E. Ensure that zoos keep up-to-date records of their collections 
F.

If a zoo or part thereof is closed, ensure that the animals are treated or disposed of under ap-
propriate conditions 

Inputs 

Financial, human and institutional resources allocated by the EU and Member States 

Activities 

Outputs 

1. Designate competent authorities 
2. Grant licences to existing zoos by 9 April 2003 and to new zoos before they are open to the 

public, with conditions ensuring that they meet the requirements of specific objectives A to E 
3. Carry out inspections before granting, refusing, extending or significantly amending licences; 

4.

5.

ensure compliance with licence conditions through regular inspections 
If a zoo is not licensed or does not meet the licensing conditions, close the zoo (or part thereof) 
to the public or impose requirements to ensure that the licensing conditions are met; if those 
requirements are not met within two years, withdraw/modify the licence and close the zoo or 
part thereof 
Take measures with a view to ensuring that if a zoo or part thereof is closed, the animals are 
treated or disposed of under appropriate conditions  

6. Determine effective, proportionate and dissuasive penalties applicable to breaches of national 

provisions 

1. Competent authorities designated 
2.
3.

Licensing system established and licences granted to new and existing zoos 
Inspections carried out before granting, refusing, extending or significantly amending licences; 
regular inspections carried out to ensure compliance with licensing conditions 

4. Closure of zoos that are not licensed or do not meet licensing conditions or requirements with-

in two years 

5. Measures taken to ensure that if a zoo or part thereof is closed, the animals are treated or dis-

6.

posed of under appropriate conditions 
Effective, proportionate and dissuasive penalties determined and applied to breaches of na-
tional provisions 

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Results 

A. Zoos take part in research and/or training and/or exchange of information and/or captive breed-

ing, repopulation, reintroduction of species into the wild 

B. Zoos promote public awareness of biodiversity conservation, in particular by providing infor-

mation about the species of wild fauna exhibited and their natural habitats 

C. Zoos accommodate their animals under conditions which satisfy their species' biological and 

conservation requirements and maintain high standards of animal husbandry  

D. Zoos prevent escape of animals and intrusion of outside pests and vermin 
E. Zoos keep up-to-date records of their collections  
F.

If a zoo or part thereof is closed, the animals are treated or disposed of under appropriate con-
ditions to breaches of national provisions 

Impacts 





Zoos play an increased role in biodiversity conservation 
Knowledge and public awareness of conservation of biodiversity are improved 
Species of wild fauna are protected and biodiversity loss is averted 

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3  METHODOLOGY 

This section sets out the overarching framework that guided the design and practical implementation 
of the study. It provides the evaluation questions (EQ) and the evaluation logic model (Section 3.1), 
and presents the  evaluation  framework (Section  3.2) that guided the data  collection, including the 
consultation strategy (Section 3.3). It also provides an explanation of the data analysis methods used 
(Section 3.4), as well as a summary of the challenges experienced in carrying out the study and the 
mitigation measures used or proposed to overcome these difficulties (Section 3.5). 

3.1  EVALUATION QUESTIONS AND CRITERIA 

This section categorises the evaluation questions  according to the five evaluation criteria,  to demon-
strate the rationale behind the questions. It also indicates the main issues to be addressed under each 
criterion. Table 3 below provides an overview of the criteria and corresponding questions.  

Table 3 Overview of evaluation criteria and questions 

Effectiveness  
EQ 1 

EQ 2 

EQ 3 

EQ 4 

Efficiency 
EQ 5 

EQ 6 

EQ 7 

EQ 8 

Relevance 
EQ 9 

EQ 10 

EQ 11 
Coherence 
EQ 12 

EQ 13 

What progress has been made over time towards achieving the objectives set out in the 
Directive?  To  what  extent  is  this  progress  in  line  with  initial  expectations?    In  particular, 
what progress has been made to achieve the conservation measures set out in Article 
3? To what extent have adequate licensing and inspection systems been put in place? 
What  is  the  contribution  of the  Directive  towards  ensuring  the  protection  of  wild  fauna 
and the conservation of biodiversity in the EU and globally (including its contribution to 
implementing the EU Biodiversity Strategy and EU commitments under international con-
ventions such as the Convention on Biological Diversity)? 
Which  main  factors  (e.g.  implementation  by  Member  States,  action  by  stakeholders) 
have contributed to, or stood in the way of, achieving these objectives? 
Beyond these objectives, what, if any, other significant changes both positive and neg-
ative can be linked to the Directive? 

What  are  the  costs  and  benefits  (monetary  and  non-monetary)  associated  with  the 
implementation of the Directive for the different stakeholders, at local, national and EU 
level?  Where  possible,  an  estimate  of  costs  broken  down  by  size  of  enterprises  (mi-
cro/small/medium-sized enterprises) should be provided 
To what extent are the costs associated with the Directive proportionate to the benefits 
that it has brought? 
What  factors  influenced  the  efficiency  with  which  the  achievements  observed  were 
obtained? In particular, what, if any, good or bad practices can be identified? If there 
are significant cost/benefit differences between Member States, what is causing them? 
Taking account of the objectives and benefits of the Directive,  what evidence is there 
that it has caused unnecessary regulatory burden  or complexity? What factors  identify 
this burden or complexity as unnecessary or excessive? 

How  well  do  the  (original)  objectives  (still)  correspond  to  the  needs  within  the  EU  and 
globally? 
How relevant is the Directive to achieving legal and policy biodiversity objectives at EU 
and global levels? 
How well adapted is the Directive to (subsequent) technical and scientific progress? 

To  what  extent  does  the  Zoos  Directive  complement  or  interact  with  other  EU  sectoral 
policies affecting biodiversity conservation and relevant animal welfare issues at Mem-
ber  State  and  EU  levels,  in  particular  as  regards  wild  animals  kept  in  captivity  for  com-
mercial reasons (notably circuses) and how do these policies affect – positively or nega-
tively – the implementation of the Zoos Directive?   
To what extent does the Directive support the EU internal market and the creation of a 
level playing field for economic operators, especially SMEs? 

EU Added Value 
EQ 14 

What has been the EU added value of the Zoos Directive compared to what could be 

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EQ 15 

EQ 16 

achieved by Member States at national and/or regional levels? 
To what extent do the issues addressed by the Directive continue to require action at EU 
level? 
What would be the consequences of not having the Directive? 

3.1.1  Effectiveness 

Effectiveness is intended as the assessment of the extent to which a certain legal provision, act or set 
of acts has achieved the objectives it was intended to achieve.  

This  question  represents  a  crucial  component  of  the  supporting  study.  The  answer  to  this  question 
builds  on  the  assessment  of  the  implementation  of  the  Zoos  Directive  (i.e.  the  state  of  play),  and  it 
focuses on: the progress made towards the general and operational objectives set out in the Directive; 
possible  additional/unforeseen  effects;  and  the  contribution  to  efforts  towards  biodiversity  conserva-
tion.  

The analysis is guided by the intervention logic presented above, and the evaluation framework pre-
sented in the next section. It investigates the actions taken by the Member States to ensure implemen-
tation of the different conservation measures foreseen by the Directive across European zoos, the ex-
tent of the progress achieved and the factors that have influenced the results. 

3.1.2  Efficiency 

The analysis of efficiency examines the range of regulatory costs implied by the implementation of the 
Directive across the 14 selected EU Member States, and assesses whether these are proportionate to 
the  benefits  delivered.  It  requires  a  structured  and  comprehensive  assessment  of  the  range  of  costs 
incurred in implementing the Directive, as well as the benefits achieved.  

The analysis also aims to  identify  the main elements behind  the  stated  costs and benefits, and  those 
which affect the efficiency of the implementation, looking at both the systems set up in Member States 
and the contextual factors.  

Compliance costs are mainly borne by zoos (the target group for the Zoos Directive), and consist of: 

  One-off compliance costs (non-business-as-usual (BAU) costs, except charges and administrative 
costs  arising  from  information/reporting  obligations)  related  to  Article  3  measures  (such  as 
investments) and/or recurring costs related to the implementation of conservation measures. 
  Administrative burdens (administrative costs to meet information obligations caused solely by the 
legislation, excluding BAU administrative costs) arising from licensing and inspection procedures 
(i.e. labour costs for completing the licence application, preparing for the inspection necessary for 
granting  of 
to  authorities,  completing  pre-inspection 
questionnaires, etc.). 

licence,  sending  documents 

the 

  Other costs and charges, i.e. licence fees.  

Member State authorities incur administrative burdens that include but are not restricted to the fol-
lowing: labour costs for processing treating licence applications; monitoring of compliance, exchange 
of information. Member States’ enforcement costs relate to compliance monitoring, e.g., preparing for 
inspection prior to granting of the licence, evaluating pre-inspection questionnaires, onsite inspections, 
compiling inspection reports, and cost of training inspectorate staff.  

In parallel, the main expected benefits correspond to the intended and unintended positive impacts of 
the Directive.     

3.1.3  Relevance 

The analysis of relevance takes into account current EU needs and the legal and policy objectives in 
biodiversity,  at  both  EU  and  global  level,  and  sets  these  against  the  original  objectives  of  the  Zoos 

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Directive.  
As  a  first  step,  the  objectives  pursued  by  the  Directive  are  framed  in  the  context  of  current  and 
emerging issues, in order to assess the role played by the Directive in the area of conservation of bio-
diversity. To this end, the developments that shape the biodiversity agenda at the EU and global level 
(such as the Aichi Biodiversity Targets – part of the CBD, the United Nations (UN) Sustainable De-
velopment Goals (SDGs), the objectives of the IUCN, etc.) are considered, together with the relevance 
of EU legislation against international conventions and the roles played by other bodies.  

The  analysis  addresses  the  technical  and  scientific  progress  achieved  during  the  implementation 
period of the Directive, in order to assess the extent to which the conservation actions and the licens-
ing and inspection systems set up by the Member States have kept pace with the latest developments.  

3.1.4  Coherence 

This evaluation question looks at the Directive in the context of the EU policy and legal framework 
in  relation  to  biodiversity  conservation  and  animal  welfare.  Indeed,  the  Zoos  Directive  fits  within  a 
wide net of laws and policies at EU and national level aimed at the conservation of biodiversity and 
animal welfare. In addition to the EU Biodiversity Strategy, the following EU legal instruments are in 
particular relevant: 

  Directive  2009/147/EC  on  the  conservation  of  wild  birds  (Birds  Directive)  and  Directive 
92/43/EEC  on  the  conservation  of  natural  habitats  and  of  wild  fauna  and  flora  (Habitats 
Directive) (together, the Nature Directives). 

  Regulation  (EC)  No  338/07  on  the  protection  of  species  of  wild  fauna  and  flora  by  regulating 

trade therein (EU Wildlife Regulation). 

  Regulation (EU) 1143/2014 on invasive alien species. 
  Directive  92/65/EEC  laying  down  animal  health  requirements  for  trade  in  and  imports  into  the 

EU of animals, semen, ova and embryos not subject to other specific rules. 

  Regulation (EC) 1739/2005 laying down animal health requirements for the movement of circus 

animals between Member States. 

Other EU actions The analysis also addresses the contribution of the Directive to the creation of a lev-
el playing field among economic operators.  

Overall, the objectives of the analysis of coherence are to: 

  Assess the extent to which the Zoos Directive complements or interacts with other EU and inter-

national policies and legislation affecting biodiversity conservation;  
Identify possible overlaps, or conflicting objectives and requirements; 

 
  Assess achievements in terms of harmonisation among Member States, and their contribution to 
the creation of comparable conditions for economic operators across the EU (with specific refer-
ence to SMEs).  

3.1.5  EU Added Value 

The assessment of EU added value brings together the findings reached under several of the evaluation 
questions.  It  draws  conclusions  about  how  effectively  and  efficiently  the  Directive  has  achieved  its 
stated  objectives  and  contributed  to  the overarching  EU  objectives  of  biodiversity  conservation,  and 
whether or not the action promoted remains relevant in the light of developments during the interven-
ing period. The analysis consolidates this evidence and goes a step further, analysing the added value 
resulting from the Directive compared to what could be achieved by Member States at national and/or 
regional levels, and the extent to which the Directive has contributed to the uniform implementation of 
biodiversity conservation measures across the EU. 

The analysis of EU added value is chiefly a qualitative assessment, built on the following elements: 

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  The results achieved and the extent to which these can be attributed to the Zoos Directive or to 
other factors, including the action of stakeholders active in the field of ex situ conservation.  
  The  review  of  the  range  of  relevant  legislation  (at  EU  and  national  level),  strategies, 
international  conventions  and  other  instruments  that  promote  ex  situ  conservation  measures 
(e.g.  including  recommendations,  guidelines,  membership  conditions  set  by  zoos’  federations, 
World  Zoo  Conservation  Strategy,  National  Species  Action  Plans  including  ex  situ  measures, 
WAZA global species management plans, IUCN technical guidelines for the management of  ex 
situ populations for conservation, requiring members to take action for the conservation of wild 
fauna, etc.). The investigation of these factors will also provide indications of scenarios in which 
the Zoos Directive did not exist, i.e. whether action at EU level would be maintained with other 
instruments,  existing  (EU  biodiversity  strategy)  or  new  (recommendation,  guidelines),  and 
whether regulation of the issue would depend on the initiatives taken at national level. 

  The  assessment  of  the  degree  of  harmonisation  between  Member  States  brought  by  the 
Directive, the extent to which the issues addressed have an EU dimension, and whether or not the 
continuation of EU intervention is justified. 

3.2  EVALUATION FRAMEWORK AND ITS LINKS TO THE INTERVENTION LOGIC 

Each of the evaluation criteria summarised above is analysed in relation to specific elements of inter-
vention presented in the intervention logic. These interactions are summarised in Figure 4 below.  

Figure 4: Evaluation logic of the Zoos Directive. 

Source: Present study 

On  the  basis  of  the  evaluation  logic  and  the  evaluation  questions  agreed,  the  study  team  drafted  an 
evaluation framework that links together: 

  The evaluation questions; 
  The evaluation sub-questions; 
 

 

Indicators; 
Success criteria;  
Sources of information used; 
 
  Comments from the study team; 
  Links with data gathered under the consultation process (see Section 3.3).  

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This evaluation framework (or ‘correspondence matrix’) is presented in Annex I.  

This matrix was critical in guiding the data collection and the subsequent use of data for the analysis. 
It ensured that all aspects of the evaluation questions were answered systematically and in a traceable 
manner,  on  the  basis  of  relevant  indicators  and  success  criteria,  and  supported  by  all  available  evi-
dence identified during the study. It was drafted in close cooperation with the European Commission 
from  the  inception  phase  of  the  study,  with  regular  revisions  to  ensure  appropriate  links  to  the  new 
sources of information identified.  

3.3  DATA COLLECTION 

3.3.1  Literature review and country fiches 

Literature review 

Desk research was carried out from the beginning of the project, with a range of documents and re-
ported reviewed in order to:  

  Develop a clear overview of the state-of-play and determine  where research and expert opinion 

stand in respect of each of the issues under investigation.  

  Collect  information  to  support  the  development  of  reporting  and  data  collection  templates  and 

guidance documents.  
Identify further relevant documents for the Member State level desk research. 

 
  Collect information to add to the reference database of the project. 
  Gather evidence to support the overall analysis.  

Many  different  information  sources  were  used  for  the  general  literature  review,  i.e.  Google,  Google 
Scholar, PubMed, Open Grey, websites of identified stakeholder groups, etc. Priority was given to the 
most recent publications and reports, with older information included when relevant.  

The  following  categories  of  information  were  identified  and  analysed:  scientific  literature,  legally 
binding documents, media sources, and studies and reports from stakeholders and authorities active at 
EU, national and international levels. 

All sources identified were added to and described in the reference database, which was configured as 
an online tool, in order to allow clear and simultaneous listing of the sources reviewed by the different 
members of the study team (see Annex IVa).  

Country fiches 

As part of the literature review, national experts compiled background information on the transposition 
of the Directive in the 14 selected Member States, the number of licensed zoos, the CAs, and active 
national stakeholders, as well as key issues faced in the implementation (including infringement pro-
cedures at national and EU level). This initial desk research led to the drafting of the country fiches, 
which were then updated to incorporate information from the questionnaires and interviews (See An-
nex II for these country fiches). To support the next stage of the study, this initial desk research was 
used to: 

  Gather national literature. 
 
  Gain  a  preliminary  understanding  of  the  transposition  and  implementation  of  the  Directive  at 

Identify relevant stakeholders. 

national level. 

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3.3.2  Consultation strategy 

The consultation strategy was discussed during a Steering Group Meeting on 5 July 2016.  
The following sub-sections outline the key elements of the consultation strategy, presenting the objec-
tives  and  scope  of  the  consultation,  the  stakeholder  groups  identified,  and  the  consultation  methods 
and tools used for the study. Figure 5 below presents the overall timeframe for the different consulta-
tion processes. There were three forms of consultation: 

  Targeted surveys for CAs, zoos’ federations, Non-Governmental Organisations (NGOs) and zoo 

operators from the 14 selected Member States (17 August – 28 November 2016). 

  Open public consultation (15 September – 8 December 2016). 
 

In-depth interviews with  CAs, zoos’ federations, NGOs and zoo operators from the 14 selected 
Member States (18 October – 12 December 2016).  

Each of these consultation processes are further developed in the following sub-sections. 

Figure 5: Timeframe for the consultation processes 

Source: Present study 

3.3.2.1  Objectives and scope of the consultation 

The consultation strategy played a key role in this supporting study, representing an important instru-
ment in ensuring robustness of the analyses, transparency and legitimacy of the process.  

The objective of the consultation was twofold: 

  Gather  information  and  data  that  cannot  be  found  through  desk  research  and  additional 
sources,  thus  triangulating  the  data  and  providing  solid  and  evidence-based  answers  to  the 
evaluation questions. This data-gathering exercise focused on the 14 selected Member States and 
extended to EU and international stakeholders in order to gain an EU wide perspective and build 
a complete picture. 
Inform  and  enable  feedback,  allowing  a  broader  range  of  stakeholders  to  provide  views, 
feedback  and  perceptions  of  the  concrete  implementation  and  performance  of  the  Directive  in 
achieving  its  goals  and  contributing  to  biodiversity  conservation,  the  issues  at  stake  and  the 
elements  to  be  improved.  The  consultation  strategy  ensured  that  the  findings  and  conclusions 
were shared with and validated by stakeholders.  

 

The consultation covered the five evaluation criteria, translating the broad evaluation questions into 
specific (more detailed and targeted) consultation questions. Correspondence between the main evalu-
ation questions outlined in Table 1, their sub-questions, and the consultation questions is detailed in 
the evaluation framework in Annex I. This allowed for information, data and views to be collected in a 
way that clearly linked to the five analysis criteria.  

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At  geographical  level,  the  consultation  focused  on  the  14  Member  States  selected  as  representative 
case  studies.  This  sample  covered  half  of  the  EU  Member  States,  and  was  defined  with  the  aim  of 
satisfying the following criteria: 

  A  mix  of  both  smaller  and  larger  (or  densely  populated)  Member  States,  with  a  significant 

number of zoos.   

  Geographical  coverage  of  the  EU  (balancing  North/South,  West/East)  and  of  different 

administrative models (e.g. federal and centralised states, etc.).  

  A  combination  of  older  and  newer  EU  Member  States10,  in  order  to  assess  different 

implementation periods.  

  General  availability  of  information  and  different  progress  on  implementation  of  the  Zoos 
Directive,  including  Member  States  where  issues  related  to  the  implementation  of  the  EU 
legislation have been raised11.  

The  14  selected  Member  States  were:  Belgium,  Bulgaria,  Cyprus,  the  Czech  Republic,  Denmark, 
France, Ireland, Italy, Germany, Lithuania, the Netherlands, Poland, Portugal and Spain. The selection 
ensured  that  the  countries  covered  were  representative  of  all  EU  Member  States.  In  particular,  all 
Member States with the highest number of zoos were included in the selection so that countries with 
significant experience of implementing the Directive were covered. The information gathered in these 
14 Member States was thus deemed representative of the situation across the EU-28. Information from 
these case studies was complemented by other tools, giving full geographical coverage of the EU (e.g., 
literature review and public consultation, and evidence provided by stakeholders operating at EU lev-
el).     

3.3.2.2  Stakeholder mapping 

Based  on  the  intervention  logic  of  the  Directive,  the  evaluation  framework  and  information  needs, 
stakeholders were selected who are directly involved in the implementation of the Zoos Directive, are 
impacted by the EU legislation, or have knowledge and/or interest in the topics concerned.  

The following stakeholder groups were directly targeted by the consultation process: 

  Competent  authorities  (CAs), 

the 
implementation and enforcement of the Zoos Directive in the 14 Member States selected as case 
studies.  

including  enforcement  authorities  responsible 

for 

  Zoos (including public, private, charity-supported and mixed entities) in the 14 selected Member 
States.  Based  on  the  information  provided  by  the  CAs  and  other  stakeholders  (such  as  zoos’ 
federations  and  NGOs),  a  mix  of  different  types  of  zoos  were  included:  membership/non-
membership  to  the  European  Association  of  Zoos  and  Aquaria  (EAZA),  large  and  small 
operators,  single/multiple  operator,  aquariums,  animal  parks,  safari  parks,  collections  of  birds, 
reptiles, etc.). 

  Zoos  associations/representative  organisations,  acting  at  international,  EU  and  national  level 
(for the 14 selected Member States), including federations and unions of zoo operators and, where 
relevant, unions of zoo and wild animals’ veterinarians, keepers and/or trainers.  

  NGOs  focused  on  biodiversity  conservation  in  general  and/or  on  ex  situ  conservation,  and  on 

animal welfare, at international, EU and national level (for the 14 Member States).  

  Experts/academics with expertise in the areas of biodiversity conservation, ex situ conservation, 

wild fauna, etc. 

A  broad  range  of  stakeholders  (including  national  stakeholders  of  the  14  Member  States  not  in-

10 Member States accessing the EU in 2004 and 2007 are considered new.  
11 More specifically, the following criteria were applied: estimated number of zoos; size of the country and presence of wild fauna; country 
localisation (North/South, West/East) and administrative structure; older and newer EU Member States; general availability of information. 
Based on the preliminary information available and on the exploratory interviews carried out during the inception phase, the sample included 
Member States where issues have been raised in relation to the implementation of the Directive.  

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volved  in  the  case  studies)  and  civil  society  at  large,  including  individual  citizens,  were  informed 
and reached through the public consultation and the dedicated webpage set up by Environment Direc-
torate-General European Commission (DG ENV) for the project12.  

3.3.2.3  Exploratory interviews 

During the inception phase of this study, exploratory interviews  were carried out in order to gain an 
initial understanding of the interests and challenges faced by the two main groups of EU stakeholders 
in the implementation of the Zoos Directive: zoos’ federations and NGOs active in animal welfare.  

Both EAZA, the Eurogroup for Animals, and Born Free were interviewed using the same set of ques-
tions, based on the evaluation questions and sub-questions contained in the evaluation roadmap.  

Those  exploratory  interviews  contributed  to  designing  the  evaluation  framework,  in  particular  the 
identification of the types of sources of information available, indicators and success criteria.  

3.3.2.4  Targeted questionnaires 

The targeted online  questionnaires aimed to collect detailed, quantitative and qualitative information 
to  support  the  answers  to  the  evaluation  questions.  The  questionnaires  focused  on  the  collection  of 
detailed  information  and  data,  especially  on  the  implementation  of  the  Directive  (the  conservations 
measures undertaken by the zoos and actions taken by the CAs and enforcement authorities), and the 
costs and benefits associated with the Directive. 

The questionnaires were discussed during a Steering Group Meeting on 5 July 2016 and revised ac-
cording to the members' comments.  

The following paragraphs present information on: 

  The stakeholders targeted and mapped and the reach out strategy. 
  The questionnaires. 
 

Information on respondents. 
Publication of answers. 

 

Targeted stakeholders  

The  questionnaires  targeted  all  stakeholder  categories  with  a  high  and  medium  interest  according  to 
the stakeholder analysis matrix, as well as those with a low interest but high influence in the 14 select-
ed Member States and at EU level: 

1.  Member States Competent Authorities (MSCAs); 
2.  NGOs, zoos’ federations, and experts at national and EU level13; 
3.  Zoo operators. 

Identification of stakeholders 

Stakeholders to be contacted for the survey were identified via different methods:  

  Zoos: mainly through desk research by the national experts drafting the country fiches. 
  MSCAs, NGOs, federations and scientific experts: through desk research, but also with input 

from EU level stakeholders (EAZA and Born Free14) and from the Commission.  

12 http://ec.europa.eu/environment/nature/legislation/refitzoosdirective/index_en.htm  
13 The questionnaire targeting these stakeholders is referred to as the ‘high level questionnaire’.  
14 An initial list of relevant stakeholders identified through desk research was communicated to the two organisations for completion.  

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Questionnaires 

The questionnaires were structured around the evaluation questions and sub-questions according to the 
evaluation framework (see Annex I). The links between questions and evaluation criteria were guided 
by, and then illustrated in, the evaluation framework in order to: 
  Guarantee the added value of each question to the supporting study.  
 
  Ensure the usability of collected data. 

Facilitate the comparison of results.  

A  major  focus  was  placed  on  those  evaluation  questions  for  which  the  information  was  likely  to be 
particularly scarce (such as state of play, effectiveness, efficiency and EU added value). The question-
naire for the targeted survey included closed questions to facilitate comparability and quantification, 
and  semi-open  questions  to  allow  for  explanations  and  qualitative  information.  The  questionnaires 
were also tailored to each type of respondents, e.g., while MSCAs were asked to provide information 
on  the  transposing  legislation,  zoos  were  asked  questions  in  relation  to  their  activities,  in  order  to 
measure the level of implementation of the Article 3 conservation measures.   

The EU survey online service was used and the three different questionnaires are included in the Tar-
geted Surveys Report (Annex VI). 

Dissemination 

Stakeholders were informed about the scope and indicative timeline of all consultation activities, in-
cluding public consultation, at the end of June 2016, six weeks before the first targeted questionnaire 
was sent out. 

Following  approval  by  the  Commission,  the  survey  was  launched  by  email  on  11  August  2016,  in-
cluding an introduction to the survey, a guidance document on the functioning of the survey  system, 
and specific links to the relevant surveys for each stakeholder type (MSCAs, zoo operators or NGOs 
and zoos’ federations).  

In order to reach a large panel of zoo operators, the questionnaire addressed to zoos was translated into 
the national languages of the 14 selected Member States. Federations and NGOs were encouraged to 
extend the invitation to participate in the survey to all of their members and other interested stakehold-
ers. The list of contacted stakeholders is presented in the Targeted Surveys Report (Annex VI).  

Follow-up took place through emails and phone calls, particularly with: 

  Non-EAZA zoos to ensure a more balanced representation of zoo members and not members of 
the association (see below); and all zoos in countries where the response rate was particularly low 
(e.g. France and Spain). 
Stakeholders  selected  for  the  interviews,  in  order  to  encourage  the  completion  of  the  survey 
before the interview.  

 

In view of the limited availability of stakeholders during the summer period and the slow response rate 
of institutional stakeholders such MSCAs, the initial deadline of the survey (12 September 2016) was 
extended several times between September and November. The surveys were closed for zoos and fed-
erations/NGOs/experts on 14 November, and for MSCAs on 28 November, on submission of the final 
outstanding contributions from national authorities.  

Information on respondents 

The CAs of the 14 selected Member States responded to the survey. Obtaining answers from some of 
these  authorities  required  close  follow-up  and,  in  some  cases,  the  assistance  of  the  European 
Commission. 

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Table 4: Overview of MSCAs responding to the questionnaire 

Member 
States 

Stakeholder type 

Organisation 

BE 
BG 

CY 

CZ 
DK 

FR 

IT 
LT 
DE 

IE 

NL 

PL 
PT 

CA 
CA 

CA 

CA 
CA 

CA 

CA 
CA 
CA 

CA 

CA 

CA 
CA 

Animal Welfare - Walloon region and Flanders 
Ministry of Environment and Water; National Nature Protection 
Service Directorate 
Ministry of Agriculture, Natural Resources and Environment, Animal 
Health & Welfare Division 
Ministry of the Environment  
Ministry of Environment and Food; Danish Veterinary and Food 
Administration 
Ministry of Environment, Energy and Sea; Sub- Directorate for the 
Protection and promotion of species and their environment 
Ministry of Environment, Land and Sea Protection 
Ministry of Environment of the Republic of Lithuania 
Federal Ministry of Environment, Nature Protection and Nuclear 
Safety, Protection of Species, Dept. NI3 
National Parks and Wildlife Service, Department of Arts, Heritage & 
the Gaeltacht 
Ministry of Economic Affairs, Directie Dierlijke Agroketens en 
Dierenwelzijn 
Ministry of Environmental Protection   
Ministry of Agriculture, General Directorate for Food and Veterinary 
services 
Ministry of Agriculture 

ES 
Source: Targeted Surveys Report (see Annex VI)  

CA 

Of the survey  addressed to  zoos’ federations and NGOs, 26 stakeholders replied,  categorised  as fol-
lows: 

Table 5: Overview of types of respondents to the high-level questionnaire 

Federations 

NGOs 

Authorities and experts15 

Level 

EU 

International 

Cont
acte
d 

4 

3 

National 

15 

10 

Respo
nded 

Response 
rate (%) 

Cont
acte
d 

Respo
nded 

Respons
e rate 
(%) 

2 

1 

50% 

33% 

67% 

3 

1 

3 

0 

35 

10 

100% 

0% 

29% 

Co
nta
cte
d 

5 

3 

2 

Respo
nded 

Respon
se rate 
(%) 

0 

0 

1 

0% 

0% 

50% 

Source: Targeted Surveys Report (see Annex VI) 

At national level, zoos’ federations and NGOs were from the following countries: 

Table 6: Geographical distribution of federations and NGOs responding to the questionnaire 

BE 

CY 

DE 

DK 

Federations 

- 

NGOs 

1 

- 

1 

2 

2 

1 

- 

Source: Targeted Surveys Report (see Annex VI) 

ES 

1 

2 

FR 

1 

1 

IT 

- 

1 

NL 

2 

- 

PT 

1 

- 

Organisations active in the field of biodiversity conservation (IUCN, CITES, CBD)  expressed a lim-

15 CBD and CITES Secretariats were considered as ‘Authorities’ and are included in the ‘Authorities and experts’ category. 

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ited interest in contributing to the study. While the CITES and CBD Secretariats considered that they 
could not usefully contribute to the study, the IUCN estimated that they were not in a position to con-
tribute as an entity to the study, instead proposing an interview with one member of a specialist group 
(see Section 3.3.2.5 below).  
In  order  to  maximise  the  outreach  to  zoos,  a  large  number  of  zoo  operators  were  contacted  directly 
(514  zoos,  representing  around  25%16  of  the  total  registered  or  recognised  zoos  in  the  14  Member 
States),  based  on  the  information  gathered  during  the  inception  phase  (desk  research  and  lists  from 
CAs17). The goal response rate of between 15% and 20% of all contacted zoos was achieved. Seventy 
zoos from the 14 selected Member States replied to the survey, with 12 additional zoos responding by 
direct email, giving a total response rate of 16%18.  

Most of the zoos that responded were part of EAZA or other national federations, meaning that EAZA 
zoos are over-represented in the survey responses (EAZA zoos represent nearly 20% of the total num-
ber of licensed zoos19 in the 14 selected Member States, and 52% of the respondents). The difficulties 
relating to representativeness are discussed in Section 3.5.1.2 below. 

However, the survey also captured the points of view of zoos affiliated to national federations, as well 
as zoos with no membership (six respondents indicated no membership, while 11 did not answer the 
question). Similarly, the replies represent zoos of different sizes, especially small establishments (be-
tween 10 and 49 employees), and include a number of very small zoos, with fewer than 10 employees 
(Figure 6). The presence of small zoos in the sample is particularly important, since one of the objec-
tives  of  the  evaluation  mandate  is  assessing  whether  small  zoos  face  more  difficulties  in  complying 
with the requirements of the Zoos Directive. It was for this reason that the questionnaire was translated 
into  each  of  the  relevant  national  languages,  a  strategy  that  proved  successful  in  increasing  the  out-
reach of the survey and enhancing the participation of smaller operators. 

Finally, the respondents to the survey represent  private and public establishments, as well as entities 
with mixed ownership.  

The charts below present the main features of the zoos that responded to the survey.  

Figure 6: Distribution of survey responses by membership, number of employees and type of entity, in absolute 
numbers  

40
30
20
10
0

Membership 

37 

16 

11 

6 

EAZA

Other
Federation

No answer

NO
Federation

40

30

20

10

0

Number of employees 

30 

21 

10 

10-49

50-249

Less than 10

16 An approximation, given the lack of precise information on the number of zoos in each Member State.   
17 MSCAs were asked to provide information and contact details of the zoos, possibly recorded by the licensing system. In parallel, the 
mapping was conducted through desk research and with the input of other stakeholders.  
18 Those zoos did not reply through the survey but highlighted their interest or lack of interest on the Directive by emails. They were there-
fore not represented in the statistical analysis survey responses but were taken into account as equivalent to position papers.  
19 As reported by MSCAs in the survey: 195 EAZA members of 1,006 zoos. 

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Type of Entity 

30
25
20
15
10
5
0

6 

1 

Charity /
foundation

Mix Private /
Charity

9 

Other

24 

19 

8 

3 

Private – 
operating a 
single zoo 

Private – 
operating 
several zoos 

Public – run 
by local 
authority 

Public – run 
by national 
authority 

Source: Targeted Surveys Report (see Annex VI) 

The  geographical  distribution  of  responding  zoos  is  illustrated  below  (together  with  the  number  of 
zoos contacted and the related response rate). 

Table 7: Geographical representation of zoos responding to the survey 

Countries 

BE 

BG  CY 

CZ 

DE  DK 

ES 

FR 

IE 

IT 

LT 

NL 

PL 

PT 

Number of zoos 
contacted  

Number of zoos 
responding 

Response rate 
(%) 

29 

7 

7 

2 

6 

1 

19 

82 

26 

20 

100 

17 

67 

6 

17 

020 

7 

10 

4 

4 

8 

1 

30 

21 

22 

2 

1 

8 

24% 

29% 

17% 

35% 

21% 

0% 

35% 

10% 

23% 

6% 

12% 

7% 

5%  36% 

Source: Targeted Surveys Report (see Annex VI) 

Publication of responses 

The responses of all of those who did not require total anonymity (option provided in the survey) were 
published by the European Commission on its webpage dedicated to the evaluation. 

3.3.2.5 

In-depth interviews 

Defining the scope and objectives of the interviews 

The aim of the interviews was to obtain an in-depth view of the relevant issues in each of the selected 
countries, together with an overview of the situation at EU and international level. Where appropriate, 
the interviewees were asked to provide written supporting evidence (e.g. for issues that require quanti-
tative assessments, such as costs).  

The  interview  questions  ensured  full  coverage  of  the  evaluation  questions,  tailored  to  the  different 
stakeholder  groups  identified  (see  previous  Section  3.3.2.4).  The  links  between  the  evaluation  ques-
tions  and  interview  questions  were  added  to  the  evaluation  framework  (see  Section  3.2).  A  semi-
flexible  approach  was  adopted,  meaning  that  while  the  same  topics  were  covered  in  all  interviews, 
each interview took into account the specific context and issues raised by the stakeholder in the target-
ed survey.  

The interview questions were drafted in collaboration with the European Commission. The interview 
questions,  as  well  as  the  targeted  stakeholders  and  the  general  approach,  were  discussed  during  a 
Steering Group Meeting on 6 October 2016.  

20 Danish zoos did not reply individually to the survey, as they mandated their national zoo association (DAZA) to reply on their behalf.  

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The interviews were organised with: 
  National  stakeholders:  within  each  of  the  14  Member  States,  depending  on  the  number  of 
relevant stakeholders acting at national level, between two and four interviews were held. These 
included  at  least  one  interview  with  the  CA.  The  remaining  interviews  were  carried  out  with  a 
different type of stakeholder, preferably the main national zoo federation or an NGO involved in 
ex situ conservation or having zoos in their field of activity. While not initially foreseen, where 
possible, one zoo was also interviewed in order to gather additional information for the efficiency 
analysis.  

  EU  and  international  stakeholders:  in  addition  to  the  stakeholders  within  the  14  Member 
States, the data collection team performed eight additional interviews with stakeholders from the 
EU  and  international  level.  In  total,  44  stakeholders  were  interviewed:  13  MSCAs,  eight  zoo 
federations, six NGOs, nine zoo operators and eight EU and international stakeholders (See Table 
9). This is higher than the target initially provided in the consultation strategy21.  

Table 8: Overview of stakeholders interviewed 

Number  Country  
1 
2 
3 
4 
5 
6 
7 
8 
9 
10 

BE 
BE 
BE 
BG 
BG 
CY 
CY 
CY 
CZ 
DE 

11 
12 
13 

14 
15 

16 
17 
18 
19 
20 
21 
22 
23 
24 
25 

26 
27 
28 
29 

30 
31 

DE 
DE 
DK 

DK 
ES 

ES 
ES 
ES 
FR 
FR 
FR 
IE 
IE 
IE 
IT 

IT 
IT 
IT 
LT 

LT 
NL 

Stakeholder type 

Organisation 

MSCA 
NGO 
Zoo 
NGO 
Zoos 
MSCA 
NGO 
Zoo 
MSCA 
MSCA 

MSCA 
Zoos Federation 
MSCA 

Zoos Federation 
MSCA 

Zoo 
NGO 
Zoos Federation 
NGO 
Zoo 
MSCA 
MSCA 
Zoos Federation 
Zoo 
MSCA 

Zoos Federation 
Zoo 
NGO 
MSCA 

Zoo 
MSCA 

Walloon and Flemish Public Service for Animal Welfare 
GAIA 
BE Zoo (anonymity requested) 
Four Paws 
Sofia Zoo 
Veterinary Services 
ARC Cyprus 
Pafos Zoo 
Ministry of the Environment of the Czech Republic  
Regional Department for Health and Food Safety; Regional 
Institute for Animal Health, Bavaria 
Federal Ministry for the Environment, Nature Conservation 
Verband der Zoologischen Gärten – VdZ 
Ministry of Environment and Food; Danish Veterinary and Food 
Administration 
Danish Association of Zoos and Aquaria - DAZA 
Ministry of Agriculture, Food and Environment, General 
directorate for environmental quality and evaluation, General 
sub-directorate for natural environment  
Zoobotanico Jerez 
Infozoos 
Asociación Ibérica de Zoos y Acuarios - AIZA 
Code Animal 
FR Zoo (anonymity requested) 
Ministry of Environment 
Ministry of the Environment 
British and Irish Association of Zoos and Aquariums - BIAZA 
Fota Wildlife Park 
Ministry of Environment, Land and Sea Protection; Nature and 
Sea Protection Directorate; CITES Management Authority 
Italian zoos federation 
IT zoo 
Animalisti Italiani 
Ministry of Environment; Nature Protection Department, 
Biodiversity Division;  
Lithuanian Zoological Gardens 
Ministry of Economic Affairs 

21 Minimum 28 and maximum 42 interviews at national level, plus up to eight interviews at EU/international level. 

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Number  Country  
32 
33 
34 
35 
36 
37 

PL 
PL 
PT 
PT 
PT 
EU 

38 

39 

40 

41 

42 

43 

44 

EU 

EU 

EU 

EU 

EU 

EU 

EU 

Stakeholder type 

Organisation 

Zoo 
Zoos Federation 
Zoo 
Zoos Federation 
MSCA 
EU and 
international 
EU and 
international 
EU and 
international 
EU and 
international 
EU and 
international 
EU and 
international 
EU and 
international 
EU and 
international 

Wroclaw Zoo 
Board of Directors of Polish Zoological Gardens and Aquaria 
Jardim zoologico e de aclimaçao em Portugal 
Associacao Portuguesa de Zoos e Aquaria - APZA 
Division of Animal Welfare - DGAV-DSPA 
Eurogroup for Animals 

EAZA 

BornFree  

EAAM 

European Commission, DG Environment, Unit D.2 (Biodiversity) 

IUCN SSC Commission expert/Vice-Director of Copenhagen 
Zoo  
Expert in biodiversity conservation  

Expert in biodiversity conservation  

Source: Interviews Report (see Annex VII) 

Some stakeholders were difficult to reach, slow to respond, non-responsive or declined to reply. Most 
international stakeholders contacted declined an interview (WAZA, CITES Secretariat and CBD Sec-
retariat).  

While an expert of the SSC Commission of IUCN was interviewed, no formal contribution was pro-
vided from IUCN as an organisation.  

Interview guidelines 
The project management team developed interview guidelines, with the guidance document subject to 
approval  by DG  ENV, and afterwards circulated  among the study team.  The  guidance document in-
cluded information on: 

 

 

 

 

Purpose of the interviews. 
Stakeholders targeted. 
Instructions for contacting stakeholders, preparing (and/or tailoring) the questions and conducting 
the interviews. 
Interview questions, including:   
  Background  information  on  the  context  of  certain  questions  (brief  overview  of  the  main 
findings from questionnaires which triggered specific interview questions, if relevant);  
  Links  to  the  questions  for  each  targeted  questionnaire.  To  prepare  the  interviews,  the 
interviewer  was  asked  to  check  the  answers  provided  by  the  interviewee  to  these  specific 
questions. 

In addition to this guidance document, the interviewers received: 

  Online survey questionnaires completed by the interviewees. 
  All answers from the other stakeholders from the relevant Member State. 
  An Excel matrix (‘general transcript’) to report the information gathered during the interviews. 
  List  of  questions  to  send  to  the  interviewee  ahead  of  the  interview.  Four  different  lists  were 

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prepared,  one  for  each  stakeholder  type22.  For  additional  information,  please  see  the  Interviews 
Report provided in Annex VII.  

Carrying out the interviews  

To  ensure  effective  interviews,  interviewers  sent  the  list  of  questions  to  the  interviewee  in  advance, 
allowing awareness or preparation of the topics to be discussed.  

Results of the interviews were validated by cross-checking information, such as asking the same ques-
tion of different stakeholders, and verifying statements by evidence as far as possible (legislation, pub-
lications, etc.).  

Finally,  the  interviews  took  place  in  the  national  language  of  the  interviewee  where  an  interview  in 
English was not possible. 

Transcripts of interviews 

Transcripts of interviews were requested for each interview. Once drafted, the transcripts were sent to 
the interviewee for approval and additional input. Transcripts were then fed into a general transcript in 
an Excel document (in English) in order to allow the study team to compare and collect the relevant 
information for answering the evaluation questions. The Interviews Report summarising the results of 
the interviews is provided in Annex VII.  

3.3.2.6  Public consultation 

The public consultation aimed to invite the views and perceptions of a wide set of stakeholders on the 
contribution  of  the  Directive  to  strengthening  the  role  of  zoos  and  enhancing  biodiversity  conserva-
tion. It was intended to enlarge the scope of the consultation beyond those stakeholders consulted in 
the 14 selected Member States, and to give stakeholders from other countries and private citizens the 
opportunity to express their opinions.  

Study support for the public consultation was threefold: firstly, the development of the questionnaire, 
in cooperation with the European Commission; secondly, supporting the set-up and dissemination of 
the public consultation; and, finally, the drafting of a report (Public Consultation Report) outlining 
the number of responses,  problems  encountered, lessons learned, and summarising  the results  of the 
consultation per criterion and per question. The Public Consultation Report is provided in Annex VIII 
to this Report. 

Defining the questionnaire for the consultation 

The questionnaire closely followed the logic of the REFIT exercise, seeking to obtain feedback on the 
five evaluation criteria. The questions aimed to collect opinions and input on the different evaluation 
questions,  in  order  to  easily  evaluate  the  outcome  of  the  public  consultation  and  strengthen  the  evi-
dence base.  

The public consultation focused on 10 key questions. These were closed questions, in order to ensure 
the comparability of data and to facilitate their analysis (there was some possibility to provide limited 
input,  i.e.  limited  number  of  words  to  complement  closed  questions;  for  multiple  choice  questions 
‘other, please specify’). The links between the questions in the public consultation and the evaluation 
questions are included in the evaluation framework in Annex I).  

22 MSCAs, federations and NGOs, zoos, EU stakeholders. 

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The public consultation was intended as a complementary tool to supplement the information gathered 
through the other tools (in particular the targeted questionnaires and interviews). Questions were draft-
ed in a way that ensured the manageability and usefulness of the answers, and related to the awareness 
of citizens and their perceptions of the implementation of the Directive.   

The questions were drafted in close cooperation with the European Commission, both within DG ENV 
and with the Secretariat General, following a Steering Group meeting held on 5 July 2016. 
Supporting the setting up and dissemination of the public consultation 

Once the questionnaire was approved, it was translated by the services of the European Commission 
into the national languages of the 28 Member States. The online consultation was then set up on the 
EU Survey tool and published via the Internet portal ‘Your voice in Europe’. The survey was adver-
tised on the DG ENV website.  

The project team supported the dissemination of the public consultation by reaching out to the main 
stakeholders  involved  in  the  study  and  to  additional  relevant  stakeholders.  European  organisations, 
such as Eurogroup for Animals, EAZA and Born Free, were encouraged to further reach out to a wider 
audience.  

The public consultation was open for 12 weeks, between 15 September 2016 and 8 December 2016.  
The online consultation questionnaire was accompanied by general information for the public, which 
included the following: 

  A summary of the context, scope and objectives of the consultation. 
  Contact details and deadlines.  
 

Information on the target group.  
Information on how to contribute.   

 
  Reference to background documents. 
  Explanation  of  the  Commission’s  processes  for  dealing  with  contributions,  the  feedback  to 

expect, and details of the next stages of the REFIT exercise.  

Consultation report 

In  total,  2,297  responses  to  the  public  consultation  were  received.  The  two  main  categories  of  re-
spondents  were  individuals  (e.g.  zoo  visitors)  with  1,944  answers,  and  zoo  operators,  with  148  an-
swers. An overview of the type of respondents is presented in Figure 7 below.  

A Public Consultation Report was drafted to set out the results of the overall process and methodolo-
gy. In addition to the elements described here, the Report is provided in Annex VIII. 

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Figure 7: Types of respondents  

0,91% 

0,78% 

1,65% 

0,70% 

0,30% 

4,57% 

6,44% 

84,63% 

Individual (e.g. zoo visitor)

Zoo operator

Other

Non-governmental organisation

Business or business representative

Academic/research institute

Organisation or association (other
than NGO)

Government or public authority

Source: Public Consultation Report (see Annex VIII) 

In the Public Consultation Report (Annex VIII), answers to closed questions are given, with frequen-
cies,  measures  of  central  tendency  and  dispersion  presented  to  show  the  distribution  of  respondents 
across the different question and answer categories. The report gives an overview of the extent of cer-
tain opinions and possible problems. Break-down analyses to compare opinions of different types of 
stakeholders are also provided.  

In  analysing  the  text  to  complement  closed  questions  (i.e.  the  limited  number  of  words  allowed), 
common or similar arguments and issues raised were aggregated to the extent possible, and then added 
to the quantitative analysis.  

Finally, the analysis of semi-open fields allowed certain patterns to be identified, including campaigns 
of  influence.  Given  the  limited  influence  of  such  campaigns,  these  were  flagged  and  analysed  sepa-
rately where necessary (see Section 3.5.1.3).  

This report will be made available on the Commission’s website to ensure transparency of the process.  
The results of the public consultation are also incorporated into the analysis of answers to the different 
evaluation questions, as part of the evidence pool. 

3.4  DATA ANALYSIS METHODS 

The evaluation framework guided the data collection and formed the basis for the detailed review of 
evidence  and  analysis  of  each  evaluation  question.  The  evaluation  framework  (Annex  I)  maps  the 
links between the evaluation questions and the questions posed by the different surveys (targeted and 
public) in the study.  

The main analytical method used was content analysis, based on the aggregation and analysis of in-
formation  collected  through  the  literature  review,  desk  research,  interviews,  targeted  questionnaires 
(open-ended  answers)  and  public  consultation.  Replies  to  closed  questions  were  analysed  using  de-
scriptive statistics.  

In order to conduct a structured analysis,  the available evidence was organised in Excel  ‘databases’, 

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which linked the data and information collected with the relevant evaluation questions.  

The  replies  to  the  targeted  questionnaires  were  organised  according  to  the  relevant  evaluation  ques-
tions (on the basis of the correspondence matrix) and, for each survey, replies were analysed in order 
to establish and compare the opinions of different types of stakeholder. Zoo replies were investigated 
according  to  sub-groups,  i.e.  membership  of  a  national,  European  or  international  federation,  and 
number of employees23. Replies to the questionnaire addressed to federations, NGOs and experts were 
disaggregated according to the category of stakeholder, and to level of action (EU, national, interna-
tional or mixed). Open-ended replies were also screened and represented an important means of gain-
ing deeper insights and better understanding of the reasons behind the answers provided,  with exam-
ples integrated into the analysis for illustrative purposes.  

The  country  fiches  for  the  14  selected  Member  States  (Annex  II)  each  included  an  overview  of  the 
national system, with particular attention  paid to the legislation at national level, potential additional 
sources of information, and review of the main achievement and challenges experienced in implemen-
tation at national level. 

Data were aggregated and analysed according to the principles of triangulation of evidence from dif-
ferent perspectives (stakeholder categories) and different sources.  

Finally, the reliability of information was assessed according to the following criteria: 

 

 

Internal validity of the evidence (i.e. is the evidence precise and reliable?): less weight was given 
to opinions, compared to studies with well-described methodologies and references to sources of 
information, and/or to official statistics. However, greater weight was accorded where a number 
of similar opinions were expressed by different stakeholders.  
Sample  size  and  representativeness  (i.e.  is  the  evidence  based  on  an  adequate  number  of 
cases/representative of the overall population?): here, evidence is presented as illustrative when it 
does not represent several consistent cases or where it does not cover the overall population. 
  Temporal  relevance  and  geographical  relevance:  the  analysis  takes  into  account  the  extent  to 
which the evidence is up to date (or refers to a time period relevant to the evaluation), and refers 
to the geographical area in the scope of analysis.  

When  the  reliability  of  sources  and  the  possibility  for  triangulation  were  inadequate,  the  limitations 
have been described.  

3.5  CHALLENGES, MITIGATION MEASURES AND ROBUSTNESS OF THE FINDINGS 

3.5.1  Main challenges 

A number of challenges were encountered during the implementation of the first phase of this study in 
relation to the availability and quality of information and data, the quality of stakeholder input and, in 
some  cases,  the  limited  possibility  for  triangulating  sources  and  opinions.  The  main  issues  can  be 
summarised as follows: 

3.5.1.1  Lack  of 

reporting  obligations  and  consolidated  data  on 

the 

implementation of the Zoos Directive 

Member States are not required to report on the implementation of the Zoos Directive and no mecha-
nisms for the systematic monitoring of its implementation exist at EU level. The information available 
at the beginning of the study was limited to infringement procedures launched by the European Com-
mission  against  the  Member  States  (mainly  because  of  late  transposition),  pilot  cases  preceding  in-

23 Another possibly relevant breakdown could have been related to the type of entity, i.e. public, private or mixed. However, the results 
disaggregated according to the type of entity did not show major differentiations. 

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fringements, and stakeholder reports24.  
As a result, considerable effort was required to collect basic elements of information essential for the 
supporting study, such as the designated CAs and features of the licensing and inspection systems in 
the  14  selected  Member  States,  data  on  the  number  of  zoos  falling  under  the  definition  of  the  Di-
rective, and number of closures of zoos or breaches of the legislation detected at national level.  

This  information  was  mainly  gathered  through  desk  research  in  each  of  the  14  Member  States  and 
through answers to the questionnaires addressed to MSCAs and other stakeholders (Zoo  federations, 
NGOs, experts and zoos). However, in many cases, it was not possible to obtain reliable and/or com-
parable data.  

The  availability  of  consolidated  and  complete  data  on  the  total  number  of  zoos  subject  to  the  Zoos 
Directive, licensing  procedures completed  and ongoing, breaches of the legislation, closures of zoos 
and  sanctions  imposed  during  the  implementation  period  is  a  particular  issue.  The  data  provided  by 
MSCAs appear in many cases to contain solely the number of licensed zoos, are not comparable and 
are limited to the most recent years of implementation.  

3.5.1.2  Limited  evidence/available  information  supporting  the  analysis  of  the 

evaluation questions  

Gaps  did  not  relate  solely  to  the  information  available  on  the  implementation  of  the  Zoos  Directive 
and the licensing  and inspection systems set up. Limitations of information/data availability also af-
fected the other general and specific aspects addressed by the evaluation questions.  

Several evaluation issues lacked extensive documented and/or independent research, and it was possi-
ble to fill the gaps through primary data collection only to a limited extent.  

Firstly, there is a general  lack of information on contextual elements that would have allowed the 
study to better frame the implementation of the Zoos Directive and investigate long-term trends. The 
gap concerns the baseline25, as well as consolidated data at EU and national level on the distribution of 
zoos by number of employees or type of entity (public, private, mixed, etc.), size and composition of 
the animal collections, number of visitors, revenues, or expenses in research. Data exist mainly in rela-
tion to zoos which are members of European or international zoo federations (EAZA and WAZA), for 
specific years, or aggregated at European (rather than EU) or even global level.  

Secondly, there are no consolidated and comprehensive data on research projects and other con-
servation measures implemented by zoos. Again, some evidence on conservation measures (such as 
participation in research, captive breeding programmes, reintroduction into the wild, etc.) is limited to 
specific (often EAZA) zoos and is analysed in the context of specific studies or projects (such as the 
database of European Endangered Species Programme, EEP and European Stud Books programmes, 
ESB). More comprehensive evidence is provided by stakeholder organisations, such as the Born Free 
Foundation, which has supported the so called ‘EU Zoo Inquiry’ for several years now, an investiga-
tion into the status and performance of zoos across most of the Member States. Although this investi-
gation provides many insights and useful information, it does not represent a consolidated database but 
it is based on in-depth analysis of a sample of EU zoos. Nor can it be ignored that the Born Free Foun-
dation is an interest group, and no other comparable source that allows proper triangulation is current-
ly  available.  The  survey  addressed  to  zoos  provided  some  input  with  respect  to  the  conservation 
measures implemented, by bringing real life examples of, and insights into, the main activities under-
taken in EU zoos. Nevertheless, it is important to mention that the results of the survey are biased by 
the  over-representation  of  zoos  belonging  to  federations  (in  particular  EAZA).  More  generally,  the 
survey is likely to have captured mainly conservation focused zoos. It is clear, therefore, that the re-

24 In particular, the Born Free Inquiry. 
25 The data on the situation prior to the Directive is very limited, and relies primarily on the 1988 Survey of Zoological Collections, the 
previously legislation existing at national level, and preparatory documents from the European Parliament.   

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plies to the survey cannot be used to extrapolate data on the share of EU zoos implementing conserva-
tion measures (nor was this the intended objective) but only to complement the information collected 
at national level on the actions taken by Member States in order to ensure the compliance of zoos with 
the legislation.  
Finally, an important gap in questionnaire responses from zoos and Member State authorities is related 
to the lack of information on the costs and benefits triggered by the Zoos Directive. This infor-
mation is key for the assessment of ‘Efficiency’. Yet, most of the zoos and Member State authorities 
replying to the survey did not provide suitable data and information. The challenge for both zoos and 
MSCAs  is  to  disentangle  the  effects  of  the  Zoos  Directive  from  what  would  happen  anyway  (BAU 
costs).  Zoo  inspectors,  in  most  cases,  have  responsibilities  in  addition  to  those  under  the  Zoos  Di-
rective, a factor that makes estimates of the effort dedicated to the enforcement of the Directive diffi-
cult. Similarly, zoos were often unable to determine which costs (e.g., investments for the renovation 
of enclosures) are attributable to the Directive, rather than  to other developments (e.g. responding to 
changes in public perception and a general increase in awareness of species conservation issues). The 
differentiation of zoos by size and collection also makes it difficult to provide general estimates.  

The difficulty of isolating the effects of the Zoos Directive is even more significant when it comes to 
the estimate of benefits: all stakeholders experienced difficulties in responding to this element of the 
supporting study. 

3.5.1.3  Duplicate  responses  and  campaigns  affecting  the  targeted  and  public 

consultations 

The influence of interest groups affected the results of the consultations launched as part of the  sup-
porting study.  

This issue partly affected the replies provided by zoos (belonging to EAZA) in the targeted ques-
tionnaire.  Of  the  70  replies,  around  10  provided  duplicate  responses  to  the  section  of  the  question-
naire  relating  to  the  evaluation  issues  (whereas  the  section  on  the  implementation  of  conservation 
measures is, of course, related to the specific experience of the zoo).  

Another issue relates to the public consultation, which took place over a period of 12 weeks and was 
announced on the evaluation website. At least two NGOs involved in animal welfare (Born Free26 and 
Eurogroup  for  Animals27)  provided  suggested  replies  to  the  public  consultation.  Such  guidance  was 
also disseminated through other EU/international associations (such as Animal Defender International, 
ADI28), and other associations at national level (such as Animal Public29, which is active in Germany). 
It  is  expected  that  additional  examples  may  be  found  on  other  websites.  A  very  limited  number  of 
respondents followed all indications for the closed questions (40 of the 2,297 respondents)30.  

Responses to semi-open fields revealed the presence of additional campaigns by other interest groups, 
including zoos associations at both EU and Member State level. In these cases, overall, only a limited 
number of stakeholders provided input in semi-open fields, most of which appear to be influenced by 
interest  groups31.  These  campaigns  were  followed  by  various  stakeholder  categories:  individuals, 
NGOs, other associations and zoo operators.  

It  is  not  possible  to  precisely  assess  the  impact  of  these  campaigns  on  the  overall  results  (some  re-
spondents may have followed the guidance only partly, or might have answered closed questions simi-

26 http://www.bornfree.org.uk/fileadmin/user_upload/files/zoo_check/EU_Zoo_Inquiry/Public_consultation_on_Zoo_Directive_REFIT.pdf 
27 http://www.eurogroupforanimals.org/wp-content/uploads/2016/10/Suggested-Replies.pdf 
28 Suggested replies are the same as those provided by Eurogroup for animals (http://www.ad-
international.org/animals_in_entertainment/go.php?id=4264&ssi=12). 
29 Suggested replies provided by Eurogroup for animals are the same as those provided by BornFree (http://www.animal-public.de/europas-
zootiere-brauchen-ihre-hilfe/). 
30 36 respondents followed the indications of Born Free (1.5% of the total number of respondents); four respondents followed the indications 
of Eurogroup for Animals (0.17% of the total number of respondents). 
31 Depending on the question, from 56% to 84% of the respondents provided replies affected by campaigns.  

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larly  by  coincidence).  However,  the  overall  impact  of  replies  that  followed  all  indications  for  the 
closed questions is very limited (40 of the 2,297 respondents or 1.74%). These identical reply patterns 
were not, therefore, analysed separately. For semi-open questions, repeated comments were taken into 
account in the overall analysis. 
Finally, on a more positive note, several organisations disseminated the information on the public con-
sultation without any recommended replies, suggesting that considerable visibility was achieved.  

3.5.2  Mitigation measures and robustness of the findings 

The challenges described above have been addressed as far as possible by setting up and conducting 
an extensive collection of primary data, and through targeted questionnaires addressed to the different 
stakeholder categories, complemented with interviews. Additional interviews with zoos also sought to 
gain a better understanding of the steps for obtaining and keeping a zoo licence, and to collect suitable 
information  for  a  more  comprehensive  assessment  of  costs,  particularly  administrative  costs.  Where 
relevant, for instance in order to assess the level of implementation of conservation measures by zoos, 
literature was also used as an additional source of information.   

However, some limitations remain in the robustness of the data collected and, consequently, the find-
ings. To summarise the main challenges:   

  There are gaps in the data provided by stakeholders, especially when it comes to historical data 
(e.g. in relation to Member State authorities, data on number of zoos licensed, number of detected 
breaches of the legislation, etc.) and data on costs. These gaps have, in some cases, prevented the 
use of the data provided by some of the Member States or zoos.  

  Where data are provided, their quality is sometimes low (e.g. the breakdown of zoos by status of 
the licensing procedure does not match the total number of zoos identified).  Data have not been 
used  where  it  has  not  been  possible  to  verify  the  information  (or  it  has  been  used  only  for 
illustrative purposes).  

These issues limit the possibility of a detailed analysis based on reliable quantitative data, especially 
for certain evaluation questions: EQ 1 (Progress towards the achievement of the objectives: setting 
up  of  adequate  licensing  and  inspection  systems  and  implementation  of  the  conservation 
measures set out in Article 3); in relation to the assessment of the ‘Efficiency’ of the Zoos Directive; 
and in relation to the assessment of the ‘EU Added Value’ (data before and after the implementation 
of the Directive are missing).  

It  was  difficult  to  obtain  the  level  of  detail  required  by  the  evaluation  questions  and  to  quantify  the 
relevant  indicators.  The  available  data  and  information  were  therefore,  combined  with  the  data  on 
stakeholder perceptions, and the underlying reasons behind the opinions were investigated by substan-
tiating the findings with examples and specific arguments.   

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4 

IMPLEMENTATION OF THE ZOOS DIRECTIVE 

4.1  STATE OF PLAY: IMPLEMENTATION OF THE DIRECTIVE IN THE MEMBER STATES 

4.1.1  Status of zoos in the EU 

Article 2 of the Zoos Directive defines ‘zoos’ as ‘all permanent establishments where animals of wild 
species are kept for exhibition to the public for seven or more days a year, with the exception of cir-
cuses,  pet  shops  and  establishments  which  Member  States  exempt  from  the  requirements  of  the  Di-
rective on the grounds that they do not exhibit a significant number of animals or species to the public 
and that the exemption will not jeopardise the objectives of the Directive’. 

The term ‘zoos’, an abbreviation of zoological gardens, now represents  a wide range of collections 
that  contain  non-domesticated  animals.  Such  establishments  may  concentrate  on  specific  groups  of 
species, geographical regions, conservation ambitions, or solely on attracting visitors. They comprise, 
therefore, places denominated ‘zoo’, ‘aquarium’, ‘safari park’, ‘bird garden’, etc.  

Zoos may be owned and run as charitable or not-for-profit organisations and societies, owned by mu-
nicipal authorities, or run explicitly as commercial enterprises with the intention of generating income. 
The  different  purposes  and  structures  are  likely  to  lead  to  a  diverse  array  of  establishments  per-
ceived  widely  as  zoos  and  which  fall  within  the  Directive’s  definition.  There  may,  for  example,  be 
tourist attractions, learning  and research centres, conservation  organisations or  various combinations 
of these.  

The majority of Member States have no official information on either the number of zoos or the nature 
of zoo ownership (public, private, and other). This lack of data is often the consequence of the absence 
of a zoo registry at national level (centralised databases have been reported only for Cyprus, the Czech 
Republic, Ireland, Poland and Portugal). Where data are available on the number of zoos at national 
level,  it is unclear which criteria are taken into account  in their identification  (i.e. exclusion of non-
licensed zoos; inclusion of establishments displaying both domestic and wild species).  

For the purposes of the supporting study, data on the number of zoos were collected in the 14 Mem-
ber States selected as case studies. According to MSCAs, there are at least 1,000 licensed zoos in these 
selected countries32.  

32 Data on the number of zoos provided by MSCAs for the survey. These numbers do not include non-licensed zoos, which could be zoos for 
which the licence has been refused, or zoos for which the licensing procedure is pending. Nor are exempted zoos considered. In some Mem-
ber States, other sources (e.g. Born Free) tend to report a higher number of zoos (which either could not be detected by the Member State 
authorities or are considered exempted from the zoo legislation).   

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Figure 8: Number of licensed zoos in selected Member States in 2015 

Source: Data from the present survey of MSCAs 

Across the 14 Member States surveyed, 195 zoos (19% of the licensed zoos) are EAZA members33. 
In  two  EU  Member  States,  no  zoos  are  members  of  EAZA  (Cyprus  and  Malta).  Table  9  shows  the 
number of EAZA zoos in each country across the 28 Member States and, for the 14 Member States 
surveyed, the share of licensed zoos which are EAZA members.  

Table 9: EAZA membership and percentage of licensed zoos in the 28 EU Member States 

Member 
State 
AT 
BE 
BG 
CY 
CZ 
DE 
DK 

EAZA zoos 

Percentage of licensed zoos members of EAZA 

6 
7 
1 
0 
14 
47 
11 

N/A 
17.5% 
7.15% 
0% 
56% 
14% 
35.5% 

33 In the 28 EU Member States, 286 zoos are members of EAZA. 

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Percentage of licensed zoos members of EAZA 

EAZA zoos 

Member 
State 
EE 
EL 
ES 
FI 
FR 
HR 
HU 
IE 
IT 
LT 
LU 
LV 
MT 
NL 
PL 
PT 
RO 
SE 
SI 
SK 
UK 
Source: Elaboration of data from the 2016 EAZA database; present survey of MSCAs34 

N/A 
N/A 
13.5% 
N/A 
18.75% 
N/A 
N/A 
12% 
44% 
20% 
N/A 
N/A 
0% 
26% 
46% 
28% 
N/A 
N/A 
N/A 
N/A 
N/A 

1 
1 
16 
3 
54 
2 
7 
2 
10 
1 
1 
1 
0 
14 
11 
7 
2 
13 
1 
3 
50 

The nature of zoo ownership varies across Member States (private, public, and other ownerships). In 
some of the countries surveyed, zoos are all publicly owned (e.g. Bulgaria), while in others, the major-
ity of zoos are privately owned (commercial enterprise; scientific establishment, e.g. Germany, Den-
mark, Italy). In some Member States, both public (including those with a charitable status) and private 
entities operate zoos (e.g. France, Ireland).  

4.1.2  Market overview 
It is estimated that more than 140 million visits35 are made each year to zoos that are members of EA-
ZA (EAZA 2016) and that some 700 million visits to zoos are made worldwide annually (Barongi, et 
al. 2015). In the context of this study, there are no official figures on the number of zoo visitors in 
the 14 Member States surveyed. Nonetheless, data on the number of zoo visits are available for mem-
bers of zoo federations and/or associations in some countries. For instance, in Germany, 33.4 million 
visits were made to zoos belonging to the Association of Zoological Gardens in 2014 (Germany has a 
population of 81 million). In Denmark, four million visits to zoos belonging to DAZA were registered 
in 2015 (Denmark has a population of 5.6 million)36. 

4.1.3  Relevant stakeholders 

In all 14 Member States surveyed, NGOs and associations are active on issues directly relevant to the 
implementation of the Zoos Directive (e.g. biodiversity issues, animal welfare, safety of zoo staff). 
In 12 Member States, national NGOs are active on issues related to  zoos and animal welfare (Bel-

34 This table takes into account three types of membership: 1) full membership (granted to a zoo or aquarium located in a European country 
that maintains suitable standards of management and animal husbandry and complies with all other EAZA standards); 2) temporary member-
ship (granted to zoos and aquariums that do not yet meet the standards required for full/associate membership of EAZA or to zoos and aquar-
iums that are under construction and want to apply for full membership directly after opening); 3) candidate for membership (granted to zoos 
and aquariums under construction - not yet open to the public - in Eastern and Central Europe and to those institutions that are working 
towards compliance with EAZA accreditation standards).  
35 Note that reports and studies refer usually to number of visitors rather than to number of visits. The numbers provided cannot take multiple 
visits of the same person into account. This report likely refers to the ‘number of visits’.  
36 Other sources such as academic studies provide information on the number of zoo visits in some of the 14 Member States surveyed (see 
country fiches in Annex II). 

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gium,  Bulgaria,  Cyprus,  the  Czech  Republic,  Germany,  Spain,  France,  Ireland,  Italy,  Lithuania,  the 
Netherlands,  Poland).  Only  some  NGOs  deal  exclusively  with  animals  in  captivity  (zoo,  circus,  e.g. 
Code Animal in France). These NGOs have different roles and activities: 

  Advocacy (political lobbying; expertise provided to policy-makers). 
 

Public  education  and  awareness-raising  (spreading  information  about  specific  animal  welfare 
issues). 

  Targeted individual actions (animal rescue). 

National associations representing the interests of zoos or those of zoo professionals (e.g. veterinari-
ans)  also  exist  in  11  Member  States  (Belgium,  the  Czech  Republic,  Germany,  Denmark,  Spain, 
France, Ireland, Italy, the Netherlands, Poland and Portugal) and are engaged in: 

Protection of their members’ interests. 

 
  Representation before national and international courts.  
  Consultation on ethical or legal issues. 
  Exchange of knowledge. 

Figure 9: NGOs and associations of zoos or zoo professionals in selected Member States 

Source: Data collected at national level (see country fiches, Annex II) 

4.1.4  Adoption of national law transposing the Zoos Directive 

All of the 14 Member States surveyed enacted national law governing zoos following the entry into 
force  of  the  Zoos  Directive.  A  small  number  of  Member  States  across  the  EU  (Belgium,  Denmark, 
France and Spain, as well as the UK) had adopted national laws to regulate zoos before the entry into 
force  of  the  Zoos  Directive.  Prior  to  the  Directive,  zoos  in  all  Member  States  were  subject  to  basic 
national animal welfare laws and veterinary health regulations governing trade. 

Table  10  and  12  below  list  transposing  laws  and  regulations  (National  Implementation  Measures, 

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NIMs)  adopted  by  the  14  Member  States  surveyed37  and,  where  applicable,  relevant  regulations  al-
ready in place before the entry into force of the Zoos Directive (1999). 

Table 10: Adoption of transposing law in selected Member States: ‘old’ Member States’ (EU member before the entry 
into force of the Zoos Directive) 

Member 
State 
BE 

DE 

DK 

ES 

FR 

Before entry into force 

After entry into force 

 

 

Law  of  14  August  1986  on  the  pro-
tection  and  the  well-being  of  ani-
mals  
Royal Order of 10 August 1998 on the 
recognition of zoos 

  Ministerial  Order  of  3  May  1999  on 
setting  minimum  criteria  for  keeping 
mammals in zoos  

  Ministerial  Order  of  7  June  2000  on 
setting  minimum  criteria  for  keeping 
birds in zoos 
Not regulated by national law 

  Act on animal welfare of 1967 
  Act  on  State  subsidies  to  zoological 

gardens of 1977 

  Decree 1119/1975 of 24 April 1975 on 
the  authorisation  and  registration  of 
zoological centres, establishments to 
practice horse-riding, centres for the 
enhancement and care of compan-
ion animals and other similar centres 
Law  no.76-629  on  the  protection  of 
nature 

 

  Amended Ministerial Order of 25 Oc-
tober 1995 on the implementation of 
the control of establishments holding 
non-domestic animal species 

  Ministerial  Order  of  21  November 
1997  defining  two  categories  of  es-
tablishments  other  than  establish-
ments practicing breeding, sale and 
transit  of  game  species  for  which 
hunting 
is  allowed,  holding  non-
domestic animal species 

  Ministerial  Order  of  23  June  2004  on 
setting  minimum  criteria  for  keeping 
reptiles in zoos 

 

 

 

 

2002  Federal  Nature  Conservation 
Act  
Implementing  regulations  at  Länder 
level (x16)38 
Zoos Order 1023 (2003) and Zoos Or-
der 1397 (2015) 

Law  31/2003  of  27  October  2003  on 
wild fauna preservation in zoological 
parks 

  Decree  No.  2002/266  of  22  February 
2002  on  establishments  holding  non-
domestic  animal 
species  and 
amending  Article  R213  of  the  Rural 
Code 

  Order of 25 March 2004 laying down 
the  rules  of  operation  and  the  gen-
eral  characteristics  of  facilities  of 
zoological  establishments  of  a  fixed 
and  permanent  nature,  presenting 
the  public  with  live  specimens  of  lo-
cal or foreign wildlife under heading 
21-40  of  the  nomenclature  of  facili-
ties  classified  for  environmental  pro-
tection 

IE 

Not regulated by national law 

  Order of 10 August 2004 establishing 
the  conditions  for  the  detention  of 
animals  of  certain  non-domestic 
species  in  establishments  practicing 
the  breeding,  sale,  rental,  transit  or 
public  presentation  of non-domestic 
animal species 
European  Communities 

(Licensing 

 

37  National Implementing Measures (NIMs) communicated by the Member States under Council Directive 1999/22/EC of 29 March 1999 
relating to the keeping of wild animals in zoos http://eur-lex.europa.eu/legal-
content/EN/NIM/?uri=CELEX:31999L0022&qid=1481147356708  
38 Germany, National Implementing Measures (NIM) communicated by the Member States under Council Directive 1999/22/EC of 29 March 
1999 relating to the keeping of wild animals in zoos http://eur-lex.europa.eu/legal-
content/EN/NIM/?uri=CELEX:31999L0022&qid=1481147356708  

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Member 
State 

Before entry into force 

After entry into force 

IT 

Not regulated by national law 

 

and  Inspection  of  Zoos)  Regulations 
2003 
Legislative  Decree  21  March  2005  n. 
Directive 
73 
1999/22/EC  relating  to  the  keeping 
of wild animals in zoos 

implementing 

NL 

Not regulated by national law 

PT 

Not regulated by national law 

Source: Data collected at national level (see country fiches, Annex II) 

  Decree  of  the  Ministry  of  Environ-

 

 

ment 18 January 2006  
Legislative Decree 4 April 2006 n. 192 
implementing  Directive  1999/22/EC 
relating  to  the  keeping  of  wild  ani-
mals in zoos 
Zoos Law of 19 April 2002; amended 
by the 2014 Animal Act  

  Animal  Act  (Wet  Dieren)  Animal 
holders,  and  Governmental  decree 
(Besluit  houders  van  Dieren),  July 
2014 
Flora  en  fauna  Act  (Flora  en  fauna 
Wet) is applicable to zoos 

 

  Decree-Law  No.  59/2003  of  April 

2003 

All of the Member States which joined the EU after 2004 and are covered by this study had adopted 
national law governing zoos before their accession to the EU.   

Table  11  lists  the  transposing  laws  and  regulations  adopted  by  Member  States  which  joined  the  EU 
after the entry into force of the Zoos Directive, according to their date of accession.   

Table 11: Adoption of transposing legislation in selected ‘new’ Member States (EU member since entry into force of 
the Zoos Directive) 

Member 
State 
BG  

CY 

CZ 

LT 

Transposing legislation 

 

 

2002 Biodiversity Act (amended in 2003 and 2006 to in-
clude  provisions  specific  to  zoo  licensing  and  animal 
keeping) 
Regulation 81/2002: The Animal Protection and Welfare 
Act 

  Act of 18 April 2003 on Conditions for the Operation of 

Zoological Gardens  
1997 Wildlife Protection Act (amended in 2010) 

 
  Order  No.  298  for  licensing  and  inspection  of  zoos 

(04/06/2002) 

  Order No. 346 for the standards for the keeping of wild 

animals in zoos (27/06/2002) 

PL 
Source: Data collected at national level (see country fiches, Annex II) 

  Nature Protection Act, ‘NPA’ (16/04/2004) 

Before  accession 
membership39 
 

to  EU 

 

 

 

 

4.1.5  Competent authorities for transposition and implementation 

Depending on the nature of the NIM (act, decree, order, etc.), various CAs are involved in the transpo-
sition  of  the  Directive:  national  parliaments,  ministerial  authorities,  etc.  Generally,  the  Ministry  of 
Environment  is  the  ministerial  authority  in  charge  of  the  transposition  (Bulgaria,  Cyprus,  the  Czech 

39 Cyprus, the Czech Republic, Lithuania, and Poland joined the EU on 1 May 2004. Bulgaria became an EU Member State on 1 January 
2007. 

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Republic, Germany, Denmark, France, Italy, Lithuania and Poland). 

In two Member States, transposition also occurs at Länder/regional level (Germany, Belgium). In Bel-
gium,  the  transposition  of  the  Directive  originally  took  place  at  federal  level.  However,  since  2014, 
regions  are  competent  to  enact  legislation  on  animal  welfare.  To  date,  and  until  regions  enact  new 
legislation on animal welfare, federal legislation continues to apply to zoos. In Germany, transposition 
takes place both at federal and Länder levels. Full transposition of the Directive in all 16 Länder was 
not fully achieved until 2005.  

In  two  Member  States  (Spain  and  Italy),  conflicts  have  occurred  between  CAs  at  different  levels 
(States/Regions  or  Communities)  regarding  the  transposition  of  the  Zoos  Directive.  Ultimately,  na-
tional courts ruled that State authorities are the competent transposing authorities.  

In general, the authorities competent for the implementation of the Zoos Directive (including licensing 
and inspection) are ministerial authorities and/or local authorities. CAs may be national or decentral-
ised and/or local agencies, and they may belong to various types of services (environmental, forestry, 
veterinary,  food).  In  most  of  the  Member  States,  the  Ministry of  Environment  is  responsible  for  the 
implementation of the Directive (Bulgaria, Czech Republic, Cyprus, Germany, France, Ireland, Lithu-
ania and Poland). In some Member States, Ministries dealing with other subject matters, such as agri-
culture, food or economic activity, may sometimes act as the main CA (Denmark and the Netherlands) 
or they may share competence on zoos with the Ministry of Environment (Belgium, Spain, Italy and 
Portugal). Implementation takes place at national or local level, or sometimes both. In seven Member 
States, regional and/or local authorities are competent to ensure the licensing and inspection of zoos 
(Belgium, Bulgaria, Germany, Spain, France, Lithuania and Poland).  

Table 12 below provides an overview of the authorities competent for the implementation of the Di-
rective. Enforcement authorities, competent for inspections, are presented in Table 16 in Section 5.1.1.   

Table 12: Competent authorities for the implementation of the Zoos Directive in the 14 selected Member States 

Member 
State 
BE 

BG 
CY 
CZ 
DE 

DK 
ES 
FR 

IE 

IT 

LT 

NL 

PL 

PT 

Implementation 

Regional authorities: Regional governments; regional Animal Welfare Services; Flanders Envi-
ronment,  Nature  and  Energy  Department;  Walloon  Department  for  Development;  Walloon 
Quality Directorate  
Ministry of Environment and Water; Regional Inspectorate of Environment and Water 
Veterinary Services of the Ministry of Agriculture, Rural Development and Environment 
Ministry of Environment 
Federal Ministry for the Environment, Nature Conservation 
Länder 
Ministry of Environment and Food; Danish Veterinary and Food Administration 
CAs of the Autonomous Communities  
Ministry of Environment:  
Departmental prefects; departmental veterinary services (licensing and inspection) 
National  Parks  and  Wildlife  Service  (of  Department  of  Arts,  Heritage,  Regional,  Rural  and 
Gaeltacht Affairs) under Minister for Arts, Heritage, Regional, Rural and Gaeltacht Affairs; 
Contracted zoo license inspectorate services 
Ministry  of  Environment,  Land  and  Sea  Protection;  Nature  and  Sea  Protection  Directorate; 
CITES Management Authority 
Nature Protection Agency under the Ministry of Environment; 
Regional Nature Protection Departments 
Netherlands Enterprise Agency under the Secretary of State of Economic Affairs; 
Food and Consumer Product Safety Authority  
Ministry of Environment; 
General  Directorate  for  Environmental  Protection;  Regional  Directorate  for  Environmental 
Protection  
National Authority for Animal Health (General Directorate for Food and Veterinary Medicine); 
Institute for Nature Conservation and Forestry 

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Source: Data collected at national level (see country fiches, Annex II) and surveys of MSCAs  

4.1.6  National case law 

Desk research found no national case law pertaining to the transposition of the Zoos Directive in 13 
of the 14 Member States surveyed. In Italy, however, conflicts arose between authorities at state and 
regional  level  regarding  the  attribution  of  competence  to  transpose  the  Zoos  Directive40.  The  Italian 
Constitutional Court ruled that the State is the only territorial entity competent to legislate in environ-
mental and zoo matters41. 

With  regard  to  the  implementation  of  the  Zoos  Directive,  relevant  court  cases  were  identified  in 
France, where the French national courts ruled on various matters relevant to zoo functioning, such as 
licensing or tax exemptions42. In addition, NGOs brought criminal complaints against various zoos for 
failure to respect the provisions transposing the Zoos Directive, particularly provisions on animal wel-
fare43. An example is provided in Box 1 below.  

Box 1: Example of case law at national level - France 

Tribunal Administratif de Limoges, 11 February 2016 - Ruling (Administrative Court) 

This case relates to the interpretation of the legislation transposing the Zoos Directive. 

In this case, the owner of two emus had seen his request to keep these animals rejected by the Prefect 
on the grounds that the plaintiff did not hold, contrary to Article 1 of the Order of 10 August 2004, the 
competence certificate requested to keep non-domestic animals pursuant to Article L413-2 of the En-
vironmental  Code.  The  plaintiff  challenged  the  applicability  of  Order  of  10  August  2004,  on  the 
grounds that he had had emus since 2003. The Limoges Administrative Court rejected the plaintiff’s 
argument. It held that, pursuant to Order of 10 August 2004, the possibility to keep emus was subject 
to Articles L413-2 and L413-3 of the Environmental Code and, as a result, to the retention of a compe-
tence certificate. More importantly, the Court held that the fact that the owner had the animals before 
the entry into force of Order of 10 August 2004 did not preclude the application of this Order. Fur-
thermore, the Order could not provide for a different set of rules applicable to persons owning non-
domestic animals before its entry into force. 

Further detail on national case law can be found in the country fiches (Annex II).  

4.2  STATE OF PLAY: INFRINGEMENTS PURSUED AT EU LEVEL 

The following paragraphs describe the EU infringement procedures which took place in the context of 
the implementation of the Zoos Directive in the 14 Member States surveyed for this study.  

Overall, there have been 17 cases of infringement against all selected Member States except Belgium, 
Bulgaria, the Czech Republic, Lithuania and Poland44 (Table 14). All cases are now closed. 

Most infringements related to the late transposition of the Zoos Directive or to non-communication 
of national implementing rules. Pursuant to Article 9(1) of the Zoos Directive, Member States were 
required to transpose the Directive into their national law by 9 April 2002 and to inform the Commis-

40 Corte Costituzionale Italiana, Sentenza n. 220/2008, Pubblicazione in G. U. 25/06/2008  n. 27, available at: 
http://www.cortecostituzionale.it/actionSchedaPronuncia.do?anno=2008&numero=220 (accessed October 2016); Corte Costituzionale 
Italiana, Sentenza n. 387/2008, Pubblicazione in G. U. 03/12/2008  n. 50, available at: 
http://www.cortecostituzionale.it/actionSchedaPronuncia.do?anno=2008&numero=387 (accessed October 2016). 
41 Corte Costituzionale Italiana, Sentenza n. 387/2008. 
42 Cass (crim), 4 October 2011, n°11-80198; Tribunal Administratif de Limoges, 11 February 2016, M. A…, n° 1300852. 
43 See Criminal complaint against the Strasbourg Zoo for violation of Order of 25 March 2004 and Directive 1999/22/E (2013). 
44 This includes cases of infringements by all Member States covered by this study until 10 March 2016. There have been 21 cases of in-
fringement of the Zoos Directive overall by all 28 Member States. This information was collected from the Commission database on in-
fringements.  

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sion  thereof  immediately.  They  were  also  required  to  communicate  the  main  provisions  of  national 
law adopted in the field covered by the Zoos Directive45. 
In  2002,  the  European  Commission  launched  an  infringement  procedure  for  non-communication  of 
NIMs against eight Member States (Germany, Denmark, Spain, France, Ireland, Italy, the Netherlands 
and Portugal). In the case of France and the Netherlands, although they had transposed the Zoos Di-
rective in due time, they  had failed to communicate the main provisions of national law transposing 
the Directive to the European Commission. In the remaining six cases, Member States did not trans-
pose the Zoos Directive on time (Germany, Denmark, Spain, Ireland, Italy and Portugal). For instance, 
Italy  transposed  the  Zoos  Directive  in  May  2005,  three  years  after  the  deadline  imposed  by  the  Di-
rective. In the infringement procedure against Germany, the Zoos Directive was supposed to be trans-
posed at both federal and Länder levels. While the federal authorities transposed the provisions of the 
Directive  falling  under  their  responsibility  within  the  deadline  of  the  Directive,  a  number  of  Länder 
did not transpose the rest of the Directive until 2005.  

The  European  Commission  launched  an  infringement  procedure  for  non-conformity  with  the  Zoos 
Directive  against  one  Member  State  (Italy).  This  infringement  procedure  related  to  the  definition  of 
zoos  in  national  law.  Italian  Legislative  Decree  No  73  of  21  March  2005  excluded  establishments 
which  did  not  pursue  the  objective  of  protecting  biodiversity  and  wild  fauna  from  the  definition  of 
zoos, meaning that its scope did not conform to the scope of the Zoos Directive. In 2008, Italy amend-
ed Legislative Decree No 73, thus resolving the non-conformity. 

Other  infringements  were  launched  by  the  European  Commission  for  bad  application  of  the  Di-
rective, following complaints from stakeholders (Members of the European Parliament) or on its own 
initiative. Additional information on these cases is provided in Table 13 below. 

The European Commission referred five cases to the European Court of Justice (CJEU) for two types 
of infringement. Firstly, it referred four Member States (Germany, Spain, Ireland and Italy) for non-
communication (failure to adopt the laws, regulations, and administrative provisions necessary to im-
plement the Zoos Directive; failure to notify NIMs to the European Commission)46. The Court decided 
in favour of the Commission in two cases (Germany and Italy), while in the remaining two cases, the 
European Commission withdrew its application following the notification of their NIMs by Spain and 
Ireland. Secondly, the Commission referred one Member State (Spain) for failure to comply with its 
obligations under the Zoos Directive. The Court decided in favour of the European Commission47.   

The  European  Commission  launched  a  second  infringement  procedure  against  two  Member  States 
(Spain and Italy) for failing to comply with judgments of the CJEU (Article 260 procedure).  

Table 13 presents the infringement procedures initiated against the 14 Member States within the scope 
of the analysis. It provides information on the type of infringement and the latest stage of the EU pro-
cedure reached before closure. All of these cases are now closed. 

Table 13: EU infringement cases for non-compliance with the Zoos Directive 

Member 
State 
BE 
BG 

CY 

Period 

Infringement 

Facts 

- 
- 

2004  
– 
2005 

- 
- 
Bad  application  of 
Zoos  Directive  (ille-
functioning  of 
gal 
the Limassol Zoo) 

- 
- 
A  complaint  from  an  MEP 
highlighted  that  the  Limas-
sol  Zoo  was  operating  with-
out a licence 

Last stage of procedure 

- 
- 
Request for information 

45 Article 9(2) Zoos Directive. 
46 Judgment of 14 October 2004 in Case C-339/03 Commission v Germany ECLI:EU:C:2004:634; Case C-256/03 Commission v Ireland; 
Judgment of 10 June 2004 in Case C-302/03 Commission v Italy ECLI:EU:C:2004:368; Case C-298/03 Commission v Spain.  
47 Judgment of 9 December 2010 in Case C-340/09 Commission v Spain.  

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Member 
State 

Period 

Infringement 

Facts 

Bad  application  of 
Zoos  Directive  (ille-
gal 
functioning  of 
the Limassol Zoo)  

2009  
– 
2012 

CZ 

- 

- 
Non-communication 
of NIMs  

DE 

DK 

ES 

FR 

IE 

IT 

2002  
– 
2005 

2002  
– 
2003 
2002  
–  
2003 

2002  
–  
2003 

2006  
– 
2010 

2010  
– 
2013 

2002 

2002  
– 
2004 
2003  
– 
2004 
2002   
- 
2005 

2006 

2007  
– 
2008 

Non-communication 
of NIMs 

Non-communication 
of NIMs 

Bad  application  of 
the  Zoos  Directive 
(poor  animal  condi-
tions in the  Valencia 
Zoo) (complaint) 
Bad  application  of 
the  Zoos  Directive 
(poor  animal  condi-
tions  in  various  zoos) 
(complaint) 
Failure  to  implement 
CJEU ruling50  

Non-communication 
of NIMs 
Non-communication 
of NIMs 

Non-communication 
of NIMs (complaint) 

Non-communication 
of NIMs  

Failure  to  implement 
CJEU  ruling52  (com-
plaint) 
Non-conformity  with 
Zoos Directive 

Contrary  to  their  response 
to  the  European  Commis-
sion  in  the  2004  case,  the 
local  authorities  did  not 
close  Limassol  Zoo  and 
planned to expand it 
- 
Germany  did  not  transpose 
the  Zoos  Directive  in  due 
time.  The  transposition  of 
the  Zoos  Directive  occurred 
at  two  levels  –  federal  and 
Länder.  Some  Länder  were 
late  to  transpose  the  Zoos 
Directive  (latest  NIM  was  in 
2005)  
Denmark  did  not  transpose 
the  Zoos  Directive  in  due 
time 
Spain  did  not  transpose  the 
Zoos Directive in due time 

A  complaint  from  an  MEP 
raised  the 
living 
conditions  of  animals  in  the 
Valencia Zoo 

issue  of 

Complaint  raising  the  issue 
of  living  conditions  of  ani-
mals in various zoos – failure 
in the licensing system 

ruling  on 

Spain  failed  to  comply  with 
CJEU 
licensing 
issues 
France  failed  to  notify  all of 
its NIMs in due time 
Ireland  did  not  transpose 
the  Zoos  Directive  in  due 
time 
Ireland  did  not  transpose 
the  Zoos  Directive  in  due 
time 
Italy  did  not  transpose  the 
Zoos Directive in due time 

Despite the CJEU ruling, Italy 
late  to 
continued  to  be 
transpose the Zoos Directive 
The  scope  of  the 
Italian 
transposing  legislation  (Leg-
islative  Decree  No  73)  was 
too restrictive and excluded 

48 Judgment of 14 October 2004 in Case C-339/03 Commission v Germany ECLI:EU:C:2004:634. 
49 Judgment of 9 December 2010 in Case C-340/09 Commission v Spain. 
50 Judgment of 9 December 2010 in Case C-340/09 Commission v Spain. 
51 Judgment of 10 June 2004 in Case C-302/03 Commission v Italy ECLI:EU:C:2004:368. 
52 Judgment of 10 June 2004 in Case C-302/03 Commission v Italy ECLI:EU:C:2004:368. 

Last stage of procedure 

Letter of formal notice 

- 
CJEU)  ruling 
European Commission48 

in  favour  of 

Reasoned opinion 

Referred 
drawn in 2003) 

to  CJEU 

(with-

Request for information 

ruling 

CJEU 
European Commission49 

in 

favour  of 

Second  Letter  of 
notice 

formal 

Letter of formal notice 

Referred 
drawn in 2003) 

to  CJEU 

(with-

Referred 
drawn in 2003) 

to  CJEU 

(with-

formal 
Second  Letter  of 
notice  following  failure  to 
implement CJEU ruling51 
Second  Letter  of 
notice  

formal 

Reasoned opinion 

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Member 
State 

Period 

Infringement 

Facts 

Last stage of procedure 

LT 

NL 

PL 

PT 

- 

2002 

- 
2002  
– 
2003 
2009 

- 
Non-communication 
of NIMs 
- 
Non-communication 
of NIMs 

Complaint 

some  establishments  from 
being  covered  by  the  Zoos 
Directive  
- 
The  Netherlands  failed  to 
notify its NIMs in due time 
- 
Portugal  did  not  transpose 
the  Zoos  Directive  in  due 
time 
- 

- 
Letter of formal notice 

- 
Reasoned opinion 

- 

Source: Information collected from the Commission database on infringements 

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5  RESULTS: ANALYSIS AND DISCUSSION OF EVALUATION QUESTIONS 

The results of the analysis of the literature and documentation review, and the targeted and public con-
sultation are presented below. The reporting follows the evaluation criteria and questions presented in 
Section 3.2, and the elements of the evaluation framework presented in Annex I.   

5.1  Effectiveness 

This section is intended to: assess the extent to which the general and specific objectives of the Zoos 
Directive have been achieved; identify any significant factors that may have contributed to, or inhibit-
ed progress towards, meeting those objectives; and investigate any negative or positive changes pro-
duced beyond the intended effects of the Zoos Directive. 

In order to assess the achievement of the objectives pursued under the Zoos Directive, the analysis was 
carried  out  according  to  the  intervention  logic  presented  above  and  the  related  indicators  of  output, 
result and impact. More specifically, the supporting study aimed to analyse the following:  

  Actions  taken  in  the  14  selected  Member  States  to  ensure  the  implementation  of  the  different 
conservation  measures foreseen by the Directive  across European  zoos, and to address  cases of 
non-compliance and handle zoo closures (output). 

  The  results  achieved,  looking  at  the  actual  implementation  of  conservation  measures  by  zoos 

operating in the 14 Member States, and how zoo closures have been handled in practice (result).  

  The broader contribution of the Zoos Directive to the protection of wild fauna and conservation of 

biodiversity (impact).  

The first two points were addressed by EQ 1 (Section 5.1.1). This addressed the systems for inspec-
tion and licensing set up in the 14 Member States, and discussed the extent to which these systems are 
suitable to ensure an effective and consistent enforcement of the zoo legislation, the progress made in 
terms of licensing and inspection procedures, and the issues encountered. In parallel, the results of the 
survey addressed to zoos (although not representative of the whole population of zoo operators in the 
selected Member States53), offered insights and real life examples of the results achieved in terms of 
implementation of conservation measures, from a sample of 70 zoos. 

EQ 2 (Section 5.1.2) addressed the broader impacts of the Zoos Directive, i.e. its contribution towards 
conservation of biodiversity and protection of wild fauna. Here, the analysis examined the effects that 
conservation  measures defined in Article 3  are expected to produce, based on existing  evidence and 
relevant literature, and assessed the possible contribution of the Directive to the biodiversity goals set 
at EU and international level.   

Following the discussion of the achievements of the Zoos Directive,  EQ 3 (Section  5.1.3) discusses 
the factors that have contributed to, or hindered, progress to date. The factors analysed related to the 
Zoos  Directive  itself  and  its  transposition  in  the  14  Member  States,  the  activities  designed  to  bring 
about the expected effects (i.e. actions to be undertaken by the Member State authorities), and external 
factors such as stakeholder actions, developments in the public opinion, etc. 

Finally, other effects beyond the objectives specifically pursued, are identified from stakeholder inputs 
(EQ 4, Section 5.1.4).  

5.1.1  Effectiveness – EQ 1 

What progress has been made over time towards achieving the objectives set out in the Directive? To 
what  extent  is  this  progress  in  line  with  initial  expectations?  In  particular,  what  progress  has  been 

53 See Section 3.5.1 on this point.  

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made to achieve the conservation measures set out in Article 3? To what extent have adequate licens-
ing and inspection systems been put in place? 

The general objective of the Zoos Directive is ‘to protect wild fauna and to conserve biodiversity by 
strengthening the role of zoos in the conservation of biodiversity’ in the EU.  

In order to achieve these general objectives, the Zoos Directive requires Member States to establish a 
licensing and inspection system, ensuring that zoos implement a set of conservation measures (Article 
3). In order to obtain and keep the licence and, therefore, to operate and be open to the public, zoos are 
required to:  

 

 

Participate in one or more of the following: i) research and training through which conservation 
objectives  may  be  achieved;  ii)  exchange  of  information  relating  to  species  conservation;  iii) 
captive  breeding;  iv)  repopulation;  or  v)  reintroduction  of  species  into  the  wild  (Article  3  first 
indent). 
Promote  public  education  and  awareness  in  relation  to  the  conservation  of  biodiversity, 
particularly  by  providing  information  about  the  species  exhibited  and  their  natural  habitats 
(Article 3 second indent). 

  Accommodate  animals  under  conditions  which  aim  to  satisfy  the  biological  and  conservation 
requirements of the individual species and maintain a high standard of animal husbandry (Article 
3 third indent). 
Prevent  the  escape  of  animals  in  order  to  avoid  threats  to  indigenous  species  and  intrusion  of 
outside pest and vermin (Article 3 fourth indent). 

 

  Keep appropriate records of the zoo’s collection (Article 3 fifth indent). 

In  addition,  in  cases  of  closure  of  a  zoo  or  part  thereof,  the  Member  State  authorities  must  take 
measures to ensure that animals are treated or disposed of under appropriate conditions (Article 6). 

In line with the intervention logic, and in order to evaluate the progress made in achieving the objec-
tives of the Directive, this analysis focuses primarily on the systems for inspection and licensing set up 
in the 14 representative Member States in order to assess the extent to which the national authorities 
can ensure that the conservation measures set out in Article 3 are implemented by zoos. The existence 
of  effective  and  adequate  licensing  and  inspection  systems  is,  indeed,  expected  to  ensure  that  only 
those  zoos  that  are  compliant  with  the  Zoos  Directive  (and  which  implement  its  conservation 
measures) are allowed to operate. As detailed in the evaluation framework  (See Annex I), the effec-
tiveness and adequacy of the national licensing and inspection systems are evaluated against a large 
set of assessment criteria, notably: the setting up of a system compliant with the requirements of the 
Zoos Directive (e.g. designation of the CA, definition of a system to carry out controls before granting, 
extending or significantly amending  a  licence,  etc.);  the frequency  of regular inspections;  the use of 
clear and explicit criteria to assess the conservation measures implemented by zoos; the overall pro-
gress achieved in performing the licensing and inspection procedures at national level (i.e. number of 
licensed zoos compared to the total number of identified zoos, the timing for completing inspections 
and  licensing  procedures  following  the  entry  into  force  of  the  Directive);  the  capabilities  (e.g. 
knowledge of the inspectors); and improvement actions undertaken.  

The overall analysis draws on several sources: the responses by Member States authorities and zoos to 
the targeted questionnaires circulated  for the purposes of this study; the interviews with national au-
thorities and other national stakeholders (i.e. zoo federations and NGOs dealing with biodiversity con-
servation/animal  welfare);  interviews  with  stakeholders  acting  at  EU  level;  desk  research  (including 
national  legislation,  documents  provided  by  Member  State  authorities  in  relation  to  the  inspection 
system; documents provided by zoos and retrievable on the web, in relation to research and education 
strategies  implemented,  and  other  general  literature).  The  results  of  the  public  consultation  are  also 
integrated.  

As mentioned in Section 3.5, two main limitations apply: data provided by Member State authorities 

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on  the  performance  of  the  licensing  and  inspection  system  are  not  reliable  in  all  cases  and  are  not 
comparable  across Member States.  They are  also limited  to  the  most recent  years.  These  limitations 
are closely linked to the lack of any reporting obligation for the Member States on the implementation 
of the Zoos Directive. In addition, the results of the questionnaire addressed to zoos are partly biased 
by the higher representation of zoos belonging to zoos’ federations. Such survey results are, therefore, 
used solely as illustrations, while the overall of assessment of the effectiveness of the Zoos Directive 
is  based  on  the  combination  of  several  sources  and  draws  on  the  analysis  of  the  key  features  of  the 
licensing and inspection systems set up by the Member States.   

5.1.1.1  Overview  of  the  national  licensing  and  inspection  systems  and  provisions 

aimed at ensuring that conservation measures are implemented by zoos 

In order to ensure that all zoos implement the conservation measures of Article 3 and meet the objec-
tives of the Zoos Directive, Member States are required to:  

 

 

Identify the CAs for the purposes of the Directive (Article 7). 
Set up an adequate licensing and inspection regime (Articles 4 and 5), along with a procedure for 
the closure of zoos in cases of non-compliance (Articles 4, fifth indent and Article 6). 

  Define a system of effective,  proportionate and dissuasive penalties for breaches  of compliance 

(Article 8). 

On  this  basis,  each  Member  State  has  established  CA(s)  responsible  for  the  overall  application  and 
enforcement  of  the  Zoos  Directive,  and  has  defined  the  system  for  inspecting  the  zoos:  (a)  before 
granting or refusing a licence, extending the period of a valid licence or significantly amending it; (b) 
on a regular basis, for the purposes of monitoring the application of the legislation.  

The following sections provide an overview of the licensing and inspection system implemented in the 
14 Member States within the scope of the supporting study. Particular attention is paid to the legisla-
tive provisions and practices of the Member States aimed at ensuring that conservation measures set 
out in Article 3 of the Zoos Directive are implemented by zoos. 

a.  CAs and organisation of the licensing and inspection system 

Across  the  14  Member  States,  CAs  for  the  implementation  of  the  Zoos  Directive  are  found  within 
various  departments,  either  dealing  with  environmental  and  biodiversity  issues  or  focused  on  food 
security  and  agricultural  matters.  In  most  Member  States,  the  Ministry  of  Environment  (Bulgaria, 
Czech  Republic,  Germany54,  France,  Ireland55,  Italy,  Lithuania  and  Poland)  is  generally  responsible 
for the implementation of the Directive, while in some others, Ministries dealing with Agriculture and 
Food act as MSCAs (Belgium, Cyprus, Denmark, Spain and Portugal56)57.  

In both cases, veterinary and animal welfare services (chiefly national, but also regional and local lev-
el) are normally involved in the enforcement of the legislation on the ground, by supporting the CA in 
the inspection of zoos (for the issuing of licences and for monitoring purposes), or in the detection of 
potential irregularities and breaches of the legislation58.  

54 In the 16 Federal States.  
55 CA is the Department of Arts, Heritage, Regional, Rural and Gaeltacht Affairs, which has taken over some of the competences previous 
attributed to the Ministry of Environment.  
56 CA is the Directorate General of Veterinary Medicine (Direção Geral de Alimentação e Veterinária - DGAV), which falls under the juris-
diction of the Ministry of Agriculture, Sea, Environment and Planning. The Institute of Nature Conservation and Biodiversity (Instituto da 
Conservação da Natureza e Florestas - I.C.N.F) is also involved.  
57 A specific case is represented by the Netherlands, where responsibility is under the Ministry of Economic Affairs, supported by the Neth-
erlands Enterprise Agency (RVO), while inspection and enforcement is attributed to the Food and Consumer Product Safety Authority 
(NVWA). 
58 This is the case in 11 Member States: Belgium, Bulgaria, Cyprus, Czech Republic, Germany, Denmark, France, Italy, the Netherlands and 
Portugal. 

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Table 14 below provides an overview of the approaches adopted by the 14 Member States to allocate 
competences for inspections. In general terms, Member States have implemented quite differentiated 
systems for the implementation and enforcement of the Zoos Directive, bringing together authorities 
with different competences and acting at national, regional and local level.  

Given the nature of the activities to be carried out, some Member States defer to external experts with 
appropriate technical knowledge (Bulgaria, Belgium, Czech Republic, and the Netherlands; Denmark 
for licensing or amendments to the licence; or depending on the need, France, Spain and Poland). In 
the Netherlands and Poland, zoo federations at national and/or European and  international level (i.e. 
EAZA and WAZA respectively) participate in the inspection teams. A specific case is represented by 
the Netherlands,  whose system allows for  zoos that are members of EAZA or NVD (the Dutch Zoo 
Federation)  to  be  inspected  by  EAZA/NVD  inspectors.  Based  on  their  report,  the  MSCAs  decide 
whether or not further inspection is needed.  

Table 14: Overview of the institutions, authorities and external bodies involved in inspections 

Member 
State 
BG 

BE 

CY 

CZ 

DE 

ES 
DK 

FR 

IE 

IT 

Institution(s) or CA(s) responsible for inspect-
ing zoos 
Ministry of Environment and Water, Ministry of 
Agriculture and Food, Regional Inspectorate 
of  Environment  and  Water,  Regional  Veteri-
nary  Office  for  Licences.  The  Regional  In-
spectorate  of  Environment  and  Water  is  re-
sponsible  for  conducting  regular  inspections 
in zoos, after licensing 
Animal  Welfare  Service  and  the  Animal 
Welfare Inspection Service (Flanders). 
Département Police et Contrôle (Wallonie). 
Ministry of Agriculture, Natural Resources and 
Environment,  Department  of  Veterinary  Ser-
vices and District Veterinary Office 
Commission  for  Zoos  of  the  Ministry  of  the 
Environment, Department  of Species Protec-
tion  and  the 
Internal 
Commitments;  Czech  Environmental  Inspec-
torate,  State  (and/or  Regional)  Veterinary 
Administration 

Implementation  of 

Federal  Ministry  for  the  Environment,  Nature 
Conservation,  Building  and  Nuclear  Safety  is 
responsible  for  the  Zoos  Directive  on  the 
Federal  Level.  Authorities  for  the  conserva-
tion of nature and veterinary authorities can 
be involved (depending on the State) 
CA of each Autonomous Community 
Danish Veterinary and Food Administration 

Local  veterinary  services  (Directions  dépar-
tementales  de  la  protection  des  popula-
tions), in coordination with the national office 
of hunting and wildlife (Office national de la 
chasse et de la faune sauvage) 
National  Parks  and  Wildlife  Service,  through 
contracted zoo license inspectorate services 
for  the  Minister  for  the  Department  of  Arts, 
Heritage,  Regional,  Rural  and  Gaeltacht 
Affairs 
Zoo  Commission  made  up  of  at  least  one 
component  from  three  ministries:  Ministry  of 
Environment,  Ministry  of  Agriculture  and  the 

Other (non-governmental) bodies involved in 
inspections/providing ad hoc advice 
Bulgarian  Academy  of  Science,  Institute  of 
Biodiversity  and  Ecosystem  Research  (for 
assessing  enclosures  and  the  environment 
created for the animals) 

Members  of  the  Zoo  Commission  appointed 
every five years.  

No 

Commission  for  Zoological  Gardens  as  an 
advisory  body  of  the  Ministry  of  the  Environ-
ment. Members of the Commission are nom-
inated  by  the  Ministry  of  Agriculture,  the 
State  Veterinary  Administration,  the  Union  of 
Czech  and  Slovak  Zoological  Gardens  and 
the Czech Environmental Inspectorate 
Only in exceptional circumstances 

Depending on the Communities 
Advising experts (external) required for a zoo 
licence or amendment 
Network of experts attached to the National 
Museum of Natural History  

No 

No 

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Member 
State 

LT 

NL 

PL 

PT 

Forest 

Department 

Institution(s) or CA(s) responsible for inspect-
ing zoos 
Ministry of Health 
National 
(Corpo 
Forestale) acts as the enforcement authority, 
detecting  potentially  irregular  entitles  and 
referring these to the Ministry of Environment  
Ministry  of  Environment 
is  responsible.  Li-
cences  are  granted  by  the  Nature  Protec-
tion  Agency  and  Regional  Environmental 
Protection Department 
Netherlands  Enterprise  Agency  (RVO)  and 
the  Food  and  Consumer  Product  Safety  Au-
thority (NVWA), assisted by external experts 

Regional  Director  for  Environmental  Protec-
tion competent for the location of the zoo 

Directorate  General  of  Veterinary  Medicine 
(DGAV) and Institute of Nature Conservation 
and Biodiversity (ICNF)  

Other (non-governmental) bodies involved in 
inspections/providing ad hoc advice 

No 

Board 

The  Advisory 
(visitatiecommissie 
dierentuinen)  includes  members  of  the  RVO, 
the NVWA and external zoo experts.  
EAZA/NVD  members  are  inspected  by  EA-
ZA/NVD  inspectors;  RVO  decides  if  NVWA 
inspectors  need  to  carry  out  further  inspec-
tions 
An  opinion  from  the  association  of  repre-
sentatives of zoos is obtained, the Council of 
Directors of Polish Zoos and Aquaria 
If needed 

Source: Data collected at national level (see country fiches, Annex II) and survey of MSCAs  

Differences  across  Member  States  can  also  be  seen  in  the  inspection  process  and  frequency.  The 
Zoos Directive does not determine the frequency of ‘regular inspections’, nor does it specify the dura-
tion of licences. An overview of the situation in the 14 selected Member States is presented in Table 
15 below. In nine of the 14 Member States, licences are issued for indefinite (unlimited) time. Annual 
inspections have been established in seven of the 14 Member States, while three inspect zoos biannu-
ally  and  three  inspect  every  three  years.  Belgium  inspects  25%  of  the  zoos  annually,  meaning  that 
each zoo is inspected only every four years. A risk-based system providing for additional inspections 
has  been  established  by  Germany  and  the  Netherlands.  One  criterion  for  targeted  inspections  is  the 
zoos’ membership of EAZA or other organisation(s) In the Netherlands, inspections are less frequent 
in zoos that are members of the national zoo federation NVD, because compliance issues are less fre-
quently  observed  in  these  zoos.  This  target-based  approach  reduces  the  burden  on  inspection  re-
sources. 

Table 15: Duration of licences and indicated frequency of inspections59 

Member 
State 
BG 

BE 

Cyprus 
CZ 
DE 

ES 
DK 
FR 
IE 

Duration of the licence 

Frequency of inspections 

First  licence:  five  years;  consecutive 
license: from five to 10 years 
Unlimited  (restrictions  may  apply  de-
pending  on  the  number  of  species  of 
animals) 
Five years 
Two years 
Unlimited 

Annual (at least) 

Annual (limited to at least 25% of the zoos) 
Twice per year 
Biannual 
Annual (or more frequently, depending on irreg-
ularities or shortcoming observed)  

Not specified in the national legislation  Annual (at least) 
Unlimited 
Unlimited 
Up to five years 

Annual 
Annual (at least) 
Annual 

59 Based on MSCA questionnaire. 

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Member 
State 

Duration of the licence 

Frequency of inspections 

(first  licence:  two  years;  subsequent 
licences: three years) 
Unlimited 
Unlimited 
Unlimited 
Unlimited 
Unlimited 

IT 
LT 
NL 
PL 
PT 
Source: Legal review and survey of MSCAs  

Annual (at least) 
Biannual 
Every three years 
Every three years 
Every three years 

In seven Member States (Bulgaria, Spain, France, Ireland, Italy, Poland and Portugal), the inspections 
are structured in two steps, including a preliminary audit of documentation supplied by the zoos to the 
authorities, followed by an on-site visit60.  

b.  Inspection systems and provisions ensuring that zoos apply conservation measures (Article 3) 

According to the questionnaire responses supplied by the MSCAs and based on an analysis of the rel-
evant  national  legislation  in  the  14  Member  States,  inspection  related  requirements  cover  the  re-
quirements applicable to zoos under Article 3 of the Directive. However, Member States differ in 
their implementation of the national legislation, with different systems for inspection and verifica-
tion of compliance of zoos with the requirements.  

Several elements characterise the inspection systems and can impact the overall quality of the inspec-
tion process61: 

  Use  of  inspection  protocols  and  elements  checked  during  the  inspections:  Inspection  forms, 
which  offer  a  structured  inspection,  exist  in  seven  of  the  14  Member  States  (Belgium,  Cyprus, 
Czech Republic, Spain, Ireland, the Netherlands and Portugal), while in some countries the law 
itself  contains  detailed  guidance  (Bulgaria,  Lithuania,  Italy  and  Poland).  In  France,  there  is  no 
inspection  form  as  such,  but  a  circular  issued  by  the  Ministry  on  the  conditions  for  granting  a 
certificate  of  capacity  includes  a  form  listing  the  information/evidence  to  be  provided  if  such  a 
certificate is to be granted.   
The  forms  differ  greatly  in  layout  and  approach,  but  each  contains  the  conservation  measures 
mentioned  in  Article  3  of  the  Zoos  Directive.  Additional  requirements  (notably  on  safety  and 
hygiene  measures  for  the  public,  and  standards  for  animal  welfare)  are  defined  by  several 
Member  States  (inspection  forms  or  provisions  in  legislation,  in  Bulgaria,  Belgium,  Cyprus, 
Czech Republic, France, Ireland, Italy, the Netherlands, Portugal and Spain).  

  Use of external experts: Six Member States (Bulgaria, Belgium, Czech Republic, Denmark, the 
Netherlands and Poland) use external experts, mostly from zoo associations or retired zoo experts 
that participate on a personal basis in  zoo commissions, to ensure independence.  In other  cases 
(France, Spain, Germany and Portugal), external experts are mobilised depending on the need or 
the local body competent for the inspections. A specific case is represented by Ireland, where the 
zoo inspectorate is appointed on a contract basis.  
As discussed in more detail in Section 5.1.1.2, a recurring issue is that zoos require specific skills 
and knowledge if they are to be adequately inspected. The use of external experts is considered 
good  practice62  and  is  supported  by  the  zoo  community,  as  a  means  of  addressing  the  need  for 

60 Information required might include: animal stock details, list of enclosures and their features, organigram, documents on education and 
conservation strategies, environmental enrichment measures. 
61 The elements of the inspection systems analysed in this paragraph have been defined on the basis of the analysis performed during the 
current evaluation and the main elements of differentiation encountered in the national systems. The EU Zoos Directive Good Practices 
Document has been taken as a point of reference. It should be noticed that the elements discussed in this paragraph (inspection forms, use of 
external experts, guidance) are not requirements of the Zoos Directive, but have been investigated as indicators to assess the adequacy of the 
licensing and inspection systems set up. 
62 See the Good Practices Document (VetEffecT 2015).  

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specialist expertise on animals in captivity. 

  Availability  of  a  centralised  zoo  database:  Although  there  is  no  requirement  in  the  Zoos 
Directive,  the  availability of  a  centralised  database  might  add  to  the  quality  of  zoo  inspections. 
Such  a  database  might  contain,  for  example,  inspection  protocols,  past  inspections,  guidance 
documents,  and  information  on  zoo  closures  (and  would  be,  for  example,  also  accessible  to 
regional  authorities).  Several  countries  (Czech  Republic,  Denmark,  the  Netherlands,  Poland, 
Portugal and Spain) have a public website that specifies the licensed zoos (even if it is not always 
up to date). According to the replies to the targeted questionnaire, only five Member States have 
gone  beyond  that  and  use  a  centralised  database  as  specified  above  (Czech  Republic,  Cyprus, 
Ireland, Poland and Portugal).  

Table 16 recaps the key characteristics of the inspection system in each Member State, according to 
these three elements.  

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Table 16: Key features of the national inspection systems 

Article 3 conservation measures addressed in inspection 
forms 

Other requirements 

Use of 
external 
experts 

Centralised 
database 

Website 
listing 
licensed 
zoos 

Partici
pa-
ting in 
resear
ch 
and/or 
trainin
g 
and/or 
excha
nge of 
inform
ation 
and/or 
captiv
e 
breedi
ng, 
etc. 

Promo-
ting 
public 
educatio
n and 
awarenes
s 

Accommoda-
tion and 
husbandry of 
animals 

Preven-
ting the 
escape 
of 
animals 
and 
intrusion 
of 
outside 
pests 
and 
vermin 

Keeping 
up-to-
date 
records  

Safety 
and 
hygie-
ne for 
the 
public 

Animal 
health 
and/or 
welfare 

Yes 

Yes 

Yes 

Yes 

Yes 

Yes 

Yes 

Yes 

No 

No 

Yes 

No 

Yes 

Yes 

Yes 

Yes 

Yes 

Yes 

No 

No  

Yes 

No 

Yes 

Yes 

Yes 

Yes 

Yes 

No 

Yes 

No 

Yes 

Yes  

Yes 

Yes 

Yes 

Yes 

Yes 

Yes 

Yes 

Yes 

Evaluation Study to support the evaluation of the Zoos Directive/ 79 

Member 
State 

National 
inspection 
form 
available? 

Reference 

Ordinance № 
1 of 9.05.2006 
for licensing 
zoos 

Rapport de 
control parc 
zoologique 
(FR/NL) 
Zoo 
Inspection 
Form 
Protocol 
according to 
law 

BG 

NO (detail 
in law) 

BE 

YES 

CY 

YES 

CZ 

YES 

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DE 

ES 

DK 
FR 

IE 

IT 

LT 

NL 
PL 

PT 

NO 
(Regional 
authorities 
are 
responsible
) 
YES 

NO 
NO 
(regional 
information 
notes) 
YES 

NO (detail 
in law) 
NO (detail 
in law) 
YES* 
NO (detail 
in law) 
YES 

162/2003Sb  
- 

Protocol of 
inspection 
and 
evaluation of 
zoos 
- 
Information 
Notice for zoo 
certificate 

Zoo Licence 
Guidance 
Notes 

- 

N/A*  
- 

Zoos 
Inspection 
Protocol 

- 

- 

- 

- 

- 

- 

- 

No**  

No 

No 

Yes 

No 

Yes 

Yes 

Yes 

Yes 

Yes 

No** 

No 

Yes 

- 
- 

- 
- 

- 
- 

- 
- 

- 
- 

- 
- 

- 
- 

Yes  
No** 

No 
No 

Yes 

Yes  

Yes 

Yes 

Yes 

Yes 

Yes 

No*** 

Yes 

No 

No 

Yes 

Yes 

Yes 

Yes 

Yes 

- 

Yes 
- 

- 

- 
- 

- 

- 
- 

- 

- 
- 

- 

- 
- 

- 

Yes 
- 

- 

- 
- 

No 

No 

Yes 
Yes  

Yes 

Yes 

Yes 

Yes 

Yes 

Yes 

Yes 

No** 

No 

No 

No 
Yes 

Yes 

Yes 
No 

No 

No 

No 

Yes  
Yes 

Yes 

Source: This study 
*Not publicly available; **If needed/depending on the local bodies; ***IE has completely outsourced its zoo inspections.

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It is also important to understand the level of detail in the protocols for inspection, and how fulfilment 
of  the  requirements  of  Article  3  of  the  Zoos  Directive  is  checked,  in  practice,  during  inspections. 
While, as presented in Table 16, the requirements of Article 3 (i.e. the conservation  measures) are 
taken into account by eight of the 14 Member States in the inspection forms, they are rarely detailed 
and specified in terms of operational criteria and measurable parameters.  

In  Ireland63  and  the  Netherlands64,  guidance  documents  for  zoo  inspectors  were  identified  by  this 
study. In most of the surveyed Member States, no specific reference document for inspectors was re-
trieved and the assessment appears to depend almost entirely on the inspectors’ skills.  

This is especially the case of Article 3, first indent of the Zoos Directive, which defines a set of op-
tions available to zoos to implement conservation  measures:  participation in research from which 
conservation  benefits  accrue  to  the  species,  and/or  training  in  relevant  conservation  skills, 
and/or  exchange  of  information  relating  to  species  conservation,  and/or  captive  breeding,  re-
population or reintroduction of species into the wild.  

In their national law, most Member States have taken the approach of the Zoos Directive, by defining 
the measures listed in Article 3, first indent, as  alternative options, and by requiring zoos to imple-
ment at least one of them65. According to the information collected through interviews, in those Mem-
ber States where the options are considered alternatives, participation in research projects by zoos is 
sufficient  to  ensure  and  assess  their  conservation  role  while,  in  some  cases,  other  measures  such  as 
captive breeding, repopulation, and reintroduction of species into the wild are considered as optional 
alternatives  to  research  and  training  (e.g.  Belgium,  Bulgaria,  Cyprus,  Czech  Republic,  Ireland,  the 
Netherlands,  Spain  and  Portugal).  While  this  approach  allows  for  differences  among  zoos  and  their 
capacity, it also increases differentiation across the Member States. Little detail is available (in either 
the inspection form and/or the legislation) on the criteria used to assess whether or not the  inspected 
zoos  meet  the  requirements  of  Article  3,  first  indent,  and  can  be  qualified  as  conservation-oriented 
entities. These criteria are varied and include: lists of publications of the zoo; reports of specific activi-
ties carried out by the zoo; participation in EEP and ESBs; collaboration with universities; or results 
achieved over time (verifying the progress made since previous inspections).  

With  regard  to  the  promotion  of  public  education  and  awareness  of  conservation  of  biodiversity 
(Article 3, second indent), some countries require evidence to verify this fulfilment, e.g. presentation 
of a written education strategy/plan/programme, and the review of educational and information mate-
rial (signs, website, leaflets, presentations) (e.g. Ireland, Portugal and Spain).  

Different considerations apply when it comes to verification of the requirements related to the accom-
modation of animals and standards for animal husbandry (Article 3, third indent). Minimum standards 
for  the  accommodation  of  animals  are  mentioned  in  national  laws  in  a  few  Member  States  and  are 
binding (Bulgaria, Belgium66, Italy67, Lithuania68, and Poland69). Other Member States use guidelines 

63 Department of Arts, Heritage, Regional, Rural and Gaeltacht Affairs, Irish Standards of Modern Zoo Practice, 2016. One of the criteria 
used in the Irish Guide is that the conservation policy of the zoo should include consideration of how it relates to the World Zoo and Aquari-
um Conservation Strategy, and the type and level of input the zoo provides for national or international conservation programmes.   
64 Based on information provided by stakeholders. The document is not public.  
65 Exceptions are Bulgaria, Italy, Poland, Portugal, and France only in relation to zoos that host conservation sensitive species.  
66 Specific requirements for the keeping of mammals (Ministerial Order of 3 May 1999 laying down minimum standards for the keeping of 
mammals in zoos), birds (Ministerial Order of 7 June 2000 laying down minimum standards for the keeping of birds in zoos) and reptiles 
(Ministerial Order of 23 June 2004 laying down minimum standards for the keeping of reptiles in zoos). 
67 Legislative Decree 21 March 2005, n. 73, Annexes 1 and 2 specify a range of measures for animal welfare and veterinary care. The mini-
mum standards are only for the keeping of dolphins (tursiops truncatus) in zoos.  
68 Minimum standards for animal accommodation/enclosures are set out in Annex 4 on the Rules on Use of Wild Animals, approved by 
Order No D1-533/B1-310 of the Minister of Environment and the Director of State Food and Veterinary Service, as last amended on 24 April 
2014.  
69 Ordinance of the Minister of the Environment of 20 December 2004 on the conditions for breeding and keeping particular groups of ani-
mal species in zoos (Dz.U. of 2005 No. 5, item 32). The ordinance specifies the necessary rooms and technical equipment for the places 
where animals stay, as well as minimum spatial conditions for breeding and keeping animals of particular species or groups of species, as 
well as the necessary conditions for reproducing animals. 

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which are not legally binding (Germany70 and Ireland71). Across the Member States, major emphasis is 
placed on the size of the enclosures and animal health (e.g. provision of veterinary medical care, feed-
ing  plans,  measures  for  hygiene).  These  standards  or  guidelines  generally  focus  on  animal  welfare 
aspects that go beyond the objectives and provisions of the Zoos Directive (which require attention be 
paid to animal accommodation and husbandry for conservation purposes).  

Regarding the measures to prevent possible escapes that can cause threats to indigenous species, and 
intrusion of outside pests and vermin (Article 3, fourth indent), the provisions of the Zoos Directive 
specifically  relate  to  escapes  that  can  cause  ‘possible  ecological  threats  to  indigenous  species’  (i.e. 
escapes  of  invasive  alien  species  or  ‘IAS’).  Rather  than  focusing  only  on  escapes  of  IAS,  Member 
States  tend  to  introduce  several  requirements  addressing  the  safety  of  visitors,  specifying  measures 
related to enclosures, gates, barriers and staff duties in order to avoid escapes72. Again, these measures 
are not related to the objectives of the Zoos Directive. 

Interestingly, from interviews with CAs in Germany, Lithuania and the Netherlands73, animal welfare 
and prevention of escapes were considered key elements for a zoo inspection that may even outweigh 
conservation of biodiversity. One explanation is that animal welfare issues and escape of animals have 
a much more disturbing effect on the general public and fully expose CAs, more so than less promi-
nent activities related to conservation of biodiversity.  

Overall, it can be concluded that there is considerable variation in the execution of inspections in the 
14  Member  States.  Not  all  of  the  Member  States  use  inspection  forms,  and  there  might  be  a  risk  of 
incomplete inspections where such protocols are lacking. However, as with existing protocols, other 
factors such as the level of detail required and the elements checked during inspection, greatly deter-
mine the quality of that inspection. The information collected at national level suggests that detailed 
criteria has been established to assess the fulfilment of animal accommodation requirements, as well 
as other aspects such as safety of visitors, that do not have a direct relevance to the conservation objec-
tives of the Zoos Directive.  

In the absence of detailed criteria, the quality of the inspection will depend significantly on the level of 
knowledge of the inspector when evaluating the different elements.  

The box below describes the situation in Ireland, where the licensing and inspection system depends 
on the expertise of an external entity and detailed guidance documents have been made publicly avail-
able in order to support the inspection process.  

Box 2: Irish inspection system 

Prior  to  1999,  the  Republic  of  Ireland  had  no  statutory  licensing  and  inspection  arrangements  in 
respect  of  its  zoos.  The  Zoos  Directive  was  transposed  as  European  Communities  (Licensing  and 
Inspection of Zoos) Regulations 2003, S.I. No. 440/2003 of 19/09/2003, Irish Statute Book (Office 
of the Attorney General, 2016).  

In it, zoos are defined as in the Zoos Directive. In addition, the Irish Zoo Licence Guidance notes - 
GN03  contain  exemption  criteria  and  advise  that  a  collection  will  be  considered  exempt  from  the 
zoos legislation if, among other things also set out in the guidance document, it does not normally 
exceed 100 specimens. 

The CA has outsourced its zoo inspections to a separate organisation, the National Parks and Wild-

70 Guidelines by BMEL (http://www.bmel.de/DE/Tier/Tierschutz/Tierschutzgutachten/_texte/GutachtenDossier.html). 
71 Appendix 9 of the Irish Standards of Modern Zoo Practice (ISMZP) sets out specific sizes for elephant enclosures both indoor and outdoor.  
72 Zoos are also subject to Regulation 1143/2013 on the control of invasive alien species, including provisions aimed at preventing escapes 
(Regulation (EU) No 1143/2014 of the European Parliament and of the Council of 22 October 2014 on the prevention and management of 
the introduction and spread of invasive alien species).  
73 MSCAs questionnaire. 

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life Service, which issues licences for the Minister for the Department of Arts, Heritage, Regional, 
Rural  and Gaeltacht Affairs  (the sole  CA for the Zoos Directive  in Ireland). The  Zoo License In-
spectorate  is  appointed on  a  contract  basis  by  the  National  Parks  and  Wildlife  Service  of  the  De-
partment of Arts, Heritage, Regional, Rural and Gaeltacht Affairs. This has enabled the CA to spec-
ify  the  required  expertise  and  working  methods  for  adequate  zoo  licensing  and  inspection,  which 
provides the CA the certainty of competence and compliance with the existing law. 

The CA has produced a Zoos Standards document and has enhanced the licensing process, includ-
ing questionnaires which allow a stronger interaction between zoos and their inspectors. Inspection 
teams have a greater breadth of experience, permitted under the framework provided by the Zoos 
Directive74. 

The approach in Ireland has been to encourage, rather than force compliance. The emphasis, there-
fore, has been on raising standards in zoos over a number of years, from a situation where, pre-Zoos 
Directive, there were no agreed standards. The context within which zoos operate in the country is 
now strengthened and there is publicly available guidance that spells out expectations. Bringing a 
consistent approach to the regulation of this sector across the EU is a worthy aim and is being suc-
cessfully achieved in this Member State75. 

c.  Closure of zoos and penalties 

Rules for the handling of closures and the establishment of penalties are the other two components of 
the overall licensing and inspection system.  

Handling the closure of zoos represents a major challenge for Member State authorities, with difficul-
ties related to ensuring that appropriate conditions are provided for the animals (as required by Article 
6 of the Zoos Directive). Responsibility for the animals and the related costs for their accommodation 
remain  with the owner of the zoo, who retains  ownership of the animals in cases of closure (except 
where the animals are seized). However, CAs are ultimately responsible76. In their survey responses, 
10 CAs77 mentioned having specific action plans or arrangements to relocate the animals in cases of 
closure and/or necessity78. Depending on the specific case, animals can be relocated to other zoos or 
institutions, including sanctuaries and facilities managed by NGOs (in the Member State or abroad).  

Two  Member  States  (Portugal  and  France)  have  explicitly  indicated  the  use  of  a  network  of  nation-
al/international contacts, involving professional organisations and NGOs. Italy takes a difference ap-
proach where zoos, in order to obtain a licence, must enter into an agreement with other entities who 
may keep the animals in case of closure.  

Based on the data provided by the MSCAs, partial or total closures of zoos have been a  rare event 
since the entry into force of the Zoos Directive79. Overall, there is little evidence of how zoo closures 
have been handled. The tendency observed in most of the Member States is to ask the zoos for adjust-
ments in order to comply with the requirements (as allowed by Article 4 of the Zoos Directive). There 
have been also cases of zoos operating regardless of the CA’s refusal to grant a licence. A well-known 
case is that of Limassol Zoo (Cyprus) that continued to operate and remained open to the public until 
2010, when it was closed following an EU infringement procedure80.  

74 Interview with Zoo Federation. 
75 Interview with MSCA. 
76 According to Article 6 of the Directive, ‘the competent authority shall ensure that the animals concerned are treated or disposed of under 
conditions which the Member State deems appropriate and consistent with the purposes and provisions of this Directive’. 
77 Belgium, Lithuania, the Netherlands, Czech Republic, Denmark, Italy, Portugal, France, Germany and Bulgaria. 
78 If the owner is unable to ensure that animals are kept in adequate conditions.  
79 Closures reported by MSCAs during the stakeholder consultation, or reported by other sources, include two in Belgium; around nine in 
Germany between 2011 and 2016, including complete and partial closures; three in Bulgaria (Born Free Foundation, 2011).  
80 Infringement case 2009/2285. After renovation works, the zoo was re-opened in 2012 (http://limassolzoo.com/home/2012-07-23-03-10-
56.html).  

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The  information  collected  among  MSCAs  through  the  targeted  questionnaire  shows  that  closure,  in 
most  cases,  stems  from  breaches  of  the  legislation  in  relation  to  the  accommodation  of  animals  and 
animal husbandry conditions81. Although no detailed information is available and no conclusive find-
ing is possible, this trend may reflect the increased attention devoted by MSCAs to animal accommo-
dation and standards for animal husbandry across zoos. Those are also the aspects that tend to be de-
tailed in specific criteria in the inspection forms or in the legislation.  

Penalties  established  in  the  Member  States  for  breaches  of  the  legislation  vary  considerably  across 
Member States, depending on the type of offence and on other elements, such as the recurrence of the 
illicit action or the differentiation between private and legal persons. Table 17 illustrates the approach 
taken at national level in the selected Member States, providing a simplified representation of the main 
criminal penalties82.  

Table 17: Penalties for breaches of zoo legislation in the 14 Member States 

Mem
ber 
State 
BE* 

Lt 

NL 

CZ 

DK 

IT 

CY 

PL 

ES 

PT 

IE 

FR 

DE 

BG 

Range of monetary penalties (EUR) 

€450 - €12,000 

€28 - €579 

€1,500 - €2,500 

If zoos operate without a licence: up to €110,900; up to €184,900 (if the breach is repeated with-
in one year)83/ For other administrative breaches: up to €18,500; up to €37,000 (if the breach is 
repeated within one year)84. 
Penalties set by the courts, up to and including imprisonment 

€1,500 -  €90,000 

Up to €5,000 (administrative fine by the Director of Veterinary Services); €1,700 - €3,400 and/or 
imprisonment (on court conviction) 
€4,400 - €11,100 or detention 

€300 - €300,500 

€25 - €44,891.81  

Up to €3,000 and/or six months’ imprisonment 

Up to €15,000 and one-year imprisonment 

Up to €10,000 

€500 - €12,500   

Source: Legal review and survey of MSCAs  

As  illustrated  by  Figure  10  below,  most  of  the  stakeholders  responding  to  the  survey  (including 
MSCAs,  zoos,  federations,  NGOs  and  experts)  agreed  that  penalties  are  effective,  proportionate  and 
dissuasive (46 out of 111 selected the options ‘totally agree’ or ‘somewhat agree’), with 43 unable to 
express a judgement.   

However,  concerns  were  expressed  about  the  adequacy  of  the  resources  available  to  Member  State 
authorities to enforce the legislation  and  make sure  that breaches are actually detected and penalties 

81 Responses to the targeted questionnaire for MSCAs showed the most common breaches detected to be related to the following require-
ments: accommodating animals under conditions which aim to satisfy the biological and conservation requirements of the individual species; 
maintaining high standard of animal husbandry with programmes of preventative and curative veterinary care and nutrition. 
82 This table does not detail how the different penalties apply to different circumstances, except in some cases, and it was not possible to 
provide an accurate picture solely by indicating the range of fines. 
83 Values approximated. In Czech Republic Koruna the amounts are, respectively: 3,000,000 CZK (€110,952.45); 5,000,000 CZK 
(€184,954.74). 
84 Values approximated. In Czech Republic Koruna the amounts are, respectively: 500,000 CZK (€18,493.13); 1,000,000 CZK (€36,987.82). 

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applied. The effectiveness of enforcement capacity is discussed in the next paragraph.  

Figure 10: Stakeholder opinions of the effectiveness, proportionality and dissuasiveness of penalties (absolute number 
of replies per each stakeholder category, total number of respondents = 111) 

Source: Survey of MSCAs, federations NGOS and experts, and zoos 

5.1.1.2  Progress made, results achieved and issues hindering the effectiveness of 

the national licensing and inspection systems 

a. 

Implementation of the licensing and inspection system: results achieved and gaps identified 

Data on the results achieved in terms of zoos licensed, procedures concluded and overall progress in 
the implementation of the licensing and inspection systems in the Member States have been difficult to 
collect, in view of the somewhat fragmented information provided by the Member States.   

Based on the licensing and inspection systems set up, Member States were requested to complete the 
process  of  identification  and  licensing  of  zoos  within  four  years  of  the  entry  into  force  of  the  Zoos 
Directive  (Article  4).  Delays  in  transposition  and  issues  in  the  correct  application  of  the  legislation 
have been detected in six of the 14 Member States (Germany, Denmark, Spain, Ireland, Italy and Por-
tugal), as shown by several infringement procedures started by the European Commission (see Section 
4.2 above).  

The  data  on  enforcement  of  national  legislation  collected  through  the  survey  and  provided  by  12 
Member States, suggests that difficulties have been encountered in making their licensing and inspec-
tion  systems  operational.  Table 18 below shows the number of  zoos (already existing  at the time of 
entry into force of the Zoos Directive) that have been granted a licence within, and after, four years 
from  the  application  of  the  zoo  legislation  (i.e.  the  maximum  period  established  by  Article  4  of  the 
Zoos Directive).  

Except for Belgium and the Czech Republic, all of the remaining 10 responding Member States have 
licensed  a  significant  or  a  major  part  of  the  existing  zoos  only  after  the  four-year  transitional 
period established by the Zoos Directive. In some cases, no licence was issued within the four-year 
period (the Netherlands, Ireland and Italy).  

Table 18: Zoos licensed within, and after, four years of the entry into force of the legislation in 11 Member States 
(absolute numbers) 

Member  Number of zoos licensed within four years 

Number of zoos licensed later than four years 

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State 
14* 
BG 
33 
BE 
1 
CY 
17 
CZ 
79 
DE 
4 
DK 
0 
IE 
0 
IT 
2 
LT 
0 
NL 
16 
PL 
PT 
15 
* licensed under conditions 
Source: Survey of MSCAs  

(excluding new zoos) 
1 

3 
0 
182 
24 
6 
24 
0 
47 
10 
10 

Reasons for this differ and depend on several factors specific to each Member State, including delays 
and issues in transposition. As mentioned in Section 2.1, there was little by way of a comprehensive 
and consistent approach to ex situ conservation in the EU prior to the adoption of the Zoos Directive. 
The Directive prompted the introduction of a  new system for all Member States in the scope of the 
analysis (except Belgium, which continued to apply its previous system), implying time and effort in 
identifying those entities qualifying as zoos under the new definition, the setting up of the inspection 
regime, and the actual application of the new rules.  

Many countries experienced particular issues at the start of zoo licensing, chiefly the absence of guid-
ance in areas such as inspection protocols, and a lack of knowledge on zoo-specific issues among en-
forcement staff, which took time to develop (e.g., Bulgaria, Germany and the Netherlands). 

The difficulty in mobilising resources for inspections during the years of financial crisis might have 
undermined the capacity of some Member States to find the resources needed for licensing and inspec-
tion  of  zoos  (as  mentioned  by  Ireland85),  whereas  revisions  of  the  legislation,  and  burdensome  and 
bureaucratic  procedures  might  have  slowed  down  the  process  in  other  Member  States.  For  instance, 
particularly long licensing procedures have been recorded in Italy, where delays in licensing have been 
caused by the non-compliance of many zoos following the entry into force of the new legislation and 
the related time needed to implement the adjustments. Further difficulties stem from the characteristics 
of the licensing regime set up, based on the preliminary acquisition and analysis of the documentation 
and the follow-up on-site visits (carried out only when the documentation acquired is complete). Cou-
pled  with  the  legislative  revisions  occurring  at  national  level,  some  licensing  procedures  have  taken 
several years, and the licensing of some zoos existing at the time of entry into force of the Directive is 
still pending. Licensing also may take a long time because MSCAs favour dialogue with zoos to allow 
them to redeem deficiencies rather than taking a direct decision to close the zoo86. 

Member  States  are  gradually  catching  up,  overcoming  the  issues  faced  during  the  period  of  adjust-
ment, and speeding up and simplifying the process (e.g. through better use of digital tools for commu-
nication). In parallel, zoo operators are adjusting to the new legislation.  

Table 19 below presents the data on the status of licensing procedures for the 14 Member States ac-
cording  to  the  information  gathered  in  the  survey  of  MSCAs.  Not  all  of  the  zoos  identified  in  the 
Member States are licensed yet, because of pending procedures, exemptions and refusals.  

The share of licensed zoos has increased between 2010 and 2015 in all the Member States, excluding 
Bulgaria, while the gap between total number of zoos and the number of licensed zoos has decreased. 

85 Targeted questionnaire for MSCAs.  
86 Interview with MSCA. 

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Moreover,  the  data  collected  shows  that  several  Member  States  refused  the  issuance  of  licenses  be-
cause conditions were not met (Belgium, the Netherlands, Lithuania, Italy, Poland, Portugal, Germany 
and Bulgaria), or initially refused the license and granted it only after improvements were made by the 
zoo (Belgium, the Netherlands, Czech  Republic, Lithuania, Cyprus, Poland, Germany)87. This infor-
mation provides a broad indication of the setting up of operational licensing and inspection systems.  

However, looking at the evolution of licensed zoos over the years, differences between 2010 and 2015 
might be due to different factors (including the decrease in the overall number of zoos, or changes in 
the number of pending procedures). In general terms, there are no reliable historical data records for 
analysing  the  evolution  of  licensing  procedures  during  the  overall  implementation  period88.  In  addi-
tion, differences in the registration system of each Member State (e.g. inclusion/ exclusion of exempt-
ed zoos as part of the total) hinder comparability. 

Table 19: Number of zoos (licensed and unlicensed) and number of licensed zoos in 14 Member States89 

2010 

2015 

Number of licensed 
zoos 

Member 
State 

Number of zoos 
(licensed and 
unlicensed) 
20 
BG 
39 
BE 
4 
CY 
19 
CZ 
21 
DK 
N/A 
FR 
319 
DE 
N/A 
IE 
20 
IT 
2 
LT 
85 
NL 
18 
PL 
20 
PT 
ES 
N/A 
* First set of data referred to 2008-2010.  
Source: Present survey of MSCAs  

17 
37 
1 
19 
21 
N/A 
290 
10 
4 
2 
47 
18 
20 
108 

Number of zoos 
(licensed and 
unlicensed) 
21 
40 
4 
25 
31 
288 
364 
30 
40 
5 
107 
24 
25 
NA 

Number of licensed 
zoos 

14 
40 
4 
25 
31 
288 
337 
17 
23 
5 
54 
24 
25 
119 

Overall, while this analysis suggests that Member States have progressed in implementing their licens-
ing and inspection systems, the lack of data limits the possibility to draw solid conclusions about the 
progress  made  in  ensuring  that  all  zoos  are  licensed  and  comply  with  the  requirements  of  the  Zoos 
Directive. Opinions and evidence provided by stakeholders, however, give indications in this regard.  

Stakeholders consulted in the context of this study highlighted that the Zoos Directive has introduced 
rules on a subject largely unregulated before90 and represents a significant step forward compared to 
the situation before its implementation91. The Directive has contributed to raising standards and quali-
ty across EU zoos. MSCAs, zoos, zoos’ federations and NGOS recognise (although to varying extents) 
that the conditions of EU zoos have gradually improved, with growing attention paid to conservation 

87 Targeted questionnaire for MSCAs.  
88 As part of the preparatory work for the Zoos Directive, data from the European Parliament on the total number of zoos were reported for 
some Member States (Italy, Luxembourg, Portugal, Spain, the UK) (European Parliament 1993). However, the figures (referring to the 
situation before the entering into force of the Directive) are not consistent with the figures collected by Member State authorities for the 
purposes of this evaluation.  
89 Depending on the definition of zoo, numbers of zoos may differ between CAs, zoo associations, and NGOs. 
90 Before the introduction of the Zoos Directive, legislation existed in Belgium, Denmark, France and Spain (although with different scopes 
and provisions on licensing than those of the Zoos Directive). 
91 As mentioned in Section 2.1, in 1993, only five of the then 12 Member States had relevant legislation on the subject, although it was not 
focused on conservation objectives. In that context, the European Survey of Zoological Collections (in those 12 Member States) found that 
few zoos broadly met ‘the standards required by international guidelines of modern zoo practice in the areas of animal husbandry, species 
conservation and public education’, and limited focus on conservation activities. 

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activities and the provision of information to the public92.  

A  majority of respondents  to the public consultation  considered that  one of the benefits of the Zoos 
Directive has been to ensure improved licensing and inspection schemes, with 60% of the stakeholders 
seeing crucial or significant benefits in this field. This share rises to 89% if the opinions expressed by 
zoos and NGOs are included. In parallel, the different conservation measures defined in the Zoos Di-
rective (i.e. research, training, education and awareness raising, information on exhibited species, ap-
propriate animal keep and veterinary care, collection of data on zoo animals) are sufficiently promoted 
across the EU93.  

However, the perceptions vary depending on the types of measure concerned. While the majority of 
respondents are positive about the measures taken by zoos to provide information, educate and raise 
awareness94, less than half of the participants consider actions related to animal conditions and care, or 
to research on species conservation as sufficiently promoted by zoos95.  

Opinions also change depending on the stakeholder group considered, with a clear tendency to a more 
negative judgement among NGOs. This group has the lowest rate of positive appreciation for all activ-
ities,  being  particularly  low  in  relation  to  research  (33%  or  803  respondents),  training  (36%  or  826 
respondents)  and  animal  accommodation  and  care  (35%  or  758  respondents).  However,  national  li-
censing and inspection systems are the subject of several criticisms, especially by the animal welfare 
associations surveyed and interviewed, who claimed that several zoos are not compliant with the legis-
lation  (even  if  they  own  a  valid  licence)  and  that  non-compliant  zoos  have  been  closed  in  very  few 
cases.  

In particular,  the latest Born Free EU  Zoo  Inquiry 2016 (publication pending) argues that  ‘little im-
provement was identified in those five Member States [Italy, France, Lithuania, Germany and Malta] 
that were also included in 2010 investigations’96.  

In addition, the Inquiry points out that unlicensed, although operational, zoos remain and ‘a number of 
registered “exempt” facilities appear to warrant a zoo licence’ (for example, in Italy)97. This concern is 
echoed by some zoos responding to the survey, several of whom point to the doubts remaining on the 
enforcement of the licensing system, due to the continued presence of unlicensed and operational zoos, 
and/or the issuing of licences to zoos that are not actually compliant with the Directive98. 

92 These considerations are based on the general feedback provided by stakeholders in the targeted consultations (survey and interviews). 
More detailed results are included in other sections of the report, e.g. the benefits brought about by the Directive (Section 5.2.1.2), the results 
attributed to the implementation of the Zoos Directive and its EU Added Value (Section 5.5.1).  
93 Question 21 of the public consultation questionnaire asked for an opinion in relation to the promotion of eight activities corresponding to 
the Article 3 measures: a. Research on species conservation issues; b. Training on relevant species conservation skills; c. Exchange of infor-
mation relating to species conservation between zoos, authorities and other organisations; d. Provide education on, and raise awareness of, 
biodiversity and broader nature protection topics; e. 
habitats; f. Provide information on exhibited species and their habitats; g. Keep animals under appropriate conditions with good veterinary 
care; h. Collect data on animals in zoos. 
Please see the Public Consultation Report (Annex VIII).  
94 The majority of respondents rated the following activities as sufficiently promoted: 

Provide education on, and raise awareness of, species, wild animals and their natural 

 
 
 

Providing information on exhibited species, wild animals and their natural habitats: 70% or 1,607 positive answers; 
Providing education on, and raising awareness of, species, wild animals and their natural habitats: 62% or 1,424 positive answers;  
Providing education on, and raising awareness of, biodiversity and broader nature protection topics: 57% or 1,309 positive an-
swers.  
95 Negative opinions related to: 

 
 

Animal conditions and care (point 21g): 46% or 1,056 negative answers;  
Research in species conservation issues (point 21a): 43% or 987 negative answers. 

96 Findings of the EU Zoo Inquiry 2016 submitted to Milieu before publication of the Inquiry. The project is an assessment of 55 zoological 
collections in seven EU Member States: Italy, France, Lithuania, Germany, Malta (which were also included in the EU Zoo Inquiry 2011), 
Denmark and Croatia. 
97 Ibid. 
98 In the targeted consultation, zoos were asked to state whether or not they agreed with the statement ‘Every zoo is licensed’. Fifteen zoos 
(of the 70 in the sample and the 49 that provided an opinion) disagreed with this statement. In the open comments accompanying the ques-
tions about the licensing and inspection system, the concern about the presence of non-licensed zoos was raised in six cases.  

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Born Free, as part of the EU Zoo Inquiry 2016, concluded that the majority of the zoos investigated 
are  failing  to  properly  implement  the  conservation  measures  of  Article  3,  and  that  zoo  inspections 
across the Member States are failing to identify breaches or penalise violations of the law.  

Stakeholders  pointed  out  that,  although  progress  has  been  achieved,  it  should  not  be  overestimated. 
The implementation of licensing and inspection requirements remains challenging for CAs in terms of 
the  resources  and  knowledge  required,  and  there  are  still  many  non-compliant  zoos  across  the  EU, 
leading to unfair and unacceptable competition for well performing and dedicated zoos99.  

The field assessment of the actual situation across EU zoos (going beyond the available data and in-
formation  provided  by  stakeholders)  is  outside  the  scope  of  this  supporting  study.  Nonetheless,  this 
analysis has identified a range of gaps and factors that hinder the functioning and effectiveness of the 
licensing and inspection systems, and these elements are discussed below.  

b.  Main issues hindering the effectiveness of the licensing and inspection system 

Different stakeholders (including zoos and zoos’ federations) have expressed concern about the capac-
ity of the Member States’ authorities to effectively implement the legislation, pointing to gaps in terms 
of both resources available and knowledge of the inspectors. This concern was also raised during the 
workshop,  where  it  was  stated  that  MSCAs  struggle  with  the  appropriate,  highly  specialised 
knowledge required to properly carry out inspections100.  

Some  countries  solve  this  issue  by  using  external  expertise,  where  Member  States  defer  to  external 
experts  with  appropriate  technical  knowledge  (in  Bulgaria,  Belgium,  Czech  Republic,  Denmark, 
France, the Netherlands and, depending on the need,  in Spain and Poland) to assist enforcement au-
thorities (see Table 14 above). 

In all Member States assessed, zoo inspectors are usually responsible for a range of different duties, 
in addition to the application of the Zoos Directive. These duties include the implementation of other 
legislation  (e.g.  animals  used  for  scientific  purposes,  exotic  animals,  companion  animals,  farms, 
transport,  slaughter,  food  safety,  animal  health,  epidemics  control,  environmental  and  safety  risks, 
compliance with other legislation dealing with IAS and CITES).  

As  a  consequence,  the  skills  of  zoo  inspectors  are  quite  broad  and  not  necessarily  focused  on  wild 
fauna  or  species-specific  issues.  Inspectors  are  generally  specialised  in  veterinary  science  (Belgium, 
Denmark, Cyprus, Italy, Ireland, Germany and Portugal). Other accepted specialist areas are life sci-
ences  (the  Czech  Republic)  and  zoology  (Germany),  while  other  Member  States  request  additional 
specific experience in the management of zoo animal collections (Ireland), or knowledge of protected 
species and their habitats and relevant legislation (Poland), including CITES (the Netherlands).  

Seven of the Member States surveyed (Bulgaria, France, Germany, Spain, Ireland, the Netherlands and 
Poland)  provided  information  on  the  training  activities  organised  regularly  for  zoo  inspectors,  often 
including both legal and technical aspects (some examples are provided in Box 3 below).  

Box 3: Examples of training for zoo inspectors organised in the Member States 

Ireland: The Inspectorate operates a two-tier training system. The first part is training in the ‘Irish 
Standards of Modern Zoo Practice’ (ISMZP) and related legislation (i.e. the Zoos Directive and the 
national law transposing the Zoos Directive). The second part is a biannual training weekend, where 
a specific topic is covered to ensure consistency across an area of inspection or a specific zoo type. 
This helps to ensure that all inspectors have the basic fundamentals required to conduct an inspec-

99 See Workshop Report, June 2017, available at: 
http://ec.europa.eu/environment/nature/legislation/refitzoosdirective/pdf/Workshop_report.pdf 
100 See also Findings of the EU Zoo Inquiry 2016 submitted to Milieu before publication of the Inquiry on this point. 

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tion of a premises, irrespective of individual knowledge gaps or weaknesses.  
Spain:  the  CA,  together  with  the  Foundation  of  Biodiversity,  has  organised  three  courses  at  state 
level with which it has sought to contribute to the training of inspectors of the Autonomous Com-
munities in accordance  with Law 31 /  2003. These  one-week  courses  were  developed in 2009, in 
June and October of 2011, and consisted of theoretical and practical inspection in zoos.  
Source: Present survey of zoos 

Overall, the survey showed that adequate knowledge and training of inspectors was considered a weak 
point of the current system by federations, experts and NGOs. Although the majority of zoos (40 out 
of  70)  agreed  on  the  adequacy  of  inspectors’  knowledge  and  training,  a  significant  proportion  ex-
pressed a negative opinion (18 out of 70) (see Figure 11 and Figure 12). 

Figure 11: Opinion of zoos on the national licensing and inspection systems, in terms of: adequacy of the national 
licensing and inspection systems, knowledge training of inspectors, and human and financial resources (absolute 
numbers, total number of respondents = 70) (data referred to zoos in 14 Member States) 

Source: Present survey of zoos 

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512102724533161341624121405101520253035Appropriate licensing and inspection systemAdequate inspectors' knowledge/trainingSufficient (financial and human) resourcesDon't know/no  opinion/no answerSomewhat agreeTotally agreeSomewhat disagreeTotally disagree 
 
 
 
 
 
Figure 12: Opinion of federations/NGOs/experts on the national licensing and inspection systems, in terms of: 
adequacy of the national licensing and inspection systems, knowledge training of inspectors, and human and financial 
resources (absolute numbers, total number of respondents = 26) (data referred to federations/NGOs/experts in 14 
Member States)  

Source: Present survey of federations, NGOS and experts 

The opinions expressed by zoos and by federations, NGOS and experts differ from the feedback pro-
vided by MSCAs. The majority of MSCAs consider the knowledge/training of inspectors as sufficient, 
while it is the adequacy of financial and human resources that seems to be questioned (Figure 14).  

Figure 13: Opinion of MSCAs on the national licensing and inspection systems, in terms of: knowledge training of 
inspectors, and human and financial resources (absolute numbers, total number of respondents = 15)  

Explanations  behind  the  negative  judgements  include  the  lack  of  updated  and  comprehensive 
knowledge to properly inspect wild/exotic animals, and the wide variety of species exhibited in zoos. 
Given the variety of areas of expertise to be covered, it is difficult for zoo inspectors to perform de-
tailed and holistic licensing inspections. A recent survey by Born Free and VetEffecT argued that sub-
standard conditions are the result of CA’s inability to effectively apply relevant legislation, including 
lack  of  sufficient  knowledge  and  expertise,  especially  in  relation  to  different  species  of  wild  ani-

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111873721610144670246810121416Appropriate licensing and inspection systemAdequate inspectors' knowledge/trainingSufficient (financial and human) resourcesDon't know/no  opinion/no answerSomewhat agreeTotally agreeSomewhat disagreeTotally disagree01111458810123456789Inspectors have sufficient knowledge/trainingInspectorate has sufficient (financial and human)resourcesTotally disagreeNASomewhat disagreeSomewhat agreeTotally agree 
 
 
 
 
 
 
mals101. Although the MSCAs consulted for this supporting study seem to consider the knowledge and 
training of inspectors sufficient (Figure 14 above), the survey conducted by Born Free and VetEffecT 
identified several training needs for national inspectors, including the following top five: conservation 
programme objectives and evaluation protocols; animal welfare indicators and assessment criteria; in 
situ conservation - effective participation and linking to other zoo activities; specific housing require-
ments; specific husbandry requirements (Born Free Foundation 2016). These needs indicate the diffi-
culties  faced  by  inspectors  in  assessing  zoos’  compliance  with  requirements;  as  observed,  MSCAs 
generally have not detailed these criteria in measurable and objectives parameters, leaving the quality 
of the inspection to depend on the skills on the experts involved (see Section  5.1.1.1). These training 
needs, however, also serve to confirm the difficulty of ensuring specialised knowledge.   

Other issues raised by stakeholders in relation to the national licensing and inspection systems point to 
the  inconsistency  among  Member  States  and  among  regions,  as  well  as  to  the  lack  of  sufficient 
resources to perform a systematic screening of the establishments in question.   

Member States have undertaken, and are in the process of implementing, several improvements to the 
licensing and inspection system. Two  Member States (Belgium and Cyprus) are currently reviewing 
their national legislation, taking into account the experience  gained during the implementation of the 
Zoos Directive (Belgium), and with the aim of addressing problematic areas of the current legislation 
(e.g.  zoo  closure,  establishment  of  an  advisory  committee,  use  of  expert  advice,  clarification  of  the 
current legal requirements, penalties) (Cyprus). Another example is the renewal of the team of inspec-
tors in charge of zoos in Ireland. During the last year, inspectors were changed for the first time (pre-
vious inspectors were in post for nine years) in order to make sure that zoos are inspected by different 
inspectors,  there  is  less  predictability  and  the  quality  of  inspection  is  raised  overall.  In  addition,  the 
current system added inspectors (now with a team of eight to nine), with diverse expertise and able to 
cover the full range of situations likely to be encountered in Ireland102.  

Other Member States (the Netherlands103 and Ireland104) have adopted guidelines on zoo inspections, 
in order to clarify and standardise the methods used. In Germany, many regional authorities have de-
veloped  their  own  inspection  standards  but  these  have  not  been  harmonised  across  the  16  Federal 
States. 

Other Member States (Bulgaria, Italy, Spain, Portugal, France and Germany) promote training, period-
ic  meetings  among  inspectors  and  other  tools  to  ensure  coordination  and  the  exchange  of  practices 
among  zoo  inspectors  (e.g.  in  France,  through  the  project  to  develop  a  national  harmonised  infor-
mation system).   

5.1.1.3 

Implementation of the Article 3 conservation measures by zoos 

Each of the 14 Member States within the scope of the analysis has transposed, in many case literally, 
Article 3 of the Directive (with the exception of Belgium, where the existing legislation was applied), 
and  translated  its  requirements  into  the  conditions  for  the  issuance  of  the  licence.  While  the  correct 
transposition  and  effective  enforcement  of  the  legislation  by  Member  States  should  ensure  that  all 
operating zoos implement the conservation measures in line with Article 3, some limitations have been 
identified:  delays  in  setting  up  an  operational  licensing  and  inspection  system  by  several  Member 
States; lack of detailed criteria for the inspection of zoos and the assessment of the implementation of 
Article  3  measures,  with  related  risks  in  terms  of  inconsistencies  (among  Member  States  and  at  re-
gional/local level); and ineffective application of the legislation. 

This  section  highlights  the  progress  made  towards  the  implementation  of  the  Article  3  conservation 

101 Between August 2014 and January 2015, VetEffecT created an online survey with the Born Free Foundation to identify the knowledge 
gaps among authorities at national and regional level.  
102 Interview with the Irish MSCAs.  
103 Document not public.  
104 Irish Standards of Modern Zoo Practice.  

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measures by presenting the survey evidence collected from 70 zoos across the 14 Member States. As 
mentioned above (Section 3.5.1.2 and Section 5.1.1), the survey is likely to have captured mainly con-
servation focused zoos.  The replies to the survey  are, therefore, used to complement the  analysis on 
the actions taken by Member States in order to ensure the compliance of zoos with the legislation, and 
the findings are discussed and compared with the feedback from stakeholders, including the results of 
the public consultation105. 

Implementation of conservation measures: results of the survey addressed to zoos 

Overall,  the survey results show  that  zoos  which  are members of EAZA,  as well as large zoos (250 
employees or more), tend to be more conservation-oriented and to have a structured approach to im-
plementing  the  requirements  of  the  Zoos  Directive  (such  as  a  written  conservation  strategy  and/or  a 
written  education  system,  high  rates  of  participation  in  research  projects  and  training  activities  that 
benefit conservation). This trend is consistent with the findings of previous studies, which pointed out 
that membership of zoo associations is positively correlated with the fulfilment of conservation objec-
tives and the implementation of Article 3 measures (Fabregas et al 2012)106.  

The data collected through the survey reveal that the majority of EAZA zoos (28 out of 37, or 75.6%) 
have a written conservation strategy, with this share being significantly lower among zoos that are part 
of other federations (6 out of 16, or 37%) and zoos that are not members of any federation (two out of 
six, or 33%) (Figure 14). Most of the respondents refer to EAZA Best Practice Guidelines107 and Re-
gional Collection Plans108, or guidelines issued by national associations.  

105 In particular, the following questions were considered: Question 21 of the public consultation, ‘Do you think the following activities are 
sufficiently promoted in zoos across the EU’; Question 20 asking respondents about their personal experiences of the actual implementation 
of the Directive’s requirements. The feedback received is briefly reported in this paragraph and is also used in other sections of the report, 
where relevant. For complete analysis, please see the Public Consultation Report (Annex VIII).   
106 The study conducted in Spain found that private zoos with large zoological collections, located within or near metropolitan areas and 
members of a zoo association, tended to comply with the conservation requirements of the Directive. The membership of a zoo association 
(AIZA in the specific case) was the descriptive variable that explained more than 70% of fulfilment of the requirements, except where the 
requirement related to record-keeping. This finding is explained by the fact that membership helps to ensure that a zoo adheres to the highest 
industry standards [Hutchins and Smith, 2003], through accreditation processes carried out by a group of experts designated by the Associa-
tion.  
The current survey under discussion found little difference between public and private zoos. The analysis therefore focused on the differenti-
ation between zoos belonging to EAZA or other association vs. zoos not belonging to any association; and between small (fewer than 10 
employees; and 10-49 employees) vs. bigger zoos (50-249 employees; and 250 employees or more). 
107 For example, EAZA Best Practice Guidelines, species-specific.  
108 EAZA Regional Collection Plans describe which species are recommended to be kept, why, and how these species should be managed. 
The Regional Collection Plans also identify which species need to be managed in European Endangered Species Programmes and European 
Studbooks. 

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Figure 14: Number of zoos surveyed with a written conservation strategy, by membership  

Source: Present survey of zoos 

Similar differences exist between large and smaller zoos: while all large zoos (nine out of nine)109 and 
the majority of medium zoos (17 out of 21, or 81%) have a written conservation strategy, only 12 out 
of 40 (or 30%) of the smaller zoos (up to 49 employees) declared themselves to have such a strategy 
(Figure 15). 

Figure 15: Number of zoos surveyed with a written conservation strategy, by number of employees 

Source: Present survey of zoos  

a.  Article  3,  first  indent:  research,  training  in  relevant  conservation  skills,  exchange  of  in-
formation  relating  to  species  conservation,  captive  breeding,  repopulation  or  reintroduc-

109 Seven out of nine large zoos are EAZA members.  

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22910483128621370510152025303540EAZAOther FederationNo  FederationNo informationabout membershipTotalNANoYes112418931817111370510152025303540250 employeesor moreBetween 50-249employeesBetween 10-49employeesLess than 10employeesTotalNANoYes 
 
 
 
 
 
 
                                                 
tion of species into the wild. 

Turning to the conservation measures implemented by the zoos surveyed, the first key element relates 
to the actions taken in line with Article 3, first indent, of the Zoos Directive, listing several conserva-
tion  measures,  as  alternative  options:  participation  in  research  from  which  conservation  benefits 
accrue to the species,  and/or training in  relevant conservation skills,  and/or exchange of infor-
mation relating to species conservation, and/or captive breeding, repopulation or reintroduction 
of species into the wild. The wording of the Zoos Directive, presenting the different measures as al-
ternative, answers to the need to take into account the varied landscape of EU zoos and accommodates 
differences in capacities (see Section 5.1.3.1).  

Figure 16 presents the approach taken to Article 3, first indent by the zoos surveyed.    

Figure 16: Overview of participation in research projects, training and exchange of information  

Source: Present survey of zoos 

Most of the zoos declare that they take part in research activities that benefit conservation (52 out of 
70, or 74.3%). All of the EAZA zoos that replied to the survey participate in research projects. While 
90% of the medium-large zoos (27 out of the 30 zoos with at least 50 employees) take part in research 
projects,  the  share  decreases  to  60%  among  smaller  establishments  (25  out  of  the  40  zoos  with  be-
tween 10 and 49 employees and those with fewer than 10 employees). 

A large majority of zoos engage in the exchange of information (65 out of 70, or 92.8%), usually by 
communicating with other zoos, or through  participation  in meetings with  other regional  or national 
stakeholders  (e.g.  zoos’  federations,  national  authorities),  or  with  international  stakeholders  (e.g. 
IUCN, EAZA). It is also worth mentioning that a significant share of zoos (40, or 57.1%) use ‘Spe-
cies360’,  a  tool  developed  to  facilitate  international  collaboration  on  the  collection  and  sharing  of 
knowledge on wild animals in zoos and aquariums (counting around 1,000 members across 90 coun-
tries110). 

Concerning the other measures implemented, only 35 zoos (53% of the 66 that replied to the question) 
engage in training on conservation skills (of these, 26 are EAZA zoos), usually for their own employ-
ees or employees of other zoos, students, veterinarians and biologists, and volunteers.  

110 http://www.species360.org/about-us/mission-history/ 

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523565444529153128712343181829010203040506070Participation inresearch projectsTraining incoservationInformation sharingactivitiesCaptive breeding(EEP)Captive breeding(ESB)Reintroduction ofspecies into thewildYesNoNo Answer 
 
 
 
 
 
 
 
 
 
                                                 
The fact that many zoo survey participants are part of EAZA or other national federations explains the 
high share of zoos taking part in EEP or ESB programmes, i.e. breeding programmes aimed at manag-
ing and conserving populations of animals in captivity. Nevertheless, zoos which are not part of EA-
ZA  also  take part  in EEP  (10  non-EAZA zoos)  and/or ESB  (11  non-EAZA zoos). In general terms, 
participation of non-EAZA zoos in these programmes has increased in  recent years; in 2015, almost 
50% of zoos participating in these programmes were non-EAZA facilities. EAZA attributes this trend 
to the existence of the Directive and its provisions promoting participation in conservation111.  

Finally, a remarkable achievement relates to the fact that 28 (40%) of the zoos surveyed have reintro-
duced species into the wild112 over the last 15 years, both in Europe and in other parts of the world. 
Similarly, 16 zoos (22.9%) indicated that species have been down-listed in Global/European/Regional 
red  lists  (i.e.  moved  to  a  lower  threat  category)  because  of  conservation  programmes  by  zoos.  This 
was the case for the Iberian lynx (Lynx pardina), previously considered critically endangered and now 
considered  endangered.  The  Proyecto  Eremita  (Reintroduction  of  Northern  Bald  Ibis  in  southern 
Spain) allowed the reintroduction of an extinct species in Andalusia (example provided by one zoo).  

Ten  zoos  out  of  70  (14.3%)  did  not  flag  any  of  the  options  related  to  the  participation  in  research, 
training, captive breeding programmes or reintroduction into the wild113. These zoos appear to be in-
volved only in information-sharing activities, suggesting a narrow application of Article 3, first indent, 
measures. These are mainly small establishments (five zoos with between 10 and 49 employees; four 
zoos with fewer than 10 employees, and one zoo  with between 50-249 employees). However, many 
small zoos take part in research programmes and have achieved significant results. Of the 40 zoos in 
the  sample  with  fewer  than  50  employees,  16  participate  in  EEP  and  18  participate  in  ESB  pro-
grammes. In addition, eight have successfully reintroduced species into the wild.  

Box 4: Promotion of Article 3, first indent, measures, results of the public consultation 

According to the feedback provided through the public consultation, stakeholders generally agreed 
that the measures under Article 3, first indent, are sufficiently promoted in zoos across the EU, alt-
hough NGOs express a more general negative opinion. To be more precise, stakeholders agreeing 
that each measure is sufficiently promoted, were distributed as follows: 

  Research on species conservation issues: 44% of total stakeholders; 87% of zoos and only 
33% of NGOs. 56% of the respondents (of which 38% fully agreed) noticed improvements 
in research activities carried out by zoos over the last 15 years. Improvements in research 
activities were observed by 53% of NGOs and 93% of zoos114. 

  Training  on  relevant  species  conservation  skills:  41%  of  total  stakeholders;  82%  of  zoos 

and only 36% of NGOs. 

  Exchange of information relating to species conservation, between zoos, authorities, other 

organisations: 48% of total stakeholders; 96% of zoos and only 52% of NGOs. 

b.  Article 3, second indent: education and awareness 

Most of the zoo respondents stated that they have written  strategies for public education and aware-
ness of the conservation of biodiversity. 

111 Interview with EAZA. 
112 Reintroduction usually focuses on species that are naturally scarce or threatened and/or are already declining or are extinct locally or 
globally. 
113 Out of these 10 zoos: 2 are EAZA, 1 is member of another federation; the remaining are not member of any federation or did not provide 
information about membership.  
114 Question 20 of the public consultation.  

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Figure 17: Number of zoos surveyed with a written education strategy, by membership 

Source: Present survey of zoos  

Figure 18: Number of zoos surveyed with a written education strategy, by size of zoo 

Source: Present survey of zoos  

In  many  cases,  zoos  have  adopted  the  guidelines  on  education  activities  issued  by  EAZA  and/or  by 
national  federations115.  The  description  provided  reveals  that  several  educational  activities  are  per-

115 World Zoo and Aquarium Conservation Strategy (WAZA, published 2015); EAZA Conservation Education Standards (published 2016) 
and EAZA Education and Exhibit Design Committee Aims 2013-2016.  

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235742114281247510102030405060EAZAOtherFederationNoFederationNoinformationonmembershipTotalNANoYes1121547314816216510102030405060250 employeesor moreBetween 50-249 employeesBetween 10-49employeesLess than 10employeesTotalNANoYes 
 
 
 
 
 
                                                 
formed by zoos, addressed to both schools and the general public, with the objective of educating and 
raising awareness of biodiversity and environmental issues. To this  end, the activities carried out in-
clude guided tours, illustrated species talks and keeper talks, but also provision of information on the 
zoo and its animals (zoo maps, species information boards, literature provided at the entrance), as re-
quired by Article 3, second indent, of the Directive (Table 20). 

Some  zoos  have  also  set  up  dedicated  education  services  and  projects  and/or  are  engaged  in  formal 
education processes with schools at different levels (providing for the issuance of certificates to school 
pupils attending the educational activities).  

Table 20: Activities carried out by zoos 

Main activities carried out by zoos 
Animal shows 
Animal handling 
Keeper talks 
Guided tours 
Illustrated species talks 
Interactive displays 
Zoo maps 
Species information boards 
Literature provided at the entrance 
Source: Present survey of zoos  

Answers 
18 
39 
53 
66 
52 
31 
52 
67 
43 

Ratio116 
26.9% 
58.2% 
79.1% 
98.5% 
77.6% 
46.3% 
77.6% 
100.0% 
64.2% 

Box 5: Promotion of Article 3, second indent, measures, results of the public consultation 

The activities related to the provision of information and education by zoos were particularly posi-
tively assessed by respondents to the public consultation:  

  Providing  information  on  exhibited  species,  wild  animals  and  their  natural  habitats:  70% 

positive answers; 

  Providing  education  on,  and  raising  awareness  of,  species,  wild  animals  and  their  natural 

habitats: 62% positive answers;  

  Providing  education  on,  and  raising  awareness  of,  biodiversity  and  broader  nature  protec-

tion topics: 57% positive answers. 

Again, the opinions vary according to the stakeholder category. NGOs provided positive answers in 
slightly more than 50% of cases, compared to over 90% among zoos117.  
Progress in ensuring an adequate level of education is confirmed by the following results: 72% of 
the respondents indicated having received information on species and conservation, and 74% con-
sidered (fully or partly) the information of species and their habitats to be well-presented. Finally, a 
high  proportion  of  respondents  (43%  ‘totally’/  26%  ‘somewhat’)  observed  improvements  in  the 
educational activities provided by zoos in the past 15 years118.  

c.  Article 3, third indent: accommodation of animals and animal husbandry 

Another provision of the Zoos Directive (Article 3, third indent) requires zoos to  accommodate ani-
mals under conditions that satisfy their biological needs and ensures the conservation of differ-
ent species. This provision refers, among others, to the implementation of environmental enrichment 
measures, high standards for animal husbandry and programmes for preventative and curative care and 
nutrition.  Regarding  animal  accommodation,  54/70  (77.1%)  of  the  zoos  responding  reported  that 
standards for animal accommodation and husbandry are used, referring mainly to EAZA standards119, 

116 Based on the total number of respondents to the survey rather than the number of respondents to the corresponding question (i.e. 67 
respondents).   
117 Question 21 of the public consultation.  
118 Question 20 of the public consultation. 
119 EAZA has adopted Minimum Standards for the Accommodation and Care of Animals in Zoos and Aquaria (this document is also referred 
in the preamble to the Zoos Directive).  

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standards defined by national federations, or by national authorities in some Member States (Bulgaria, 
Belgium, Italy, Ireland, Lithuania and Poland). In Germany, animal welfare guidance documents are 
used, even if not specifically part of the legislation implementing the Zoos Directive. 

Thirty-nine zoos (out of 70, or 55.7%) mentioned that they have implemented environmental enrich-
ment measures, with most (24 of the 39) declaring that all of the enclosures are designed to provide 
environmental  enrichment.  This  seems  to  be  an  area  for  debate,  as  the  Born  Free  Foundation  often 
found  lack  of  enrichment  (BornFree  2011).  These  differences  may  stem  from  a  lack  of  unanimous 
agreement on what constitutes sufficient enrichment.  

Several elements should be taken into account concerning the capacity of the zoos surveyed to ensure 
high  standards  for  animal  husbandry.  Firstly,  over  half  of  the  zoos  (40  out  of  70,  or  57.1%)  require 
their animal keepers to have a specific qualification on animal care. This is especially true for EAZA 
zoos, of which 23 out of 37 (or 62.2%) ask for specific qualifications. Most of the zoos have  put in 
place measures to make sure that the capacity is provided to properly manage animal husbandry (See 
Figure 19). Zoos tend to have hygiene plans and nutrition and health programmes, and, while it is gen-
erally more difficult for zoos to have in-house qualified veterinarians, this capability was encountered 
especially among members of EAZA or other federations.  

Figure 19: Zoos’ capabilities in the field of animal husbandry 

Source: Present survey of zoos 

Box 6: Promotion of Article 3, third indent, measures, results of the public consultation 

48% of stakeholder respondents to the public consultation considered that zoos ‘keep animals under 
appropriate  conditions  with  good  veterinary  care’.  Again,  this  opinion  is  not  shared  by  NGOs,  of 
whom only 35% expressed a positive opinion, compared to 96% of zoos. Finally, 47% of individual 
respondents expressed a positive opinion120.  
It is worth noting that the public consultation results are, in part, contradictory.  67% have noticed 
improvements in the size and design of spaces where animals are kept over the last 15 years. How-
ever, regarding accommodation, 53% of the respondents disagree with the fact that animals live in 
conditions that satisfy their needs. As expected, significant differences were noted between stake-
holder  categories:  while  90%  of  zoo  operators  agree  that  animals  live  in  appropriate  conditions, 
only 41% of NGOs and 43% of individuals shared this opinion121. 

120 Question 21 of the public consultation.  
121 Question 20 of the public consultation. 

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d.  Article  3,  fourth  indent:  Prevention  of  escapes  of  animals  and  intrusion  of  outside  pests 

and vermin 

Most of the zoos surveyed have a formal plan/protocol to prevent both the escape of animals and the 
intrusion  of  outside  pests  and  vermin  (Table  21),  in  line  with  the  Directive’s  provision  aimed  at 
‘preventing the escape of animals in order to avoid possible ecological threats to indigenous species 
and preventing intrusion of outside pests and vermin’ (Article 3, fourth indent).  

Table 21: Zoos with plans for the escape of animals and the intrusion of outside pests and vermin, by membership 

Formal 
plan/protocol 
for: 

EAZA 

n. 

% 

9 

23 

Escape  of  ani-
mals 
Escape  of  ani-
mals  and  intru-
sion  of  outside 
pests  and  ver-
min 
Intrusion 
outside 
and vermin 
No plan 
No answer 
Total 
Source: Present survey of zoos  

of 
pests 

1 
1 
37 

3 

24.3% 

62.2% 

8.1% 

2.7% 
2.7% 

n. 

3 

9 

1 

3 

16 

Other 
tion 

federa-

No federation 

% 

n. 

% 

No  information 
on  member-
ship 
n. 

% 

Total 

n. 

% 

18.8% 

1 

16.7% 

3 

27.3% 

16 

22.9% 

56.3% 

4 

66.7% 

3 

27.3% 

39 

55.7% 

6.3% 

18.8% 
0.0% 

0.0% 

2 

18.2% 

6 

8.6% 

1 

6 

16.7% 
0.0% 

1 
2 
11 

9.1% 
18.2% 

6 
3 
70 

8.6% 
4.3% 

Box 7: Promotion of Article 3, fourth indent, measures, results of the public consultation 

74% of all stakeholders agreed that zoos are adequately designed to prevent the escape of animals. 
The lowest share was recorded among NGOs (65%), with 76% of individuals and 94% of zoos stat-
ing a positive opinion. It should be noted that the provision of Article 3 of the Directive is focused 
on preventing the escape of species  to avoid possible ecological threats to indigenous species and 
preventing  intrusion;  this  aspect  is  not  captured  in  the  replies  to  the  public  consultation,  which 
asked a more general question about protection from escape122.  

e.  Article 3, fifth intent: Record-keeping system 

The vast majority of zoos have a record-keeping system (68 out of 70), as established by Article 3, 
fifth indent. In most cases, the system is electronic and includes record per individual animal (rather 
than group records per species), in line with requirements at national level, which usually ask for indi-
vidual records (Belgium, Ireland, Portugal and Spain123).  

Over half of the zoos sampled (40 out of 70) indicated that the complete collection is covered. While 
this can be explained by the effort required to record accurate and detailed information, it can limit the 
capability  of  zoos  to  adequately  manage  the  animal  collection  or  manage  research  activities,  and  it 
may hamper exchange of information with other zoos and organisations on breeding programmes or 
activities, especially if species of conservation interest are not entered in the record-keeping system.   

122 Question 20 of the public consultation.  
123 Article 6 of Law no. 31/2003, on the conservation of wildlife in zoological parks. 

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Figure 20 below summarises the main features of the record-keeping systems.   

Figure 20: Main features of zoos’ record-keeping systems, number of answers per option (based on the answer 
provided by 68 zoos) 

Source: Present survey of zoos   

Box 8: Promotion of Article 3, fifth indent, measures results of the public consultation 

54% of stakeholders shared the opinion that zoos sufficiently promote the collection of data on their 
animals.  This  share  ranges  from  74%  among  individuals,  65%  among  NGOs  and  97%  among 
zoos124. Here, however, results of the public consultation might carry less weight, given the ‘tech-
nical’ nature of the question.   

Overall findings and remaining issues 

The  results  of  the  survey  of  zoo  operators  suggest  that  many  zoos  are  engaged  in  research  projects, 
population management programmes (EEP and ESB), and education and awareness-raising activities. 
In  addition,  many  measures  are  in  place  for  animal  husbandry,  prevention  of  escapes  and  record-
keeping, including environmental enrichment measures, hygiene, health and nutrition plans, and elec-
tronic record-keeping systems. The results are partly biased by the presence of many zoos belonging to 
EAZA (37 out of 70, or 53%) or other national or international federations (16 out of 70, or 23%), a 
factor that is positively correlated with major attention to conservation issues. Nevertheless, the survey 
responses provide a positive overall picture, suggesting that zoos are undertaking the expected actions 
and are progressing towards the fulfilment of Article 3 requirements.  

The  interviews  with  different  stakeholder  categories  and  the  public  consultation  confirmed  that  pro-
gress has been made over the implementation period. The level of knowledge and the quality of the 
information  provided  to  the  visitors,  the  quality  of  zoo  infrastructure  and  enclosures  (as  a  result  of 
radical changes since the end of the 20th century), the specialisation of zoo personnel, and collabora-
tion between zoos and educational institutes, are all elements that have shown improvements in recent 
years.  

Stakeholders  have,  however,  raised  issues  in  the  effective  implementation  and  enforcement  of  the 

124 Question 20 of the public consultation.  

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Zoos  Directive  at  national  level.  The  EU  Zoo  Inquiry  project,  run  by  the  Born  Free  Foundation  in 
2011 and in 2016, highlighted failures in implementation and enforcement, suggesting that the objec-
tives  of  the  Directive  were  yet  to  be  realised  in  the  majority  of  Member  States.  Shortcomings  were 
also signalled in relation to the small contribution to conservation by zoos (mainly because of the lim-
ited conservation interest of species kept), minimal measures to prevent the escape of non-native ani-
mals, and poor enclosure design (BornFree 2011) (Born Free 2016 report pending).  

5.1.1.4  Summary and conclusions 

Overall,  progress  has  been  made  in  achieving  both  the  general  objectives  (protect  wild  fauna  and 
conserve  biodiversity  by  strengthening  the  role  of  zoos  in  the  conservation  of  biodiversity)  and  the 
specific objectives (ensuring that zoos implement Article 3 conservation measures and that closures of 
zoos are appropriately handled) of the Zoos Directive.   

Despite delays in the transposition of the Zoos Directive and in the inspection of zoos, all 14 repre-
sentative  Member  States  have  gradually  set  up  the  legislative  and  practical  conditions  to  ensure  the 
implementation and enforcement of the zoo legislation. Most of the Member States have put in place a 
structured process for inspection (supported by inspection forms), and make use of external experts in 
order to ensure specialised knowledge.  

In  parallel,  despite  the  difficulties  in  collecting  comprehensive  data,  many  zoos  implement  several 
conservation measures, have set up written conservation and education strategies, and ensure that high 
standards  of  animal  husbandry  are  ingrained.  These  achievements  are  not  limited  to  EAZA  zoos 
(which are generally more involved in conservation activities), but also include  non-EAZA zoos. In 
addition, they concern small-medium entities operating in different Member States, and not necessari-
ly bigger zoos.  

However,  the  progress  towards  the  achievement  of  the  objectives  is  limited  by  remaining  issues  in 
terms of implementation and enforcement of the Zoos Directive.  The assessment identified a number 
of shortcomings that can be recapped as follows:  

 

Some of the Member States transposed the Directive after the deadline and further  delays were 
recorded in the establishment of the licensing and inspection systems. Most of the Member States 
inspected and licensed existing zoos only after the four-year transitional period, with procedures 
still pending for existing zoos. Progress towards the achievement of the objectives has thus been 
slower than expected in many cases. 

  The Zoos Directive provides a framework for the implementation of conservation measures but it 
does not provide detailed indications about the conservation  measures listed in Article 3. Many 
Member States have transposed the Article 3 measures literally in their legislation and, although 
most of the Member States use inspection forms, in most cases no detailed criteria or indicators 
are  provided  as  a  basis  to  perform  the  inspections  and  assess  compliance.  Where  such  detailed 
criteria  have  been  established,  these  are  mainly  related  to  animal  accommodation,  and  aspects 
such  as  safety  of  visitors,  that  do  not  have  direct  relevance  to  the  conservation  objectives 
pursued by the Zoos Directive. Conversely, little focus appears to be placed on the measures to 
prevent escapes of IAS (whereas, as mentioned, the requirements about escape of animals tend to 
address the safety of visitors). 
While  this  gap  can  be  explained  by  the  wide  differences  among  zoo  collections  (making  it 
difficult to define and apply standard criteria), there is the risk of inconsistent application of the 
requirements,  both  across  Member  States  and  within  each  Member  State  (when  the  inspection 
system is managed at local or regional level).  

  The accommodation of animals under adequate conditions in case of closure of a zoo represents a 
challenge for Member State authorities. So far, the closure of non-compliant zoos has been rare. 
Solutions depend on cooperation between the authorities and the zoo owners on the one hand, and 
other zoos and/or NGOs taking charge of the wild animals on the other hand.  

  The  full  effectiveness  of  the  licensing  and  inspection  system  is  hindered  by  lack  of  resources 

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and capacity. Zoo inspectors are usually responsible for the enforcement of different legislation 
related to animal welfare, trade of wild animals and endangered species (i.e. CITES). The broad 
range of responsibilities has consequences in terms of limiting the resources that can be mobilised 
for zoo inspections, as well as creating practical obstacles to the knowledge and understanding of 
the specificities of zoos.   

  The targeted survey (that reached 70 zoos across the 14 Member States) showed that most of the 
zoos have implemented conservation measures (as listed in Article 3 of the Zoos Directive), albeit 
in a varied manner, by participating in research, and/or with ex situ conservation programmes or 
some other measure, as required by the Directive. Not all conservation measures receive the same 
attention; for example, not all zoos take part in research that benefits conservation, and less 
than half of the zoos surveyed are not involved in training activities in conservation skills. 
This  result  appears  to  relate  strictly  to  the  alternative  wording  of  Article  3,  first  indent,  which 
gives zoos the possibility to comply with the requirements by choosing one or more of the options 
offered, and is aimed at taking into account the differences (also in terms of capacity) among EU 
zoos. Similarly, not all zoos have the same capabilities in terms of qualified zoo staff (in-house 
qualified  veterinarians,  or  animal  keepers  with  specific  qualifications  on  animal  care). 
Differentiation  remains  among  zoos  that  are  members  of  a  European  (EAZA)  or  national 
federation, and zoos that are not members of any federation.  

  The overall positive picture emerging from the targeted survey addressed to zoos is confirmed in 
the public consultation, which shows that the public considers that the implementation of con-
servation measures is, generally, sufficiently promoted by EU zoos. This is especially the case for 
activities related to the provision of information on exhibited species, wild animals and their natu-
ral habitats, and for activities related to  education and awareness  raising. However, the level of 
negative perception among stakeholders is higher in relation to animal conditions and care.  53% 
of the respondents to the public consultation disagree with the fact that animals live in conditions 
that satisfy their needs. 

5.1.2  Effectiveness – EQ 2 

What is the contribution of the Directive towards ensuring the protection of wild fauna and the conser-
vation of biodiversity in the EU and globally (including its contribution to implementing the EU Bio-
diversity  Strategy  and  EU  commitments  under  international  conventions  such  as  the  Convention  on 
Biological Diversity)? 

This question aims to understand the contribution made by the Directive to the achievement of its gen-
eral objective of protection of wild fauna and conservation of biodiversity. In order to evaluate this 
contribution, two main elements can be, to some extent, objectively measured: 

 

 

Impact of the achievement of certain of the Directive  specific objectives: zoos’ participation in 
research,  captive  breeding,  repopulation  and  reintroduction,  and  promotion  of  public  education 
and awareness; 
Impact of the implementation of the Directive on the achievement of EU and global conservation 
objectives  (implementation  of  other  policies),  by  measuring  the  interactions  of  the  Directive 
with other EU legislation and international agreements.  

The  analysis  for  this  question  is  mostly  based  on  desk  research,  with  limited  input  drawn  from  the 
stakeholder consultation. Desk research involved a literature review of the academic literature and the 
reports listed in the bibliography (Annex IV) and the reference database (Annex IVa), and of the rele-
vant legislation. The combined analysis of the extensive literature existing on the topic and of the rele-
vant EU and international legal texts provides a sound source of information to answer the evaluation 
question.     

5.1.2.1  Contribution of zoos to the conservation of biodiversity  

As previously explained, the Directive aims to strengthen the role of zoos in conservation of biodiver-
sity. In order to measure the effectiveness of the Directive,  therefore, this strengthened role  must be 

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assessed.  

The  role  of  zoos  in  conservation  has  long  been  subject  to  debate  (Bowkett  2014)  (see  also  Section 
5.3.3.1) and has given rise to extensive academic research and articles from a range of different per-
spectives (scientific, economic, etc.). The existing literature focuses on measuring the impact of cer-
tain key areas of activities of zoos in relation to conservation, as defined in Article 3 of the Directive: 
research, captive breeding and reintroduction, and public education and awareness promotion (activi-
ties and results A + B of the Intervention logic of the Zoos Directive). The analysis concentrates on the 
Article  3  conservation  measures  to  assess  contributions  to  achieving  the  objectives  of  the  Directive. 
This will allow an understanding of whether achieving key results from proper implementation of the 
Directive results in its intended impacts (see Intervention logic in Section 2.2 above).   

a.  Impact of participating in research on conservation 

Research is expressly mentioned as a possible conservation measure in Article 3, first indent, of the 
Directive. As mentioned in Section  5.1.1.3 above, research is widespread among  the zoos which re-
plied to this present survey. All EAZA zoos which replied participate in research activities, and EAZA 
has a research committee to support research125 undertaken by its members (EAZA 2015, p.23). Figure 
21  below  presents  the  data  on  zoos’  participation  in  research  projects,  with  a  significant  proportion 
being EAZA members.  

Figure 21: Survey results on zoos’ participation in research projects 2003-2016 (number of projects) 

30

25

20

15

10

5

0

11 

8 

6 

6 

8 

1 

1 

1 

4 

3 

1 

EAZA

Other Federation

No Federation

No information on
federation

26 

9 

8 

7 

Total

From 0 to 10

From 10 to 25

From 25 to 50

More than 50

Source: Present survey of zoos  

As  per  the  Directive,  research  shall  aim  to  benefit  conservation  of  biodiversity,  i.e.  ‘research  from 
which conservation benefits accrue’. An analysis undertaken in 2005 (P. A. Rees 2005) analysed the 
topics of papers published in a specialised journal (Zoo Biology) between 1996 and 2004, and noted 
that only two out of 349 papers dealt with ecology, field biology, conservation or reintroduction. Rees 
explained this perceived under-representation by stating that such research would more likely be pub-
lished in ecology or conservation journals. He also stated that ‘a great deal of zoo research is not pub-
lished in peer-reviewed scientific journals and is therefore largely lost to the wider scientific commu-
nity’.  Rees  concluded  that  ‘it  is  unrealistic  to  expect  the  quantity  of  conservation  relevant  research 
from  zoos  to  substantially  increase  as  a  result  of  the  Zoos  Directive’,  for  economic  reasons  (no  re-

125 Research should be understood in this context as the ‘systematic collection and analysis of biological data by scientists, or the develop-
ment of now scientific techniques, as opposed to day-to-day record-keeping performed by keepers’ (P. Rees 2005). 

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sources for researchers or research facilities inside zoos), for scientific reasons (more difficult to find 
conservation relevant subjects that can be set up in zoos), and for ethical reasons (welfare concerns).  

This analysis covered two years of the implementation period of the Directive and the situation is like-
ly  to  have  evolved.  With  the  aim  of  understanding  this  evolution,  the  publications  of  the  Journal  of 
Zoo and Aquarium Research (JZAR)126 were analysed. EAZA launched JZAR in 2012 to publish inter 
alia  peer-reviewed  research  papers,  reviews,  technical  reports  and  evidence-based  case  studies.  Re-
search  categories  covered  by  JZAR  includes  studies  in  biological  sciences,  in  situ  conservation  re-
search, and research aimed at developing other roles of zoos and aquariums (e.g. visitor learning and 
marketing surveys) (JZAR 2016). A quick search based on 92 papers with key words resulted in one 
match for ‘biodiversity’ and 27 matches for ‘conservation’. In the latter results, most studies related to 
biological sciences (nutrition, reproduction)127.  

The limited extent of research was also one of the key findings of the 2016 Zoo Inquiry, according to 
which only 7.14% of the zoos studied took part in scientific research128. Academics surveyed for this 
study also observed that, although there are zoo-driven research programmes (e.g. Antwerp Zoo) and 
some successful examples of cooperation between zoos and universities (e.g. Edinburgh zoo and uni-
versities), collaboration between zoos and academia could be improved, and that zoos are rarely, ex-
cept  for  the  most  modern  ones,  involved  in  research.  They  experienced  this  problem  directly  when 
looking for zoos in which to implement their research129.  

One explanation provided by Rees in 2005, and which still applies, may be the absence of incentives 
to carry out research to comply with Article 3, due to the alternative options provided under Article 3, 
first indent (training, captive breeding, exchange of information), which are  activities  in which  zoos 
are likely already engaged prior to the Directive (See Section 5.1.3). The absence of a commitment to 
research is an observation shared by an important proportion of the respondents to the public consulta-
tion, which showed that 43% of respondents consider research insufficiently promoted in zoos across 
the EU. This is one of the responses with the highest share of negative opinions among the activities 
listed for this question in the consultation130.   

However,  though  there  is  some  evidence  that  would  indicate  that  research  amongst  zoos  is  limited, 
other elements may bring some nuance to this observation. 

Firstly, the number of publications is not a fully reliable indicator, since, in terms of timescales, it may 
be that insufficient time had elapsed between the adoption of the Directive in 1999 and for the impli-
cations  to  be  understood,  projects  to  be  conceived,  funds  secured,  research  activities  conducted  and 
results then analysed and submitted to lengthy peer-review prior to publication in the scientific litera-
ture.  In  addition,  it  was  reported  that  zoos  often  contribute  to  research  without  being  mentioned  as 
authors in papers published by universities or research institutes, which indicates that the number of 
publications  is  not  necessarily  a  reliable  indicator  of  the  research  activity  of  zoos.  This  observation 
was also raised during the discussions at the Workshop held at the end of the present study (see Work-
shop Report in Annex IX). According to the stakeholders present at the Workshop, zoos undertake a 
lot of research that might not be immediately visible and may not always be published, and they are 
often not considered as co-authors by academics. 

The present survey of zoos shows the zoos’ own perceptions of their contribution to publications dur-
ing the implementing period. This is illustrated in Figure 22 below. 

126 The International Zoo Yearbook is also a relevant publication in this context. For the purpose of the exercise, however, the research was 
limited to European publications.  
127 Research on 1 December 2016. 
128 Information provided in a document submitted by Born Free to Milieu in advance of the publication of the Zoo Inquiry 2016.  
129 High-level questionnaire and report of exchanges between academia and the Commission.  
130 See Public Consultation Report (Annex VIII), analysis of Question 21.  

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Figure 22: Survey results on the number of publications benefiting conservation 2003-2016 

20

18

16

14

12

10

8

6

4

2

0

18 

11 

6 

5 

Total

From 0 to 10

From 10 to 25

From 25 to 50

More than 50

Source: Present survey of zoos 

In total, 41 of the 70 responding zoos contributed to publications. Even though the  question covers a 
broad range of publications (general interest publications, scientific publications and guidance docu-
ments), the proportion remains quite high, particularly since it does not take ongoing or unpublished 
research into account.  

Secondly,  while  the  research  on  the  conservation  of  species  remains  limited  and  needs  to  be  better 
promoted, research which does not have conservation of biodiversity as its main purpose, e.g. on pop-
ulation  genetics,  reproduction,  nutrition  or  concerned  with  influencing  the  behaviour  of  people,  can 
also result in conservation benefits. Research relating to animal welfare benefits conservation, for ex-
ample, is relevant to the extent that, as per Article 3 third indent, proper care and accommodation con-
tribute to the conservation of biodiversity. Also, research in the other fields of biological science men-
tioned  above  (e.g.,  nutrition,  reproduction)  contribute  to  conservation  by  supporting  the  keeping  of 
viable  captive  populations  and  the  management  of  small  populations  in  the  wild.  One  stakeholder 
mentioned that zoos can be ‘a key resource for primary research on animal biology because the ani-
mals’ ages, diets, medical/ life histories etc. are known. This complements studies in the wild, where 
behaviour is natural but less contextual information is available’131. It was also observed at the Work-
shop that zoos contribute significantly to research on veterinary issues (see Workshop Report in An-
nex IX). In that regard, Rees’s selection of subjects and identification of research outlets seems very 
narrow and will capture an unknown, and probably very small, proportion of potentially relevant re-
search findings.  

It  remains  difficult,  however,  to  measure  the  impact  of  zoo-based  research  on  the  conservation  of 
biodiversity. It can be asserted that a wide range of research has conservation impacts without it being 
supported  by  direct  evidence.  More  generally  (beyond  conservation  and  the  context  of  the  Zoos  Di-
rective) there is an increasing desire both for research to have impact on society and for this impact to 
be  demonstrated.  For  example,  the  UK  Research  Councils  now  require  a  statement  of  ‘Pathway  to 
Impact’ for research proposals132. A stronger framework for linking zoo-based research to conserva-
tion  impact  would  help  to  significantly narrow  the  uncertainty about  links  between  research  in  zoos 
and changes in the status of species, for example. Without this, the very large range of research disci-

131 High-level questionnaire; answer by academia. 
132 UK Research Councils: Pathways to Impact http://www.rcuk.ac.uk/innovation/impacts/  

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plines that are now known to be important for conservation, and the extremely voluminous and diverse 
literature that documents scientific findings, makes it is a significant challenge to provide an overall 
assessment of the relevance and impact of zoo-based research on conservation of species in particular, 
and biodiversity more widely.  

On  a  positive  note,  the  public  consultation,  in  response  to  the  question  of  the  progress  achieved  in 
relation  to  research,  showed  56%  of  the  respondents  (of  which  38%  fully)  noticed  improvements  in 
research activities carried out by zoos over the last 15 years (point 20e). This number increases to 93% 
positive perceptions among zoos operators, which are the stakeholders the most directly impacted by 
this measure. This seems to illustrate a positive trend in the involvement of zoos in research.  

b.  Impact of captive breeding, repopulation and reintroduction of species 

The  initial  role  allocated  to  zoos  in  biodiversity  conservation  was  to  maintain  populations  of  threat-
ened species ex situ, reintroduction being ‘the ultimate goal’ of ex situ conservation as defined in the 
first World Zoo Conservation Strategy (IUDZG/CBSG 1993).  

Even though the perspective has since then evolved  (Lees C & Wilcken 2009) (McGowan, Traylor-
Holzer and Leus 2016), the efforts to conserve the most threatened species ex situ must be assessed. 
According to a 2011 study, globally, zoos members of the Species360 programme hold about one in 
seven  threatened  vertebrate  species133  according  to  the  IUCN  red  list  (i.e.  15%  of  the  species)  and, 
more  precisely,  25%  of  threatened  bird  species,  20%  of  threatened  mammal  species,  12%  of  threat-
ened reptile species and 4% of threatened amphibian species (Conde, Flesness, et al. 2011). Zoos tak-
ing part in Species360 show clear improvements over the last 20 years regarding the number of threat-
ened species. The most substantial increase was noted for amphibians, with an increase of 1020% be-
tween 1990 and 2009. There has also been an increase of mammal metapopulation sizes (<250 indi-
viduals) by 48.6% in the same time period (Conde DA 2011b). It has been established, however, that 
zoos usually hold species (in particular  mammals and  birds) that are less threatened than their close 
relatives not held in zoos (Martin, et al. 2014).  

Of the 70 responding zoos, 42 provided an estimation of the percentage of species they keep that are 
on the global IUCN red list. For each of these 42, the population of threatened species represents be-
tween 0 and 100% of the species they hold, with an average of 35.35%. As indicated in Figure 23 be-
low, EAZA zoos hold the greatest proportion of threatened species.  

133 Classified as vulnerable (VU), endangered (EN) or critically endangered (CR). 

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Figure 23: Survey results on zoos’ estimations of the percentage of species they keep that are on the global IUCN red list 

16

14

12

10

8

6

4

2

0

15 

12 

10 

8 

7 

6 

2 

4 

3 

1 

1 

2 

1 

4 

1 

1 

2 

2 

EAZA

Other Federation

No Federation

No info on federation

Total

0

1%-19%

20%-49%

50%-69%

70%-100%

Source: Present survey of zoos 

This is consistent with the observations in literature, that less than half of the species kept in zoos are 
threatened.   

The question, then, is the extent to which keeping threatened species contributes to the conservation of 
biodiversity.  Even  though  the  number  of  species  kept  is  low,  some  authors  consider  that  ‘each  zoo 
may make a larger conservation contribution by specialising in breeding a few at-risk targeted species 
rather  than  aiming  to  increase  its  species  diversity,  as  specialisation  increases  breeding  success’ 
(Conde, Flesness, et al. 2011). There is no evidence to substantiate this observation in the data collec-
tion for this current study.  

Activities  at  EU  level  in  relation  to  threatened  species  include  breeding  programmes,  such  as  the 
EEP and ESB coordinated by EAZA, which aim at ‘conserving healthy populations of animals in cap-
tivity while safeguarding the genetic health of the animals under the care’ of their zoos (EAZA 2016). 
There  are  currently  199  ESBs  and  201  EEPs.  In  2015,  these  programmes  included  not  only  EAZA 
zoos,  but  also  192  non-EAZA  facilities  (EAZA  2015).  As  indicated  in  Section  5.1.1,  a  significant 
number  of  the  zoo  respondents  in  this  study  survey  participate  in  such  programmes.  In  spite  of  the 
very low proportion of threatened amphibians held in zoos (4% of Species360 zoos (Conde, Flesness, 
et  al.  2011)),  projects  such  as  the  Amphibian  Ark  aim  to  restore  a  healthy  population  of  amphibian 
species.  The  Amphibian  Population  Management  Advisory  Group  is  co-chaired  by  EAZA.  In  2004 
and 2005, EAZA also promoted a campaign on ‘safety net populations’ for turtles and tortoises (EA-
ZA Turtle and tortoise campaign 2004/2005). 

In  terms  of  the  outcomes  of  conservation  breeding  programmes,  reintroduction  of  animals  kept  ex 
situ into the wild remains a minor activity of zoos. Nevertheless, this survey indicated that 34 of the 70 
zoo respondents (almost half) have reintroduced species into the wild within the last 15 years. Accord-
ing to literature, the impact of such reintroductions on conservation is nuanced. Captive breeding has 
so far played a major role in the recovery of 16 of the 68 species whose threat level was reduced (e.g. 
Prewalski horse or back-footed ferret) (Hoffman, M et al 2010), with zoos playing a key role either by 
contributing stock from captive breeding or otherwise in 13 cases (D. Conde 2011a). Reintroduction, 
however, has its limits, notably due to the limited population in zoos, resulting in limited genetic di-
versity and effects of captivity on the behaviour of the animals kept ex situ (Balmford, et al. 2011).  

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Breeding programmes and reintroduction do not only cover threatened species. While animal welfare 
organisations  interviewed  for  this  study  considered  that  only  endangered  species  should  be  kept  in 
zoos134, and some authors have argued in favour of zoos focusing on the more survival-compromised 
species (Fa, et al. 2014), other stakeholders consider that breeding of non-threatened species may also 
have an impact on conservation. In particular, species should not only be selected because of the level 
of  threat,  but  also  ‘for  their  potential  to  excite  public  attention  and  help  to  protect  habitat  and  other 
taxa’ (Hutchins, Willis and Wiese 1995). Charismatic animals kept in zoos serve as flagship species or 
ambassadors  that  raise  public  awareness  and  support  for  in  situ  conservation  (Keulartz  2015).  In 
addition, the breeding of other species can also be an asset to develop additional breeding techniques 
that can be used for in situ conservation and threatened species (Redford and Jensen 2012). There are 
linkages  between  the  knowledge  and  expertise  acquired  from  working  with  non-endangered  species 
and the conservation (in situ and ex situ) of endangered species (e.g. the management of endemic bird 
species  on  Mauritius  or  management  of  the  Montserrat  Mountain  Chicken  were  mentioned  in 
interviews). Also, contributions may arise from keeping non-threatened species, as there is a risk for 
such  species  to  see  their  status  change  from  non-threatened  to  threatened,  or  for  species  threatened 
regionally  although  not  globally  (  (Bowkett  2014),  corroborated  by  interview  with  zoos’  federation 
and by discussions held at the Workshop; See Workshop Report in Annex IX).  

With more and more wild populations becoming dependent on species-specific management, zoos not 
only  contribute  animals  for  repopulation  or  reintroduction,  they  also  contribute  techniques, 
approaches, knowledge and personnel for in situ population management. The work of zoos becomes 
increasingly  important  in  respect  of  their  knowledge  of  the  genetics  of  small  populations  to  avoid 
inbreeding, reproduction, health assessment, sedation and transport, and remote sensing technologies 
(Redford, Jensen and Breheny 2012). 

The contribution of zoos to conservation is not limited to ex situ programmes or to providing expertise 
and techniques for in situ conservation; zoos also participate in the funding of in situ programmes (see 
Box 9 below). This aspect of zoos’ contributions to biodiversity conservation was emphasised at the 
Workshop at the end of this project (see Workshop Report in Annex IX) 

Box 9: Impact of financial support to in situ conservation programmes 

According to a 2011 survey, the world zoos and aquarium community reportedly spent about USD 
350  million  on  wildlife  conservation  in  2008,  with  European  and  American  zoos  and  aquariums 
reporting  97%  of  their  expenses  dedicated  to  wildlife  conservation  (Gusset  and  Dick  2011).  This 
makes  WAZA  zoos  the  third  major  contributor  to  conservation  worldwide,  after  the  Nature  Con-
servancy and the World Wildlife Fund (WWF). Such expenses frequently include funding of in situ 
conservation projects. A 2010 study looked more closely at the impact of zoos’ contributions to 113 
WAZA conservation projects. The study observed that the main source of project support from zoos 
and aquariums was monetary funding (48%), and concluded that ‘thanks to the investments made 
by zoos and aquariums, particularly financial, such projects reached overall impact scores of a mag-
nitude suggestive of an appreciable contribution to global biodiversity conservation’. On the other 
hand, the study also indicated that the resources allocated by most zoos to in situ conservation pro-
jects  was  relatively  small  (Gusset  and  Dick  2010).This  observation  is  supported  by  a  2011  study 
which found that, at a global level, zoos invested about 5% of their budget in conservation projects 
(Fa, Funk and O'Connell 2011).  
The EAZA Guidelines on the definition of a direct contribution to conservation (EAZA 2015) refer 
to grants to other conservation organisation or persons to support field work as a mean of contribu-
tion.  At  the  Workshop,  EAZA  mentioned  a  EUR  9.7  million  investment  in  conservation  projects 
across the globe (Workshop Report). 

134 See also the findings of the Zoos Inquiry 2016, which observes, in relation to marine mammals, a limited representation of the most 
threatened species in the facilities investigated, and gives the example of the bottlenose dolphin (Tursiops truncatus) largely represented and 
bred in aquariums in spite of its status of ‘least concern’ in the IUCN red list, with wild populations largely stable and not threated with 
extinction.  

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Captive  breeding  of  threatened  or  non-threatened  species  is  commonly  considered  only  one  of  the 
tools by which zoos can contribute to the conservation of biodiversity (Bowkett 2009). Research and 
education are among the other recognised channels whereby zoos have contributed to conservation.  

c.  Impact of public education and awareness promotion   

Education is expressly mentioned in Article 3, second indent, of the Directive, making it a compulsory 
conservation measure. With an estimated 140 million visitors to European zoos in 2015 (EAZA 2015), 
the potential for increasing awareness of conservation issues is considerable.   

As indicated in Section 5.1.1, the survey shows that most zoos (51 of the 65 which provided an an-
swer) have a written education strategy. Education thus seems well embedded in the activities of EU 
zoos.  This  is  also  confirmed  by  the  results  of  the  public  consultation,  according  to  which  providing 
information on exhibited species, wild animals and their natural habitats is sufficiently promoted for 
70% of the respondents. Further, over half of respondents considered that zoos provide sufficient edu-
cation on, and raise sufficient awareness of, biodiversity (57%) and on species, wild animals and their 
natural habitats (62%). A high proportion of respondents (43% ‘totally’/ 26% ‘somewhat’) observed 
improvements in the educational activities provided by zoos in the past 15 years.  

However, zoos have been criticised for misleading the public as to their commitment to conservation 
by stakeholders (BornFree 2011)135 and likewise in literature (Carr and Cohen 2011). For instance, the 
educational benefits of animal shows are questioned by NGOs136, and were clearly an area of concern 
in the public consultation, which found that 54% of the respondents, and 60% among individuals, did 
not agree that animal shows were adapted to the animals’ natural behaviours. Besides, the educational 
impact of zoos is difficult to measure (Marino, et al. 2010) (Balmford, et al. 2007). A 2014 large scale, 
global study (Moss, Jensen and Gusset 2015) measured the impact of visits to zoos and aquariums on 
visitors. The study showed that zoo and aquarium visits contribute to increasing the number of people 
who  understand  biodiversity  and  know  the  actions  they  can  take  to  help  protect  biodiversity,  with  a 
comparatively better response rate in European zoos137. A previous study focused on children aged 7-
15  visiting  London  zoos  reached  similar  conclusions  (Jensen  2014).  The  respondents  to  the  public 
consultation largely acknowledged a link between a visit to the zoo and their level of awareness:  

  On species: 66% of the respondents (65% for individuals) agreed that they knew more about wild 

animals and protected species after a visit to the zoo.  

  On biodiversity conservation in general: 54% (51% for individuals) agreed that they knew more 

about biodiversity and conservation after a visit to the zoo. 

Nevertheless,  the  2015  study  pointed  out  that  only  over  half  of  the  respondents  reportedly  saw  or 
heard  biodiversity  information  during  their  visits,  thus  limiting  the  potential  effect  of  education 
measures  and  showing  room  for  improvement  in  zoos’  communication  on  biodiversity.  By  contrast, 
the  public consultation  for this study  showed  86% of  survey respondents  indicating  having  received 
information on species and conservation during a visit, and 86% considered (fully or partly) the infor-
mation of species and their habitats well presented. Given the geographical coverage and the samples 
of the two studies138, this seems to indicate a significantly higher rate of information in the EU, which 
might be attributable to the Directive.     

The 2015 study pointed out that the impact of education on conservation is not necessarily tangible, to 
the extent that increased knowledge does not systematically result in improved behaviour but, rather, 
knowledge can be built upon to drive pro-conservation behavioural and social change (Moss, Jensen 
and  Gusset  2015).  The  same  authors  further  explored  this  link  in  a  2016  study  (Moss,  Jensen  and 

135 Also confirmed by the findings of the Born Free 2016 Inquiry submitted to Milieu before its publication.   
136 Ibid.  
137 European zoos surveyed for this study were based in Germany, Sweden and the UK.  
138 1,905 visitors responding to the public consultation across the EU-28, 5,661 visitors in 19 countries around the globe, of which only three 
were in the EU.   

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Gusset 2016). The study observed that biodiversity understanding was only the sixth most important 
variable in significantly predicting knowledge of actions to help protect biodiversity,  and that biodi-
versity understanding was the least important variable of those that were significantly related to self-
reported pro-conservation behaviour. The study concluded that the link between knowledge and pro-
environmental behaviour, even though established, is very limited.  This is in line with the results of 
the public consultation here, according to which NGOs and individuals still have rather negative per-
ception of possible behavioural changes triggered by a visit (zoo visits encourage visitors to become 
more engaged in the protection of species - 33% for NGOs and 51% for individuals; and in the protec-
tion of biodiversity- 36% for NGOs and 49% for  individuals). This perception is strikingly different 
from  that  expressed  by  public  authorities  and  zoos  operators,  who  have  assessed  such  measures  ex-
tremely positively (100% for all points listed above for public authorities and between 88 and 90% for 
zoo  operators).  These  results  would  tend  to  indicate  that  educational  measures  are  not  as  successful 
among visitors as perceived by public authorities and zoos. It was acknowledged during the Workshop 
that,  based  on  these  recent  studies,  a  different  approach  to  education  in  zoos  is  needed.  It  was  also 
pointed out that, although it is hard to achieve and measure long-term changes in behaviours by zoos 
visits, smaller achievements, such as ‘cherishing nature’, should also be recognised.   

Overall, the literature agrees that more progressive zoos have shifted from a purely entertainment per-
spective to a more conservation-oriented perspective over the last 50 years, well before the adoption of 
the Directive, which itself participated in the trend towards a conservation shift within zoos (Pritchard, 
et al. 2011). There remains  a dichotomy  between keeping those charismatic species that attract visi-
tors, and conducting direct conservation, research, and education. The answers to the survey and inter-
views carried out, as well as the public consultation, consistently supported the view that the Directive 
participated in this shift towards conservation (see Section 5.5.1.2 below).    

5.1.2.2  Contribution of the Zoos Directive to ensuring the protection of wild fauna 

and the conservation of biodiversity at the international level  

a.  Contribution to implementing the CBD 

The main instrument to protect biodiversity at international level is the CBD. As a contracting party to 
the Convention since 1994, the EU is bound to implement and comply with its requirements, as are its 
Member States. The Zoos Directive was adopted with the aim to fulfil the EU’s ‘obligations to adopt 
measures for ex situ conservation under Article 9 of the Convention’ as stated in the fourth recital of 
the Directive. This Directive is the only piece of legislation in the EU legal order which regulates these 
matters.   

It  is  widely  acknowledged  that  efforts  to  protect  biodiversity  should  focus  on  measures  applying  in 
situ, and Article 9 provides that ex situ conservation measures shall be undertaken ‘predominantly for 
the purpose of complementing in situ measures’. This has been recognised in the international legisla-
tion and in literature but is not expressly reflected in the Directive, and few zoos currently combine ex 
situ and in situ conservation efforts (see Section 5.3.3). 

Ex situ conservation measures envisaged under Article 9 of the CBD include:  

  Adoption of measures for the ex situ conservation of components of biological diversity (Article 

9(a)). 

  Establishment and maintenance of facilities for ex situ conservation and research (Article 9(b)).  
  Measures for the recovery and rehabilitation of threatened species and for their reintroduction into 

the wild (Article 9(c)). 

  Regulation  and  management  of  the  collection  of  biological  resources  for  ex  situ  conservation 

purposes in a way that does not threaten in situ populations of species (Article 9(d)). 

  Cooperation  in  providing  financial  and  other  support  for  ex  situ  conservation,  and  in  the 
establishment and maintenance of ex situ conservation facilities in developing countries (Article 

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9(e)).  

The adoption of the Directive in itself responds to the Article 9(a) requirement139. On the other hand, 
the conservation measures of Article 3 of the Zoos Directive on research participation, captive breed-
ing,  repopulation  and  reintroduction  into  the  wild,  and  the  prevention  of  animal  escapes  in  order  to 
avoid possible ecological threats to native species, reflect to a great extent the ex situ measures fore-
seen in Article 9(b) to (d).  

This correspondence was observed in the present survey, where nearly all respondents from MSCAs 
and federations/NGOs (11 out of 12 and 15 out of 19, respectively) observed a synergy between the 
two  texts.  Similarly,  54%  of  respondents  to  the  public  consultation  who  expressed  an  opinion  also 
considered the Directive and the CBD to be mutually supportive140. However, literature points to cer-
tain discrepancies between the Convention and the Directive that would impede proper implementa-
tion of the Convention, with the Directive described as a ‘lost opportunity to implement the Conven-
tion’ (P. A. Rees 2005a). On the basis of the literature and interviews, some such elements can indeed 
be observed.  

One discrepancy refers to the alternative wording provided in Article 3 first indent, where the Con-
vention requires its parties to engage in all activities (P. A. Rees 2005). Indeed, this may go against the 
spirit  of  the  Convention,  and  even  though  the  alternative  wording  may  impede  greater  protection  of 
biodiversity (see Section 5.1.3 below), from a legal perspective, the Convention’s requirement is ad-
dressed to the parties, and it can be argued that the different approach adopted by the Directive stems 
from giving Member States the option to enable zoos to implement one or other of the measures yet 
ensuring that, overall, all measures adopted at national level cover all types of measures.  

Another issue is that the Directive does not expressly requires zoos to participate in the captive breed-
ing and reintroduction of endangered species, as per Article 9(c) (P. A. Rees 2005a). The Directive 
takes a broader approach and refers to species in more general terms. Even though, as previously de-
scribed,  zoos  can  contribute  to  conservation  by  breeding  non-threatened  species,  and  this  survey 
showed a contribution of zoos to the reintroduction of threatened species, the current wording of the 
Directive does not in itself guarantee that the requirements of Article 9(c) will be properly implement-
ed.  

While the CBD provides that measures for ex situ conservation, in particular the establishment of ex 
situ conservation facilities, should be undertaken preferably in the country of origin of the species, 
such wording is absent from the Directive. Measures have nevertheless been adopted at EU level and 
are  described  in  the  analysis  of  the  contribution  of  the  Directive  to  biodiversity  conservation  at  EU 
level developed below.  

The common points and differences between the Convention and the Directive illustrate that, from a 
theoretical (legal) perspective, the Directive properly reflects the requirements of the Convention, with 
some limitations. In terms of practical implementation, this, in turn, means that where zoos have en-
gaged in activities in the area of research,  captive breeding, reintroduction and  prevention of escape 
(as  seems  to  be  the  case,  see  Section  5.1.1),  the  Directive  has  contributed  to  implementing  the  re-
quirements of the Convention. While discrepancies are observed, national legislation or zoos which go 
further than the Directive (by cumulative conservation measures and a proportion of reintroduction of 
threatened species) can be considered to fully implement Article 9 of the Convention.  

b.  Contribution of the Directive to implementing CITES 

There is a clear connection between the Zoos Directive and CITES, which aims to conserve biodiver-
sity by regulating trade in species of wild fauna and flora. Trade is regulated through a system of pro-
cedures and documents requiring, among other things, the issuing of import and export permits admin-

139 Article 9(d) goes beyond the scope of the Directive, though funding is an important component of zoos’ activities (see previous sub-
section on contribution of zoos to biodiversity conservation).  
140 See Annex I to the Public Consultation Report (Annex VIII), Section 1.6. 

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istered by the Management Authorities. Importantly, trade and the display to the public of certain spe-
cies  (listed  in  Annexes)  for  commercial  reasons  are  prohibited.  Exemptions  from  the  prohibition  of 
displaying such species to the public may be granted for research and education purposes aimed at the 
preservation and conservation of species, as well as for species intended for breeding that will build up 
conservation benefits for the species concerned.  

There are synergies between CITES and the role of zoos which could enhance the achievement of the 
common objective on biodiversity conservation, such as the signing of a memorandum of understand-
ing  (MoU)  between  CITES  and  WAZA  in  2011  (CITES  Secretariat  and  WAZA  2011).  Zoos  in  the 
WAZA network have considerable experience in the care of wild animals and the MoU aims to facili-
tate  the  use  of  this  expertise  to  assist  CITES  Parties  to  implement  the  Convention,  particularly  the 
conservation objective.  

In relation to the implementation of the Zoos Directive itself,  this survey indicated that zoos record-
keeping systems are also used for permits, information exchange and transport certificates (in 45 out 
of 70 cases), and for animal identification in line with the CITES Regulation (in 41 out of 70 cases). 
To that extent, the fifth indent of Article 3 may have contributed to the implementation of CITES (or 
the other way around).  

In several instances, surveys and interviews indicated that the same authorities are in charge of imple-
menting (e.g. France, Italy) and or enforcing (e.g. the Netherlands, Czech Republic, Ireland) the two 
instruments. Conversely, it was mentioned during interviews that the lack of communication and co-
ordination between enforcement authorities in charge of CITES and other zoos inspectors could be an 
obstacle  to  effective  zoo  inspection141.  However,  it  was  also  mentioned  during  interviews  that  the 
CITES  database  was  used  to  inventory  zoos  in  several  countries  (e.g.  Spain),  in  which  case  CITES 
would contribute to the implementation of the Zoos Directive rather than the contrary. EU stakehold-
ers142 also observed that the implementation of CITES has positive impacts for the Zoos Directive in 
terms of consistency between the Zoos’ registers and CITES databases. The public consultation also 
indicated that 50% of the respondents expressing an opinion saw synergies between the Directive and 
the  Convention,  with  a  rate  of  positive  opinion  increasing  to  83%  among  zoo  operators  and  public 
authorities143.  

c.  Contribution of the Directive to implementing other international agreements 

Other international agreements (often known as multilateral environmental agreements or MEAs) are 
directed  at  species  either  wholly  or  in  part.  These  include  the  Convention  on  Migratory  Species 
(CMS)144, the ‘Ramsar’ Convention (formally known as the Convention on Wetlands of International 
Importance)145  and  the  World  Heritage  Convention146.  These  global  processes  predate  the  Zoos  Di-
rective and whilst zoos may become involved in work that supports the objectives of one or more of 
these conventions, this is likely to be quite specific and targeted. Such work may not involve  ex situ 
management but could involve in situ work or other approaches to conservation.  

5.1.2.3  Contribution of the Zoos Directive to ensuring the protection of wild fauna 

and the conservation of biodiversity at the European level  

a.  Contribution of the Directive to implementing the EU Biodiversity Strategy 

The EU Biodiversity Strategy adopted in 2011 ((COM)2011) 244) is one of the elements that reflect 
the commitment of the EU to implementation of the CBD. The Strategy lays down the framework for 
EU action to  meet the 2020 headline target:  ‘Halting  the loss of  biodiversity and the degradation  of 
ecosystem services in the EU by 2020, and restoring them in so far as feasible, while stepping up the 

141 Interview with NGO.  
142Interview with one federation. 
143 See Annex I to the Public Consultation Report (Annex VIII), Section 1.6. 
144 http://www.cms.int/  
145 http://www.ramsar.org/ 
146 http://whc.unesco.org/  

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EU contribution to averting global biodiversity loss’; and the 2050 vision: ‘By 2050, European Union 
biodiversity  and  the  ecosystem  services  it  provides  –  its  natural  capital  –  are  protected,  valued  and 
appropriately  restored  for  biodiversity's  intrinsic  value  and  for  their  essential  contribution  to  human 
wellbeing and economic prosperity, and so that catastrophic changes caused by the loss of biodiversity 
are  avoided’.  The  EU  Biodiversity  Strategy  to  2020  is  built  around  six  mutually  supportive  targets, 
which address the main drivers of biodiversity loss and aim to reduce the key pressures on nature and 
ecosystem services in the EU.  

Target 6 ‘To help avert global biodiversity loss’ is most relevant in the context of the Zoos Directive. 
In addition, contribution to Target 1 ‘Protect Species and Habitats’ (mainly in relation to Natura 2000, 
see point b below), and Target 5 ‘Combat invasive alien species’ can be observed through interlinkag-
es with the Nature Directives and Regulation 1143/2014 on invasive alien species (IAS) (see Section 
5.4.1 below). 

b.  Contribution of the Directive to implementing the Nature Directives 

As  outlined earlier,  Article 9  of the CBD refers to  ex situ conservation, preferably  in the country  of 
origin of the species. Conservation of endemic species of the EU is regulated by the Nature Directives. 
The complementary role of the Nature Directives and the Zoos Directive is particularly important in 
this regard; while the latter is the main EU instrument specifically covering  ex situ conservation, the 
former have created a comprehensive scheme of protection of all wild bird species and natural habitats 
occurring in the EU.   

There are many interactions with the Nature Directives, with zoos  frequently involved in survey and 
conservation efforts for endemic species. In particular, zoos hold species protected by the Nature Di-
rectives (e.g. European mink, red squirrel, bearded vultures, European hamster, corncrake).  

Educational programmes in some zoos address biodiversity and Natura 2000. For instance, in Ireland, 
zoos have used materials from the Ministry on Natura 2000 in their educational programmes. Zoos are 
also  involved  in  the  reintroduction  of  endemic  species.  In  Italy,  for  example,  several  reintroduction 
and repopulation programmes have been carried out in conjunction with Natura 2000 sites (examples 
include the reintroduction of the griffon and the repopulation of the turtle emys orbicularis). This has 
also been the case in France, with reintroduction programmes for prey birds and Alsace Hamsters. 

Six zoos responding to the survey indicated projects  in which they participated in the context of the 
Nature Directives. However, overall, it appears that there is limited participation of zoos in such pro-
jects, or a limited awareness of the link with the Nature Directives.  One authority mentioned during 
interviews that contribution of zoos to conservation programmes in the context of Birds and Habitats 
were  individual  actions  and  that  the  link  should  be  enhanced.  The  results  of  the  public  consultation 
also clearly demonstrate a positive perception of the link between the  Zoos Directive and the Nature 
Directives, with 85% of the  respondents expressing an opinion  considering the Zoos Directive to be 
consistent with, and/or mutually supportive of, the Nature Directives.  

Another good indicator of the interlinkages between the Nature Directives and the Zoos Directive is 
the use of LIFE funding for conservation activities undertaken by zoos. Some stakeholders have ob-
served that zoos may, in order to fulfil the requirements of Article 3 of the Zoos Directive, apply for 
EU funding. In particular, some zoos working on the reintroduction of species in the wild have applied 
for LIFE funding. Smaller educational programmes are also funded by LIFE.  

More than 80 LIFE funded nature projects have included ex situ measures. Between 1995 and 2014, 
17 zoos were involved in LIFE projects and contributed to conservation actions supported by this pro-
gramme147.  In  addition,  over  300  species  included  on  the  Annexes  of  the  Birds  and  Habitats  Direc-
tives, and which are among Europe’s most vulnerable species, benefited from such projects (European 

147 Information provided by the European Commission, DG Environment.  

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Commission 2011). Zoos have participated in these projects by hosting breeding centres, or by provid-
ing  expertise  on  breeding  (European  Commission  2015).  Examples  of  involvement  of  zoos  in  LIFE 
projects are presented in Box 10 below.  

Box 10: Examples of participation of zoos in LIFE funded projects 

Reintroduction of the European mink - programme established by Tallinn Zoo (Estonia) 
The 2000-2004 Estonian project (LIFE00 NAT/EE/007081) aimed to increase European mink num-
bers on the island of Saarema by releasing animals bred in captivity under a programme established 
at the Tallinn Zoo in 1999. The captive breeding stock numbered some 100 individuals and a trial 
release programme began on Hiiumaa Island in western Estonia in 2000. The LIFE project built on 
previously  acquired  experience  to  launch  a  more  substantial  breeding  programme  to  reinforce  the 
size  and  the  genetic  status  of  the  captive  population  at  the  Tallinn  Zoo.  Releases  also  helped  the 
existing captive-bred population on Hiiumaa. By the end of the project, 149 animals had been re-
leased into the wild and the surviving population was estimated to be 16-28 animals. 
Supportive breeding of the European pond turtle - collaboration of Kaunas Zoo (Lithuania) 
In Lithuania, a project (LIFE05/NAT/LT/000094) aimed at improving the reproductive success of 
surviving small populations in the wild was carried out using supportive breeding from turtles bred 
in captivity at Kaunas Zoo. There were also plans to release individuals for recolonisation of sites 
where the turtles were previously found. 
Reintroduction of the fire-bellied toad - specimens bred in Latgale Zoo (Latvia) 
In  order  to  facilitate  the  reintroduction  of  the  fire-bellied  toad,  Latgale  Zoo  established  a  captive 
breeding programme (LIFE04 NAT/LV/000199) for  Bombina bombina, starting off with five ma-
ture toads. As a result of the programme, some 870 individuals were reintroduced to selected wet-
lands  in  the  park  between  2006  and  2008.  The  captive  breeding  programme  is  continuing  after 
LIFE, with up to 300 individuals being released and monitored each year by researchers working in 
cooperation with Latgale Zoo. 
Reintroduction of the Hungarian meadow viper - veterinary support from Budapest Zoo (Hungary) 
With  financial  assistance  from  LIFE  (LIFE04  NAT/HU/000116),  the  beneficiary  started  a  pro-
gramme of collecting individuals from threatened populations and reintroducing them into the wild 
in  suitable  and  secured  habitats.  Veterinary  support  –  and  food  sources  (crickets)  for  the  vipers  – 
came from Budapest Zoo. 
Source: LIFE preventing species extinction - Safeguarding endangered flora and fauna through ex situ conser-
vation, European Commission, 2011. 

One EU stakeholder148 mentioned that the Zoos Directive created the assumption that zoos contribute 
to biodiversity as they are  ex situ biodiversity conservation centres, which facilitates the granting  of 
LIFE funding. The European Commission, when evaluating LIFE funded ex situ projects, concluded 
that even though ex situ actions were not always successful and have faced a range of challenges, it 
was ‘clear that many of the ex situ programmes supported by LIFE have effectively meant the recov-
ery  of  species  that  would  otherwise  have  become  extinct  if  only  habitat  management  measures  had 
been  applied’  (European  Commission  2011,  p.7).  Zoos,  as  conservation  entities  under  the  Directive 
and key stakeholders in these programmes, have contributed to this success.  

Erasmus grants are also available for training and education programmes among zookeepers.  

Nevertheless,  interviews  and  the  literature  (Gusset  and  Dick  2010)  indicate  that  most  projects  are 
funded by the zoos themselves, or by their federations (in particular by EAZA).  

c.  Contribution of the Directive to other EU instruments 

A  few  other  instruments  are  worth  mentioning,  in  view  of  their  synergies  with  the  Zoos  Directive. 
Such synergies imply a contribution to the Directive, and vice versa.  

148 Interview with EU stakeholder. 

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One such instrument is Regulation (EC) No 338/97 on the trade of endangered species. This act im-
plements the CITES Convention, and thus contributes similarly to the Directive as does the Conven-
tion (see Section 5.1.2.2).  

Another  instrument  is  Council  Directive  92/65/EEC of  13  July  1992  laying  down  animal  health  re-
quirements governing trade in and imports into the Community of animals. Some potential synergies 
are explored in Section 5.4.1 below.  

Finally, Commission documents (European Commission 2011, p. 8) refer to a Commission project of 
an EU strategy for ex situ conservation. This project, initiated under the previous Biodiversity Action 
Plan, would aim to have an EU-wide strategic approach to ex situ conservation, revolving around 10 
actions,  such  as  awareness-raising,  promotion  of  good  practices,  data  sharing  and  research.  The  Di-
rective would be instrumental in implementing this strategy.  

5.1.2.4  Summary and conclusions 

The Directive intends to ‘strengthen the role of zoos in the conservation of biodiversity’. Although the 
evidence gathered shows that, overall, zoos undertake the activities listed in Article 3 of the Directive, 
it is difficult to assess the potential of zoos to contribute concretely to conservation through Article 3 
measures. Based on the existing literature on the subject and feedback from stakeholders in the course 
of this study, the following conclusions can be drawn:   

 

Participation  in  research:  there  is  no  evidence  to  assess  the  contribution  of  zoos  to  biodiversity 
conservation  through  research  activities.  Firstly,  the  extent  of  research  activities  is  difficult  to 
measure.  This  may  be  explained  by  the  absence  of  visibility  of  the  research  done  by  zoos  (e.g. 
problems  of  authorship).  Secondly,  the  impact  of  such  research  on  overall  conservation  is 
unknown.  Indeed,  it  is  not  possible  to  definitively  measure  the  impact  of  research  activities  on 
conservation at a macro scale.  

  Captive breeding, repopulation and reintroduction: captive breeding is one of the  most common 
conservation  activities  carried  out  by  zoos,  reintroduction  being  less  frequent.  The  level  of 
contribution of these activities to conservation is subject to debate both within the literature and 
among  stakeholders,  in  particular  in  relation  to  the  benefits  (or  lack  thereof)  of  keeping  non-
threatened species in zoos. Here again, the existing evidence does not permit an assessment of the 
actual level of contribution of such activities to conservation.   
Public awareness: public education is a longstanding activity undertaken by zoos. Recent studies 
point to a real benefit in terms of  visitor  awareness of conservation  issues. The  impact on their 
long-term behaviour towards biodiversity conservation, however, remains limited.  

 

In parallel, the evidence also indicates that the Zoos Directive represents an essential condition for the 
achievement of the general objectives set at European and global level in relation to the protection of 
wild fauna and conservation of biodiversity, in particular: 

  At EU level, Targets 6, 1 and 5 set in the EU Biodiversity Strategy and the preservation of local 

fauna promoted in the Nature Directives. 

  At international level, Article 9 of the CBD and CITES.  

5.1.3  Effectiveness – EQ 3 

Which main factors (e.g. implementation by Member States, action by stakeholders) have contributed 
to, or stood in the way of, achieving these objectives? 

This question aims to understand the underlying reasons for the progress and difficulties observed in 
the achievement of objectives of biodiversity conservation and protection of wild fauna, as presented 
in EQ1. It shall identify the elements that have enabled the completion of the  activities described in 
the intervention logic presented in Section 2.2.  

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The analysis is based mainly on the consultation  with stakeholders. The survey and, to a greater de-
gree, the interviews, provided insightful information as to the elements believed to have positive and 
negative effects on the achievements of the Directive’s objectives. Literature research is also consid-
ered  in  the  analysis,  including  legislation  and  documents  accompanying  the  implementation  of  the 
Directive. The public consultation did not provide significant information in relation to this question, 
and is included only where relevant.   

The factors influencing the achievement of the Directive’s goals can be articulated around three key 
elements: 

 

 

Firstly, and most importantly, the Directive places obligations on the Member States through its 
licensing and inspection requirements. The transposition, implementation and enforcement by the 
Member States’ authorities of the legislation therefore needs to be assessed. 
Secondly, other stakeholders, and in particular the European Commission, the federations, NGOs 
and zoos themselves, also play a role in implementing the Directive, and their actions necessarily 
influence the achievement of the Directive’s objectives.  

  A final emerging factor is that the economic component of zoos’ activities had a non-negligible 

impact on the achievement of the Directive’s goals. 

The analysis is therefore structured according to these three points.   

5.1.3.1  The 

impact  of 

implementation  and 
enforcement  by  Member  States’  authorities  on  achieving  the  objectives 
of the Zoos Directive 

interpretation, 

transposition, 

As explained in Section 2.2, the Directive’s obligations lie with the Member States. Activities under-
taken by the authorities therefore play a key role in the achievement of the Directive’s objectives. The 
authorities intervene in three main areas: transposition, implementation and enforcement. Overall, the 
stakeholders surveyed (federations, NGOs and scientific experts) had different perceptions of the im-
pact of transposition, implementation and enforcement: nearly all federations (11 out of 13) considered 
the  contribution  positive, while  NGOs  were  much  more  divided  on  the  question  (four  positive/  four 
negative/ two no effect). An analysis of the impact of the actions corresponding to these three areas is 
presented below. The targeted consultation and literature both suggested that the level of clarity of the 
wording of the Directive  had a significant  impact on the level of implementation of the Directive in 
the Member States and thus on the achievement of its objectives.  

a.  Interpretation of the Directive 

The Directive is quite  generic in its wording, and this has in  some instances prevented a  consistent, 
and  effective,  implementation  of  the  Directive  in  the  Member  States.  In  general,  most  stakeholders 
surveyed  (federations  and  NGOs)  assessed  the  impact  of  the  level  of  clarity  of  the  Directive  on  its 
implementation  positively  (11  respondents,  mainly  federations149),  while  six  respondents  considered 
the  impact  negative  (all  NGOs),  and  five  opted  for  neutral150.  Given  the  size  of  the  sample  (22  re-
spondents expressed an opinion), and the clear division of opinion of answers depending on the type 
of stakeholder, it is not possible to draw conclusions on the actual impact of the level of clarity of the 
Directive based on the survey. However, the interviews conducted as part of the study provided addi-
tional elements of understanding, with some recurring issues visible:   

  The  definition  of  ‘zoos’,  in  Article  2  of  the  Directive151:  the  question  of  the  clarity  of  the 
definition  was  asked  of  all  stakeholders  during  interviews.  Thirteen  respondents  (all  types  of 
stakeholder) assessed the impact of the definition as negative, while six assessed it positively. A 
few elements emerge as being problematic: 

149 Eight federations, two NGOs, one international organisation.  
150 Four federations, one NGO.  
151 See overview table in Annex III. 

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  Minimum of seven days of exhibition is not reflected in the definition in several countries, 
including  Belgium  and  Spain.  On  one  hand,  some  stakeholders152  argued  that  this 
requirement omits those establishment exhibiting animals only for ‘open days’. On the other 
hand,  others,  including  federations,  considered  that  all  establishments  keeping  animals 
should be subject to the Directive, irrespective of their opening to the public. Spain offers an 
interesting  example  here.  Even  though  it  does  not  provide  a  minimum  number  of  days  for 
opening, it has two different regimes: one for zoological gardens and another for zoological 
centres (núcleos zoológicos), which do not have to meet the stricter licensing requirements of 
zoological gardens. Zoological gardens are open to the public, while zoological centres are 
not. However, it has been reported153 that in order to maintain their public-related activities, 
zoological  centres  have  taken  advantage  of  the  existing  legislation,  without  meeting  the 
requirements for zoological gardens. For instance, they sign up to education activities (such 
as training courses) in order to have some open days for the public but still are not required 
to meet the licensing requirements of zoological gardens.  Here, the differentiation between 
open to the public or not has clearly impeded the objectives of the Directive.  

  The exemption on the ground that the establishment does not exhibit ‘a significant number 
of  species  or  animals’  has  been  interpreted  very  differently  where  such  exemptions  have 
been used. The number of species varies between five (Germany) and 20 (Czech Republic) 
in the countries surveyed154, and the number of specimens between five (Germany) and 100 
(Ireland), while some countries transpose the definition literally (e.g. Bulgaria) or assess the 
exemption on a case-by-case basis, irrespective of the number (e.g. Italy and Cyprus). Some 
countries, such as Italy, have used a greater margin of interpretation in order to exempt zoos 
(see Workshop Report in Annex IX). Also, several stakeholders from federations and NGOs 
likewise consider that the criterion  of ‘number of species’ is not relevant, having observed 
that  ‘excellent  facilities  with  programmes  of  biodiversity  conservation  can  focus  on  one 
single species’. One stakeholder pointed to good practices in Austria and the UK, where zoos 
are  categorised  based  on  the  number  of  species,  proportion  of  specific  taxa  and/or  species 
conservation status (see Box 11 below). 

Box 11: Categorisation of zoos in Austria 

According to the Ordinance on minimum requirement for zoos (BGBl II Nr. 491/2004) transposing 
the Zoos Directive, zoos are classified into three categories: 

  Category  A  zoos  are  allowed  to  keep  any  species,  without  restriction:  this  is  subject  to  the 
supervision  of  a  highly  qualified  zoologist,  biologist  or  veterinarian,  and  presence  of  a  sufficient 
number  of  qualified  keepers  and  caregivers.  These  zoos  are  required  to  participate  in  research, 
training activities and exchange of information.  

  Category B zoos are not allowed to keep certain species which are explicitly listed. If the supervisor 

does not have the necessary qualification, an external veterinarian must be contracted.  

  Category C zoos are only allowed to keep species that are exhaustively listed in the Act. Caretakers 

should be present in sufficient number and be sufficiently qualified.  

Category B and Category C zoos are required to fulfill at least one of the conservation tasks listed in the 
legislation,  which  include  participation  in  research,  training,  exchange  of  information,  or,  where 
appropriate, captive breeding, repopulation or reintroduction.   

  The  concept  of  wild  species:  this  concept  is  defined  in  most  countries  surveyed155.  The 
definitions do not vary significantly from one county to another and thus do not appear to be 
problematic.  

  The concept of ‘mobile zoo’: several stakeholders referred to a challenge with the definition 
of zoos when it comes to ‘mobile zoos’ (e.g. ‘Hawk Walks’) and whether these are included 

152 One MSCA. 
153 Interview with NGO. 
154 The Born Free 2011 Inquiry refers to Member States with licensed large animal collections of over 300 species.  
155 Lithuania, the Netherlands, the Czech Republic, Denmark, Cyprus, Poland, Ireland and France. 

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in  the  scope  of  the  Directive.  For  instance,  mobile  (or  ‘travelling’)  zoos  are  expressly 
covered in the Belgian definition of zoos, while they are expressly excluded (‘on the spot’) 
in the French and British definitions.  

Each of these elements of definition has a direct impact on the scope of application of the Directive, 
and thus on the achievement of its objectives. The impact of the definition of ‘zoos’ may be positive or 
negative, depending on whether they include or exclude certain establishments from the scope. Over-
all, the margin of discretion given to the Member States for interpretation has resulted in significant 
discrepancies  and  is  likely  to  have  impeded  implementation.  Several  stakeholders  interviewed  ex-
pressed the view that the definition was ‘outdated’ and would need to be reviewed  in order to avoid 
the discrepancies observed in the different national legal systems. On the one hand, EU-level federa-
tions  considered  that  the  current  scope  was  too  broad  to  allow  the  conservation  aim  to  be  achieved 
(e.g. the inclusion of natural history museums or aviaries not dedicated  to conservation or ‘catch-all 
that applies to a wide range of institutions with little common grounds’). On the other hand, several 
stakeholders (including federations) stated that the scope was too narrow, with establishments such as 
sanctuaries not being covered by the Directive because they are not open to the public, despite playing 
an  important  role  in  conservation.  One  federation  advocated  for  a  ‘two-speed’  system,  whereby  the 
terms ‘zoo/zoological parks’ would be reserved for institutions that are mainly committed to biodiver-
sity conservation, education, research or training in these fields, while other facilities, including sanc-
tuaries, would be included under the Zoos Directive under a broader concept of ‘animal facilities’. All 
facilities hosting animals would abide by certain minimum standards and requirements, while zoologi-
cal parks would be recognised as having a specific role in the conservation of biodiversity.  

  The  alternative  options  provided  under  Article  3,  first  indent,  provides  the  possibility  for 
Member States to choose between participating in research, training, exchange of information and 
captive breeding, repopulation or reintroduction. This flexible approach has pros and cons: 
 

It is considered by some stakeholders as the most reasonable option to ensure that all zoos, 
including  small  ones,  can,  within 
to 
conservation156. As one EU stakeholder observed157, ‘institutions have different capabilities 
and objectives’, and it therefore ‘makes sense to leave a margin for them to prioritise their 
objectives and resources’. 

their  possibilities,  contribute 

the  remit  of 

  On the contrary, for one MSCA and two NGOs158, compliance with a selection of measures 
cannot  guarantee  a  strengthening  of  biodiversity  conservation.  It  is  also  argued  in  the 
literature that most zoos would already have necessarily complied with at least one of these 
elements in their daily routine as a zoo (P. A. Rees 2005a). This is particularly the case for 
measures  such  as  captive  breeding  or  exchange  of  information.  Besides,  the  impact  on 
conservation  of  such  measures  taken  in  isolation  is  arguable,  and  the  range  of  measures 
proposed  have  a  more  or  less  strong  link  with  conservation  (for  the  latter  point,  see 
(BornFree 2011, p.30) and a variable impact on biodiversity (see Section 5.1.2.1).  

While it may be unrealistic to expect the same level of investment and commitment from all zoos irre-
spective of their size or resources, the contribution of some of the measures listed by Article 3, first 
indent, to conservation if implemented as a single measure (e.g. training) is unclear. On that point, the 
zoos  survey  responses  revealed  that  zoos  are  likely  to  be  engaged  in  exchange  of  information  with 
other  zoos,  while  other  measures  such  as  training  on  conservation  skills  and  captive  breeding  pro-
grammes  are  less  frequently  undertaken  (see  Section  5.1.1).  It  should  nevertheless  be  kept  in  mind 
that, at a broader scale, it is the varied and cumulative activities of all members of the zoo community 
that will have an impact  on biodiversity conservation, rather than  the activities of each  zoo taken in 
isolation.  

156 Interview with one zoo federation and MSCA.  
157 Interview with EU stakeholder.  
158 Interviews with MSCA, EU stakeholder and NGO. 

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  The  lack  of  clarity  of  the  Directive’s  wording  in  Article  3  has  been  mentioned  by  many 
different  stakeholders,  authorities,  NGOs  and  federations  as  a  key  factor  impeding  the  proper 
implementation of the Directive.  
 

In relation to research, training, exchange of information and captive breeding, repopulation 
and reintroduction, the lack of indications on measuring the proper implementation of these 
activities, together with the lack of common criteria for such an assessment, were mentioned 
as problematic issues by national authorities. In particular, one MSCA pointed  out that the 
Directive ‘does not provide the necessary elements to assess the correspondence between an 
activity and its objectives, be it from a qualitative or from a quantitative point of view’159. 
  The lack of specific rules results in the same problem for assessing proper implementation of 
public education in the Member States. One stakeholder mentioned that the lack of specific 
rules sometimes resulted in biased information being provided by zoos to the public160.  
  NGOs161  and  national  authorities162  both  stated  that  the  provisions  on  care  and  keeping  of 
wild  animals  needed  better  definition.  More  precisely,  the  expression  ‘satisfying  the 
biological and conservation requirements’ of species was deemed too vague to ensure proper 
implementation163. The lack of standards at EU level leaves Member States with the choice 
of adopting standards, or not; and while many countries have adopted specific standards for 
accommodation and care (e.g. Belgium, Bulgaria and Italy)164, these may vary considerably 
from  one  country  to  another  (see  the  comparative  analysis  in  (BornFree  2011,  p.  37-38). 
Several stakeholders, however, including authorities and federations, stated that the adoption 
of  standards  in  the  EU  legislation  would  be  problematic,  since  guidance  on  animal 
husbandry  is  very  complex  and  detailed  (species-specific),  needs  constant  updating  and  in 
view  of  the  fact  that  a  consensus  among  stakeholders  on  appropriate  standards  would  be 
difficult  to  obtain  (as  illustrated  by  the  differences  in  existing  standards  among  Member 
States).    

The  wording  of  the  Directive  has  given  much  lee-way  to  the  Member  States  in  their 
implementation  of  conservation  measures.  This  is  likely  to  come  at  the  expense  of  more 
ambitious conservation goals which would improve the achievement of the Directive’s objectives. 
The Good Practice Guidance Document provides an in-depth explanation on how to interpret the 
provisions of the Directive but was issued a long time after the entry into force of the Directive 
and its dissemination remains problematic (see Section 5.1.3.2a below).  

b.  Transposition of the Directive in the Member States  

Key factors influencing the effectiveness of the Directive also  stem from  the legislative activities of 
the Member States. 

Impeding factors 

The  infringements  launched  at  EU  level  (see  Section  4.2)  provide  a  good  overview  of  the  problems 
experienced by Member States in relation to the transposition of the Zoos Directive in their legal or-
der. The Commission launched 11 cases for late transposition165 of the Directive at national level. A 
brief overview of the delays experienced in transposition which gave rise to infringement procedures 
is provided below.  

Table 22: Overview of late transposition of the Directive 

Member State 

Date  of  adoption  or  entry  into 
force of the legislation 

Delay in transposition 

159 Interview with MSCA. 
160 Interview with NGO. 
161 Interview with EU stakeholder. 
162 Interview with MSCA. 
163 High-level questionnaire, Q40.  
164 An overview of countries which adopted standards is provided in Section 5.5.2.1. 
165 An infringement case against France was opened for non-communication but closed once existing measures were notified in July and 
August 2002. The same applied to Sweden. 

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Member State 

Delay in transposition 

Date  of  adoption  or  entry  into 
force of the legislation 
30 January 2003 (Burgenland) 
1 January 2003 
25 June 2003 (Aland) 
1 August 2005 (Bavaria) 
3 March 2004 
19 September 2003 
2 May 2005 
10 February 2003 
1 April 2003 
27 October 2003 
31 March 2003 

10 months 
Nine months 
14 months 
Three years and three months 
Two years 
17 months 
Three years 
10 months 
12 months 
18 months  
11 months 

Austria 
Denmark 
Finland 
Germany 
Greece 
Ireland 
Italy 
Luxembourg 
Portugal 
Spain 
UK 
Source: Desk research for the present study  
With delays ranging from between nearly one year to more than three years, late transposition is one 
of the elements that impeded the proper implementation of the Directive. In practical terms, it meant 
that, in most of these cases, the issue was not (properly) regulated in these Member States. The same 
observation  applies  to  countries  which  adopted  new  legislation  even  though  their  transposition  was 
already effective (i.e. France and Germany). While transposition was considered effective by the dead-
line in France and by 2004 in Germany, both countries later adopted new legislation with a significant 
increase in the quality of transposition (in 2004166 and 2010167, respectively)168. 

Four infringement cases were also launched for  non-conformity against Austria, Italy, Slovakia and 
Latvia. These cases indicate that the national legislation was not in line with the Directive. Incorrect 
transposition  prevents  the  full  achievement  of  the  Directive’s  objectives  in  the  Member  States  con-
cerned. For instance, the Italian case referred to an incorrect transposition of the definition of ‘zoo’. As 
a result of incorrect transposition, the scope of the Italian legislation was wrongly narrowed down to 
establishments  being  de  facto  compliant  with  the  Directive  (see  Section  4.2),  thus  preventing  other, 
more ‘entertainment-oriented’, zoos to increase their standards to reach the conservation objectives of 
the Directive.    

While transposition may, in some instances, have impeded proper conservation and protection of wild 
fauna, in other areas  it has been instrumental in contributing to the achievement of these objectives, 
such  as  providing  additional  requirements  to  those  of  the  Directive,  in  order  to  avoid  some  of  the 
shortcomings described above.  

Contributing factors 

  Additional  requirements  provided  in  the  transposing  legislation  at  national  level  have  been 
observed in several instances (See Annex III for an overview of selected instances of additional 
requirements169). Analysis of additional requirements shows that national legislation has, in some 
cases, been designed so as to remedy the ambiguities observed in the Directive.  
 

In relation to the definition of zoos, the Spanish definition does not refer to a number of days 
of opening to the public.  

  According  to  the  Born  Free  2011  Enquiry,  four  Member  States  (Bulgaria,  France,  Poland 
and Portugal) require a combination of three or more of the measures listed as alternatives in 
Article 3, first indent (BornFree 2011, p.30). It is also the case for Italy. 
France has an additional requirement relating to the level of qualification of zoos operators. 

 

166 Order of 25 March 2004 constitutes the key transposing act for the Zoos Directive.  
167 Federal Nature Conservation Act of 2010 replaced the framework provisions with a set of provisions at the federal level, which are direct-
ly applicable without additional Federal States’ regulations. 
168 In addition, the Netherlands adopted their transposing act with a slight delay (10 days). In this case, it cannot be considered that the timing 
of transposition had a negative impact on the level of implementation.    
169 Annex III, Table 9: Prepared mainly on the basis of the Good Practice Document, with supporting information from this survey and desk 
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There, in addition to the zoo licence, zoo operators are required to have a personal certificate 
of capacity. The granting of this certificate is decided by a Committee, and requires a good 
understanding and commitment to conservation of biodiversity. In bigger zoos, all managers, 
including financial managers, have this certificate.  

  Legislation existing prior to transposition has also contributed to the proper implementation of 
the Directive’s requirement in some Member States. Legislation regulating zoos existed in several 
of the Member States before the adoption of the Directive (see Section  4.1). In these countries, 
pre-existing legislation facilitated the implementation of the Directive thus contributing to more 
rapid achievement of the Directive’s objectives (e.g. Belgium, Denmark and France). Similarly, 
although  transposition  occurred  later  for  the  Member  States  which  became  members  after  the 
deadline,  most  countries  had  already  regulated  the  issue  before  accession170.  In  these  cases,  it 
cannot  be  considered  that  the  timing  of  transposition  had  a  negative  impact  on  the  level  of 
implementation.  If  at  all,  transposition  before  accession  in  the  new  Member  States  limited  the 
differences in the timeframe for the implementation between the ‘new’ and ‘old’ Member States.   

c.  Implementation of the Directive’s Article 3 and Article 6 requirements in the Member 

States  

Section  5.1.1  provides  an  overview  of  the  status  of  implementation  of  the  Article  3  conservation 
measures. 

Two infringement cases for bad application have been launched by the Commission. The first related 
to non-compliance of a zoo  in Cyprus171 with conservation  measures, while the second  related  to li-
censing  issues  in  Spain  (see  point  d  below).  Of  these  two,  the  Cypriot  case  was  based  on  problems 
observed with one zoo and arguably has little impact on the protection of wild fauna and biodiversity 
of conservation172. The number of cases is very low, and would not indicate major issues with the im-
plementation of the Directive.  

Nevertheless,  some  factors  relating  directly  to  MSCAs’  implementation  were  mentioned  by  the  sur-
veyed  stakeholders  as  impacting,  either  positively  or  negatively,  the  achievement  of  the  Directive’s 
objectives. These factors are summarised below.  

Impeding factors:  

  Organisation  of  Member  State  administration  to  implement  the  Directive  has,  in  some  cases, 
proved  problematic.  The  division  of  competences  between  different  levels  of  administration 
(federal/ national/ regional) has, in some instances, complicated the proper implementation of the 
Directive and thus impacted its effectiveness. In three of the cases of late transposition (Austria, 
Germany and Spain, see above), the delay was experienced because of late transposition by one 
or  more  regions.  This  problem  was  also  mentioned  in  both  the  literature  and  in  the  survey  for 
other  countries  (e.g.  Belgium,  France173).  Coordination  between  different  authorities  was 
considered a negative or non-existent factor for the achievement of the Directives’ objectives by 
13 out of 26 respondents to the high-level questionnaire, while five considered coordination to be 
both  present  and  positive.  Another  element  raised  by  a  few  stakeholders  is  the  portfolio  of 
national  authorities  which  often  includes  other,  more  demanding,  areas  (e.g.  CITES,  animal 
health) and which make implementation of this Directive a second rank issue174 (see also Section 
5.1.1.2).  As  explained  in  detail  earlier  (see  Section  5.1.1.2),  the  lack  of  knowledge  among 
national  authorities  and  the  absence  of  exchanges  across  MSCAs  were  also  mentioned  as 
impediments to implementation of the Directive by many stakeholders175.  

170 For example, Lithuania adopted basic legal acts on wild fauna, regulating zoos, in 2002, Bulgaria and the Czech Republic in 2003. 
171 Limassol Zoo in Cyprus. 
172 Consistent with the analysis given by the Commission. 
173 Mentioned in the Born Free Inquiry 2011- not experienced as an issue by the authorities interviewed.  
174 Interview with MSCAs. 
175 Interview and survey of EU stakeholders, federations, experts and NGOs. 

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  The identification and inventory of zoos has proved very difficult in the context of the present 
exercise. Several Member States’ authorities agreed that gaining an overview of zoos existing in 
the country was a problem176. Of the 14 Member States surveyed, five reported having a central 
database for zoos (Cyprus, the Czech Republic, Ireland, Poland and Portugal)177, three of which 
are  accessible  to  all  local  and  regional  authorities  dealing  with  the  Zoos  Directive  (see  Section 
5.1.1.2). Monitoring of the proper implementation of the Directive can only be impaired by this 
lack of data.  

  The  requirements  of  Article  6  on  the  closure  of  zoos  have  been  difficult  to  implement  (see 
Section  5.1.1),  partly  because  the  authorities  failed  to  regulate  the  rehoming  of  animals.  This 
resulted  in  zoos  remaining  open  in  spite  of  their  non-compliance  with  the  Directive’s 
requirements178, among other issues.  

Contributing factors:  
The proactive attitude to implementation among the national authorities and the support they provid-
ed  to  implement  the  requirements  were  considered  as  a  positive  factor  by  some  of  the  stakeholders 
surveyed and interviewed. In particular: 

  Guidance documents have been adopted at national level by several Member States (e.g. Spain, 
Ireland, the Netherlands, the UK, Germany). Several stakeholders, such as associations and zoos, 
deemed this a positive element. 

  Training and workshops given by national authorities were also mentioned by stakeholders as a 
contributing  factor.  In  Bulgaria,  for  example,  the  authorities  organised  three  training  sessions 
between 2012 and 2014 for zoo staff, inspectors and zoo managers. 

d.  Enforcement of the Directive in the Member States  

The explanation provided in Section 5.1.1 on the licensing and inspection procedures in the Member 
States provides an overview of the factors which influenced the proper enforcement of the Directive. 
These are listed below (see Section 5.1.1 for more detail).  

Impeding factors:  
  Lack  of  adequate  knowledge  and  training  among  Member  States’  authorities  in  charge  of 

enforcing the Directive. 

  Lack  of  sufficient  resources  to  perform  systematic  screening  of  the  establishments  on  the 

 

national territory. 
Inconsistencies among Member States and among regions  in the level of enforcement of the 
Directive (i.e. level of requirement, frequency of inspections, level of sanctions and consistency 
in their application).   

 

Contributing factors:  
  Additional  enforcement  activities,  such  as  legislative  updates,  preparation  of  guidance 
documents or protocols for inspections, or organisation of training (e.g. training programme for 
inspectors) to counteract the lack of clarity of the Directive.  
Sub-contracting  of  inspections  (e.g.  Ireland),  as  well  use  of  external  experts  with  appropriate 
technical  knowledge  to  assist  in  inspections  (see  Table  14  above).  According  to  an  Irish 
stakeholder, subcontracting of inspection was ‘the biggest change [in implementation] in the last 
two  years,  […]’  which  ‘resulted  in  a  comprehensive  zoo  inspection  process  and  the  tools  to 
enforce  it  which  has  provided  the  operators  with  clear  expectation  and  the  means  to  meet  the 
Directive and its legislative transposition into Irish law’179. 
Synergies  with  other  EU  acts  resulting  in,  for  example,  combined  inspections  for  the 
enforcement of the different acts applying to zoos (see Section 5.4). 

 

176 Interview with MSCA. 
177 Websites with list of zoos have been identified in the Czech Republic, Denmark, the Netherlands, Poland, Portugal and Spain (Table 16). 
178 Mentioned in interviews, Born Free Inquiry 2001 and Born Free Inquiry 2016, and observed in EU case law.  
179 Interview with MSCA. 

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5.1.3.2  The  impact  of  other  stakeholders’  activities  on  the  achievement  of  the 

objectives of the Zoos Directive 

According to the stakeholders surveyed, stakeholder involvement generally has contributed to the ef-
fective implementation of the Directive180.  

a.  Actions by the European Commission 

Impeding actions 
  The  lack  of  monitoring  and  reporting  requirements  in  the  Directive  has  been  repeatedly 
mentioned by stakeholders as a factor which, even if not an impediment, did not contribute to the 
effective implementation of the Directive. As pointed out by stakeholders181 and observed by the 
project team, the absence of monitoring results in scarcity of data and makes it difficult to assess 
the progress achieved under the Directive.   

  The absence of a forum for exchange among MSCAs, such as a European Commission Steering 
Group or Stakeholders’ group on zoos and aquariums, comparable to those in place for other EU 
acts  (e.g.  CITES  Regulation)  has  been  raised  as  an  issue  in  both  the  survey182  and  the 
interviews183.   

Contributing actions 
  The Commission has launched 21 infringement actions and five pilot procedures. Seven of these 
cases reached the Court of Justice, and a judgment was issued in one case (Germany) (see Section 
4.2).  The  Commission’s  enforcement  activity  was  therefore  quite  limited.  However,  the 
Commission’s involvement has been beneficial to the proper implementation of the Directive, as 
transposition has been sped up by the Commission’s intervention in many cases, and since it can 
be assumed that full compliance was unlikely to be achieved without those interventions.   

  The  Good  Practices  Document  (VetEffecT  2015)  was  viewed  as  a  positive  tool  by  all 
stakeholders  interviewed  (i.e.  MSCAs  and  EU-level  stakeholders).  Some  authorities  expressly 
confirmed that they used it (e.g. France, Denmark and the Netherlands), while others considered 
it  to  be  of  limited  interest  because  of  the  level  of  detail  of  their  national  legislation  or  national 
guidelines (e.g. Belgium, Germany). The document is directly mentioned in the Zoos Standards 
document in Ireland. 
However,  several  stakeholders  complained  about  the  lack  of  distribution  of  the  document,  with 
the  language  of  the  document  cited  by  many  stakeholders  as  the  main  issue  for  its  lack  of 
dissemination184.  One  EU  stakeholder  suggested  including  a  reference  to  the  Good  Practices 
Document  in  the  Directive  to  improve  its  visibility185.  The  lack  of  clarity  (multiple  cross-
references to other documents) was also mentioned as an issue by one stakeholder186.   

  Funding  of  research  or  education  programmes  is  another  action  by  the  European  Commission 
which  has  supported  the  application  of  the  Directive,  in  particular  the  LIFE  and  ERASMUS 
funding  awarded  to  zoos  leading  or  contributing  to  conservation  work  (see  Section  5.1.2.3  b). 
However, contributions remain limited, as zoos tend to fund their own projects. Applications for 
EU funding are considered too burdensome and time-consuming for zoo operators187, confirmed 
by  the  high-level  survey,  in  which  only  three  respondents  agreed  that  dedicated  funding  and 
resources  contributed  to  the  implementation  of  the  Directive,  while  15  respondents  considered 
impact negative (11) or non-existent (four). The problem of funding conservation activities was 
also raised as an issue by stakeholders in the public consultation188.   

  Training  by the  Commission  was  mentioned  by  one  interviewee189.  Training  was  organised by 

180 High-level questionnaire, Q45f:  17 positive answers, two negative, four neutral.  
181 Interview with two EU stakeholders. 
182 Zoos questionnaire - one respondent. 
183 Interview with MSCA and NGO. 
184 Interviews with EU stakeholders and MSCAs.  
185 Interview with EU stakeholder. 
186 High-level questionnaire - answer from academia.  
187 Interview with EU stakeholder. 
188 80 respondents referred to the need to increase EU funding for zoos in the semi-open fields of Question 29 of the Public Consultation.  
189 Interview with EU stakeholder. 

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DG  SANTE  in  2011  on  animal  welfare190,  with  some  sessions  dedicated  to  animal  welfare  in 
zoos.  The  interviewee  however,  observed  that  the  zoo  community  had  little  involvement  in  the 
training, being invited solely as observers, with the training itself given by Born Free. Given this 
lack of involvement, the lack of visibility of such training191, and the focus on animal welfare, the 
contribution of this activity to the achievement of the Directive was probably extremely limited.    

b.  Actions by zoos’ and aquarium federations  

Actions  by  zoos’  associations  at  EU  and  national  level  were  considered  instrumental  in  the  proper 
implementation of the Zoos Directive, according to many stakeholders surveyed for this question192.  

At European level 
As indicated in Section 4.1 above, EAZA is a key stakeholder in the implementation of the Directive, 
with 346 EU zoos members of EAZA in all Member States, except for Cyprus and Malta193. From the 
currently available data, this represents around 17% of licensed zoos in the EU-28194. EAAM has 21 
accredited institutional members (zoos and aquaria) across 10 Member States.  

EAZA,  as  well  as  the  European  Association  for  Aquatic  Mammals  (EAAM),  intervene  in  various 
forms to  support the implementation  of the Directive in order to ensure its effective achievement  of 
conservation objectives: 

  Membership of EAZA and the EAAM involve stricter requirements than those specified by the 
Directive.  Members  must  operate  in  accordance  with  certain  practices  and  standards,  usually 
exceeding  legal  requirements.  The  accreditation  process  to  belong  to  these  associations  is  also 
demanding,  requiring  both  a  financial  investment  and  submission  to  frequent  inspections.  This 
investment  benefits  the  conservation  purposes  of  the  Directive,  even  though  these  activities  go 
well beyond the simple implementation of the EU legal requirements.  As pointed out in Section 
5.1.1,  the  results  of  this  current  survey  support  the  observation  that  membership  of  zoos’ 
associations  is  positively  correlated  with  the  fulfilment  of  conservation  objectives  and  the 
implementation of Article 3 measures.  

  EAZA has adopted detailed standards with which its zoos must comply: the EAZA Standards for 
the  Accommodation  and  Care  of  animals  in  zoos  and  aquaria,  Research  Standards,  the 
Conservation  Standards  and  the  Conservation  Education  Standards.  Similarly,  the  EAAM  has 
published Standards and Guidelines for the management of bottlenose dolphins under human care 
(EAAM  2016).  Such  standards  and  guidelines  help  to  counterbalance  the  lack  of  clarity  in  the 
Directive,  reducing  the  level  of  discrepancies  with  national  implementation  rules.  The  role  of 
standards  produced  by  organisations,  in  particular  EAZA’s  guidelines  for  the  care  and 
accommodation of animals, is expressly acknowledged in the Preamble to the Directive as helpful 
in guiding the development and adoption of national standards. The EAAM also stated that this 
work contributes to increasing zoos’ understanding of expected of them and preparing them for 
licensing195.  

  EAZA  also  provides  training  to  all  of  its  members’  zoo  professionals  on  a  range  of  topics, 
including  breeding  programmes  and  other  conservation  related  issues  (e.g.  education)  (EAZA 
Academy 2016).  This training has been mentioned as a good practice by another federation.  

190 See http://ec.europa.eu/dgs/health_food-safety/information_sources/animals_events_2011_en.html  
191 Only one stakeholder mentioned this training.  
192 No statistical information is provided on this question, as the results of the survey cannot be considered representative. It has been ob-
served that EAZA, as well as several (at least 13) zoos have provided the exact same answer, according to which ‘associations (like EAZA) 
contributed strongly to strengthening the role in biodiversity conservation, as indeed did the many leading zoos and aquariums in EAZA, 
resulting in significantly increased conservation action’. While the statistical information is therefore excluded, the statement is nevertheless 
based on overall trends in responses in the survey and in interviews.  
193 See Section 4.1 above.  
194 Assuming an overall number of zoos of around 2,000, taking the numbers of licensed zoos gathered from MSCAs of 14 Member States in 
the context of this study (1,006 zoos), and the estimations provided in the Born Free EU Zoo Inquiry 2011 and the Born Free /VetEffecT 
Survey (2014). This number cannot be considered fully reliable as these other sources did not provide information for some of the Member 
States and reflected a broad definition of zoos (not only licensed ones) in some others. Another number circulated by NGOs is 7-8% of all 
European zoos.  
195 Interview with EU stakeholder. 

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  EAZA-led  breeding  programmes  (EEPs  and  ESBs),  as  indicated  in  Section  5.1.2,  provide  a 
significant contribution to conservation. These are followed not only by EAZA members but also 
by other zoos196. The EAAM also supports two breeding programmes (EAAM 2016a).  

  EAZA and EAAM organised workshops and conferences to bring zoos together and allow them 
to exchange information (e.g. the EAAM annual scientific symposium). Of 70 responding zoos, 
44 (i.e. 62%) indicated their attendance at meetings with international stakeholders.   

  Public awareness-raising is an important component of federation activity. EU federations also 
organise  campaigns  to  engage  the  public  in  biodiversity  conservation,  thus  contributing  to  the 
Directive’s  objectives.  One  example  is  the  ‘Let  it  Grow’  campaign  (Let  it  grow  2016)  by 
EAZA197 which encourages visitors to measure biodiversity in their living environment. 

At national level 
National  federations  exist  in  most  EU  Member  States  (see  Section  4.1).  They  usually play  a  similar 
role  to  EU-level  ones,  such  as  issuing  guidelines  and  standards,  facilitating  exchange  of  infor-
mation and public awareness-raising activities.  
In  addition,  as  highlighted  in  the  survey,  national  federations  have  established  close  working  rela-
tionships  with  the  authorities  to  ensure  proper  implementation  of  the  legal  requirements.  Positive 
feedback on cooperation between federations and authorities has been reported by stakeholders in both 
the survey and the interviews in several cases  (e.g. France, Germany, Ireland, Sweden and the UK). 
This collaboration also contributes to the achievement of the Directive’s aims.  

c.  Actions by EU and national NGOs  

NGOs  playing  a  significant  role  in  the  implementation  of  the  Directive  are  either  conservation-
oriented or animal welfare organisations. At EU level, Born Free and Eurogroup for animals are the 
main stakeholders, and are animal welfare-oriented organisations (see Section 4.1 for a full overview 
of associations). Although the primary objective of the Directive is conservation of biodiversity, rather 
than animal welfare, nevertheless the activities of animal welfare-oriented NGOs have also impacted 
on the implementation and achievement of the Directive’s conservation objectives. The contribution of 
EU and national NGOs can be summarised as follows:    

  Monitoring of implementation of the Directive’s requirements has been a key area of work for 
NGOs active in this field. The Born Free EU Zoo Inquiry is the most comprehensive project in 
that regard. It aims at ‘evaluating the status and performance of zoos across the European Union 
set against the obligations of the EU Zoos Directive 1999/22’ and ‘identifying the causes behind 
the  substandard  conditions  in  Europe’s  zoos’.  To  that  end,  ‘in  2009  and  2010,  a  total  of  200 
zoological collections in 20 European Union Member States were assessed as part of the EU Zoo 
Inquiry 2011 project, and in 2015, a total of 54 zoological collections in seven EU Member States 
were  assessed  under  the  EU  Zoo  Inquiry  2016  project.  Activities  included  an  evaluation  of  the 
national  zoo  law  of  each  EU  Member  State  against  the  requirements  of  the  EU  Zoos  Directive 
1999/22, an assessment of the implementation  and enforcement  of the law and  an investigation 
into  the  status  and  performance  of  a  sample  of  zoos  in  each  Member  State’  (Born  Free  2016). 
Other NGOs monitor the situations in zoos on a daily basis. The monitoring done (in particular by 
animal  welfare  organisations)  has  been  instrumental  in  flagging  implementation  issues  to  the 
authorities.  For  instance,  the  Zoos  Inquiry  has  triggered  some  Member  States  (e.g.  Cyprus)  to 
review their legislation and zoos to improve their conditions (Born Free 2012, p.17).  
However, it should also be mentioned that this role entails some risks. As pointed out by several 
stakeholders198, animal welfare NGOs are fundamentally against the existence of zoos and their 
work is, accordingly, orientated towards one message. This entails the risk of inaccuracies, which 

196 Interview with EU stakeholder. 
197 In partnership with the European network of science centres and museums (Ecsite) and Botanic Gardens Conservation International. 
Substantial differences exist between Member States, many of which have not set minimum species standards (e.g. the Netherlands). Among 
those that have set such standards (e.g. Belgium, Bulgaria and Germany), the (scientific) basis on which it was done is subjective and thus 
debatable. For most species, the knowledge and expertise for establishing such standards are only available among stakeholder groups with 
specific interests (e.g. zoos’ federations, animal welfare NGOs) which challenge each other’s expertise rather than academia (BGCI). 
198 Interview with MSCA and EU stakeholder. 

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may eventually be counterproductive199.  

  NGOs  play  also  a  central  role  in  informing  the  public.  However,  while  some  NGOs  (in 
particular in the field of conservation) may contribute to informing the public on the conservation 
role of zoos and thus enhance its objective of public awareness, there is also a risk that the public 
awareness activities of other animal welfare focused NGOs may draw public attention away from 
the role of zoos in conservation.  

  NGOs  also  give  training  to  zoo  professionals.  For  example,  Born  Free,  in  collaboration  with 
EAZA, provided training to veterinarians and other practitioners (see Workshop Report in Annex 
IX).  

d.  International stakeholders 

A few international organisations play an active role in the implementation of the  Zoos Directive, in 
particular through their guidelines on  ex situ conservation  measures, their specialist groups, or other 
activities. This is especially the case for the IUCN and WAZA.  

  WAZA  and  the  IUCN  have  adopted,  respectively,  the  IUCN  Technical  Guidelines  on  the 
Management  of  Ex  Situ  Populations  for  Conservation  (2002)  or  the  World  Zoo  and  Aquarium 
Conservation Strategy (WZACS). Those documents seek to support zoos by providing guidance 
and  recommendations  on  the  conservation  measures  that  they  should  undertake.  The  WAZA 
conservation  strategy  includes  advice  on  the  development  and  improvement  of  conservation 
research  strategies,  and  the  development  of  education  and  media  strategies  to  engage  staff, 
visitors, volunteers and the wider community in order to broadcast the importance of the role of 
zoos  in  conservation.  It  also  urges  zoos  to  partner  with  other  biodiversity  institutions  and 
conservation  organisations  to  implement  conservation  actions.  The  IUCN  technical  guidelines 
indicate  when  ex  situ  conservation  should  be  initiated,  what  the  objectives  of  conservation 
projects should be, and calling for ex situ institutions (including zoos) to develop ex situ protocols 
prior  to  any  forthcoming  ex  situ  management  projects,  giving  due  consideration  to  institutional 
and  financial  viability  before  embarking  on  any  such  project.  These  documents  have  been 
mentioned by stakeholders as being equally useful to the EAZA guidelines, as contributing to the 
implementation of the Directive and its objective of biodiversity conservation, and as ‘key drivers 
for the teams in charge of the scientific management of zoos’200.  

  Thirteen zoos (18.5 %) of those responding to the survey have staff that are members of an IUCN 
specialist group. Of particular importance in this context is the Conservation Breeding Specialist 
Group  (CBSG), whose  mission is to ‘save threatened  species  by increasing the effectiveness of 
conservation  efforts  worldwide  […by  providing]  species  conservation  planning  expertise  to 
governments, Specialist Groups, zoos and aquariums, and other wildlife organisations’ (CBSG). 
This specialist group plays a significant role in creating an environment whereby zoos can pursue 
the  Directive’s  objectives.  There  is  a  CBSG  Europe,  which  works  closely  with  EAZA  and  is 
supported strongly (including financially) by the Copenhagen Zoo.  

  The IUCN red list of threatened species is an essential tool to assess the level of conservation of 
the worlds’ species. As explained in Section 5.1.2, the conservation status of species kept ex situ 
is  a  central  element  in  understanding  zoos’  contributions  to  biodiversity  conservation  and  the 
protection of wild fauna.  

e.  Actions by zoos  
Several stakeholders201 stated that modern zoos make a positive contribution to the protection of 

 

199 The Belgian CAs highlighted that the Zoo Inquiry in Belgium adopted a biased interpretation of the implementation of the Directive in 
Belgium. The Born Free report implies that automatic licensing in Belgium was the general principle for licensing zoos up to 2011. The 
authorities denied that this was the case and underlined that systematic inspections took place to confirm and adapt the first wave of authori-
sations that were granted in a semi-automatic manner before 2002. After 2002 the authorities inspected all new zoos and undertook regular 
inspections (25% of zoos in Flanders, on an ad hoc basis in Wallonia). A corrigendum letter drafted by the public authorities was, according 
to the authorities, supposed to be published by Born Free. This did not occur and, from the point of view of the authorities, seemed to have 
led to a counterproductive antagonisation between the animal welfare organisation and the public authorities. 
200 Interview with international stakeholder. 
201 No statistical information is provided on this question, as the results of the survey are not representative. It was observed that several (at 
least 10) zoos provided identical answers, according to which ‘The increased impact of modern zoos in the protection of global biodiversity, 

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global biodiversity, public education, research and animal husbandry, with differences observed 
between  more  ‘conservation-oriented’  zoos  and  other  zoos.  Conservation-oriented  zoos  in 
particular  have  played  a  key  role  in  implementation  by  sharing  their  knowledge  with  less 
advanced  zoos,  e.g.  through  the  drafting  of  guidelines  and  technical  standards  for  ex  situ 
management, or through visits and training with other zoos.  

  One stakeholder202 observed that there appears to have been a change in zoo owners’ perceptions 
during  the  implementation  period  because  they  are  now  more  responsible  and  take  public 
opinion  very  seriously  (and  thus  biodiversity  conservation  and  husbandry  standards).   This 
perception was confirmed during the discussions held during the Workshop for this study, where 
it was observed that zoos increasingly include conservation objectives in their activities and that 
the importance of conservation activities in zoos at a small scale, i.e., at local level, should not be 
undermined. 

  Another stakeholder203 observed that the sector attracts highly motivated staff, which has driven 
many  innovations  in  enhancing  captive  care.  In  that  respect,  the  work  done  by  veterinarians  in 
zoos  was  also  highlighted  as  a  significant  contribution  to  conservation.  Veterinarians  carry  out 
substantial research, although this may not be very visible because their work is not published in 
conservation-oriented reviews (see Workshop Report in Annex IX).  

  By  contrast,  a  lack  of  commitment  on  the  part  of  certain  zoos  has  been  observed  by  several 
stakeholders, either due to the lack of capacity or because of reluctance to abide by the rules. This 
is  corroborated  by  the  EU  Zoo  Inquiry  findings.  On  this  point,  it  was  mentioned  that  the 
difference  in  the  level  of  expertise  between  zoo  operators  and  enforcement  authorities  was 
sometimes exploited by operators, who would ‘impose their authority’ during inspections204.  

f.  Action by academia 

One stakeholder205 surveyed stated that the academic literature is a critical source of information but 
can  be  difficult  for  non-academics  to  access  and  interpret.  While  there  are  outstanding  examples  of 
successful collaborations between zoos and academics, and effective tools for translating research into 
zoos, this relationship is not necessarily sector-wide. Box 12 below provides an example of successful 
collaboration  between  the  University  of  Birmingham  and  the  Birmingham  Zoo.  Other  examples  in-
clude collaboration  between the  Antwerp Zoo and the Centre for Research and Conservation  (CRC) 
and the research institute of the Royal  Zoological Society of Antwerp (RZSA), between the Leipzig 
Zoo  and  the  Max-Planck  Institute  for  Evolutionary Anthropology,  between  the  London  Zoo  and  the 
Institute of Zoology, and between the  University of Southern Denmark and the Max Planck Odense 
Centre.  

Box 12: Example of successful contribution to conservation by joint efforts of zoos and academia 

The University of Birmingham’s Enclosure Design Tool for great apes[1]  
Because of their sedentary lives and tendency to develop heart disease, anxiety and stress due to a 
lack  of  species-typical  physical,  social  and  mental  opportunities,  great  apes  are  some  of  the  most 
difficult  species  to  keep  successfully  in  captivity.  The  University  of  Birmingham  developed  the 
‘Enclosure Design Tool’ (‘EDT’) to help to address this issue. The EDT guides zoo keepers in col-
lecting data on their great apes, from which it then provides recommendations on possible modifica-
tions of enclosures to correct missing or under-represented wild-type behaviours of those apes.  
These  improved  enclosures  allow  zoos  to  exhibit  great  apes  that  behave  in  more  natural  ways, 
thereby  enhancing  public  education  about  the  species.  It  also  is  an  example  of  applied  academic 
research made accessible to zoo keepers, which can, in turn, trigger improved animal welfare given 

public education, research and animal husbandry is mainly due to the efforts of each individual zoo as well as the exchange with zoo associa-
tions, wildlife-experts from the zoo community and our in-situ colleagues, scientists and other conservation related NGOs as well as donors’. 
While the statistics are excluded, the statement is nevertheless based on overall trends in responses to the survey and interviews.  
202 Zoos questionnaire. 
203 High-level questionnaire. 
204 Interview with NGO.  
205 High-level questionnaire. 
[1] Dr Thorpe, Dr Chappell, University of Bimingham, ‘An Enclosure Design Tool to enable zoos to create integrated, wild-type enclosures 
for great apes’: http://gtr.rcuk.ac.uk/project/ED68C067-9547-4772-A382-C0536EF1151A (last accessed on 14.03.2017). 

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the increased understanding of the animals’ needs. Finally, it is an evidence-based monitoring tool 
with which zoo keepers can reliably demonstrate that measures are implemented to ensure the wel-
fare of their great apes. 

g. 

 Action by the media  

To a certain extent, the media have contributed to the implementation of the Directive. The literature 
review showed that many press articles deal with the question of zoos, not only from an animal wel-
fare  perspective  but  also  for  their  conservation  role,  or  to  explore  the  link  between  conservation 
(breeding activities in particular) and animal welfare. In that respect, media coverage of the 2014 case 
of  the  giraffe  ‘Marius’  euthanised  by  Copenhagen  Zoo  for  conservation  management  reasons,  is  a 
good example.  

Likewise, TV programmes, such as ‘reality shows’ (e.g. in Germany and France) showing the day-to-
day work of zoos, also have an educational purpose.  

The contribution of such programmes or press reports to the achievement of the Directive’s objectives 
is complex, however. Such media intervention is usually one-sided (either pro- or anti- zoo), relies on 
the emotions of the public to convey a message, and  is, in the case of shows,  a commercial tool for 
participating  zoos.  There  is  therefore  a  risk  of  lack  of  information  on  biodiversity  issues  in  order  to 
focus on animal welfare or to present a ‘glamorous’ vision of zoos’ day-to-day work at the expense of 
their actual contribution to biodiversity conservation. 

In addition to the lack of clarity on the educational benefits of media activities, the impact of public 
awareness  on  conservation  objectives  is  unclear.  This  is  also  confirmed  in  the perceptions  of  NGOs 
and  federations  surveyed  for  this  study.  Thirteen  respondents  considered  that  public  awareness  and 
support contributed effectively to the effective implementation of the Directive, while 11 considered it 
to have no effect.  

5.1.3.3  Economic factors  

An additional source of influence emerged from the consultation: economic factors. Zoos can be im-
portant economic actors, relying wholly or partly on entertainment and tourism expenditure. Two re-
curring issues must be mentioned here:  

  The  impact  of  the  2008  economic  crisis  was  mentioned  as  a  factor  impeding  the  proper 
implementation of the Directive by several zoos, especially southern ones206. The crisis resulted 
in  fewer  visitors  and  decreased  income  for  private  zoos,  and  budget  cuts  for  public  zoos.  This 
impacted the human resources dedicated to specialised work (e.g. research or education), as well 
as investments in facilities, research and conservation activities.  

  Zoos, depending on their size, can generate significant revenue and/or employ large numbers of 
local people. The economic influence of zoos at local level has sometimes been detrimental to 
the  proper  implementation  of  the  Directive.  ‘Local  politics’  was  repeatedly  raised  during  the 
interviews  with  all  types  of  stakeholders207  and  stated  to  have  a  negative  impact  on  the 
implementation of the enforcement of the licensing requirements, with MSCAs having difficulties 
imposing  licensing  conditions  and  controls  on  zoos  that  are  popular  attractions  and  important 
economic actors at local level. 

5.1.3.4  Summary and conclusions 

The  factors  influencing  the  achievement  of  the  Directive’s  objectives  can  be  grouped  into  three  key 
points: 

 

Firstly, and most importantly, the Directive places obligations on the Member States through its 

206 Zoos questionnaire, answer provided by Spanish and Portuguese zoos.  
207 Interviews with federations, NGOs and MSCAs. 

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 

licensing and inspection requirements. The transposition, implementation and enforcement of the 
legislation by the Member States’ authorities therefore needs to be assessed. 
Secondly, other stakeholders, in particular the European Commission, the Federations, NGOs and 
zoos themselves, also play a role in implementing the Directive, and their actions necessarily in-
fluence the achievement of the Directive’s objectives.  

  Thirdly, the economic component of zoos’ activities had a notable impact on achievement of the 

Directive’s goals.  

With respect to the first point, the analysis concludes that:  

a. The Directive is broad in its wording and this has, in some instances, prevented consistent and ef-
fective implementation of the Directive across the Member States. The main difficulties are: 

  Definition  of  zoos  and  the  corresponding  concepts  (e.g.  ‘significant  number’,  number  of  days, 

‘wild species’). 

  Alternative options provided under Article 3, first indent. 
  Lack of detail and broadness of the requirements of Article 3.  

b. Transposition of the Directive at national level resulted in both impeding and contributing factors. 
The main impeding factors are: 

  Late  transposition,  corresponding  to  inadequate  regulation  of  the  issue  at  national  level,  thus 

delaying implementation of the Directive’s objectives. 

  Cases  of  non-conformity  of  the  transposing  legislation,  which  resulted  in  four  infringement 

procedures launched by the Commission.  

The most significant contributing factors are: 

  Additional  requirements  provided  in  the  transposing  legislation  to  remedy  the  ambiguities 

 

experienced in interpreting the Directive. 
Pre-existing  legislation  in  some  Member  States,  which  facilitated  the  implementation  of  the 
Directive’s requirements. 

c. Implementation of the Article 3 and Article 6 measures in the Member States have proved to be 
particularly challenging for the stakeholders, in particular:  

  Organisation  of  the  Member  States’  administrations  (division  of  competence,  portfolio  of 

MSCAs, absence of communication) has impeded the implementation of the Directive. 
Identification and inventory of establishments to be regulated under the Directive is very difficult. 
 
  Closure of zoos represents a major difficulty for implementation due to the absence of rehoming 

options and organisation by the MSCAs. 

However, in terms of contributing factors, the proactive attitude of MSCAs, especially the preparation 
of guidance documents and the organisation  of training and workshops, has significantly contributed 
to achieving the Directive’s objectives.  

d.  The  effectiveness  of  the  Directive  relies  heavily  on  enforcement  (See  Section  2.2  above).  Some 
factors have impeded proper enforcement:  

  Lack of knowledge and training of enforcement authorities. 
  Lack of resources (human and financial) to carry out enforcement effectively. 
 

Inconsistencies  in  the  level  of  enforcement  among  Member  States  and  among  regions  in  some 
Member States.  

Some  other  factors,  such  as  additional  enforcement  activities,  the  use  of  external  experts,  guidance 

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documents, training and harnessing synergies with other acts, have contributed positively to enforce-
ment.     

The second point is the impact of the actions undertaken by the  various stakeholders active in the 
field. These can be summarised as follows: 

  The  Commission’s  actions  have  contributed  minimally  to  the  achievement  of  the  Directive’s 
objectives. The Commission does not have the legal means to monitor implementation, nor does 
it provide for a forum for exchange  of information between MSCAs. Its enforcement activity is 
limited,  funding  difficult  to  obtain,  and  training  nearly  inexistent  and  not  inclusive.  The 
enforcement  activities  of  the  Commission  and  the  Good  Practice  Document  are  the  main 
contributing  activities  from  the  Commission,  even  though  distribution  of  the  latter  was  deemed 
unsatisfactory (low awareness and no translation). 

  Zoos’ and aquarium federations have been very active in supporting the implementation of the 
Directive,  through  their  membership  requirements,  standards,  training,  breeding  programmes, 
workshops  and  conferences,  and  public  awareness-raising  activities.  The  role  of  EAZA’s 
standards is expressly mentioned in the Directive’s Preamble.  

  EU  and  national  NGOs  have  been  instrumental  in  monitoring  the  implementation  of  the 
Directive,  flagging  issues  to  the  authorities,  and  informing  the  public,  although  animal  welfare 
NGOs focus more on animal welfare than conservation. 
International  stakeholders  (the  IUCN,  WAZA)  have  published  key  documents  assisting  with 
the implementation of the Directive. 

 

  Zoos themselves have played a key role in implementation as well. Academia has contributed to 
involving  zoos  in  research  and  improving  their  knowledge  on  conservation  and  species’  needs, 
while  the  media  have  a  less  clear  impact  in  terms  of  contribution  to  awareness-raising  and  an 
even less clear impact on biodiversity conservation.    

Under  the  third  point,  it  was  observed  that  zoos  can  be  important  economic  actors,  with  the  2008 
economic crisis mentioned as a factor impeding the proper implementation of the Directive by several 
zoos, especially southern ones208. In addition, the economic influence of zoos at local level has some-
times been detrimental to the proper implementation of the Directive.  

5.1.4  Effectiveness – EQ 4 

Beyond  these  objectives,  what,  if  any,  other  significant  changes  both  positive  and  negative  can  be 
linked to the Directive? 

This question discusses whether other positive or negative effects were produced, beyond the imple-
mentation  of  conservation  measures  and  the  strengthened  role  of  zoos  in  biodiversity  conservation. 
The identification of positive and negative effects has been guided by stakeholder input at interviews 
and through targeted survey responses.   

Only a few stakeholders pointed out negative effects and these were generally related to the legitimisa-
tion  of  the  role  of  zoos,  even  where  their  participation  in  conservation  activities  and  contribution  to 
conservation is very small.  

Most of the stakeholders agreed that the Directive had a positive role in increasing public awareness of 
the role of zoos in biodiversity conservation and increasing attention paid to the welfare of wild ani-
mals in zoos. 

These elements are discussed briefly below.  

208 Zoos questionnaire, answer provided by Spanish and Portuguese zoos.  

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5.1.4.1  Effects on public awareness 

As discussed earlier, enforcement appears weak and is faced with resource constraints while, simulta-
neously, the Zoos Directive provides  only  limited  guidance on conservation measures,  leading to  its 
inconsistent application across the EU. Nevertheless, the Directive has raised zoos’ standards, particu-
larly among  those not part  of federations, and in  those  Member  States  where  no relevant  legislation 
existed  previously.  This  was  noted  by  many  stakeholders  and  is  one  of  the  most  important  achieve-
ments of the Directive.  

As such, the Zoos Directive has helped to create a minimum legal framework, ensuring that zoos fulfil 
certain obligations, and has had a positive effect on harmonisation across the EU209. 

Another effect concerns the increased awareness among the general public  of conservation of biodi-
versity and the role played by zoos. On the one hand, although the effectiveness of zoos as education 
centres should be explored further, millions of people visit zoos every year210 and are exposed to learn-
ing  opportunities  for  the  species  exhibited  and  their  natural  habitats  and,  more  generally,  about  the 
importance of biodiversity conservation (Gusset et Dick 2011). On the other hand, the expectations of 
the public of zoos have gradually evolved. EU legislation, combined with this increased public aware-
ness, has also amplified the possibility for NGOs to mobilise public opinion and other players, at both 
EU and national level, in order to make sure that the improved role of zoos is actually achieved.  

These  results  are  confirmed  by  the  public  consultation  findings.  According  to  the  respondents,  the 
most  significant  benefits  related  to  the  creation  of  a  common  legal  framework  across  the  EU,  im-
proved systems for licensing and inspection (missing in most of the Member States prior to the enter-
ing  into  force of the Zoos Directive),  and better knowledge of biodiversity among  the public.  There 
seems to be widespread agreement among stakeholders on the ability of the Zoos Directive to ‘ensure 
a coherent legal framework for zoos to operate across the EU’ (63%, or 1,447 responses rated benefits 
in this field as significant or crucial) and to ‘promote public education and better knowledge on biodi-
versity’ (59% or 1,355 responses)211. 

5.1.4.2  Effects on animal welfare 

According  to  some  stakeholders212,  a  significant  positive  effect  of  the  Zoos  Directive  relates  to  im-
provements in accommodation and housing conditions (including environmental enrichment measures, 
consideration of species-specific needs, etc.) which have led directly to better animal welfare in zoos 
across the EU. This may be considered an important side-effect, as this objective is partly outside the 
scope of the Zoos Directive.  

Most of the existing European animal welfare legislation is concerned with farm animals213 and ani-
mals used in experiments214. Article 3, third indent, of the Zoos Directive requires zoos to accommo-
date animals  under conditions which  ‘aim to satisfy the biological and conservation requirements  of 
the individual species’. Although this provision represents a conservation rather than a welfare meas-
ure, it has contributed to establishing a framework across the Member States and raising the standards 
for husbandry of animals kept in zoos, currently not covered by European animal welfare legislation.  

Many  Member  States,  in  implementing  the  Zoos  Directive,  have  paid  specific  attention  to  adequate 

209 In line with the general objectives of the Zoos Directive. In particular, the 7th recital of the Directive mentions the necessity ‘to provide a 
common basis for Member States' legislation with regard to the licensing and inspection of zoos’. 
210 Estimates of WAZA for 2008 indicates 142 million visits per year, compared to 125 million visits estimated in 1990 (Gusset et Dick 
2011).  
211 See the Public Consultation Report (Annex VIII).  
212 In particular, eight stakeholders (zoos, zoos’ federations and MSCAs) out of the 44 interviewed.  
213 Council Directive 98/58/EC of 20 July 1998 concerning the protection of animals kept for farming purposes; Council Decision 
78/923/EEC concerning the conclusion of the European Convention for the protection of animals kept for farming purposes. 
214 Directive 2010/63/EU of the European Parliament and of the Council of 22 September 2010 on the protection of animals used for scien-
tific purposes. 

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conditions  for  accommodation  and  animal  husbandry.  In  some  of  the  14  evaluated  Member  States, 
specific standards or non-binding guidelines have been defined for keeping animal in zoos (Bulgaria, 
Belgium, Italy, Lithuania, Poland, Germany and Ireland). In parallel, elements such as the size of the 
enclosures, existence of hygiene and feeding plans and veterinary care are all explicitly mentioned by 
most of the Member States as indicators used to assess the compliance of the zoo with Article 3, third 
indent (see also Section 5.1.1).  

The provisions related to the accommodation of animals in the event of closure of a zoo add a further 
element and ensure that a legal framework exists to protect the animals in these situations.  

Overall, these elements suggest that animal accommodation and welfare represent important compo-
nents of zoo legislation across the Member States, and receive specific attention when it comes to the 
implementation of the legislation and the inspection of zoos.  

These are also two of the main benefits of the Zoos Directive highlighted by stakeholders participating 
in  the  public  consultation.  57%  of  stakeholders  (1,320  respondents)  reported  significant  or  crucial 
benefits in the conditions under which animals are kept and standards of animal husbandry. Although 
influenced by the interest groups, a high number of stakeholders also pointed out (in their open com-
ments) the importance of the Zoos Directive for the establishment of animal husbandry standards and 
the introduction of stricter rules for animal welfare215. 

5.1.4.3  Summary and conclusions 

The  Directive  did  not  bring  significant  negative  effects,  other  than  the  negative  loop  created  by  the 
lack of effective implementation. It does, however, risk giving legitimacy to zoos that are not in line 
with the requirements and/or only provide a limited contribution to conservation of biodiversity.  

Positive effects have been identified in relation to: 

 

 

Increased  awareness  among  the  public  in  relation  to  the  role  played  by  zoos  in  biodiversity 
conservation.  
Increased  standards  for  the  welfare  of  animals  kept  in  zoos  not  covered  by  EU  legislation  on 
animal welfare. Although animal welfare is not the objective of the Zoos Directive, its provisions 
on  animal  accommodation  and  animal  husbandry  (Article  3,  third  indent)  have  contributed  to 
increased  attention  by  Member  State  authorities  and  thus  better  conditions  for  animals  kept  in 
captivity. 

5.2  Efficiency 

Efficiency  is  essentially  a  comparison  between  inputs  used  in  a  certain  activity  and  the  outputs  and 
results produced. The key question addressed is whether the range of regulatory costs imposed by the 
implementation of the Directive are reasonable and proportionate in view of the benefits delivered.  

This requires a structured assessment of the range of costs incurred in implementing the Directive and 
the benefits achieved. Since the costs and benefits that accrue may differ according to the size of  the 
zoo, it is important to assess whether the costs are higher for small zoos. These issues were addressed 
in  EQ5  (Section  5.2.1).  The  remaining  questions  investigate  whether  or  not  the  costs  are  dispropor-
tionate to the benefits (EQ6, Section 5.2.2), the factors driving costs and benefits (EQ7, Section 5.2.3) 
and whether evidence exists that the Directive has caused unnecessary regulatory burden or complexi-

215 When asked about ‘Other benefits’ besides those listed in the consultation questionnaire, stakeholders provided some answers; 20 pointed 
to the establishment of stricter rules for animal welfare; 100 pointed to the importance of the Directive in ‘recognising that each animal 
species has specific welfare needs and animal husbandry standards will ensure animals are appropriately kept in zoos’; 67 comments high-
lighted the benefits of the Directive in terms of establishment of animal husbandry standards. All these comments are considered to be based 
on suggested replies communicated by different interest groups (i.e. they represent repeated comments, although it is not always possible to 
establish the extent of this). See the Public Consultation Report in Annex VIII for more detail.  

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ty (EQ8, Section 5.2.4).  

Based  on  the  intervention  logic  presented  in  Section  2.2,  and  the  activities  identified,  the  analysis 
examined costs accrued for both Member State authorities (responsible for setting up and implement-
ing  the  licensing  and  inspection  system),  and  zoos  (required  to  implement  a  set  of  conservation 
measures and undergo inspection and licensing procedures).  

The sections below are based on the analysis of the licensing and inspection systems in the 14 Member 
States (EQ1, Section 5.1.1.1), and the specific information collected through stakeholder consultations 
(targeted surveys, interviews, and public consultation).  

It is important to point out that the possibility of quantifying the costs and benefits is limited, as is the 
possibility of drawing any general conclusions, due to:  

  Lack of literature and any independent assessment that might have provided a point of reference. 
  The  paucity  and  low  quality  of  information  provided  by  stakeholders  and,  importantly,  the 
difficulty  of  attributing  the  costs  and  benefits  to  the  Zoos  Directive.  Both  Member  States’ 
authorities  and  zoos  were,  in  most  cases,  unable  to  identify  the  costs  directly  due  to  the  Zoos 
Directive, a factor which strongly limits the possibility to provide validated and shared estimates 
of  the  costs.  Similar  considerations  are  true  of  the  benefits.  In  addition,  there  has  been  no 
systematic gathering of data on the provisions of the Directive over time that would allow for an 
independent analysis of benefits over time. Such data might have comprised  zoos’ contributions 
to  enhanced  conservation  status  of  species,  trends  in  educational  visits  to  zoos,  enhanced 
awareness of biodiversity issues, increased availability and accuracy of records, as well as general 
statistics on zoos as such (number, size, visitors, turnover, etc.). 

  Most  of  the  benefits  of  the  Directive  (e.g.  public  awareness,  species  conservation)  cannot  be 
effectively  expressed  in  quantitative  terms  and  mainly  represent  non-monetary  benefits  (with 
some  exceptions).  This  suggests  that  a  comparison  of  costs  and  benefits  in  monetary  terms  is 
neither feasible nor appropriate.  

This study’s approach to the evaluation of costs and benefits, their proportionality, and the extent to 
which they can be attributed to the Directive, combined the quantitative data provided by the entities 
directly affected by the Directive (the MSCAs and zoos), with qualitative information on the imple-
mentation of the Zoos Directive in the 14  selected Member States, and perceptions expressed by the 
stakeholders involved.  

The  results  of  the  analysis  remain  largely  qualitative.  This  approach  ensures  that  the  information  is 
used  in  a  defensible  way,  and  that  conclusions  drawn  are  appropriate  to  the  information  available. 
Indeed, the lack of reliable data and the difficulty  experienced by the stakeholders in providing esti-
mates make any robust quantification and generalisation at EU level difficult.   

5.2.1  Efficiency – EQ 5 

What are the costs and benefits (monetary and non-monetary) associated with the implementation of 
the Directive for the different stakeholders, at local, national and EU level? Where possible, an esti-
mate  of  costs  broken  down  by  size  of  enterprises  (micro/small/medium-sized  enterprises)  should  be 
provided. 

The  purpose  of  this  question  is  to  understand  the  costs  imposed  by  implementation  of  the  Directive 
and the benefits that have arisen from it.  

Given the lack of any independent published analyses, information to address this question is drawn 
largely  from  the  targeted  questionnaire  survey,  with  some  context  provided  by  the  interviews.  Re-
spondents providing information include MSCAs, zoos, zoos’ federations, NGOs and other stakehold-
ers. Results of the public consultation are also integrated.  

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This section:  

  Reports on the estimates of costs and benefits that have been provided by stakeholders; and  
 

Seeks  to  identify  where  costs  (and  benefits)  are  believed  to  have  been  incurred  as  a  direct 
consequence of the Directive.  

Overall, while there is a paucity of data detailing costs and benefits (i.e. quantification), respondents 
have expressed clear views on the scale of costs that they believe they have incurred and the perceived 
benefits that have arisen. These form the basis of the assessment of this question.  

The  approach  taken  in  relation  to  EQ5 also  applies  to  the  analysis  of  the  other  evaluation  questions 
under ‘Efficiency’.  

5.2.1.1  Costs  for  zoos  and  Member  States’  authorities  associated  with  the 

implementation of the Directive 

The implementation of the Zoos Directive requires MSCAs to set up and run a licensing and inspec-
tion system and to take action to ensure appropriate treatment or disposal of animals in the case of zoo 
closures (see the Intervention Logic defined in Section 3.2). For their part, zoos are required to imple-
ment several conservation measures (as defined in Article 3 of the Zoos Directive) in order to obtain a 
licence.  These  activities  are  expected  to  translate,  to  different  extents,  to  increased  costs  for  both 
MSCAs and zoos.  

Table 23 maps the main activities to be carried out by zoos and MSCAs in line with the provisions and 
Articles of the Directive, and lists the types of costs that may reasonably be expected to be attached to 
each activity216.  

Costs for MSCAs are related to the enforcement of the legislation at national level. Zoos are expected 
to bear direct compliance costs, falling into different categories: substantive compliance costs (‘com-
pliance costs’), including one-off investments and recurring expenses to comply with the requirements 
of  the  Directive;  administrative  costs  related  to  the  procedures  to  be  followed  in  order  to  obtain  the 
licence; charges paid to obtain the licence, etc. As described in the following paragraphs, the possible 
costs stemming from delays in obtaining a licence have also been explored. 

216 The relevant types (or categories) of costs are defined on the basis of the Better Regulation toolbox (http://ec.europa.eu/smart-
regulation/guidelines/tool_51_en.htm). 

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Table 23: Links between the Articles of the Directive and related activities, types of costs and stakeholders involved 

Article 
Article  3,  indent 
1 
Article  3,  indent 
1 
Article  3,  indent 
2 
Article  3,  indent 
2 
Article  3,  indent 
3 
Article  3,  indent 
4 
Article  3,  indent 
5 
Article 4 
Article 4 
Article 4 

Article  4,  indent 
3 
Article 4 

Article 4 

Article 4 
Article 8 
Article  4,  indent 
5, and Article 6 

Provision 
Conservation 
measures 

Licensing 
and 
tion system 

inspec-

Closure  and 
sanctions 

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Activity 
Participation in research and conservation projects 

Type of cost 
Compliance cost 

Stakeholder 
Zoos 

Participation in training activities in relevant conservation skills 

Compliance cost 

Zoos 

Promotion of education and awareness-raising activities 

Compliance cost 

Zoos 

Provision of information on exhibited animals 

Compliance cost 

Zoos 

Renovation of enclosures, provision of resources for animal husbandry 

Compliance cost 

Zoos 

Setting  up  and implementation  of systems  to  prevent  escape  of alien  species  and intru-
sion of outside pests and vermin 
Setting up and implementation of record-keeping/animal identification systems 

Compliance cost 

Zoos 

Compliance cost  

Zoos 

Treating licence applications received by zoos 
Preparing, conducting and following-up on on-site inspections of zoos 
Training of inspectorate staff on the requirements of the national legislation implementing 
the Zoos Directive 
Monitoring compliance with the Zoos Directive 

Enforcement cost  MSCAs 
Enforcement cost  MSCAs 
Enforcement cost  MSCAs 

Enforcement cost  MSCAs 

Preparing the application to obtain the licence 

Preparatory  work  for  the  inspection,  taking  part  in  the  visit  of  the  MSCAs,  providing  an-
swers to the inspection report 
Charge paid to obtain the licence 
Penalties applied for non-compliance with licensing requirements 
Ensuring that the animals are treated or disposed of under appropriate conditions in the 
event of the closure of a zoo 

Zoos 

Administrative 
cost 
Administrative 
cost 
Charges 
Compliance costs 
Enforcement costs  MSCAs 

Zoos 
Zoos 

Zoos 

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This mapping represented the starting point for the collection of information about the additional costs 
imposed  by  the  Zoos  Directive  among  MSCAs  and  zoos  in  the  14  Member  States.  Information  has 
been collected through targeted questionnaires and interviews, with a two-fold objective:  

  Understand  which  provisions  of  the  Zoos  Directive  have  implied  additional  costs  for  zoos  and 

MSCAs, and identify the most relevant costs. 

  Collect information on the magnitude of the costs incurred by zoos and MSCAs (including one-

off investments and recurring costs due to activities to be carried out on a regular basis).  

The following paragraphs present the results by category of stakeholder (i.e. MSCAs and zoos).  

a.  Costs for MSCAs  

The replies to the questionnaire indicated that a certain increase in costs followed the implementation 
and enforcement of the Zoos Directive at national level.  

As shown  in  Table 24, responses were received by 15 CAs from the 14 Member States217. Of those 
CAs that were able to give an opinion, the majority considered the Zoos Directive to have led to in-
creased efforts and thus new enforcement costs in relation to all aspects of the licensing, inspection 
and monitoring processes, although no CA was able to provide quantification details.  

An exception is represented by Belgium, which has had legislation on zoos since 1998. Here, the Zoos 
Directive had the effect of enhancing the existing system and imposed only a minor increase in effort 
and related costs. For the remaining Member States, increased costs are reported, especially with ref-
erence to the  treatment of licence applications and to the need  for preparing, carrying  out and 
following-up on inspections (cost categories from a) to e) in Table 24). 

Table 24: CAs’ opinions on increased costs triggered by the Directive for licensing, inspection and monitoring 

Costs 

a) Treating licence applications 

b)  Preparing  the  inspection  necessary  for 
granting the licence 

c) Desk-based inspections (e.g. analysis of 
records) 

d) On-site inspections 

e) Follow-up of inspections 

f) Training of inspectorate staff 

Yes 

8 

9 

8 

9 

8 

5 

No 

3* 

2* 

3* 

3* 

3* 

5 

Don’t know 

No Answer 

3 

3 

3 

3 

3 

4 

1 

1 

1 

1 

1 

1 

3 

7 

g)  Monitoring  compliance,  providing  in-
formation  to  the  European  Commission, 
and other authorities 
* Regarding cost categories a) to e), no cost increase was reported by three Member States. However, based on 
the information collected during the interviews and other questions of the survey, it can be assumed that two of 
the three Member States actually recorded increased costs (compared to the situation in place before the entry 
into force of the Directive). While this table reflects the replies provided in the survey, the comment has been 
adjusted in order to take that into account.  
Source: Present survey of MSCAs  

3 

2 

In practical terms, the introduction of the Zoos Directive has required all MSCAs (except Belgium) to 
dedicate new resources to the inspection of zoos,  either by mobilising internal staff and/or engaging 
with external contractors (as in the case of Ireland).  

217 For Belgium, two replies were received, from two regional authorities.   

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However, as also mentioned in Section  5.1.1.1, zoo inspectors are usually responsible for a range of 
different duties, including the enforcement of other legislation concerning biodiversity protection and 
animal  welfare  (e.g.  IAS  Regulation,  CITES,  animals  used  for  scientific  purposes,  exotic  animals, 
companion animals, etc.). As a result, for most of the Member States, calculating the staff fully dedi-
cated  to  zoo  licensing  and  inspections  (expressed  in  Full  Time  Equivalent  -  FTE  –  units)  is  neither 
possible nor practical. Where estimates have been provided, the resources of MSCAs fully dedicated 
to the enforcement of the Zoos Directive  appear to be relatively limited with, for example, less than 
one FTE in Denmark, and between one and two FTE in Italy, Portugal and Belgium. However, if the 
involvement of external experts or bodies is included, the number of staff dedicated or costs borne by 
MSCAs  is  obviously higher.  This  is  the  case  in  the  Netherlands  (where  the  involvement  of  external 
experts and NVWA218 veterinarians must be considered) and in Ireland (where a zoo license inspec-
torate is appointed on a contract basis)219. 

The average time needed to carry out an inspection also varies considerably, depending on the size of 
the  zoo  and  the  nature  of  the  inspection  (i.e.  monitoring  inspection  versus  inspection  to  grant  a  li-
cence). Accordingly, indications of the time for completing a licensing procedure (including prelimi-
nary and follow-up activities) also vary, from one day to seven days or more220. In addition, each in-
spection involves teams of different sizes, generally ranging from a minimum of two to four or more 
inspectors, depending not only on the size of the zoo or the type of inspection, but also on the system 
set  up  in  each  Member  State,  whether  involving  different  authorities  and  organised  in  a  central-
ised/decentralised manner221.  

While there is agreement among MSCAs on the increase in costs directly related to the performance of 
the inspections, it is interesting to note that an increase in training costs is reported by only half of the 
Member States that provided an answer (i.e.  five out of 10). This is in line with the issues raised by 
stakeholders,  including  MSCAs,  about  the  lack  of  appropriate  knowledge  of  zoo  inspectors,  and  the 
need for better targeted training activities (see Section 5.1.1.1).  

Finally, no MSCA was able to quantify the costs incurred following the closure of a zoo and the relo-
cation and accommodation of animals. Zoo closures incurred a cost in the order of EUR 1000 for one 
CA, but otherwise costs were thought to be zero or were unknown, due to the few cases registered in 
the Member States222. Again, the burden placed on Member States in cases of zoo closure is expected 
to vary, depending on the agreements set up at national level and, for example, the obligation placed 
on zoo operators to cover the expenses of the relocation and accommodation of animals, or the reli-
ance on NGOs (supported through private funding223) for the relocation of animals.  

b.  Costs for Zoos 

As shown in Table 23, potential increased costs for zoos related to two main aspects: 

218 Food and Consumer Product Safety Authority. 
219 The number of FTE dedicated to inspection of zoos depends, primarily, on the number of zoos in the Member State and the frequency of 
inspections. The number of licensed zoos in the Member States that provided estimates varied from 23 (in Italy) to 54 (in the Netherlands). A 
higher effort in terms of resources might be expected in Member States with a significant number of zoos (i.e. Germany, France and Spain); 
however, these Member States did not provide estimates of the effort, in terms of FTE, needed for the inspection of zoos.  
220 Based on the estimates provided by the Member State authorities in the targeted questionnaire. Very different estimates were provided. 
For example, Poland indicated up to two weeks and Portugal around 60 days for completing all the procedure (including one day for the 
inspection).  
Data should be intended as the time for the inspection only, and not the time needed for the completion of the overall licensing procedure.  
221 The number of inspectors involved in each on-site visit may depend on several factors, including the system set up at national level. In 
Member States where several authorities are involved (e.g. in Italy, three different Ministries are involved), the number of inspectors taking 
part in the visits is established in order to ensure representation of all the authorities. 
222 According to the information collected through the targeted survey, two closures were recorded in Belgium; around nine in Germany 
between 2011 and 2016, including complete and partial closures; two in Italy. 
223 During the workshop, it was noted that when the relocation of animals relies on NGOs, costs following the closure of a zoos are placed on 
citizens contributing to the work of NGOs or rescue centres through funding (see Workshop Report, June 2017, available at: 
http://ec.europa.eu/environment/nature/legislation/refitzoosdirective/pdf/Workshop_report.pdf). 

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 

 

Implementation of conservation measures, as foreseen in Article 3 of the Zoos Directive and in 
line  with  national  legislation:  this  translates  into  compliance  costs,  i.e.  one-off  investments  in 
order  to  adapt  to  the  requirements  and  obtain  the  licence,  and  recurring  expenses  related  to  the 
implementation of conservation measures.  
Procedures  to  request  and  obtain  the  licence,  translating  into  administrative  costs  and  (when 
foreseen by the Member State) charges. 

Looking at compliance costs, it should be mentioned that incurring additional costs depends not only 
on the changes brought about in the  national system by the Zoos Directive, but also on the fact that 
zoos  might  have  implemented  conservation  measures  irrespective  of  the  Directive  and/or  national 
legislation.  The  analysis  is  primarily  aimed  at  understanding  whether  additional  costs  have  actually 
been incurred by zoos because of the Zoos Directive and, if so, investigating the magnitude of these 
costs. Obtaining information on the investments and recurring expenses of zoos, and the proportion of 
these incurred as a direct result of the Directive, was problematic. As a consequence, the high number 
of  zoos  not  replying  to  the  relevant  survey  questions  does  not  allow  for  solid  inferences,  although 
some trends can be clearly identified.  

As reported in Table 26, regarding one-off investments, among the zoos that provided a reply, a num-
ber of zoos reported that investments were incurred along a range of expenditure types, such as invest-
ing especially for the renovation of enclosures, but also for the provision of information on exhibited 
animals, improved standard of animal husbandry, record-keeping/animal identification systems and, to 
a lesser extent, for systems to prevent the escape of animals.  

Where zoos have reported investing money, these costs are not usually seen as a direct consequence of 
the Directive. For example, of the 31 zoos that reported investments for enclosure renovation, only 12 
attributed part of these costs to the Zoos Directive. Similarly, for the other types of expenditures, the 
majority of responding zoos did not consider their expenditure a direct consequence of the Directive.  

Some  of  the  zoos  answering  the  survey  reported  additional  types  of  costs  not  directly  linked  to  the 
Zoos Directive, such as extra safety measures for visitors  to  some dangerous animal facilities or for 
zoo personnel. 

Table 25: Number of zoos reporting one-off investments and, for those reporting some costs, estimates of the 
proportion attributable to the Directive (zero costs, i.e. zoos reporting no investments or none attributable to the 
Directive, are also included) 

Number of zoos reporting incurred costs 
Number  of  zoos  giving  esti-
mates 
Zero cost 

Some cost 

Number of zoos reporting ‘some cost224’ and 
allocation of costs to the Directive 
0%  of  costs 
attributable 
15 

Some  costs 
attributable 
12 

No answer 

4 

Type of expenditure 

of 

Renovation  of  enclo-
sures 
Provision 
infor-
mation  on  exhibited 
animals 
Improved  standard  of 
animal 
husbandry 
and enclosures 
Systems 
escape 
Record-

to  prevent 

2 

4 

3 

4 

3 

31 

25 

23 

17 

19 

17 

12 

8 

10 

5 

7 

7 

7 

3 

4 

2 

2 

224 Amounts indicated are highly variable, from thousands to millions of Euro. Similarly, in % terms, the share attributable to the Directive 
varies from 5% to 100%. Finally, this table also counts those zoos that have reported incurring expenses but who have not specified the 
amount (e.g. reported ‘variable’ or ‘yes’). 

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Type of expenditure 

Number of zoos reporting incurred costs 
Number  of  zoos  giving  esti-
mates 
Zero cost 

Some cost 

Number of zoos reporting ‘some cost224’ and 
allocation of costs to the Directive 
0%  of  costs 
attributable 

Some  costs 
attributable 

No answer 

keeping/animal  iden-
tification systems 
Source: Present survey of zoos  

The same pattern appears to hold for recurring expenditure, where some zoos report a wide range of 
expenditure  but  do  not  see  this  as  attributable  to  the  Directive.  The  items  of  expenditure  that  a  few 
zoos  consider  to  have  at  least  some  proportion  attributable  to  the  Directive  are  training  activities, 
information on animals exhibited, and animal accommodation and husbandry (Table 26). 

Table 26: Number of zoos reporting recurring expenditure225 and, for those reporting some costs, estimates of the 
proportion attributable to the Directive (zero costs, i.e. zoos reporting no investments or none attributable to the 
Directive, are also included) 

Type of expenditure 

Number of zoos reporting incurred costs 
Number  of  zoos  giving  esti-
mates  
Zero cost 

Some cost 

Number  of  zoos  reporting  ‘some  cost’  and 
allocation of costs to the Directive  
0%  of  costs 
attributable 
10 

Some  costs 
attributable226 
4 

No answer 

2 

3 

3 

2 

ex-

2 
4 

and 

Research  and  con-
servation projects 
Training activities 
Information 
change activities 
Education 
awareness-raising 
activities 
Information on exhib-
ited animals 
Animal  accommo-
dation  and  animal 
husbandry 
Preventing escape of 
animals 
Preventing  pests  and 
vermin 
Record-keeping  and 
animal  identification 
systems 
Source: Present survey of zoos  

1 

2 

4 

4 

16 

15 
11 

15 

17 

16 

9 

7 

13 

7 
6 

9 

8 

8 

2 

4 

6 

6 
3 

4 

6 

6 

6 

2 

5 

2 
2 

2 

3 

2 

1 

1 

2 

Where  estimates  of  the  costs  are  reported,  the  amount  spent  can  be  significant,  especially  where  in-
vestments related to the renovation of enclosures are concerned. Other significant investments can be 
related to hygiene requirements, setting up of education facilities, and certification procedures for the 
optimisation  of  organisational  structure227.  Regarding  recurring  expenditure,  costs  can  be  significant 
for ensuring high standards of animal accommodation and animal husbandry, while annual  expendi-
ture for the education of staff can also be a significant element228.  

225 i.e. expenditure incurred more than once, as opposed to one-off investment.  
226 See footnote 224. 
227 Written contribution by a zoo federation reporting estimates on costs. 
228 Based on the data provided by zoos in the questionnaire and a written contribution by one zoo federation reporting estimates on costs. 
However, these considerations should be considered as examples, given the low number of zoos that provided estimates and the low compa-
rability of data (e.g. costs largely depend on the size of the zoo). 

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Table 27 provides a summary of the information collected from the zoo survey, including the magni-
tude of the cost estimates provided by a limited number of zoos.  In brief, 15 out of 33 zoos reported 
one-off investments, ranging from hundreds to millions of Euro, that they considered directly attribut-
able  to  the  Directive.  Ten  out  of  36  reported  recurring  expenditure  (annual)  ranging  from  tens  to 
hundreds of thousands of Euro arising from the requirements of the Directive.  

Table 27: Estimates of one-off investments and recurring zoo expenditure attributed by zoos to the Zoos Directive229 

1-100 

0 

22 

Type of 
cost 
One-off capital costs 
Number 
of zoos 
Recurring costs (annual) 
1 
24 
Number 
of zoos 
Source: Present survey of zoos  

0 

Amount attributed to the Zoos Directive (EUR) 
10,001-
101-
100,000 
1000 

100,001-
1,000,000 

1001-
10,000 

1,000,000+ 

3 

0 

1 

3 

4 

3 

4 

3 

3 

0 

No 
estimate  

33 

36 

Other possible investments and recurring expenses relate to the human resources required to support 
the  implementation  of  the  conservation  objectives  and  measures  introduced  by  the  Zoos  Directive. 
However, the majority of zoos also did not report any need to employ new staff to obtain and keep the 
licence. Of the 70 zoos surveyed, nine needed new staff while 51 did not (the remaining 10 either did 
not know or did not answer). Only seven zoos listed the staff that they needed to hire, specifying veter-
inarians, biologists or personnel for promotion and education. Another zoo federation highlighted that 
the number of qualified employees on educational activities in zoos has generally increased in the past 
15 years230.  

Overall, in many cases, zoos costs incurred are not seen as a direct consequence of the Zoos Directive.  

EAZA zoos replying to the survey underlined  that investments and efforts for research activities are 
carried  out  by  zoos  in  any  case,  irrespective  of  the  Zoos  Directive,  as  part  of  the  commitments  of 
‘modern zoos’. Similarly, conditions for the membership of zoos” federations have requirements and 
investments that are close to those requested by the Zoos Directive (as well as inspections).  

Apart from EAZA zoos, investments in conservation measures and facilities for animal keeping should 
also be viewed in the context of the evolution of zoos, i.e. no longer limited to the exhibition of spe-
cies but increasingly engaged in wildlife conservation and nature protection.  

Zoos struggled  to disentangle the costs  of compliance with the Zoos Directive from those  costs that 
would have occurred anyway. This is suggested by the results of the survey presented so far, as well as 
by the opinions expressed by zoos in relation to other sections of the survey (see, in particular, Section 
5.2.2.1). At this point it is also worth noting that if little information has been provided on costs in-
curred, nor has any major issue been raised in relation to the costs imposed by the Zoos Directive.   

Different considerations apply to administrative costs placed on zoos as a result of the procedures to 
request and obtain a licence, in line with Article 4 of the Zoos Directive. These costs mirror the en-
forcement costs borne by MSCAs, and can be directly traced back to the Zoos Directive and the intro-
duction of licensing and inspection systems.  

The time needed to prepare licence applications varies considerably, due to the high variability among 

229 This table provides an overview on the basis of all amounts indicated by zoos. However, amounts indicated largely differ, therefore any 
generalisation would not provide reliable results. Compared to the tables reported above, a smaller number of zoos is considered (i.e. only 
zoos that indicated an amount, while zoos that reported expenses but were not able to provide an amount are excluded).  
230 See footnote 227.  

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Member States in terms of their procedures (e.g. documentation requested before the inspection, detail 
of information requested), or the size of the zoos and their collections.  

According to the information provided in the survey by 20 zoos across different Member States, pre-
paring an application for the licence might take anything from: no time (two zoos), through 0.5-5 per-
son days (six zoos), 6-20 person-days (five zoos), 30-40 person-days (four zoos) to 100-300 person-
days (three zoos)231. This cost, however, should be incurred only once (or for any significant amend-
ment to the licence).  

The same 20 zoos report a similar effort with respect to the inspection phase (i.e. preparatory work for 
the inspection, sending documents to authorities, completing pre-inspection questionnaires, taking part 
in the visit of the MSCAs, providing answers to the inspection report). In this case, the frequency of 
the activity generating administrative burden varies from Member State to Member State, with inspec-
tions happening anywhere from every three years to twice per year.  

Another element that creates differentiation across Member States and affects the overall costs placed 
on zoos is the existence of fees to obtain the licence (Table 28).  

Table 28: Charges applied for the issuance of a licence in the 14 Member States 

Member State 

Belgium 

Charges applied (EUR) 

€250 (if the collection contains birds or mammals); €125 (if the collection contains 
only animals other than birds or mammals) 

Bulgaria 

€500 

Cyprus 

€555.75 

Denmark 

No charge 

Czech 
Republic 

€370.10  

France 

No charge232 

Germany 

Depending on the Region, from 0 to more than €7,000. 

Ireland 

No charge 

Italy 

€2,707.05 

Lithuania 

€145 

Netherlands 

No charge 

Poland 

€17233 

Portugal 

€1,000, €2,000 or €3000, depending on the size of the collection 

Spain 

No charge 

Source: Present survey of MSCAs 

Finally,  for  some  zoos,  the  process  to  obtain  the  licence  took  several  years,  especially  in  the  initial 
phase  of  implementation  of  the  Directive  (see  also  Section  5.1.1).  Looking  at  the  zoos  surveyed,  a 
small proportion of zoos have reported that delays in licensing caused additional costs, with six zoos 
experiencing problems234, compared to 51 that did not (the remaining 13 did not know or did not an-

231 Replies were provided by zoos from nine Member States. However, the size of the sample does not allow for an analysis by Member 
State. In addition, two zoos estimated the cost financially: EUR 5,000 (a German zoo) and EUR 6,000 (a French zoo). 
232 No charge for the licence but the application should contain several environmental studies that have a cost (minimum EUR 30,000).  
233 Fees for issuing the licence. Additional costs might be related to obtaining the documents to be presented along with the licence applica-
tion.  
234 Of the six zoos that reported delays, four are based in Italy, one in France and one in Belgium.  

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swer).  Only two zoos reported  any consequences: for one zoo, they lost the opportunity to exhibit a 
threatened species and for the other they had to postpone renovations.  

In summary, administrative costs have accompanied the licensing and inspection system but the feed-
back of zoos indicate that these costs remain quite limited and do not represent a significant burden. 
The results are even more nuanced when it comes to substantive compliance costs for the implementa-
tion of conservation measures, which were triggered only to a minor extent by the Zoos Directive.  

The increase in costs for zoos appears to be quite limited overall, a conclusion that is consistent with 
the  judgement  of  zoos  on  the  balance  between  costs  and  benefits  (see  Section  5.2.2.1),  and  is  con-
firmed  by  the  zoos’  federations  survey  responses  (eight  out  of  13  replied  that  the  costs  for  zoos  in-
creased slightly, while only two indicated a substantial increase235).  

5.2.1.2  Benefits associated with implementation of the Directive 

This section presents the main benefits that can be attributed to the Zoos Directive, according to the 
opinions  provided  by  MSCAs,  zoos  and  other  stakeholders  (federations,  NGOs,  experts,  individuals 
participating in the public consultation), and in the light of the findings of the overall supporting study.  
For the sake of clarity, the results of the targeted and public consultation are presented separately.   

a.  Feedback  from  the  targeted  consultation:  main  benefits  from  the  Zoos  Directive  and 

views of the different stakeholder categories 

The main benefits have been identified on the basis of the potential impacts of the Directive, which is 
expected to enhance zoos’ roles in biodiversity conservation, knowledge and public awareness of bio-
diversity  conservation,  and  protection  of  wild  fauna  and  biodiversity  (see  the  intervention  logic  in 
Section 2.2). In parallel, the potential benefits of the Directive for zoos as economic operators, and for 
the  local  economy  at  large  are  also  considered.  The  assumption  is  that  the  enhancement  of  zoos  as 
institutions with a conservation and educational role might have an impact on the number of visitors 
(with increased income for zoo operators), the economic activities established around zoos (e.g. res-
taurants), as well as on cultural and recreational offers for citizens.  

Most of the stakeholders consulted agreed that the Zoos Directive has brought benefits across different 
areas of action.  

Figure 24 shows the replies to the surveys of MSCAs, zoos and zoos’ federations, NGOs and experts. 
The results suggest that major or moderate benefits were attributed to the Zoos Directive, especially 
in some areas:  

Improved accommodation of animals and standards for animal husbandry (g).  

  Contribution to public education and knowledge of biodiversity (aspect d).  
 
  Contribution to efforts for ex situ conservation (c).  
  Higher engagement of the public and stakeholders in biodiversity protection (f). 
Protecting species from extinction (b) and overall biodiversity conservation (a).  
 

The results of the consultation activities are consistent with the findings under the analysis of the “ef-
fectiveness”  of  the  Zoos  Directive  (Section  5.1).  While  implementation  and  enforcement  issues  re-
main, the analysis concludes that, compared to the baseline situation and in conjunction with several 
external factors (such as the evolution of the role of zoos or the action of zoo federations), the Zoos 
Directive has contributed to strengthening the role of zoos in protection of wild fauna and biodiversity, 
by  establishing  a  common  legal  framework  and  minimum  requirements  for  zoos.  Moreover,  in  line 
with the main benefits pointed out above, the analysis of “effectiveness” points to the particularly im-

235 Of the remaining zoo federations, two indicated ‘No significant costs’ and one did not answer.  

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portant role played by Directive in increasing public awareness of the role of zoos in biodiversity con-
servation and ehancing the welfare of wild animals in zoos (Section 5.1.4).  

By contrast, the stakeholders saw the Zoos Directive as bringing only minor benefits, or no benefits 
at all, in terms of: 

  Economic operators (j).  
  Boosting local economy (triggering further recreational activities, tourism, etc.) (h).  

When looking at zoos as economic operators, the only benefits recognised by stakeholders are related 
to  the  creation  of  an  EU-wide  legal  framework  for  zoos  thus  ensuring  a  level  playing  field  across 
Member States (i). 

Figure 24: Stakeholder opinions on the extent of the benefits associated with the Zoos Directive (results from the 
targeted questionnaires addressed to MSCAs, zoos and zoos’ federations, NGOs and experts. Number of replies = 111) 

Source: Present survey of MSCAs, zoos and zoos’ federations, NGOs and experts 

Looking  at  the  breakdown  by  stakeholder  category,  slightly  different  views  emerge.  In  particular, 
based on the results of the targeted consultations, MSCAs share a  slightly more positive view of the 
overall benefits achieved by the Directive, compared to zoos.  

The majority of the  MSCAs  considered  there  to be  moderate or major benefits arising from the  Di-
rective in all areas (Figure 25), especially on accommodation of animals and standards for animal hus-
bandry,  public  education  on  biodiversity  (each  14  out  of  15,  or  93%),  improved  behaviour  towards 
biodiversity  protection  (13  out  of  15,  or  87%),  and  increased  engagement  by  the  public  with  nature 
conservation activities (12 out of 15, or 80%). According to many MSCAs, moderate and major bene-
fits were also achieved in terms of protection of species from extinction (12 out of 15, or  80%) and 
overall biodiversity conservation (11 out of 15, or 73%).  

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9171927282930313237442929323326343232322828323425322930273125282320121181245457521192411161417131711110102030405060708090100110j) For zoos as economic operators as Zoos Directive triggers higher visitor numbersh) Local economy (e.g. new jobs, recreational activities, increased tourism, researchand innovation on conservation issues)i) Zoos as economic operators because of an EU wide legal framework (similarconditions among zoo operators in different EU MS)e) Positive changes of behaviour towards biodiversity protectionk) Society (e.g. health, culture, recreation)a) Overall biodiversity conservationb) Protecting species from extinctionf) Higher engagement of the public/stakeholders in biodiversity protection and othernature protection activitiesc) Ex-situ conservation effortsg) Accommodation of animals and standard of animal husbandryd) Public education and better knowledge on biodiversityMajor benefitsModerate benefitsMinor benefitsNo benefitsNo opinion/No answer 
 
 
 
 
 
 
 
Figure 25: MSCAs opinions on the extent of the benefits associated with the Zoos Directive (Number of replies = 15) 

Source: Present survey of MSCAs 

The  opinions  expressed  by  zoos  within  the  targeted  consultation  revealed  a  more  complex  picture 
(Figure 25).  

While the importance of the Zoos Directive is recognised in several areas (enhancing public education, 
accommodation and animal husbandry, ex situ conservation efforts, and higher engagement of stake-
holders and public in biodiversity conservation, overall biodiversity conservation), less than half of the 
stakeholders saw significant benefits in other areas, particularly in terms of higher visitors and benefits 
for the local economy.  

Figure 26: Zoos’ opinions on the extent of the benefits associated with the Zoos Directive (Number of replies = 70) 

Source: Present survey of zoos   

Some key themes also emerged from the interviews, which further stressed two main changes stem-
ming from the Zoos Directive: it has represented a key instrument for raising standards for animal 
accommodation and housing conditions in all zoos, and it has led to increased attention for educa-
tion and awareness-raising among zoo operators.  

Finally, zoos’ federations, NGOs and experts replying to the survey supported the general view that 
the  Zoos  Directive  has  led  to  positive  changes  in  public  education  on  biodiversity  (19  out  of  26  re-

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42345346467367658869876324332311132121112110%10%20%30%40%50%60%70%80%90%100%h) Local economy (e.g. new jobs in the zoo and related recreational activities, increasedtourism, research and innovation on conservation issues)j) For zoos as economic operators as Zoos Directive triggers higher visitor numbersi) Zoos as economic operators because of an EU wide legal framework (similar conditionsamong zoo operators in different EU MS)k) Society (e.g. health, culture, recreation)c) Ex-situ conservation effortsa) Overall biodiversity conservationb) Protecting species from extinctionf) Higher engagement of the public/stakeholders in biodiversity protection and other natureprotection activitiese) Positive changes of behaviour towards biodiversity protectiond) Public education and better knowledge on biodiversityg) Accommodation of animals and standard of animal husbandryMSCAsMajor benefitsModerate benefitsMinor benefitsNo benefitsNo opinion/No answer6121216171717151722261913151716161821191613182021182320202018171810684443225317191415101312121410100%10%20%30%40%50%60%70%80%90%100%j) For zoos as economic operators as Zoos Directive triggers higher visitor numbersi) Zoos as economic operators because of an EU wide legal framework (similar conditionsamong zoo operators in different EU MS)h) Local economy (e.g. new jobs in the zoo and related recreational activities, increasedtourism, research and innovation on conservation issues)b) Protecting species from extinctione) Positive changes of behaviour towards biodiversity protectionk) Society (e.g. health, culture, recreation)a) Overall biodiversity conservationf) Higher engagement of the public/stakeholders in biodiversity protection and other natureprotection activitiesc) Ex-situ conservation effortsg) Accommodation of animals and standard of animal husbandryd) Public education and better knowledge on biodiversityZoosMajor benefitsModerate benefitsMinor benefitsNo benefitsNo opinion/No answer 
 
 
 
 
 
 
 
 
spondents  to  the  targeted  survey,  or  73%),  ex  situ  conservation  efforts  (18  out  of  26,  or  70%),  and 
overall biodiversity conservation (each at 17 out of 26, or 65%) (see Figure 27).  

Figure 27: Opinion of zoos’ federations, NGOs and experts on the extent of the benefits associated with the Zoos 
Directive (Number of replies = 26) 

Source: Present survey of zoos’ federations, NGOs and experts 

The stakeholders saw the Zoos Directive as an important instrument to convey the message that zoos 
have a key role to play in promoting conservation, education and information on wildlife, biodi-
versity and nature protection. In parallel, the  Directive and the efforts undertaken by zoos have con-
tributed to raising public awareness and knowledge of the themes and issues related to conservation.  

Several interviews with zoos and zoos’ federations pointed to the increased commitment of zoos to-
wards conservation and education activities, which indirectly led to their increased attractiveness to 
visitors236, even if the link is difficult to demonstrate (as emerged in the questionnaire-based survey, 
Figure 27).  

More generally, it remains difficult to establish the extent to which the Zoos Directive has prompted 
investments and improvements across European zoos or if, indeed, these trends were the result of oth-
er factors, including the change in approach towards conservation and the protection of biodiversity, 
and the change in attitude among the general public.  

Firstly,  the  evolution  of  the  role  of  zoos  from  ‘living  museums’  to  conservation  centres  has  been  a 
long-term  process  since  the  end  of  the  20th  century  (IUCN/CBSG  1993)237,  including  the  1992  Rio 
Earth Summit at which the CBD was adopted.  

Secondly, the attitude of visitors to the exhibition of animals has gradually shifted. Preference is given 
to exhibits that resemble the native ecosystem of the species (Moss, Esson and Francis 2010) and visi-
tors increasingly expect animals in zoos to be  kept in appropriate conditions. The change in attitude 
among  the public has been  a strong  driver behind  the action taken by zoos to  adapt their structures, 
along with the requirements of the Zoos Directive. As noted in the analysis of the costs prompted by 
the Zoos Directive (see Section 5.1.1.3), most of the zoos would have undertaken investments in en-
closures,  for  example,  even  in  the  absence  of  the  Zoos  Directive,  as  part  of  their  commitments  as 
‘modern zoos’, and/or in order to comply with the requirements of zoos’ federations.  

236 Two stakeholders have emphasised the contribution of the Directive in terms of increased visitors (notably: one MSCA interviewed and 
the written contribution of one zoo federation).  
237 See Section 2.1.1. 

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1718610491010124411585128787115710883774478423231132323111411110%10%20%30%40%50%60%70%80%90%100%j) For zoos as economic operators as Zoos Directive triggers higher visitor numbersk) Society (e.g. health, culture, recreation)h) Local economy (e.g. new jobs in the zoo and related recreational activities, increasedtourism, research and innovation on conservation issues)g) Accommodation of animals and standard of animal husbandrye) Positive changes of behaviour towards biodiversity protectionf) Higher engagement of the public/stakeholders in biodiversity protection and other natureprotection activitiesi) Zoos as economic operators because of an EU wide legal framework (similar conditionsamong zoo operators in different EU MS)a) Overall biodiversity conservationb) Protecting species from extinctionc) Ex-situ conservation effortsd) Public education and better knowledge on biodiversityFederations/NGOs/ExpertsMajor benefitsModerate benefitsMinor benefitsNo benefitsNo opinion/No Answer 
 
 
 
 
 
 
 
 
                                                 
While it is difficult to isolate  the benefits of the Directive on  the biodiversity conservation, role and 
attractiveness of zoos, there is a strong consensus that the Zoos Directive had a crucial role in estab-
lishing an EU-wide legislative framework, balancing the standards for all zoos and allowing author-
ities to close non-compliant zoos. The creation of a common framework and the closure of substand-
ard zoos are two important benefits that emerged in the interviews with zoos and their federations, and 
that recall the importance of an effective licensing system as a condition to fully realise the benefits of 
the Zoos Directive.  

b.  Results of the public consultation 

Although the public consultation questionnaire asked for feedback on the basis of a slightly different 
list of benefits238, results point to similar findings as those emerging from the targeted consultations.  

Across  all  categories  of  benefits  proposed,  50%  or  more  of  the  stakeholders  considered  the  benefits 
achieved to be significant or crucial. Here, too, there seemed to be widespread agreement on the abil-
ity of the Zoos Directive to promote public education and better knowledge of biodiversity, along with 
other two important areas of benefit:  

  Ensure a coherent legal framework for zoos to operate across the EU.  
  Ensure improved licensing and inspection schemes for zoos. 

Conversely,  in  respect  of  benefits  to  tourism,  employment  in  areas  where  zoos  are  located,  and  in-
creased offers of cultural and recreational opportunities, a  large number of stakeholders did not pro-
vide an answer, while less than 50% of the respondents to this question rated these benefits as crucial 
or significant.  

This finding was confirmed by the zoo operators (148) and businesses (21) that replied to the public 
consultation:  while  the  feedback  on  the  benefits  achieved  was  generally  positive  across  all  aspects, 
only a slight majority of zoo operators and businesses perceived the benefits of the Zoos Directive in 
the economic sphere (i.e. in terms of increased employment, tourism, cultural and recreational oppor-
tunities for the public)239.  

Open comments on additional benefits, although influenced by the action of interest groups240, pointed 
to the ability of the Directive to promote harmonisation at EU level, to help raise standards for animal 
keeping and to promote the perception of zoos as entities contributing to biodiversity conservation and 
protection of species.  

5.2.1.3  Costs  and  benefits  associated  with  implementation  of  the  Directive  and 

size of zoos 

Given  that  there  are  significant  difficulties  in  obtaining  detailed  information  on  costs  and  benefits, 
breaking such an assessment down by zoo size is not possible. Again, however, it is possible to make 
assessments based on the perceptions of respondents to the survey and to assess if there is consistency 
between responses.  

Concerning  the  costs,  contrasting  views  prevailed  among  MSCAs  and  federations/NGOs  and  zoos. 
While  most  MSCA  survey  respondents  (nine  out  of  12  replying)  considered  that  smaller  zoos  (<10 

238 The list of impacts was slightly different in order to adapt it to the target (including citizens). The public consultation question on the 
benefits brought about by the Directive required at least a basic knowledge of the Zoos Directive in order to attribute the benefits. Indeed, the 
results of the public consultation show a high share of ‘No opinion’ (on average 19% of respondents). This element might impact the reliabil-
ity of the results slightly. See the Public Consultation Report in Annex VIII for more detail.  
239 See the Public Consultation Report (Annex VIII). 
240 Repeated comments have been identified in the replies to the public consultation, indicating that these were likely influenced by guidance 
from interest groups (see Public Consultation Report in Annex VIII). 

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employees)  found  it  more  difficult  to  comply  with  and  finance  the  requirements  listed  in  Article  3, 
most of the zoos’ federations, NGOs and experts (14 of 20  respondents) explicitly stated that it was 
not more difficult for smaller zoos.  

Most of the zoos, across all sizes, reported that it was not difficult at all to comply with and finance 
Article 3 requirements. Eight (out of 40, or 20%) zoos in the micro (<10 employees) and small (10-49 
employees) enterprise categories reported that it was very or moderately difficult for them to comply 
with and finance Article 3 requirements. This compares with no medium-sized zoos (0 of 21) and 11% 
(one of nine) of large zoos (Table 29Table 29: Reported difficulties in complying with and financing 
Article 3 requirements in order to obtain a licence for zoos of varying sizes). The different size of the 
samples makes comparison across categories difficult. Smaller zoos (up to 49 employees) appeared to 
face more difficulties compared to medium establishments (between 50 and 249 employees); however, 
only  20%  (eight  out  of  40)  of  smaller  zoos  considered  complying  with  and  financing  Article  3  re-
quirements to be very or moderately  difficult. Overall, the survey results did not reveal a significant 
difference between bigger and smaller zoos.  

Table 29: Reported difficulties in complying with and financing Article 3 requirements in order to obtain a licence for 
zoos of varying sizes 

Answer 

Very difficult 
Moderately difficult 
Slightly difficult 
Not difficult at all 
Don't know 
N/A 
Total 
Source: Present survey of zoos  

Number of employees 
<10 
2 
2 
1 
3 
2 

10-49 
2 
2 
8 
10 
3 
5 
30 

10 

50-249 

>250 

5 
14 

2 
21 

1 
1 
6 

1 
9 

Total 

4 
5 
15 
33 
5 
8 
70 

Looking at the benefits associated with the Zoos Directive, further analysis by size of zoo reveals that 
smaller zoos (i.e. up to 49 employees) found there were major or moderate benefits arising from the 
Directive in all categories (except for benefits for zoos as economic operators, and in terms of higher 
engagement of stakeholders/the public in conservation). At the same time, on average, a smaller pro-
portion  of  medium  size  zoos  (with  50-249  employees)  and  large  zoos  (>250  employees)  tended  to 
consider that significant benefits were brought about by the Directive (see Table 30).  

Table 30: Number of zoos reporting major or moderate benefits associated with various items arising from the 
Directive (numbers in parentheses are percentages of zoos reporting benefits in each size category) 

Benefits  

Overall biodiversity conservation 

Protecting species from extinction 

Ex situ conservation efforts 

Public education/biodiversity knowledge  6 (60) 

Behaviour  change  towards  biodiversity 
protection 
Higher  engagement  of  the  public  in 
nature protection activities 
Standards  of  animal  accommodation 
and husbandry 
The  local  economy  (e.g.  new  jobs,  tour-
ism and research) 
Zoos as economic operators because of 
an EU-wide legal framework 

Number of employees 

<10 

5 (50) 

5 (50) 

5 (50) 

7 (70) 

10-49 

50-249 

18 (60) 

16 (53) 

18 (60) 

21 (70) 

19 (63) 

7 (30) 

7 (30) 

8 (38) 

7 (30) 

4 (19) 

>250 

5 (56) 

5 (56) 

5 (56) 

5 (56) 

3 (30) 

Total 

35 

33 

36 

39 

33 

4 (40) 

19 (63) 

8 (38) 

5 (56) 

36 

7 (70) 

20 (29) 

6 (28) 

5 (56) 

38 

5(50) 

15 (50) 

4 (19) 

3 (30) 

27 

4 (40) 

12 (40) 

5 (24) 

4 (44) 

25 

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Benefits  

Zoos  as  economic  operators  through 
higher visitor numbers 
Society (e.g. health, culture, recreation) 

Number of employees 

Total 

4 (40) 

12 (40) 

5 (24) 

4 (44) 

25 

Number of zoos per size category 

10 

30 

21 

9 

Source: Present survey of zoos  

5.2.1.4  Summary and conclusions 

3 (50) 

18 (53) 

5 (60) 

7 (22) 

33 

70 

By introducing a licensing and inspection system and requirements for the implementation of conser-
vation measures, the Zoos Directive has imposed new costs for:  

  MSCAs, in relation to the enforcement of the legislation at national level.  
  Zoos,  who  are  expected  to  face:  one-off  investments  and  recurring  expenses  to  implement 
conservation  measures  and  comply  with  the  requirements  of  the  legislation  (i.e.  substantive 
compliance  costs);  efforts  related  to  the  procedures  to  obtain  the  licence  (administrative  costs); 
charges paid to obtain the licence. 

For MSCAs, costs are stated to have increased for all aspects of the licensing, inspection and monitor-
ing processes (in relation to the treatment of licence applications, preparing, carrying out and follow-
ing-up on inspections). However, zoo inspectors are usually responsible for a range of different tasks, 
including the enforcement of other legislation concerning biodiversity protection and animal welfare 
(e.g.  IAS  Regulation,  CITES,  etc.).  As  a  result,  where  estimates  have  been  provided,  the  resources 
fully dedicated by the Member States to the enforcement of the Zoos Directive appear relatively lim-
ited with, in some Member States, less than one FTE assigned to the enforcement of the zoo legisla-
tion. 

The picture is slightly more complicated when it comes to assessing the costs imposed on zoos by the 
introduction of the Directive. Although the information provided by the zoos surveyed was extremely 
fragmented,  between 20 and 31 zoos (of  the 70 surveyed) reported an increase in investment across 
different fields, i.e. renovation of enclosures, provision of information on exhibited animals, improved 
standards of animal husbandry and enclosures, systems to prevent escape, and record-keeping/animal 
identification  systems.  Zoos  also  report  a  wide  range  of  recurring  expenditures  related  to  the  imple-
mentation of the conservation measures established in Article 3 of the Directive. Nevertheless, a rela-
tively small part of these expenses is seen as attributable to the Directive. For all cost categories, less 
than half of the zoos reporting costs attribute those costs to the Zoos Directive. In the case of one-off 
investments, of the zoos that reported expenses across different cost categories, between 20% and 40% 
attributed  those  costs  to  the  Zoos  Directive.  A  similar  pattern  is  recorded  for  recurring  expenditure 
(between 25% and 40% of zoos reporting expenses attribute those to the Zoos Directive241).  

It appears that these costs (both recurring and one-off expenditure) cannot be easily disentangled from 
costs that zoos would have supported even in the absence of the Directive, as part of their commitment 
to conservation and education, and in line with the evolution towards  ‘modern zoos’. Feedback from 
the zoos’ federations in the survey and in interviews supported these assertions. 

Administrative burden has increased along with the licensing and inspection systems, while additional 
direct  costs  might  be  due  to  charges  set  by  the  Member  States.  Both  the  efforts  for  undergoing  the 
inspection  procedure  (in  order  to  obtain  the  licence  or  for  monitoring  purposes)  and  the  cost  of  the 
licence itself vary across Member States, depending on many factors (from the frequency of inspec-
tions, to the existence or absence of a licence fee). However, most of the zoos reported that it was not 
difficult at all to comply with and finance Article 3 requirements. There is limited evidence to suggest 

241 The only exception is in relation to the category ‘preventing escapes of animals’, with six out of nine zoos reporting expenses attributing 
this cost to the Zoos Directive.   

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that smaller zoos have faced higher difficulties in adapting to the legislation.  

Most of the stakeholders consulted agreed that the Zoos Directive had brought benefits across differ-
ent areas of action.  

The results of the different consultation activities (public and targeted consultations) suggest that the 
most notable benefits arising from the implementation of the Directive relate to: contribution to public 
education and knowledge of biodiversity; improved accommodation of animals and standards for ani-
mal husbandry; contribution to efforts for ex situ conservation; and higher engagement of the public 
and  stakeholders  in  biodiversity  protection.  The  public  consultation  further  highlighted  the  benefits 
brought about by the Zoos Directive in terms of public education and better knowledge, its importance 
in ensuring a coherent legal framework for zoos to operate across the EU, and improving licensing and 
inspection schemes for zoos. 

The benefits for zoos in terms of increased visitors and income, and the benefits for the local economy 
in triggering further recreational activities, tourism, etc. were considered less significant. 

It  remains  difficult  to  establish  the  extent  to  which  the  Zoos  Directive  has  prompted  increased  en-
gagement  in  biodiversity  conservation  across  European  zoos  and  the  related  benefits  or  if,  indeed, 
other factors (the evolution of zoos as institutions, and the change in attitude among the general pub-
lic) have played a role. Nevertheless, the fact that the Directive has contributed to achieving benefits 
related to biodiversity conservation was generally recognised by all stakeholder categories. There is a 
strong  consensus  that  the  Directive  has  played  a  crucial  role  in  establishing  an  EU-wide  legislative 
framework and raising the standards of zoos across the EU.  

5.2.2  Efficiency – EQ 6 

To  what  extent  are  the  costs  associated  with  the  Directive  proportionate  to  the  benefits  that  it  has 
brought? 

The purpose of this question is to understand whether or not the costs of implementing the Directive 
are proportional to the benefits that have arisen from it.  

As discussed in Section 5.2.1, it has proven difficult to attribute costs and benefits directly to the Zoos 
Directive  or  to  provide  any  quantification.  The  benefits  expected  from  the  Directive  are  concerned 
with aspects that are not readily, or appropriately, quantified, such as public education, improved con-
servation status and better research.   

The emphasis, therefore, is on understanding the extent to which the different stakeholder categories 
see the costs as proportionate to the benefits that have accrued. Information from the targeted and pub-
lic consultation are used to determine this.   

5.2.2.1  Proportionality of costs and benefits 

Although  the  lack  of  supporting  data  makes  this  judgement  difficult  for  stakeholders,  all  categories 
stated that the costs borne as a direct consequence of the Zoos Directive are, in most cases, not consid-
ered disproportionate when compared to the benefits.  

For the majority of MSCAs, costs had increased following the introduction of the Zoos Directive due 
to  efforts  required  in  regular  and  follow-up  inspections,  documentation  and  record-keeping,  or  the 
disposal of animals in case of the closure of zoos (see Table 24, Section 5.2.1.1). Member States can 
face difficulties in finding adequate resources to run the licensing and inspection systems at the level 
required  for  the  effective  implementation  of  the  Zoos  Directive,  and  MSCAs  have  pointed  to  issues 
related  to  the  lack  of  sufficient  resources  for  systematic  screening  of  establishments  on  the  national 
territory  (see  Section  5.1).  Concerns  were  also  raised  by  stakeholders  (including  zoos,  zoos’  federa-
tions and NGOs) about the capacity of Member States’ authorities to effectively implement the legisla-

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tion (see Sections 5.1.1.1 and 5.1.3.1). 

When asked if costs were disproportionate compared to the benefits, only one MSCA stated a dispro-
portionality, citing the costs of licensing and inspections, costs relating to closure of zoos and to moni-
toring compliance. The remaining MSCAs in the sample supported the view that costs remained pro-
portionate to the benefits.  

Benefits have arisen from the implementation of the Zoos Directive in a wide range of areas, prompt-
ing  positive  changes  in  terms  of  increased  efforts  by  zoos  in  biodiversity  conservation,  improved 
standards for animal accommodation and husbandry, and increased knowledge and awareness of bio-
diversity among the public (see Figure 25 under Section 5.2.1.2). Some elements that characterise the 
licensing and implementation systems in the Member States make costs relatively moderated.  

The Zoos Directive and its provisions for licensing and inspection have been implemented in conjunc-
tion with other legislation related to biodiversity conservation and/or animal welfare, making it diffi-
cult to separate the costs directly attributable to the Zoos Directive. It is expected, however, that syn-
ergies can be created or harnessed in the use of the resources for inspections.   

In those Member States in which a fee system exists (nine out of 14), the costs for licensing and in-
spection  borne  by  MSCAs  are  (at  least  partly)  covered  by  the  charges  paid  by  the  zoos  for  their  li-
cence. In some cases, the costs of on-site inspections are also charged to the zoos. This clearly creates 
a  differentiation  among  Member  States.  In  those  Member  States  where  no  charge/fee  system  is  in 
place, MSCAs recognise that costs implied by the Zoos Directive are reasonable and proportionate to 
the benefits.  

When  asked  specifically  about  costs  associated  with  investments,  licensing,  administration,  or  other 
financial consequences of the Directive, the majority of zoos surveyed (between 42 and 47 of the 70 
sampled) did not consider costs  to be  disproportionate (Table 31). Several zoos did not reply to this 
question, seven explicitly considered the costs of investments to comply with licensing requirements 
and administration associated with licensing to be disproportionate, and five considered the recurring 
costs associated with licensing requirements to be disproportionate.  

Table 31: Zoos’ perceptions of whether or not the Directive implies disproportionate costs for investments and 
recurring administrative or other costs (number of replies = 70)   

a)  Investments  in  order  to  ensure  compliance 
with the licensing requirements 
b)  Recurring  costs  triggered  by  the  licensing 
requirements in your zoo 
c)  Administrative  costs,  in  relation  to  the  pro-
cedures for licensing and inspection 
Source: Present survey of zoos 

Yes 
7 

5 

9 

No 
47 

47 

42 

Don’t know 
7 

No Answer 
9 

8 

8 

10 

11 

These results do not vary if disaggregated  by size of zoos. No  significant  difference is  recorded be-
tween smaller (up to 249 employees) and larger zoos (> 250 employees). In most cases, around 10% 
of zoos in each size category considered costs to be disproportionate and, given the sample sizes, these 
correspond to between one and four zoos (Table 32).  

Table 32: Number of zoos reporting disproportionate costs associated with licensing under the Directive for four 
categories of size of zoo (numbers in parentheses are percentages of zoos reporting disproportionate cost in each size 
category) 

Answer 

Investments  in  order  to  comply  with  licensing 
requirements 
Recurring  costs  triggered  by  the  licensing  re-

Number of employees 
<10 
1 (10) 

10-49 
3 (10) 

50-249 
1 (5) 

>250 
2 (22) 

Total 

7 (10) 

- 

3 (10) 

2 (10) 

- 

5 (7) 

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Answer 

Number of employees 
<10 

10-49 

50-249 

>250 

Total 

quirements in your zoo 
Administrative costs for licensing and inspection  1 (10) 
Number of zoos per size category 
Source: Present survey of zoos 

10 

4 (13) 
30 

3 (14) 
21 

1 (11) 
9 

9 (13) 
70 

Finally,  it  should  be  noted  that  zoos  reporting  disproportion  costs  and  benefits  included  both  public 
and private entities and charities.  

This data must be viewed against a background of overall uncertainty about the extent to which both 
costs and benefits can be purely attributed to the Zoos Directive or to other factors (as discussed in the 
previous section).  
Where costs have been considered a consequence of the Zoos Directive, these have been significant, 
especially in relation to the renovation of enclosures. In parallel, benefits in terms of increased visitors 
have been generally rated as less important compared to other benefits by most of the zoos surveyed 
and in the public consultation. Still, among the zoos consulted, it appeared that costs remain propor-
tionate to the benefits brought about by the Zoos Directive on several dimensions (conservation, social 
and  economic).  It  was  also  highlighted  that  the  costs  related  to  the  implementation  of  the  Zoos  Di-
rective are low compared to costs under other legislation (such as animal welfare laws) and, overall, 
the Zoos Directive represents an efficient instrument for Member States to implement Article 9 of the 
CBD242. 

These results are also supported by the opinions expressed by NGOs, zoos’ federations and experts in 
the survey243 and by the results of the public consultation.  

The results of the public consultation show that: 

  The majority of zoo operators declare that the benefits  far exceed or are somewhat greater than 
the costs (94 zoo operators out of 148, or 63.5% of total). At the same time, only 24 (of 48, 16%) 
zoos  explicitly  consider  the  costs  to  exceed  the  benefits  (the  remaining  17  did  not  answer  or 
expressed the opinion that costs more or less equal benefits). 

  The same opinion is shared by public authorities, with four respondents (out of seven) stating that 
benefits far exceed the costs (although the size of the sample does not permit generalisation)244. 

5.2.2.2  Summary and conclusions 

There is no evidence that the costs incurred by MSCAs in implementing, and zoos in complying with, 
the Directive are out of proportion to the benefits. There is limited evidence that smaller zoos may find 
it more difficult to comply because of their more limited resources (funds and personnel) to meet li-
censing requirements.  

5.2.3  Efficiency- EQ 7 

What factors influenced the efficiency with which the achievements observed were obtained? In par-
ticular, what, if any, good or bad practices can be identified? If there are significant cost/benefit differ-
ences between Member States, what is causing them? 

242 Discussion during the Workshop on the REFIT evaluation of the Zoos Directive - Brussels, 16 May 2017 (see Workshop Report, June 
2017, available at: http://ec.europa.eu/environment/nature/legislation/refitzoosdirective/pdf/Workshop_report.pdf). 
243 17 out of 26 (65%) of NGOs, zoos’ federations and experts replying to the targeted questionnaire believed there to be no disproportionate 
costs for CAs or zoos. Only one federation stated that there were disproportionate costs for zoos and a further federation felt there were 
disproportionate costs for both CAs and zoos. 
244 See the Public Consultation Report (Annex VIII).  

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5.2.3.1  Factors influencing the efficiency of the Zoos Directive’s achievements 

The purpose of this question is to understand the reasons behind the achievement of the objectives of 
the Zoos Directive at minimised costs.  

The national systems differ to a large extent in respect of several aspects of the transposition, imple-
mentation and enforcement of the Zoos Directive.  

As indicated in Sections 5.1.1 and 5.1.3, there are several sources of variation across the 14 Member 
States that affect the costs borne by both zoos and MSCAs. These include:  

  Definition  of  more  or  less  demanding  requirements,  including  the  definition  of  standards  for 
animal keeping in some Member States or the establishment of additional requirements not in the 
scope of the Zoos Directive (for example, in relation to the safety of visitors).  
System  set  up  for  the  inspection,  steps  followed  (sometimes  including  a  pre-inspection  phase 
based  on  the  submission  of  documentation),  use  of  inspection  protocols/forms,  involvement  of 
zoos’ federations and/or other external expertise.  

 

  Organisation  of  Member  States’  administrative  processes  and  administration  involved  in 
monitoring  and  enforcement  tasks  (including  the  possible  involvement  of  regional  or  local 
administrations). 
Frequency of inspection controls, varying from once every three years to once every six months. 

 
  Knowledge and capacity of inspectors.  

The presence or absence of a fee/charge system for issuing the licence may influence the opinion of 
MSCAs and zoos on the extent to which the costs are proportionate to the benefits.  

All of these elements can have an impact on the speed of the procedures related to licensing and in-
spection,  on  the  efforts  required  of  zoos  (to  adapt  to the  legislation)  and  of  MSCAs  (to  perform  the 
inspection controls).  

The results and benefits achieved from implementation of the Zoos Directive depend on a complex set 
of factors, operating at a range of different levels (e.g. legislative, executive and operational). As dis-
cussed in Sections 5.1.1 and 5.1.3, the achievement of the objectives in the Member States has been 
affected by delays in adopting transposing legislation and in implementing the licensing and inspec-
tion  systems.  The  general  wording  of  the  Zoos  Directive  resulted  in  variations  across  the  Member 
States,  which  have  adopted  different  definitions  of  ‘zoo’  and  associated  concepts  (e.g.  in  relation  to 
‘significant’ number of species or ‘wild species’), with consequences for the number and type of enti-
ties subject to regulation in each Member State. 

Understanding how these factors are related to each other requires more complete and precise infor-
mation, and a larger sample than was within the scope of this study. It is likely that there are underly-
ing drivers that influence those factors more easily seen in the operation of the Directive (e.g. the or-
ganisation  of  Member  State  administrative  processes  may  influence  the  rapidity  with  which  the  Di-
rective was transposed into national law and, therefore, how quickly an inspection system was created 
and  what  it  comprised).  Furthermore,  the  information  collected  on  the  costs  and  benefits  associated 
with  the  Zoos  Directive  does  not  enable  a  systematic  comparison  between  the  Member  States,  nor 
does it permit any conclusions to be drawn about casual links between the level of costs and achieve-
ments/benefits  on  the  one  hand,  and  the  key  features  of  the  national  implementation  system  on  the 
other hand.  

The qualitative information gathered suggests that the issues hindering the proper and efficient func-
tioning of the licensing and inspection system are mainly associated with the capacity of the national 
inspectorates (in terms of resources available to MSCAs, but also in terms of skills and  competences 

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of the inspectors)245, rather than with specific requirements of the national legislation (such as the fre-
quency  of  inspections).  As  competencies  are  often  shared  across  different  Ministries  (e.g.  environ-
ment, health and agriculture), there is a risk of lack of coordination and exchange of information be-
tween the CAs, creating bottlenecks and inefficiencies in the process246.  

The Zoos Directive has introduced a system of licensing and inspection which did not exist in most of 
the  Member  States.  As  such,  it  has  required  both  MSCAs  and  zoos  to  adapt  to  new  procedures  and 
requirements, as well as mobilising specialised knowledge. There were some examples of good prac-
tices submitted through the targeted consultation and the workshop held in Brussels, focusing especial-
ly on guidance on requirements and capacity of inspectors’ teams.  More precisely, only three of the 
MSCAs surveyed for this study provided examples of good practices (with no examples of poor prac-
tices). One MSCA considered that tendering publicly for a zoo inspectorate resulted in good value 
for  money  and  an  efficient  and  effective  zoo  inspection  process.  A  second  MSCA  sought  to  ensure 
that  requirements  were  proportional  to  the  size  of  the  establishment  (e.g.  in  information  pro-
grammes). A final MSCA reported that in one Member State guidelines were provided for local zoos, 
with a list of measures for improvement.  

Zoos also commented on good practices, particularly related to the involvement of zoo associations in 
aspects of the inspection process. For example, in countries such as the Netherlands and Denmark, the 
national (or regional247) zoo associations are involved in the licensing process in order to reduce 
the  administrative  burden.  The  involvement  of  zoo  associations  also  helps  to  increase  the  expertise 
within the licensing process.  

Links with the EAZA accreditation system were appreciated and could be strengthened in the view of 
some zoos. Eleven (out of 26, 42%) zoos’ federations, NGOs and other stakeholders provided exam-
ples of good practices, the majority of which related to the participation of zoo associations in the 
inspection process, providing both efficiency and also greater expertise.  

The  Netherlands  is  one  of  the  Member  States  where  zoos’  federations  (EAZA  and  the  national  zoo 
federation)  are  strongly  involved  in  the  inspection  process,  a  system  cited  as  best  practice  by  a  few 
respondents.  The  box  below  provides  a  short  description  of  inspections  in  the  Netherlands,  and  the 
ways in which the zoos’ federations are involved.  

Box 13: Dutch inspection system 

In the Netherlands, the licensing of zoos was a new activity for the authorities. The Directive was 
initially adopted through the Animal Act (Dierentuinbesluit) in 2002 and this law was subsequently 
incorporated in 2011 in Article 4.1-4.13 in the new Animal Law (Wet Dieren).   

The Dutch defined zoos as establishments where at least 10 species were exhibited, with the excep-
tion  of  species  that  are  protected  under  the  Flora  and  Fauna  Act.  Pursuing  this  policy  and  imple-
menting the legislation is the responsibility of the Ministry of Economic Affairs, and the Secretary 
of  State  of  Economic  Affairs  grants  the  relevant  licences.  The  Netherlands  Enterprise  Agency 
(RVO) was given the responsibility of granting licences on behalf of the Secretary of State.  

Inspection  and  enforcement  falls  under  the  remit  of  the  Food  and  Consumer  Product  Safety  Au-
thority (NVWA). A list of licensed zoos is published on the internet248, with details of application 
number, licence number, zoo name and date of licence. A Dutch zoo licence has an indefinite dura-
tion and no cost is associated with licence applications. Inspections are carried out after a licence is 

245 See Section 5.1.2. 
246 Discussion during the Workshop on the REFIT evaluation of the Zoos Directive, Brussels, 16 May 2017 (see Workshop Report, June 
2017, available at: http://ec.europa.eu/environment/nature/legislation/refitzoosdirective/pdf/Workshop_report.pdf). 
247 As discussed during the Workshop, regional associations (i.e. acting at the EU level) could provide such support, if national associations 
do not exist in the Member State or do not have a screening process.  
248 http://www.rvo.nl/sites/default/files/2015/05/Overzicht%20verleende%20vergunningen%20dierentuinen.pdf 

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granted, about once every three years, and are risk-based. This means that whenever there may be a 
suspicion that a zoo falls below the required standard, such as imports or movements of exotic ani-
mals related to a particular zoo, or upon receipt of information or a complaint from a citizen in re-
spect of animal welfare, the authorities may initiate an inspection. Other major reasons for inspec-
tions include: a zoo open to the public without a licence and exhibiting species without approval of 
any necessary changes to the licence.  

The Dutch authorities make use of zoo associations: EAZA and NVD members (Dutch Association 
of  Zoos  and  Aquaria;  Nederlandse  Vereniging  van  Dierentuinen,  NVD)  are  inspected  by  EA-
ZA/NVD inspectors, and such inspections are non-governmental. They send the reports to the RVO 
which  then  decides  if  NVWA  inspectors  need  to  do  further  inspections.  Currently,  the  licensing 
team is small and has external support: the RVO works with an advisory board (visitatiecommissie 
dierentuinen),  which  advises  on  the  granting  of  licences.  The  Chairman  and  the  Secretary  of  the 
board are staff of the RVO, while other board members are veterinarians of the NVWA and external 
zoo experts. 

For each  visit,  the Chairman  appoints a team of two  to four persons. This is because government 
staff has insufficient knowledge and experience across the wide variety of issues related to the dif-
ferent  animal  species  housed  in  zoos  and  aquariums.  The  costs  associated  with  this  external  zoo 
expert advice during inspections are borne by the government. 

NVD is able to link and relate its membership conditions to the Directive, thereby helping to make 
the Directive accessible and understood by its members. The NVD also uses the guidance provided 
in the Directive to be pro-active in achieving the requirements, for example developing conserva-
tion standards, running biodiversity campaigns, etc. The NVD also has a role in supporting the li-
censing  by  the  CA  by  providing  professional  zoo  expertise.  In  this  respect,  current  standards  of 
professional zoo associations are often more progressive than the national legal standards based on 
the Zoo Directive. 

In France, the participation of many professional members of national associations in the commissions 
involved in the implementation of the Directive (e.g. the National Commission for Wild Fauna in Cap-
tivity  which  was  consulted  for  the  granting  of  certificates  of  capacity  for  certain  species)  genuinely 
involves all the parties concerned with the Directive. 

The  emphasis  on  the  need  for  ensuring  relevant  expertise  within  the  licensing  process  is  consistent 
with the findings of the Good Practices Document (VetEffecT 2015), which highilights the importance 
of multidisciplinary teams with complementary skills and able to assess every aspect of the implemen-
tation  of  the  Zoos  Directive.  The  Good  Practices  Document  points  out  that  MSCAs  may  choose  to 
assemble  teams  complemented  with  selected  external  personnel  with  relevant  expertise,  or  advisory 
bodies composed of any combination of government, academic, zoo professional, independent or other 
experts249. 

However, as highlighted during the Workshop, it also important to ensure that licensing and inspection 
is supported through a multi-stakeholder process, in order to avoid over-representation of the interests 
of  a particular stakeholders’ group  (i.e.  zoos’ associations  or animal  welfare  organisations).  Sugges-
tions included the establishment of a committee of experts to support MSCAs in the implementation of 
the Directive, or advisors with no decision-making role, to ensure impartiality. 

A  further  example  of  good  practice  proposed  by  survey  respondents  was  the  smaller  zoos  forming 
consortia to sponsor conservation projects collaboratively. This is more aspirational than a descrip-
tion of what happens at present. It reflects a concern that many zoos are too small to have a significant 
conservation benefit on their own, whereas if they were able to work together they would be able to 

249 Good Practices Document (VetEffecT 2015). 

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pool resources so that they would have sufficient ‘critical mass’ to be able to play a more substantial 
role in field conservation.   

5.2.3.2  Summary and conclusions 

There  are  significant  variations  between  Member  States  on  a  wide  range  of  factors,  including  legal, 
executive and operational, that seem likely to influence the implementation of the Directive, its costs 
and  benefits.  The  extent  of  these  variations  (both  in number  of  factors  and  the  scale  of  each  factor) 
make it difficult to draw definitive conclusions on causal factors among the 14 Member States in this 
study.  Insights  were  drawn,  therefore,  from  responses  to  the  survey  and  from  case  studies  that  de-
scribed the inspection process in detail. 

Qualitative information gathered suggests that the issues hindering the proper and efficient functioning 
of the licensing and inspection systems are mainly associated with the capacity of the national inspec-
torates (resources, skills and competences) rather than with specific requirements of the national legis-
lation. Inputs from stakeholders suggested that the licensing process works well in countries where the 
lines of responsibility are clear and all available expertise is used.  

MSCAs, zoos, zoos’ federations, NGOs and other stakeholders identified  several good practices that 
have contributed to the positive achievements of the Directive. Drawing on zoo associations (national-
ly or at European level) is seen as a factor in enhancing the inspection process in some Member States. 
Similarly, the importance of a multi-stakeholder process was highlighted, in order to ensure impartiali-
ty and the balanced representation of all interests.   

5.2.4  Efficiency – EQ 8 

Taking account of the objectives and benefits of the Directive, what evidence is there that it has caused 
unnecessary regulatory burden or complexity? What factors identify this burden or complexity as un-
necessary or excessive? 

5.2.4.1  Evidence of unnecessary regulatory burden or complexity caused by the 

Zoos Directive  

This question deals with administrative burdens, defined in the European Commission Better Regula-
tion Toolbox (European Commission 2015) as those costs borne by businesses, citizens, civil society 
organisations and public authorities as a result of administrative activities performed to comply with 
information  obligations  included  in  legal  rules250.  The  assessment  of  administrative  burdens  is  ad-
dressed in EQ5 (as part of regulatory costs that are caused by the Zoos Directive) and the related find-
ings represent the starting point for analysis of this question.  

The evidence provided by stakeholders does not suggest major issues in terms of excessive administra-
tive burden. More specifically, administrative costs related to the Zoos Directive appear strictly related 
to  the  necessary  procedures  for  obtaining  a  licence  (from  the  point  of  view  of  zoos)  or  issuing  a  li-
cence (from the point of view of MSCAs). Few estimates  of the effort required by the licensing and 
inspection process were provided by stakeholders and, where estimates are available, these vary con-
siderably. Nevertheless, most of the stakeholders, and both zoos and MSCAs, consider the effort re-
quired  to  apply  the  Zoos  Directive  (including  the  administrative  burden  implied)  is  proportionate  to 
the benefits brought (see Section 5.2.2 above). In parallel, the different consultations with stakehold-
ers251  have  not  raised  any  specific  issues  pointing  to  burdensome  and  complex  requirements  and/or 
procedures that could be avoided or reduced. During the workshop it was highlighted that, given the 
increased focus on illegal trade of wild animals, the inspection and licensing schemes required by the 

250 In addition, in order to clarify the terminology, it should be mentioned that, according to a CEPS-Economisti Associati study for the 
European Commission, ‘administrative burdens are the part of administrative costs which is caused by regulatory requirements: accordingly, 
they do not include so-called “BAU costs”, i.e. costs that would emerge also in absence of regulation’ (CEPS-Economisti Associati 2013). 
251 The reference is specifically to the targeted consultation with MSCAs and zoos through interviews and the survey.  

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Directive are increasingly essential252.  

In this context, only two elements suggesting unnecessary complexity and need for simplification were 
identified.  

The  first  relates  to  the  organisation  of  the  licensing  and  inspection  system.  One  stakeholder  sug-
gested that subsequent (i.e. repeated) inspections from national authorities are often not coordinated, 
with one inspection not building on the other.  

The second relate to possible overlaps with other legislations and duplication of inspection controls. 
As described in Section 5.4, the licensing and inspection systems set up for the implementation of the 
Zoos Directive can overlap with the licensing and inspection regimes established in relation to other 
EU  legislations,  such  as  Regulation  (EC)  No  338/97  on  the  protection  of  species  of  wild  fauna  and 
flora by regulating trade therein, and Directive 92/65/EEC on animal health requirements for trade in 
and imports into the EU253. 

Both of these pieces of legislation entail inspections by national CAs, and involve zoos hosting CITES 
species254 and zoos that are listed as approved bodies, institutes and centres (ABICs)255. The result is a 
duplication of effort (both for zoos and CAs) and even confusion between different pieces of regula-
tion.  This  issue  has  been  reported  by  stakeholders  and  recently  raised  by  audits  conducted  by  DG 
SANTE on the application of animal welfare legislation256.  

These  factors  suggest  that  synergies  in  the  enforcement  of  different  legislations  applicable  to  zoos 
could be harnessed by improving cooperation among national authorities and the coordination of dif-
ferent  licensing  and  inspection  systems.  However,  attention  should  be  paid  to  the  recognition  of  the 
specificities  of  each  legislation  and  the  different  competences  needed  by  inspectors  for  the  correct 
application of the different rules.  

5.2.4.2  Summary and conclusions 

There  is  no  evidence  of  unnecessary  regulatory  burden  nor  were  any  poor  practices  identified  by 
stakeholders. However, some aspects that are likely to create unnecessary burden and which are, there-
fore, possibilities for simplification could be investigated. Overall, however, all MSCAs suggest that 
costs that have been incurred as a result of the Directive are proportionate and those incurred by zoos 
are widely seen as necessary business costs. All costs that have been highlighted are seen as important 
for the implementation of the Zoos Directive. 

5.3  Relevance 

Analysis of relevance relies on a comparison of the current needs and objectives with those defined at 
the  time  of  adoption  of  the  Directive  (see  intervention  logic  under  Section  2.2).  The  Zoos  Directive 
was  adopted  in  1999  and has  been  in  force  for  16 years  without further  amendments.  It  is therefore 
important to identify any mismatch between the objectives of the Directive and the current (legal, pol-
icy and scientific) situation. The analysis therefore requires: 

 

Firstly, an assessment of the current needs and their correspondence to the original objectives of 

252 Discussion during the Workshop on the REFIT evaluation of the Zoos Directive, Brussels, 16 May 2017 (see Workshop Report, June 
2017, available at: http://ec.europa.eu/environment/nature/legislation/refitzoosdirective/pdf/Workshop_report.pdf). 
253 Directive 92/65/EC laying down animal health requirements for trade in and imports into the EU of animals, semen, ova and embryos not 
subject to other specific rules. 
254 Species covered by the Convention on International Trade in Endangered Species of Wild Fauna and Flora; inspections are carried out 
under the Regulation (EC) No 338/97. 
255 Zoos defined as establishments approved in accordance with Article 13 of Directive 92/65/EC, where animal species are kept or bred for 
one or more of the following purposes: display of animals and education of the public; conservation of the species; basic or applied scientific 
research or breeding of animals for the purposes of such research. 
256 Audits performed by DG SANTE, see Section 5.4.1.3.  

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 

the Zoos Directive.  
Secondly, an assessment of the current objectives set out in the EU and global legal and policy 
framework, and the contribution of the Directive’s general and specific objectives to this bigger 
picture.     

  Thirdly,  an  assessment  of  the  technical  and  scientific  progress  achieved  during  the 
implementation period  of the Directive,  and  the correspondence of the Directive’s objectives to 
this progress. Also, an assessment of the extent to which the conservation actions promoted and 
the licensing and inspection systems set up by the Member States have kept pace with the latest 
developments.  

The first point was addressed in EQ9 (Section 5.3.1). For this question, the objectives pursued by the 
Directive are framed in the context of current and emerging issues, in order to assess the role played 
by the Directive in conservation of biodiversity.  

The second point was addressed in EQ10 (Section 5.3.2). There, the developments shaping the biodi-
versity  agenda  at  the  EU  and  global  level  (e.g.  the  CBD’s  Aichi  Biodiversity  Targets  and  the  UN’s 
SDGs) are considered against the Zoos Directive as it has been implemented to date, in order to better 
understand its relevance at present.  

For the third point, which is addressed  under  EQ11 (Section  5.3.3), the technical and scientific pro-
gress achieved was mapped, in particular in relation to ex situ management, in order to assess the level 
of adequacy of the Directive to reflect this progress. 

5.3.1  Relevance – EQ 9 

How well do the (original) objectives (still) correspond to the needs within the EU and globally? 

In this first step of analysis of relevance, the objectives of the Directive are examined in the context of 
current trends and emerging issues in biodiversity conservation, in order to assess the role played by 
the Directive in conservation of biodiversity. The following elements are provided: 

  Outline of the current trends and needs in the area of biodiversity, including an understanding of 
the status of biodiversity and the way in which it is reflected in global policy (within which EU 
responses are framed or are being framed).  

  Assessment of the extent to which the Directive’s objectives support the needs identified. 

Information to answer this question was drawn from literature, policy documents and from the target-
ed and public consultations.  

5.3.1.1  Current trends in the area of biodiversity conservation 

The attention given to the conservation of the environment, and especially biodiversity, has increased 
considerably since the Directive came into force in 1999. Some of this evolution is described in  Sec-
tion 5.3.2, but key features of these changes with regard to current EU and global needs are: 

  Biodiversity continues to decrease, with the status of species still deteriorating (e.g. (Hoffman, 

M et al 2010)), and the loss of habitats increasing (e.g. (Boakes, et al. 2010). 

  There  is  increasing  specificity  in  the  needs  of  biodiversity,  and  this  is  reflected  in  the  CBD’s 
Aichi  Targets,  and  the  detailed  targets  of  SDGs  14  and  15  (see  Section  5.3.2  below).  Species 
needs feature significantly, as does awareness-raising.  

  The  political  importance  given  to  biodiversity  conservation  has  continued  to  rise  and  is  now 

captured in the SDGs adopted by all UN Parties in September 2015. 

The priority given to biodiversity conservation needs is, therefore, still relevant and is increasing. 
The EU and its Member States have contributed to determining the nature of this global need: the EU 
is a Party to the CBD and its Biodiversity Strategy is framed within the context of the EU’s commit-

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ments to the Convention ((COM)2011) 244).  

5.3.1.2  Current needs in the area of biodiversity conservation 

The  need  to  protect  biodiversity  has  been  translated  by  international  agreements  and  literature  into 
various specific needs, in particular, the need to protect species threatened with extinction and to raise 
public awareness.  

This is confirmed by the results of  this survey. Thirty-four zoos of the 70  questionnaire respondents 
emphasised the need to raise public awareness and for the conservation of species in general. Several 
zoo operators257 expressed the view that the zoos should ‘undertake continued efforts to halt the ongo-
ing loss of biodiversity by supporting conservation projects; by successfully managing ex situ popula-
tions; by enabling non-invasive research on wildlife which could not be done likewise in the wild; by 
raising  public  awareness  for  the  protection  of  nature,  species  and  the  environment;  by  enabling  all 
citizens of our mainly urbanised societies to experience true wildlife encounters; by portraying highest 
standards of animal husbandry to build up appreciation for the needs of animals’. 

a.  Protect species threatened with extinction 

Protecting  species  threatened  with  extinction  is  an  ever-increasing  need.  According  to  IUCN  data, 
species extinction is occurring at up to 1,000 times the natural rate, and  nearly 30% of the 80,000 
species assessed on the IUCN red list are threatened with extinction (IUCN 2016).  

Stakeholder perceptions reflect this finding, as illustrated in Figure 28 below.  

Figure 28: Stakeholders considering the protection of threatened species to be relevant, in absolute numbers258 

Protect species threatened by extinction 

70

60

50

40

30

20

10

0

62 

13 

1 

1 

1 

4 

25 

1 

MSCAs

Zoos

Federations/NGOs/Experts

Yes

No

No opinion

Source: Present survey of MSCAs, federations, NGOS and experts, and zoos 

The results of the public consultation undertaken in the context of the study show a similar pattern. 
88% of the respondents (2,023 respondents) considered protecting European and globally threatened 
species as important or very important259.   

257 No statistical information is provided on this question, as the results of the survey cannot be considered representative. It was observed 
that several (at least seven) zoos provided identical answers, according to which ‘The underlying reasons for putting the EU Directive in 
place back then are still prevailing. It is of upmost importance that all zoos undertake continued efforts to halt the ongoing loss of biodiversi-
ty by supporting conservation projects; by successfully managing ex situ populations; by enabling non-invasive research on wildlife which 
couldn’t be done likewise in the wild; by raising public awareness for the protection of nature, species and the environment; by enabling all 
citizens of our mainly urbanised societies to experience true wildlife encounters; by portraying highest standards of animal husbandry to 
build up appreciation for the needs of animals’. 
258 Questionnaires of MSCAs 107a/High-level 65a/Zoos 102a 
259 Public Consultation Report (Annex VIII), Section 6.1.1. 

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In this regard, there is a clear pathway for  ex situ  management  to contribute to overall 
strategies to halt species extinction (see Section 5.1.2 on the contribution of zoos to the management 
of threatened species).  

b.  Public awareness of biodiversity conservation issues 

The importance of raising awareness is increasingly understood as a first step in changing attitudes to, 
and perceptions of, the natural world, both of which are necessary to effect behaviour change that will 
result in more sustainable use of the environment.  

Among  the  stakeholders  surveyed,  perceptions  of  public  awareness  were  that  it  remains  a  current 
need.  

Figure 29: Stakeholder perceptions of the relevance of public awareness of biodiversity conservation issues260 

Public awareness of biodiversity conservation issues 

70

60

50

40

30

20

10

0

62 

2 

13 

0 

1 

7 

1 

0 

25 

MSCA

Zoo

Federations/NGOs/Experts

No

Yes

No opinion

Source: Present survey of MSCAs, federations, NGOS and experts, and zoos 

Similarly, most respondents to the public consultation (69%, 1,578 respondents) felt that having EU-
wide rules increasing public awareness of biodiversity and nature protection by offering education and 
information on these topics remains very important, with a further 21% (470 respondents) considering 
it important261.  

Conservation of biodiversity and raising public awareness were already the essential needs that led to 
the adoption of the Directive. Sixteen years later, this survey confirmed that these needs remain the 
same. None of the respondents indicated that the needs of species and biodiversity more generally had 
changed  since  the  Directive  came  into  force,  although  there  were  diverse  views  on  the  role  of  zoos 
(and, by implication, the Directive) in addressing those needs. 

5.3.1.3  Directive’s contribution to the identified needs  

The  information  presented  above  indicates  that  the  need  for  biodiversity  conservation  not  only  still 
exists,  but  is  seen  as  ever  more  urgent  (as  the  rate  of  biodiversity  loss  increases)  and  the  policy  re-
sponses (especially CBD and UN SDGs) both contain significant detail and seek to integrate biodiver-
sity more generally into development activities. While the Directive is concerned with a specific con-

260 Questionnaires MSCAs 107c/High level 65c/Zoos 102c. 
261 Public Consultation Report (Annex VIII), Section 6.1.1. 

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servation response (the contribution of zoos to biodiversity conservation), the potential for it to play 
an enhanced role in achieving these heightened global needs is evident, through its specific objec-
tives  of  ensuring  the  participation  of  zoos  in  conservation  activities,  including  the  promotion  and 
awareness-raising activities of zoos.  

The relevance of the Directive to the prevailing global policy needs (and the EU’s responses to them) 
are supported by the trends in responses from stakeholders to the targeted survey. They felt strongly 
that the Directive was still relevant  in protecting species from extinction, regulating  ex situ manage-
ment, and raising public awareness of biodiversity conservation issues, as illustrated in Figure 28 and 
Figure 29 above. In more practical terms, the increasing realisation of the scale of the challenge facing 
biodiversity, and  the  potential  for  the  Directive  to  increase  the  effectiveness  of  zoos  in  meeting  this 
challenge, especially by providing a ‘coordinated approach’ was mentioned by the stakeholders.  

There were, however, some criticisms about the suitability of the existing approach to the current 
needs expressed in the survey. In relation to awareness-raising, one CA262 pointed out that many other 
approaches,  such  as  media,  events,  and  campaigns  could  be  used  instead  of  exhibiting  live  captive 
animals of wild species to raise public awareness of biodiversity conservation issues. Several respond-
ents to the survey suggested that present biodiversity conservation needs a more targeted approach 
to ex situ conservation, indicating that there should be some sort of guidance on how to pursue ex situ 
conservation. This is discussed further under Section 5.3.3.2.   

5.3.1.4  Summary and conclusions 

In  conclusion,  the  objectives  of  the  Directive  still  support  the  current  needs  of  biodiversity,  even 
though these needs are now seen as significantly greater. The provisions of the Directive are still seen 
as  an  appropriate  way  for  ex  situ  management  to  meet  these  needs,  although  better  guidance  would 
allow zoos to play a greater role in meeting biodiversity conservation needs.  

International and EU policies reflect an increasing recognition that concerns about deteriorating biodi-
versity must be incorporated in many other fields of social, economic and environmental endeavour. In 
other words, efforts to conserve biodiversity cannot remain in isolation from efforts to, for example, 
promote economic growth, pursue food security and alleviate poverty.  

The relevance of the Directive to the policy objectives  stemming from these changes in the status of 
biodiversity, and the way that these are now seen as integral to sustainable development, is explored in 
the next evaluation question.  

5.3.2  Relevance – EQ 10 

How relevant is the Directive to achieving legal and policy biodiversity objectives at EU and global 
levels? 

This question aims to identify the main developments that have taken place in the EU and international 
policy framework, and the corresponding changes in objectives. It will then assess the suitability of the 
Directive’s  objectives  to  address  these  developments  and  changes.  This  complements  the  analysis 
carried out under EQ2 (Section 5.1.2) which assessed the contribution of the Directive to the original 
instruments.  

The analysis is done in two steps: 

 

Firstly,  the  evolution  of  global  and  EU  policies  is  examined  in  detail  in  order  to  identify  the 
current global and EU biodiversity objectives and targets. As EU biodiversity targets are framed 
within global policy processes, notably the CBD (and increasingly the UN SDGs), the emphasis 

262 MSCAs Questionnaire Q108. 

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 

here  is  on  describing  the  global  process  as  it  sets  the  context  for  evolution  of  the  EU’s 
biodiversity policy. 
Secondly,  these  current  objectives  and  targets  are  compared  with  the  Directive’s  (general  and 
specific) objectives in order to assess the extent to which the Directive has ‘kept pace’ with the 
changes that occurred at EU and international level.  

The information used to address both parts of this question is largely drawn from documents produced 
by global policy processes, notably the CBD and the UN SDGs.   

5.3.2.1  Evolution of EU and global biodiversity and conservation objectives since 

the adoption of the Zoos Directive  

As  the  Zoos  Directive  is  a  response  to  the  CBD,  changes  in  this  Convention  are  outlined  first,  fol-
lowed by the UN SDGs, and then other global instruments and processes. The process is highlighted in 
Figure 30 below. 

Figure 30: Development of global biodiversity and conservation objectives 

Source: Desk research for this survey  

a.  Developments under the CBD since the Zoos Directive came into force 

Shortly after the Zoos Directive came into force, the CBD adopted a Strategic Plan for Biodiversity 
for the period 2002-2010 in order to guide its implementation at national, regional and global levels. 
This marked a decade since the Convention was agreed and the Strategic Plan set out  ‘to achieve by 
2010 a significant reduction of the current rate of biodiversity loss at the global, regional and national 
level as a contribution to poverty alleviation and to the benefit of all life on Earth’, and this became 
known  as  the  ‘2010  Biodiversity  Target’  (e.g.  (Balmford  and  al  et  2005),  (Secretariat  of  the  CBD 
2006), (Walpole 2009). 

Global Biodiversity Outlook 2 (Secretariat of the CBD 2006) sought to assess progress towards this 
Target. In doing so, it reported on ‘supporting’ goals and targets and indicators for evaluating biodi-
versity status and trends (see also (Walpole 2009)). It concluded that, overall, the threats to biodiversi-
ty were increasing and that the human demand for resources outstripped the Earth’s capacity to meet 
that demand by 20% ( (Secretariat of the CBD 2006)). At the end of that decade, Global Biodiversity 
Outlook 3 ( (Secretariat of the CBD 2010a)) concluded that the 2010 target had been missed, perhaps 
not surprisingly, given the work that needed to be done on many levels and the relatively short dura-
tion of the Strategic Plan. At the same time, and after taking almost a decade to consider how the sta-

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tus of biodiversity could and should be measured, there were some concerns that the 2010 target itself 
had been problematic for monitoring progress, including inter alia that it was vague ‘about timescales, 
baselines, acceptable rates and measures’ (Mace GM 2010). 

Current CBD Targets  
A revised and updated Strategic Plan for Biodiversity 2011-2020 was adopted at the 10th Conference 
of the Parties (in Decision X/2:  (Secretariat of the CBD 2010b); (2010)). A significant development 
was the inclusion within this strategy of 20 targets, known as the Aichi Targets. These included spe-
cific reference to species and to raising public awareness. The 20 targets are grouped under five strate-
gic goals263. 

The Aichi Targets have provided a tighter focus for biodiversity conservation efforts under the CBD 
than existed when the Zoos Directive came into force in 1999 (CBD Article 9), or from the 2010 Bio-
diversity Target that was adopted shortly after. This improved focus comes from both the specification 
of particular components of biodiversity for attention (i.e. threatened species, genetically and cultural-
ly important species) and the sort of attention required (e.g. education and awareness, mainstreaming 
and protected areas), as well as providing clarity for some of the targets on what precisely is pursued. 
Some of these targets have strong indicators associated with them. 

All of these provide a stronger framework within which the contribution of zoos to globally agreed 
biodiversity targets can be set and how this contribution can be measured. A mid-point analysis of the 
CBD’s  2011-2020  Strategic  Plan  indicated  that  while  conservation  responses  were  increasing,  the 
pressures on biodiversity were increasing at a greater rate ( (Secretariat of the CBD 2014), (Tittensor 
2014)).  

b.  UN SDGs  

The world’s heads of government  adopted the  Millennium Development Declaration in 2000  (UN 
2000)), which introduced what became known as the Millennium Development Goals (MDGs). Re-
ducing the loss of biodiversity was included as a new target in the MDGs (SCBD 2016), as one of four 
targets contributing to Goal 7264, as follows: 

Goal 7: Ensure environmental sustainability 
Target 7b: Reduce biodiversity loss, achieving, by 2010, a significant reduction in the rate of loss. 

Towards the end of the 15-year lifespan of the MDGs, attention turned towards the post-2015 Devel-
opment Agenda and in September 2015, the MDGs were replaced by the SDGs (UN 2015). 

As with the CBD, where the Aichi targets provided greater focus than the 2010 Biodiversity Target, so 
too do the SDGs provide greater clarity on biodiversity conservation than the MDGs. While many of 
the goals and their targets are linked to biodiversity, there are two goals (and 22 targets) that deal spe-
cifically with its conservation: Goal 14 Life below water265 and Goal 15 Life on land266. 

These SDG targets resemble the CBD targets in places. This is especially striking where the timescale 
runs until 2020 rather than 2030, so as to match the reporting deadline for the CBD’s Strategic Plan. 
The elements of most direct consequence to the Zoos Directive are: 

SDGs relevant for Zoos 
SDG Target 15.5: Take urgent and significant action to reduce the degradation of natural habitats, 
halt the loss of biodiversity and, by 2020, protect and prevent the extinction of threatened species. 
This also mirrors the CBD’s Aichi Target 12.  

263 https://www.cbd.int/sp/targets/  
264 http://www.un.org/millenniumgoals/environ.shtml  
265 https://sustainabledevelopment.un.org/sdg14  
266 https://sustainabledevelopment.un.org/sdg15  

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SDG Target 15.8: By 2020, introduce measures to prevent the introduction and significantly reduce 
the impact of invasive alien species on land and water ecosystems and control or eradicate the prior-
ity species. This also mirrors CBD’s Aichi Target 9.  
Other targets may be relevant to the work of some zoos and fall within the provisions of the Di-
rective (i.e. they promote the role of zoos in the conservation of biodiversity). These include, but are 
not limited to, targets for habitat conservation (e.g. Targets 14.2, 15.1 and 15.4) and sustainable 
management (Target 15.2) and reducing over-exploitation of certain species in the wild (Targets 
14.4 and 15.7). Zoos may also contribute significantly to  operational targets for enhanced support 
for these SDGs, through Targets 14a and 15a-c.  

c.  Other global instruments and developments 

Global  developments  are  the  UN  Food  and  Agriculture  Organization’s  (FAO)  work  on  genetic  re-
sources (e.g. of food species and their wild relatives)267 that has seen the development of global action 
plans to reduce overharvesting (especially illegal, unreported and unregulated [IUU] fishing)268.  
There has also been a considerable increase in attention  to the escalating problem of illegal trade in 
wildlife (referring to plants, such as trees, as well as animals), including an analysis commissioned by 
the  UN  Environment  Assembly269,  which  duly  adopted  a  resolution  that,  inter  alia,  ‘Urges  Member 
States to take further decisive steps and action at the national level and through regional and interna-
tional cooperation, including with the International Consortium on Combating Wildlife Crime270 and 
other partners, to prevent, combat and eradicate the supply, transit and demand related to illegal trade 
in wildlife and wildlife products […]’271 272 

All of these global instruments and developments provide further evidence for the pressures on species 
and wider biodiversity and the need for concerted and coordinated responses. Many of them require 
action in the wild, where areas that are of special importance for biodiversity require careful manage-
ment and/or where there are very specific pressures that have to be reduced. The role of ex situ man-
agement, and of zoos more generally, is therefore, likely to be context-specific.  

d.  Development of European instruments  

The EU’s Biodiversity Strategy (Anon., (COM)2011) 244 2011) is framed within the context of the 
CBD Strategic Plan and it ‘is aimed at reversing biodiversity loss and speeding up the EU's transition 
towards a resource efficient and green economy’. It has five targets, of which the first is: 

Target 1 of the EU Biodiversity Strategy 
To halt  the deterioration  in  the status of all species and habitats covered by EU nature legislation 
and achieve a significant and measurable improvement in their status so that, by 2020, compared to 
current assessments: (i) 100% more habitat assessments and 50% more species assessments under 
the  Habitats  Directive  show  an  improved  conservation  status;  and  (ii)  50%  more  species  assess-
ments under the Birds Directive show a secure or improved status. 

5.3.2.2  Contribution of the Directive to the current EU and international objectives 

and targets 

As  described  above,  there  has  been  considerable  change  to  the  global  biodiversity  targets,  and  their 
pursuit in the EU. These are reflected in both the specificity of species-related targets, such as halting 
extinction  (rather  than  ‘reducing  biodiversity  loss’)  and  in  objectives  to  ensure  that  biodiversity  is  a 
fundamental consideration in national planning and development sectors and plans.  

267 http://www.fao.org/genetic-resources/en/  
268 http://www.fao.org/fishery/iuu-fishing/en 
269 http://www.unep.org/about/sgb/Portals/50153/UNEA/FINAL_%20UNEA2_Inf%20doc%2028.pdf  
270 The members of the Consortium are the Convention on International Trade in Endangered Species of Wild Fauna and Flora, the Interna-
tional Criminal Police Organization (INTERPOL), the United Nations Office on Drugs and Crime, the World Bank and the World Customs 
Organization.  
271 Emphasis added. 
272 http://www.unep.org/about/sgb/cpr_portal/Portals/50152/2-14/K1607258_UNEPEA2_RES14E.docx  

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Crucially, what is desired for biodiversity is now detailed in the 20 Aichi Targets of the CBD and the 
22 Targets of SDGs 14 and 15. A comparison of these against the provisions of the Zoos Directive 
provides a good indication of the extent to which the Directive is well adapted to the current needs, i.e. 
the extent to which the Directive has ‘kept pace’ with the changes that have taken place in biodiversity 
target-setting since the Directive was adopted in 1999. 

Though all potentially relevant, three of the Aichi targets are particularly important in the context of 
the Directive, as presented below. 

Key targets in view of the Zoos Directive 
  Aichi Target 1: By 2020, at the latest, people are aware of the values of biodiversity and the steps they 

can take to conserve and use it sustainably. 

  Aichi  Target  9:  By  2020,  invasive  alien  species  and  pathways  are  identified  and  prioritised,  priority 
species  are  controlled  or  eradicated,  and  measures  are  in  place  to  manage  pathways  to  prevent  their 
introduction and establishment. 

  Aichi  Target  12:  By  2020  the  extinction  of  known  threatened  species  has  been  prevented  and  their 

conservation status, particularly of those most in decline, has been improved and sustained. 

For Aichi Target 1, zoos have a very pertinent role in relation to educating visitors and raising aware-
ness  of  biodiversity  conservation,  and  their  contribution  to  education  has  been  established  (Moss, 
Jensen and Gusset, Evaluating the contribution of zoos and aquariums to Aichi Biodiversity Target 1 
2015). From that perspective, the second indent of Article 3 of the Zoos Directive implements Aichi 
Target 1. This is consistent with the interviews and survey carried out here, both of which noted the 
contribution of the Directive to the Target. The survey showed that a majority of stakeholders, regard-
less of type, considered the Directive to contribute positively to Aichi Target 1, as shown in Figure 31 
below273.  

Figure 31: Stakeholder perceptions of the contribution of the Directive to Aichi Target 1 

Contribution to Aichi Target 1 

25

20

15

10

5

0

23 

21 

11 

11 

4 

15 

7 

1 

3 

4 

0 

6 

4 

1 

Zoos

MSCAs

Federations/NGOs/Experts

Did not contribute

Slightly contributed

Strongly contributed

Fully contributed

No opinion/NA

Source: Present survey of MSCAs, federations, NGOS and experts, and zoos 

The contribution of the Directive to this Target therefore corresponds to the level of implementation 

273 Zoos Questionnaire Q 68c. 

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achieved for this provision, as presented in Section 5.1.1. 

Aichi Target 9 has mainly been reflected at EU level in Regulation 1143/2014 on invasive alien spe-
cies274. However, Article 3, fourth indent, also covers the prevention of escape of animals in order to 
avoid possible ecological threats, and is therefore highly relevant in order for the EU to reach Target 9. 
The  analysis  of  implementation  of  this  conservation  measure  (see  Section  5.1.1.3)  demonstrated  the 
successful implementation of this measure, thereby substantiating the contribution of the Directive to 
Target 9.  

Finally, the extent to which zoos contribute to the protection of threatened species remains the subject 
of  debate.  The  pros  and  cons  are  outlined  in  Section  5.3.3.1  (especially  paragraph  5  and  section  b). 
While there is clear scope for ex situ management to contribute to Aichi Target 12, through research, 
breeding programmes and reintroduction (as expressed in Article 3 of the Directive), the protection of 
threatened species per se is not expressly addressed in the Directive, and providing a meaningful as-
sessment of the extent to which protection has  actually been achieved is not straightforward. This is 
because projects and initiatives could be carried out under all types of activity listed in Article 3 but do 
not necessarily contribute directly to halting species extinctions or improving the status of the species 
most in decline. For example, breeding programmes or reintroduction targeting species that are listed 
as Least Concern on the IUCN red list will not contribute towards this target. Literature (Hoffmann, et 
al. 2010) reported that ex situ management had played a role in improving the status of some species 
prior to the establishment of the Aichi Targets in 2010 (see Section 5.1.2.1) and it is likely that there 
has been some contribution since 2010, but this has not been quantified. It is important to note that the 
Aichi Target 12 covers only a part of conservation activity that is directed towards species, and these 
include Targets 9 (sustainable use of selected species) and 13 (conservation of wild relatives of species 
important to humans). There is no available evidence of the extent to which zoo-based research, breed-
ing programme management or reintroductions have contributed, since 2010, to either species conser-
vation broadly, or, more specifically, to halting and reversing the declines of the most threatened spe-
cies, as required under Aichi Target 12. This is corroborated by the present survey, where the contri-
bution of the Directive to the protection of threatened species was assessed very variably, depending 
on the type of stakeholders (see Figure 32 below).  

Figure 32: Stakeholder perceptions of the contribution of the Directive to the protection of threatened species 

Contribution to protecting threatened species 

35

30

25

20

15

10

5

0

31 

17 

14 

3 

5 

7 

5 

2 

1 

12 

10 

3 

1 

Zoos

MSCAs

Federations/NGOs/Experts

Did not contribute

Slightly contributed

Strongly contributed

Fully contributed

No opinion/NA

Source: Present survey of MSCAs, federations, NGOS and experts, and zoos 

274 Interactions between this Regulation and the Zoos Directive are presented in Section 5.4.1 below. 

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Other targets are also applicable to zoos to some extent, as part of national efforts to meet the 2020 
targets: 
  Aichi Target 13: By 2020, the genetic diversity of cultivated plants and farmed and domesticated 
animals, and of wild relatives, including other socio-economically as well as culturally valuable 
species,  is  maintained,  and  strategies  have  been  developed  and  implemented  for  minimising 
genetic erosion and safeguarding their genetic diversity. 

This  matches  the  Zoos  Directive  ‘research,  training  and  conservation  benefits  accrue’  conservation 
measure (Article 3, first indent). 
  Aichi Target 19: By 2020, knowledge, the science base and technologies relating to biodiversity, 
its values, functioning, status and trends, and the consequences of its loss, are improved, widely 
shared and transferred, and applied. 

This  matches  the  Zoos  Directive  ‘research,  training  and  conservation  benefits  accrue’  conservation 
measure (Article 3, first indent). 
Additional targets, although not directly corresponding to specific provisions, can also potentially be 
areas to which the Directive, through its objectives, and in its implementation, contributes: 
 

Strategic  goal  A.  Address  the  underlying  causes  of  biodiversity  loss  by  mainstreaming 
biodiversity across government and society. 

  Aichi Target 4: By 2020, at the latest, governments, business and stakeholders at all levels have 
taken steps to  achieve, or have implemented plans for, sustainable production  and consumption 
and have kept the impacts of use of natural resources well within safe ecological limits. 

Other targets may be relevant to the work of some zoos and may fall within the provisions of the Di-
rective (i.e. they promote the role of zoos in the conservation of biodiversity). These  include, but are 
not limited to, targets for habitat conservation (Aichi Target 5), protected areas (Aichi Target 11) and 
the sustainable use of certain species in the wild (Aichi Target 6).  
The SDGs seek to further  embed biodiversity  considerations  into policies  to achieve  better  manage-
ment of a range of natural resources, such as forests and fisheries. As such, they are broader in scope 
than the Aichi targets, and overall are less relevant to the provisions of the Directive. There is, howev-
er,  clear  potential  for  the  Directive  to  promote  action  towards  SDG  Target  15.5  that  seeks  to,  inter 
alia, ‘protect and prevent the extinction of threatened species’.  

5.3.2.3  Summary and conclusions 

There has been a great change in global biodiversity policy since 1999 when the Zoos Directive was 
adopted. This is illustrated by the fact that the targets set by the Parties to the CBD, which provided 
the context for the Zoos Directive, have evolved markedly since 1999  when the Directive came into 
force.  These  evolutions  have  resulted  in  a  clearer  understanding  of  where  the  problems  lie  (such  as 
species  that  are  highly  threatened  or  exploited  unsustainably)  and  the  emphasis  is  now  on  reducing 
threats. The current EU Biodiversity Strategy reflects this development.  

The consequences of these developments for the relevance of the Directive are twofold: 

 

 

Firstly,  it  provides  a  more  structured  context  for  the  provisions  of  the  Directive  to  facilitate 
zoos’ contributions to biodiversity needs, at both EU and global level. Opportunities to contribute 
are  primarily,  but  not  exclusively,  through  targets  on  protecting  threatened  species  and  halting 
their extinction, and raising public awareness of biodiversity issues.  
Secondly, the evolution of both CBD and SDG targets from general aspirations to focused targets 
with  indicators  and  supporting  documentation  (e.g.  technical  rationale,  indicators  and  progress 
reports) may provide insights that would help to enhance the impact of the Directive.  

In summary, as human understanding of the pressures faced by species increases, it becomes possible 
to improve the targeting of actions to mitigate and overcome those pressures. It will also provide the 
opportunity  to  adjust  actions  as  new  pressures  on  species  increase  and,  if  it  happens,  old  ones  de-
crease.  All  of  this  means  that  it  should  be  possible  to  be  much  more  explicit  and  focused  about 
where ex situ management (along with all other conservation interventions) are most needed and can 

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have  the  biggest  impact.  Section  5.3.3  on  EQ11  discusses  the  scientific  and  technical  developments 
that help with this.  

5.3.3  Relevance – EQ 11 

How well adapted is the Directive to (subsequent) technical and scientific progress? 

The  previous  questions  evaluate  the  extent  to  which  the  Directive  remains  relevant  for  the  current 
needs of biodiversity and policy targets. At the same time, as noted in Section 2.1, zoos operate within 
a context that exists beyond the Directive and this context has also evolved over time. The understand-
ing of the needs of individual species, and therefore, the role that zoos may play in their conservation, 
has evolved significantly since the 1990s.  

This  evaluation  question  is  concerned  with  examining  the  scientific  and  technical  progress  that  has 
taken place since 1999 and considering the extent to which the Directive is valuable in light of these 
developments. This analysis has two steps: 

 

 

Firstly, an analysis of the adequacy of the Zoos Directive in view of the technical and scientific 
progress,  as  it  has  been  identified  through  scientific  literature  and  in  the  broader  perspective  of 
development of ex situ management.  
Secondly,  the  views  of  the  relevant  stakeholders  surveyed  for  this  study  provide  another 
understanding  of  the  contribution  of  the  Directive  from  the  perspective  of  the  professionals 
dealing with ex situ conservation.  

The  information  used  to  address  this  question  is  largely  drawn  from  the  questionnaire  survey  of 
MSCAs, zoos, zoos’ federations, NGOs and other stakeholders, together with a desk study of scientific 
and other (grey) literature. 

5.3.3.1  Adaptation of the Zoos Directive to technical and scientific progress  

The general societal context within which all species conservation efforts take place (including con-
servation-focused zoos) is well described by the literature (G. Mace 2014), which points to four phases 
in the human approach to nature conservation, reflecting the way that people see nature and their rela-
tionship with the environment.  

Figure 33: Timeline of approach to conservation 

Source: AAS - Permission from editor needed for publication 

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Conservation  programmes  and  policies  have,  therefore,  changed  to  reflect  this  increasingly  holistic 
view  of  human  engagement  with  species  and  with  wider  biodiversity.  This  does  not  always  make  it 
easy to see a role for species conservation and this has opened up a clear niche for zoos, as places 
where species can be celebrated, if they are exhibited appropriately.  

The prevailing approach of zoos to conservation in the years up to the adoption of the Directive was to 
create  an  ‘ark’,  where  many  species  would  be  maintained  in  captive  conditions  over  many  genera-
tions. The rationale for this was described eloquently by Michael Soulé and colleagues in their evoca-
tively titled and widely quoted paper ‘The Millennium Ark: How Long a Voyage, How Many State-
rooms, How Many Passengers?’ (Soulé, et al. 1986). It is important to note that, at that time, conserva-
tion biology was only beginning to emerge as a scientific discipline and, indeed, the Society for Con-
servation Biology only came into being in 1985 as ‘a response by professionals, mostly biological and 
social  scientists,  managers  and  administrators  of  the  biological  diversity  crisis  that  will  reach  a  cre-
scendo in the first half of the twenty-first century’ (Soulé, et al. 1986).  

The  premise  behind  the  article  was  that  the  human  population  was  increasing  at  such  a  rate  that  its 
need  would  see  a  ‘demographic  winter’  of  some  500-1,000  years  during  which  time  most  wildlife 
habitat in the tropics would be eliminated. This, they suggested, would mean that about 2,000 species 
of large, terrestrial animals would have to be bred in captivity if they were to be saved from extinction. 
The title of their paper reflected the three major considerations that they felt were crucial: 

  Number of species. 
  Number of individuals of each species.  
  Length of time for which viable populations could be sustained on the ‘voyage’.  

All  of  this  implied  that  zoos  had  to  work  together  in  order  to  ensure  that  captive  populations  were 
managed  cooperatively  so  that  overall  captive  population  targets  could  be  set  and  pursued.  As  de-
scribed in Section 2.1, significant efforts were made in this regard. Over the next 20 years or so, diffi-
culties with this approach became apparent and limitations emerged (e.g. (A. M.-W. Balmford 1996) 
(Snyder 1996), (Bowkett 2009), (Lees C & Wilcken 2009), (Williams 2009), (Bowkett 2014)). At the 
same time, there were more detailed considerations of where and how ex situ management could con-
tribute  to  species  conservation  (Conde,  Flesness,  et  al.  2011a),  (Fa,  et  al.  2014),  (Pritchard,  et  al. 
2011), (Redford, Jensen and Breheny 2012)).  

These developments can be categorised in a range of ways; here, they are considered under the three 
main  areas  where  understanding  of  conservation  needs  and  the  potential  of  ex  situ  management  to 
meet those needs (at least in part) has developed significantly since the Directive entered into force. 
They are described briefly in order to inform conclusions about how well adapted the Directive is to 
(subsequent) technical and scientific progress. 

a.  Population management 

There  is  now  a  strong  theoretical  and  analytical  basis  to  the  management  of  captive  populations.  In 
essence, these inform estimates of the size of populations that are required in order for species to min-
imise the loss of genetic heterozygosity and remain viable in the long-term, and how they should be 
managed (e.g. (Lacy, Ballou and Pollak 2012), (R. Lacy 2013), (Ivy 2016); see also (B. C. Traill LW 
2007), (B. B. Traill LW 2010)). As one publication points out (Lees C & Wilcken 2009), captive pop-
ulations often struggle to meet targets that would allow them to be considered sustainable over many 
generations. Reasons cited for this include the number of individuals in the founding population being 
too  small and  current breeding  rates too low. Ultimately, legislation  (such as restrictions on moving 
animals as part of managed breeding programmes), changing attitudes towards zoos, the differing pri-
orities of zoos, and the costs associated with maintaining large breeding problems all presented issues 
(Lees C & Wilcken 2009). 

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b.  Identifying species in need of conservation action 

Priorities for species conservation are often based on the IUCN red list275. This list is an assessment of 
the likelihood of a species to become extinct and is not, therefore, a prioritisation tool in its own right. 
As  many conservation  efforts are concerned with avoiding species extinctions, this is often taken  as 
the  basis  for  determining  species  conservation  priorities.  For  example,  the  CBD  (the  context  within 
which the Directive is framed), is now explicitly concerned with avoiding species extinctions through 
Aichi Target 12 (see Section 5.3.2 above). 

Although the process for establishing the revised IUCN categories and criteria was started before the 
Directive came into force (see (G. a. Mace 1991)), it was 10 years before the  categories and criteria 
currently in use were agreed (see (G. M.-T.-W.-G. Mace 2008)). This now provides a sound basis for 
assessing  which  species  are  most  threatened  with  extinction  and  thus  allows  comparison  between 
threatened species and those held in captivity. For example, (Conde, Flesness, et al., An emerging role 
of zoos to conserve biodiversity 2011a)) estimated that  15% of threatened species  are held  by zoos, 
although the sizes of these captive populations are often small (see above) and the total zoo capacity 
devoted  to  threatened  species  was  estimated  to  be  8%  in  2011  (  (Conde  DA  2011b);  see  also 
(Balmford, et al. 2011). This last point demonstrates that zoos determine their species mix for reasons 
other than conservation, such as for attracting visitors.  

c.  Action needed for threatened species 

The IUCN red list process requires documentation of the reason(s) for considering a species at risk of 
extinction.  Species  are  listed  as  threatened  on  the basis  of  the  rate  of  decline (of  population  or geo-
graphical range) or inherently small populations of geographical distributions, or some combination of 
these factors. The action needed to prevent extinction should, therefore, match the reasons causing the 
decline, or should consider the intrinsic vulnerability. 

In the majority of cases, the most appropriate action is likely to be in situ conservation, given that the 
widely-held aim of species conservation is to maintain species in the wild. In some cases, however, ex 
situ  management  may  be  necessary,  or  may  add  significantly  to  wider  conservation  efforts.  It  is  in-
creasingly important, therefore, that the role of the captive population in achieving the survival of the 
species is clearly identified ( (IUCN/SSC 2014); see also (McGowan, Traylor-Holzer and Leus 2016)). 
The IUCN/SSC guidelines propose a five-step process (see Box 14) for a strategic approach to consid-
ering whether ex situ management is appropriate as part of a species conservation strategy and, if so, 
what its role might be. Such roles are not restricted to the maintenance of large populations in a con-
ceptual ‘ark’, but could include, inter alia: temporary rescue, protecting against catastrophes or immi-
nent threats; demographic manipulation; or as a source for population restoration (McGowan, Traylor-
Holzer and Leus 2016).  

Box 14: Steps in assessing the relevance of ex situ management for conservation purposes 

The five-step decision-making process to decide when ex situ management is an appropriate conservation 
tool: 

STEP 1. Compile a status review of the species, including a threat analysis. 
STEP 2. Define the role(s) that ex situ management can play in the overall conservation of the species. 
STEP 3. Determine the characteristics and dimensions of the ex situ population needed to fulfil the identified 
conservation role(s). 
STEP 4. Define the resources and expertise needed for the ex situ management programme to meet its role(s) 
and appraise the feasibility and risks. 
STEP 5. Make a decision that is informed (i.e. uses the information gathered above) and transparent. 

Source: IUCN/SSC 2014 

275 http://www.iucnredlist.org/  

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Source: McGowan et al. (2016) Permission from editor needed for publication 

5.3.3.2  Broader perspective on development of ex situ management 

Zoos have evolved substantially since ‘modern zoos’ came into existence around 200 years ago (see 
Section  2.1.1).  During  the  1980s,  there  was  an  emerging  awareness  of  both  the  conditions  within 
which animals were housed and the scale of biodiversity loss. As a result, it was proposed that zoos 
could, and should, play a more significant role in conservation. This is reflected by, inter alia, Article 
9 of the CBD, the World Strategy for Conservation in Zoos and Aquaria 1993, and the Zoos Directive, 
all of which indicated that ex situ management had a role to play in overall biodiversity conservation, 
especially of species (see Section 2.1.2).  

Since the Directive came into force, understandings of the scale of biodiversity loss, the potential for 
ex  situ management to support  in situ conservation and, more importantly, how  ex situ management 
can contribute meaningfully to wider conservation objectives, have increased significantly. The criti-
cal development here is that it is increasingly recognised that zoos can be most effective in supporting 
in situ conservation if their activities are shaped by priorities arising in the wild, rather than from with-
in  zoos.  In  other  words,  they  are  demand-driven  (what  is  needed)  rather  than  determined  by  supply 
(what  zoos  feel  that  they  can  do).  Perhaps  most  importantly,  this  recognises  that  efforts  to  halt  the 
current  anthropogenically-driven  high  rate  of  species  extinctions  would  benefit  from  a  much  more 
strategic alignment of ex situ capability (e.g. through their financial resources, staff expertise, interac-
tion with the general public and animal populations) with clearly articulated  in situ biodiversity con-
servation needs.  

The Zoos Directive is framed as an EU response to the CBD and, at present, encompasses the 20 Aichi 
Targets that comprise the Convention’s 2011-2020 Strategic Plan for Biodiversity. A mid-term review 
of progress showed that while conservation responses are increasing, the pressures facing biodiversity 
are increasing at a greater rate (Tittensor et al. 2014) and the most recent CBD Conference of the Par-
ties (December 2016) revealed that progress towards Target 12 on halting species extinctions is espe-

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cially weak276. This suggests that there is a need for conservation responses to be more effective than 
they have been to date, if progress is to be made towards Target 12. Given the short time remaining 
until reporting is due (less than three years) and the long time it takes for conservation action to result 
in the improved status of species and/or wider biodiversity, it may be more realistic and timely to learn 
lessons now and put mechanisms in place so that substantial progress can be made on halting extinc-
tions and enhancing the conservation status of species post-2020, when the CBD Strategic Plan should 
surely  contain  a  similar  provision  for  reducing  species  extinctions  and  improving  the  conservation 
status of the most threatened species. 

Stronger integration of  ex situ management capacity into holistic species conservation strategies and 
plans is possible, and has considerable potential to improve the status of species. This is because: 

a)  Lessons are being learned about the capacity of zoos to contribute to conservation. For example, 
as  partly  described  in  Section  5.3.3,  there  is  now  recognition  of  the  significant  challenges  in 
managing viable populations of vertebrates in captivity over any meaningful timescale (e.g. Lees 
and Wilcken, 2009), and the role that zoos can play in species recovery is now understood to be 
much wider (e.g. IUCN SSC 2014 and McGowan et al. 2016). 

b)  There is an increasingly clear understanding of what is driving declines in individual species in 
the wild, the pressures causing those declines, and the constraints on tackling the pressures. This 
means  that  there  is  now  the  potential  for  zoo-based  activities  to  be  targeted  towards  problems 
where  their  work  has  the  greatest  prospect  of  reducing  a  problem  or  overcoming  a  constraint 
facing a species.   
It is increasingly understood that species conservation requires a strategic approach to addressing 
problems (both threats and constraints) so that scarce resources are used to best effect and the real 
problems  causing  the  decline  are  addressed.  IUCN’s  Species  Survival  Commission  published  a 
Handbook on developing species conservation strategies in 2008277, and a second edition of this 
guidance is being developed, with publication expected in 2017.  

c) 

All of this provides a context in which there is considerable scope for the contribution of zoos to  in 
situ species conservation to be increased considerably. What is needed is recognition that conservation 
actions must be targeted and informed by evidence. A collection of ‘conceptual approaches’ was gath-
ered by WAZA for its 14th newsletter in 2014 entitled Towards integrated species conservation278.  

Given the gloomy prospects for achieving CBD’s Aichi Target 12 by 2020, the urgent need is to con-
sider how to bring together the above strands quickly and effectively. This is vital if species conserva-
tion is to be in a stronger position at the end of the CBD’s 2011-2020 Strategic Plan for Biodiversity 
than it was at the beginning. This period coincides with the UN Decade on Biodiversity. 

Assessing exactly how this might be achieved at a spatial scale and on a timescale that would make a 
difference to global species extinction rates and the conservation status of a significant number of the 
most threatened species, requires significant leadership at a regional or global scale.  

5.3.3.3  Stakeholders’ perceptions of the level of adequacy of the Directive 

Stakeholders  surveyed  were  asked  the  extent  to  which  the  Directive  remains  relevant  in  the  light  of 
scientific and technical progress in: a) biodiversity conservation in general; and b) strengthening the 
links between in situ and ex situ conservation. 

276 Updated states of Aichi Biodiversity Target 12 UNEP/CBD/COP/13/INF/18, https://www.cbd.int/doc/meetings/cop/cop-
13/information/cop-13-inf-18-en.doc  
277 IUCN (2008). Strategic Planning for Species Conservation: A Handbook, 
http://cmsdata.iucn.org/downloads/scshandbook_2_12_08_compressed.pdf  
278 http://www.waza.org/files/webcontent/1.public_site/5.conservation/integrated_species_conservation/WAZA%20Magazine%2014.pdf  

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a.  Biodiversity conservation in general 

Figure 34: Number of stakeholders considering the protection of threatened species to be relevant 

Technical progress in the field of biodiversity conservation in general 

40

35

30

25

20

15

10

5

0

38 

15 

17 

5 

6 

3 

9 

1 

4 

2 

3 

MSCAs

Zoos

Federations/NGOs/Experts

To a large extent

To some extent

Not at all

No opinion

Source: Present survey of MSCAs, federations, NGOS and experts, and zoos 

Eleven of 15 (73%) of CAs considered the Directive to remain relevant to either some extent or a ma-
jor extent given  the technical and scientific progress that has taken place  in the field of biodiversity 
conservation since its adoption. The remaining four CAs offered no answer or opinion.  The Directive 
remains  well  adapted  to  at  least  some  extent  to  the  scientific  and  technical  progress  that  has  taken 
place in the field  of biodiversity, according to 76% of zoos. A  majority of zoos’ federations, NGOs 
and other stakeholders also considered the Directive still relevant in light of the progress in this field, 
with 81% of the respondents agreeing. 

b.  Strengthening the links between in situ and ex situ conservation 

Survey respondents provided nuanced views on the contribution of the Directive to strengthening the 
links between in situ and ex situ conservation, as illustrated in Figure 35 below.  

Figure 35: Stakeholder perceptions of technical progress in relation to strengthening links between in situ and ex situ 
conservation 

Technical progress in relation to strengthening links between in-situ 
and ex situ conservation 

50

45

40

35

30

25

20

15

10

5

0

43 

15 

6 

8 

3 

2 

2 

2 

5 

10 

4 

3 

To a large extent

To some extent

Not at all

No opinion

MSCAs

Zoos

Federations/NGOs/Experts

Source: Present survey of MSCAs, federations, NGOS and experts, and zoos 

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57% of MSCAs considered the Directive still relevant to either some extent or a major extent, given 
the technical and scientific progress that has taken place in relation to ex situ conservation and its links 
to in situ conservation. Three of the remaining seven felt that it was not at all well adapted. Views are 
much more uniform for zoos,  with 73% considering the Directive relevant to at least some extent to 
science and technical progress in integrating in situ and ex situ conservation. Similarly, a majority of 
zoos’ federations, NGOs  and other stakeholders  (66%)  also considered  the Directive to  remain  rele-
vant in light of the progress in this field.  

Interestingly, 18% of the federations, NGOs and experts felt that the Directive was not at all adapted 
to progress in strengthening links between in situ and ex situ conservation. This assessment was main-
ly done by NGOs, but also by one federation.  Comments offered by stakeholders in support of their 
assessments emphasises the view that there is now much more understanding of how to strengthen the 
link between in situ and ex situ conservation than is reflected in the Directive.  

Several zoos279 felt that the Directive could emphasise the link between ex situ management and in situ 
conservation  efforts  more  clearly.  They  said  that  much  had  happened  in  this  area  outside  of  the  Di-
rective, such as through the World Association of Zoos and Aquariums Strategy. Twelve zoos’ federa-
tions, NGOs and other stakeholders provided comments in their support of their opinions on ex situ-in 
situ management. The two issues that emerged from those comments were the desire to see a require-
ment for ex situ management to support in situ conservation (nine respondents) and for ex situ man-
agement  to  have  a  clearer  and  more  transparent  purpose  (four  respondents).  There  were  comments 
made by respondents to the effect that  the role of ex situ management would be enhanced if it were 
more targeted and better integrated with in situ conservation. In other words, respondents would wel-
come a more explicit requirement and greater guidance on how to pursue ex situ management, rather 
than simply saying it should be undertaken. 

5.3.3.4  Summary and conclusions 

There have been wide-ranging scientific and technical developments since 1999, and three  pertinent 
categories of relevant development were examined, i.e. population management, identification of spe-
cies in need  of conservation  action, and identifying the action needed for threatened species. Whilst 
the  second  of  these  may  appear  highly  relevant  for  identifying  species  that  require  conservation  re-
sources,  it  is  the  third  (understanding  the  action  required  by  a  threatened  species)  that  is  especially 
relevant here. This is because the processes outlined allow assessments to be made of whether or not 
ex situ management is an appropriate conservation action for a particular species, and if so, what form 
that management should take. Ways of encouraging such a strategic approach to assessing the role of 
ex  situ  management  (if  any)  in  the  overall  conservation  strategy  for  a  threatened  species  would  be 
well-received. Guidance (from IUCN’s Species Survival Commission) exists to support this decision-
making process.  

These findings are supported by the public consultation results. The majority of stakeholders consid-
ered  the  Directive  to  remain  appropriate  in  the  light  of  subsequent  technical  and  scientific  develop-
ments. There is a strong sense that it is well adapted, given the scientific and technical progress in the 
field of biodiversity generally. While there is a strong view that it is also well adapted given develop-
ments in strengthening  the interaction  between  in situ and  ex situ conservation,  it was observed  that 
that this could be greatly enhanced. Further comments pointed to the presence of such strengthening 
outside of the Directive, such as through WAZA.   

279 Zoos Questionnaire, Q.106. No statistical information is provided on this question, as the results of the survey cannot be considered 
representative. It was observed that several (at least 15) zoos provided identical answers, according to which ‘The EU Directive does not 
specifically mention/support/encourage the close cooperation between ex situ and in situ conservation strategies which have developed 
strongly over the last decade (see World Zoo and Aquarium Conservation Strategy, WAZA)’. 

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5.4  Coherence 

Evaluating the coherence of an EU act involves looking at the wider policy and legal framework, and 
placing the act alongside other interventions with similar objectives and requirements. In view of its 
objective  to  conserve  biodiversity  and  the  protection  of  wild  fauna  embodied  in  Article  3,  the  Zoos 
Directive fits within a wide net of laws and policies at EU and national level aimed at the conservation 
of biodiversity and animal welfare. In line with the Commission guidelines on evaluations, the coher-
ence analysis in this section aims to evaluate how well, or not, the different interventions work togeth-
er, by providing evidence of synergies and complementarities that could reinforce the achievement of 
common objectives, but also inconsistencies and overlapping obligations that could lead to inefficien-
cies280(EQ12, Section 5.4.1). The analysis also covers the impact of the Zoos Directive on the internal 
market and the creation of a level-playing field among zoos operators (EQ13, Section 5.4.2).  

For  the  purposes  of  the  coherence  analysis,  it  is  important  to  note  that  the  primary  objective  of  the 
Directive  is  the  conservation  of  biodiversity  through  establishing  a  conservation  role  of  zoos,  with 
animal  welfare  being  a  secondary  objective.  In  order  to  assess  the  coherence  of  the  Zoos  Directive 
with  the  wider  policy  and  legal  framework  on  biodiversity  conservation  and  animal  welfare,  an  im-
portant first exercise consisted of identifying and mapping the most relevant legislation, guidance and 
policy documents that share similar objectives or lay down similar requirements with those of the Di-
rective. The coherence analysis is primarily based on the legal examination of the strategic objectives 
and specific provisions of the targeted legislation, with a view to assessing their consistency with the 
Zoos Directive. It should be noted that there is no published literature or previous studies on this topic.   

During the targeted consultation, a number of stakeholders shared opinions and provided examples of 
complementarities and inconsistencies. The information gathered was of considerable use in targeting 
the analysis to specific legislation and provisions that merited closer examination, either due to their 
potential  for  synergies  or  because  they  allegedly  contained  overlapping  or  conflicting  requirements. 
The same applies to the responses to the public consultation, which sought to gather the opinions of 
the wider public on this question. However, given the legal nature of the coherence exercise, the issues 
raised  in  the  consultation  activities  were  followed  up  by  the  legal  team,  and  conclusions  are  drawn 
from  a  legal  analysis  of  interactions,  complementarities  and  inconsistencies  between  the  Zoos  Di-
rective and the targeted legal and policy documents. 

5.4.1  Coherence – EQ 12 

To what extent does the Zoos Directive complement or interact with other EU sectoral policies affect-
ing  biodiversity  conservation  and  relevant  animal  welfare  issues  at  Member  State  and  EU  levels,  in 
particular as regards wild animals kept in captivity for commercial reasons (notably circuses) and how 
do these policies affect, positively or negatively, the implementation of the Zoos Directive?   

The  legal  analysis  focuses  on  the  complementarities  and  interactions  with  EU  instruments,  and  then 
analyses the potential conflicting requirements with the EU framework.  

5.4.1.1  Complementarities and interactions 

This section aims to evaluate the extent to which the Zoos Directive complements or interacts with the 
legal  and  policy  framework  on  biodiversity  conservation  and  animal  welfare  at  the  EU  and  national 
level, pointing to synergies and positive interactions. As there is important EU environmental  acquis 
related to the protection of biodiversity, and long-established EU acts laying down health requirements 
for the trade, transport and accommodation of animals, with which Member States must comply, the 
analysis focuses on key legal instruments at the EU level.   

280 European Commission, Better Regulation: Guidelines on evaluation and Fitness Checks, available at: http://ec.europa.eu/smart-
regulation/guidelines/ug_chap6_en.htm 

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a.  Nature Directives 

Together with the Zoos Directive, the Nature Directives constitute the most important acts adopted by 
the EU to implement the Union’s obligations as a Contracting Party to the CBD. Their role in the im-
plementation  of  the  CBD  is  complementary:  while  the  Zoos  Directive  is  the  only  EU  instrument 
providing  for  ex  situ  conservation,  as  required  by  Article  9  of  the  CBD,  the  Nature  Directives  have 
established a comprehensive system for the protection of wild bird species and natural habitats occur-
ring in the Union that is aligned with the in situ conservation measures that Parties to the CBD need to 
adopt pursuant to Article 8 of the Convention.  

Overall, the legal analysis considers the Zoos Directive and the Nature Directives to be coherent and 
mutually supportive. In terms of strategic objectives, despite the differences in the scope and terminol-
ogy used, it is evident that they all aim  to protect and conserve species. To achieve ‘favourable con-
servation  status’,  the  Nature  Directives  require  Member  States  to  prohibit  the  capture,  keeping  and 
trade of species in need of strict protection. Article 16 of the Habitats Directive and Article 9 of the 
Birds  Directive  provide  for  exceptions  to  such  prohibitions  for  the  purposes  of  research,  education, 
repopulation and reintroduction of the species, and for breeding operations linked to those purposes. 
By  exceptionally  allowing  capture  and  keeping  for  these  specified  purposes,  the  Nature  Directives 
implicitly acknowledge the contribution that research, education and captive breeding activities could 
make to achieving favourable conservation status of European species. The derogation system under 
the Nature Directives is thus fully consistent with the conservation role of zoos (see Section  5.1.2 on 
the contribution of zoos to biodiversity).  

Article 3 of the Zoos Directive and Article 22(c) of the Habitats Directive require zoos and Member 
States, respectively, to promote education and public awareness on biodiversity conservation and the 
need to protect species of wild fauna281. The existence of requirements on the promotion of education 
in both Directives reinforces efforts towards the achievement of the first Aichi Target by the EU. With 
regard to synergies in the practical implementation of the two Directives, one MSCA indicated that the 
educational programmes of some zoos address Natura 2000 and use Natura 2000 educational materials 
prepared by the state’s Environment Office in their programmes282. 

Finally, there is a strong potential for synergies between the Zoos Directive and Article 22(a) of the 
Habitats  Directive.  Article  22(a)  calls  for  Member  States  to  study  the  desirability  of  reintroducing 
species that are native to their territory and listed in Annex IV as in need of strict protection, provided 
that an investigation indicates that reintroduction will effectively contribute to  recovering  those spe-
cies  to  favourite  conservation  status.  As  part  of  the  conservation  measures  required  under  the  Zoos 
Directive, zoos may opt to  engage in repopulation and reintroduction  activities. In fact, there is evi-
dence that some zoos are actively involved in native species breeding and reintroduction schemes in 
collaboration with other conservation organisations283. The funding opportunities available through the 
LIFE  Programme  can  further  enhance  biodiversity  conservation  through  reintroduction  programmes 
(see Section 5.1.2 for more information on the participation of zoos in LIFE funded projects).  

In view of the above, the legal analysis of the strategic objective of the three Directives, and the re-
quirements implemented to achieve those objectives demonstrate that there is coherence between the 
Zoos  Directive  and  the  Nature  Directives.  This  conclusion  is  further  supported  by  the  views  of  the 
stakeholders; of the 15 MSCAs who answered the relevant survey question, 11 considered the Direc-
tives  to  be  consistent  and  mutually  supportive,  with  the  remaining  four  indicating  that  they  did  not 
know the answer. Similarly, of the 23 NGO and zoos’ federations respondents, 15 considered the Di-
rectives to be consistent and mutually supportive, five responded that they did not know, two reported 

281 The education requirements in both Directives are coherent with the first Aichi Biodiversity Target, which provides that, by 2020, people 
must be aware of the value of biodiversity and of the actions that can be taken in order to conserve it.  
282 Interview with MSCA.  
283 The stakeholders consulted have given examples of reintroduction and repopulation programmes carried out by zoos in collaboration with 
Natura 2000 sites (reintroduction of the griffon, repopulation of the turtle emys orbicularis), while examples are also included in the EU Zoos 
Directive Good Practices Document.  

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inconsistencies, and one stated there were overlaps284, without providing further evidence or explana-
tion.   

b.  Regulation (EC) No 338/97 on the protection of species of wild fauna and flora by 

regulating trade therein (Wildlife Regulation) 

Council Regulation (EC) No 338/97 is the main EU act implementing CITES in the EU legal order. 
The  recitals  of  the  Zoos  Directive  make  reference  to  the  Regulation,  suggesting  that  there  is  a  link 
between the two legal instruments. The coherence analysis indicates coherence and synergies in their 
objectives and the requirements they contain.  

With regard to the objectives, both the Zoos Directive and the Wildlife Regulation (which pre-dates 
the Directive) aim to conserve biodiversity. To achieve this aim, the Regulation regulates trade in wild 
species of fauna and flora through a system of procedures and documents regulating imports, exports, 
re-exports, as well as intra-EU trade of the species listed in its annexes.  

Importantly, Article 8 of the Regulation prohibits the commercial trade of Annex A species. The ‘dis-
play  to  the  public  for  commercial  purposes’  clearly  figures  among  the  commercial  activities  men-
tioned in that provision. Pursuant to paragraph 4 of Article 8, derogations from the prohibition may be 
granted for research and education purposes aimed at the preservation and conservation of species, as 
well as for species intended for breeding that will build up conservation benefits for the species con-
cerned. Due to Article 3 of the Zoos Directive, which requires zoos to engage in research (expressly 
providing that  research  must  accrue conservation  benefits to the species), to promote education  and, 
where appropriate, captive breeding, repopulation or reintroduction of species into the wild, zoos can 
benefit from this derogation and display to the public those species included in Annex A of the Regu-
lation. The possibility for zoos to import and include in their collections animals that are in threat of 
extinction is fully coherent with their conservation role under the Directive. However, it was raised by 
NGOs that there may be a risk that zoos may argue their conservation role in order to obtain a deroga-
tion  from  the  prohibition  on  exporting  animals,  while  using  them  solely  for  entertainment  purposes. 
One NGO interviewed for this study stated that dolphins are listed in Annex A of Council Regulation 
No.(EC) 338/97, prohibiting the import of dolphins for commercial purposes, and yet dolphinariums 
are commercial facilities and no legislation exists to prevent further imports of wild-caught dolphins 
into the EU.  

In terms of synergies, the survey indicated that zoos record-keeping systems were often also used for 
permits, information exchange and transport certificates (in 45 out of 70 zoos surveyed), and for ani-
mal identification in line with the CITES Regulation (41 out of 70). To that extent, the fifth indent of 
Article  3  may  have  contributed  to  the  implementation  of  the  CITES  Regulation  (or  the  other  way 
around). 

To enhance such synergies, given that the implementation of the CITES and the EU Wildlife Regula-
tions entails inspections by CAs to ensure that animals are lawfully obtained, to control the validity of 
imports and the appropriateness of the facilities that accommodate the CITES species285, zoos hosting 
CITES species could benefit from the establishment of a single inspection system for zoos that would 
deal with all EU legislation applicable to them286.   

c.  Regulation (EC) No 1143/2014 on invasive alien species (IAS) 

The IAS Regulation is also part of the EU legal framework on biodiversity conservation, establishing 
rules  specifically  targeting  the  problem  of  IAS.  The  Regulation  has  close  links  with  the  Zoos  Di-

284 The interviews revealed that there is no clear understanding of the term ‘overlaps’, with some stakeholders interpreting it as having posi-
tive connotations.   
285 For the introduction into the Community of species listed in certain Annexes, Regulation 338/97 requires the applicant to provide docu-
mentary evidence that the intended accommodation for a live specimen at the place of destination is adequately equipped to conserve and 
care for it properly.  
286 This was one of the findings of a meeting organised by DG SANTE to present the findings of the audits carried out on approved bodies, 
institutes and centres (ABICs) under Directive 92/65/EEC.  

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rective. Firstly, the objective of both legal acts is conservation of biodiversity. Secondly, in addition to 
sharing a common objective, it may be argued that the two acts also contain similar requirements. The 
prevention  and  control  of  IAS  (which  is  extensively  regulated  under  the  IAS  Regulation)  is  also  an 
essential  requirement  under  the  Zoos  Directive.  Among  the  conservation  measures  that  zoos  must 
implement under the Directive is the prevention of the escape of animals  ‘in order to avoid possible 
ecological  threats  to  indigenous  species’.  This  suggests  that  even  prior  to  the  adoption  of  the  IAS 
Regulation, the Directive recognised the need to take measures to prevent the spread of invasive spe-
cies in view of the detrimental impact such spread may have on local biodiversity.   

However, the two acts have important differences in their scope of application that ought to be high-
lighted.  The  Zoos  Directive  is  a  sector-specific  instrument  aiming  to  establish  some  minimum  re-
quirements for zoos across the EU. The IAS Regulation, on the other hand, was designed as an over-
arching  act  to  comprehensively  tackle  the  problem  of  IAS,  without  targeting  any  particular  sector. 
Zoos, pet shops, pet owners and laboratories for instance, are all affected by the Regulation insofar as 
they keep or breed IAS. With regard to zoos, it should be further noted that, in practice, the 37 species 
listed as being of ‘Union concern’ under the Regulation include species that are in small minorities in 
the population of zoos287. Article 7 of the IAS Regulation essentially requires a ban in the keeping and 
breeding  of  IAS  of  Union  concern.  This  prohibition  applies  to  zoos  which  display  and  breed  those 
species and zoos will thus  have to gradually phase out  these listed species. For now, the Regulation 
allows them to keep the animals already in their collection until the end of their life, provided that they 
take steps to prevent escape and reproduction.  

Article 8 of the IAS Regulation then provides for derogations from the restrictions established under 
Article 7, enabling Member States to establish a permit system that will allow establishments to carry 
out research or ex situ conservation activities related to IAS of Union concern. Even though zoos un-
dertaking such activities could, in principle, benefit from the exemption under Article 8, the issuing of 
permits is subject to the cumulative fulfilment of strict conditions (listed in the second and third para-
graphs of Article 8), which include the physical isolation of the specimens, a continuous surveillance 
system, the design of a contingency plan covering possible escapes, and the existence and implementa-
tion of cleaning, waste handling and maintenance protocols to ensure that species cannot escape or  be 
removed by unauthorised persons. There is no evidence on the numbers of zoos that have obtained a 
permit allowing them to include IAS in their collections since the adoption of the IAS Regulation.  

During the targeted consultation, some stakeholders  argued that there are problems of coherence be-
tween the Zoos Directive and the IAS Regulation. In particular, stakeholders pointed to the fact that 
measures to  prevent escapes and the  spread  of  IAS  are already required  of  zoos under the Zoos Di-
rective.  Applying  the  provisions  of  the  Regulation  to  zoos,  in  particular  the  prohibition  to  keep  and 
breed IAS, could negatively impact the diversity of zoo collections. Stakeholders stated that this could 
also compromise the conservation, research and education objectives enshrined in the Zoos Directive, 
as some IAS are of conservation interest. Further, given their educational role, zoos could play an im-
portant role in addressing the risks from IAS invasions by raising public awareness of the issue. The 
public consultation also revealed that a greater number of respondents considered there to be a coher-
ence problem in respect of the two acts than the number observing consistency between them.  

From a legal perspective, there is no incoherence between the Zoos Directive and the IAS Regulation. 
The Regulation is the lex specialis on the IAS issue, establishing a comprehensive system of measures 
to address the negative impact of IAS on biodiversity. Biodiversity conservation, which is the over-
arching objective of both acts, must prevail over secondary objectives such as the promotion of educa-
tion and awareness of the IAS problem. The ban on keeping and breeding IAS does not annihilate the 
educational role of zoos, who may still raise awareness of the IAS problem through other means, such 
as displaying European native species that are invasive in other areas of the world. 

287 Interview with EU stakeholder.  

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By providing for an exception to the ban on keeping and breeding IAS for institutions carrying out ex 
situ conservation or research, from which zoos could benefit, the Regulation sufficiently acknowledg-
es the importance that these activities could play on biodiversity conservation. Zoos may benefit from 
this exception for listed IAS that are of conservation interest288. The fact that the derogations are sub-
ject to strict conditions, aimed at limiting the danger of escapes and IAS spread, does not hinder but 
rather reinforces the conservation objectives of the two acts. Among the issues raised in the Born Free 
2011  Zoo  Inquiry  (Born  Free,  2012)  was  the  fact  that  enclosure  fencing  in  zoos  was  frequently  ob-
served  to  be  in  a  poor  state,  such  that  it  could  permit  the  escape  of  non-indigenous  species  into  the 
natural  environment289.  Even  though  it  acknowledged  that  zoos  are  not  the  main  pathways  for  IAS, 
there  is  evidence  that  they  can  be  pathways  in  certain  circumstances,  which  justifies  taking  a  strict 
approach. There is thus full coherence between the overarching objectives of the Zoos Directive and 
the IAS Regulation, as well as potential for synergies. Zoos may play an important role in the imple-
mentation of the IAS Regulation, under the IAS management measures that Member States must have 
in place under Article 19 of the Regulation. As part of their strategy to prevent and mitigate the impact 
of invasive species, Member States may provide for zoos to take captured species and keep them in 
their collections until the end of their life, provided that reproduction and escape are prevented. In this 
way, zoos may contribute significantly in the management of those species while also benefiting from 
the opportunity to display them and educate the public.  

d.  Directive 92/65/EEC laying down animal health requirements for trade in and imports 
into the EU of animals, semen, ova and embryos not subject to other specific rules 
The coherence of the Zoos Directive with Council Directive 92/65/EEC290 has also formed part of this 
study, given the relevance of the latter for zoos. Directive 92/65/EEC is not part of the EU environ-
mental acquis on biodiversity but is, rather, an act adopted under Article 43 of the EEC Treaty giving 
the competence to the then Communities to adopt legislation for the implementation of the Common 
Agricultural Policy (CAP). The Directive lays down detailed animal health requirements for the trade 
in animals, semen, ova and embryos in the EU, including import rules, with a view to ensuring that 
intra-EU trade will not be prohibited or restricted by Member States for animal health reasons other 
than those arising from the requirements of Union legislation. As it concerns trade in all animals for 
which  no  health  requirements  are  provided  under  other,  more  specific  EU  legislation,  trade  in  zoo 
animals falls within its scope of application. Despite the absence of a biodiversity conservation objec-
tive, it is considered that by establishing detailed animal health rules that include quarantine and test-
ing requirements, Directive 92/65/EEC results in a higher level of biosecurity, which in its turn con-
tributes to biodiversity conservation and thus supports the objectives of the Zoos Directive.  

While,  in  general,  intra-EU  trade  of  animals  under  Directive  92/65/EEC  requires  a  health  certificate 
issued by the CA, the Directive establishes a special regime for ‘approved bodies, institutes or centres’ 
(ABICs),  defined  as  establishments  approved  in  accordance  with  Article  13  of  the  Directive,  where 
animal species are kept or bred for one or more of the following purposes: display of animals and edu-
cation of the public, conservation of the species, or basic or applied scientific research or breeding of 
animals for the purposes of such research. Given that Article 3 of the Zoos Directive requires zoos to 
undertake at least one of the abovementioned activities, zoos can be approved as ABICs if they com-
ply  with  the  ABICs  approval  and  supervision  conditions  listed  in  Annex  C  to  Directive  92/65/EEC. 
The  benefit  of  ABIC  approval  is  that  ABICs  can  then  exchange  animals  amongst  themselves  more 
easily.  

The approval conditions for ABICs in Annex C to Directive 92/65/EEC contain requirements that are 
similar to those imposed on zoo operators under the Zoos Directive. In particular, Annex C requires 
ABICs  to  have  quarantine  facilities  and  to  legally  secure  the  services  of  a  veterinarian  who  will  be 
responsible  for  ensuring  that  vaccination  against  infectious  diseases  takes  place  and  that  an  annual 
disease surveillance plan is applied in the approved institution. This is consistent with Article 3, third 

288 None of the species listed in the IAS list as being of Union concern are listed as endangered species under the IUCN list.  
289 Born Free 2011 Zoo Inquiry (Born Free, 2012), p. 40.  
290 The Directive is often informally referred to as ‘the Balai’ Directive.  

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indent, of the Zoos Directive, which refers to the maintenance of ‘a high standard of animal husbandry 
with a developed programme of preventative and curative veterinary care and nutrition’. The Commis-
sion Good Practices Document indicates that veterinary care in zoos should involve curative care, but 
also the development and execution of preventative health programmes that include health monitoring, 
parasite  control  and  vaccination,  quarantine  procedures  and  biosecurity  measures  (European 
Commission  2015,  p.45-47).  This  resembles  the  measures  imposed  on  ABICs  under  Directive 
92/65/EEC.    

Both Directives require the keeping of up-to-date animal records. While the Zoos Directive does not 
indicate  what  such  records  should  include,  Annex  C  to  Directive  92/65/EEC  details  the  information 
that must be registered. The Zoos Directive Good Practices Document provides some guidance on the 
content of the records, comparable to Annex C to Directive 92/65/EEC. Finally, the requirement under 
the Zoos Directive to take measures to prevent the escape of animals in order to avoid the spread of 
IAS and the intrusion of outside pests and vermin could be viewed as similar to the obligation imposed 
on ABICs to separate animal surroundings or maintain the animals confined and located in a manner 
so as not to pose risks to agricultural holdings.  

For  the  licensing  and  inspections  regime,  Directive  92/65/EEC  contains  more  detailed  requirements 
than  Article  4  of  the  Zoos  Directive.  The  frequency  of  inspections  is  regulated  in  Directive 
92/65/EEC.  In  addition,  Annex  C  Point  2  to  Directive  92/65/EEC  requires  that  in  order  to  maintain 
approval  as  an  ABIC,  an  official  veterinarian  from  the  CA  shall  visit  the  premises  of  the  ABICs  at 
least once per year, to audit the activities of the ABICs veterinarian and  to ensure that the Directive 
provisions are met.  

In practical terms, the combined effect of the Zoos Directive and Directive 92/65/EEC is that zoos that 
are listed as ABICs are inspected more often than other zoos. Stakeholders reported that the existence 
of two inspection procedures for ABIC zoos could lead to confusion and duplication of the administra-
tive  work  needed,  both  from  the  zoos  themselves  and  the  CAs  responsible  for  the  inspections.  For 
instance, audits performed by DG SANTE in Hungary to evaluate the animal health control system in 
place for ABICs, revealed that the authorities considered their obligations under Directive 92/65/EEC 
to be met through the decree implementing the Zoos Directive. The latter requires the licensing author-
ity to check the operation of a zoo once every five years, despite the fact that point 2(a)(i) of Annex C 
to the Directive 92/65/EEC requires that an inspection is carried out by an official veterinarian at least 
once a year291. A similar audit performed in Spain indicated that the authorities in charge of licensing 
and inspecting  zoos  are different to those  carrying  out approval  and inspections of ABICs,  with un-
clear respective responsibilities for the approval of such establishments. As this could lead to ineffi-
ciencies and duplication in the work of CAs and zoos, synergies between the different inspection pro-
cedures should be further exploited. Box 15 shows examples of Member States where a common in-
spection system is in place.   

Box 15: Common inspection systems 

Zoos must comply with a series of obligations, stemming from different international, EU and na-
tional laws. These include the Zoos Directive and their national transposing legislation, but also the 
CITES and EU Wildlife Regulation, Directive 92/65/EEC laying down animal health requirements, 
legislation on animal by-products etc. 
Some  Member  States  already  implement  joint  inspections  to  verify  compliance  of  zoos  with  the 
abovementioned pieces of legislation.  

  Danish  CAs  authorities  organise  common  inspections  to  check  compliance  of  zoos  with 
their obligations under the Zoos Directive, Directive 92/65/EEC and legislation on animal 
by-products.  
In Belgium, Lithuania, France and Portugal, there is a common inspection to ensure com-
pliance with the Zoos Directive and Directive 92/65/EEC. 

 

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 

In  Sweden,  authorities  cover  jointly  the  enforcement  of  the  Zoos  Directive,  the  Wildlife 
Trade Regulation and animal welfare legislation. 

  Spain has also made some efforts towards the implementation of a system of joint inspec-
tions. A coordination meeting of the national committee for identification and registration 
of ABICs agreed on a means of registering zoos approved as ABICs, while a regional ABIC 
CA  identified  possible  synergies  with  other  official  controls  to  which  ABICs,  including 
zoos, are subject. The regional ABIC CA plans to increase its coordination with other CAs, 
such as those responsible for animal welfare or environmental matters292. 

The organisation of common inspections can be beneficial both for zoos and CAs. Each time there 
is an inspection, zoos need to devote time and resources to gathering the necessary documentation 
in order to demonstrate compliance with the applicable legislation. The same applies for CAs, who 
also need time and resources to carry out the inspections and assess compliance. Common inspec-
tion procedures can be more efficient and prevent duplication in the work of zoos and CAs.  

The analysis reveals that despite the differences in their objectives and scope, the two Directives are 
generally  consistent  in  the  requirements  they  impose  on  zoos.  There  is  also  the  potential  for  further 
synergies to be exploited in order to render the inspections system more effective. Overall, it can be 
concluded that the detailed health rules and biosecurity rules in Directive 92/65/EEC are coherent with 
the Zoos Directive, as hey directly contribute to zoos fulfilling their obligations in respect of Article 3 
requirements to maintain high standards of animal husbandry, with developed programmes of veteri-
nary care, while indirectly supporting its conservation objectives through the elevated health and bi-
osecurity standards. 

5.4.1.2  Conflicting requirements 

The legal analysis revealed no coherence problems between the Zoos Directive and other EU legisla-
tion,  with  the  exception  of  some  theoretical  inconsistencies  with  Commission  Regulation  (EC)  No 
1739/2005  laying  down  animal  health  requirements  for  the  movement  of  circus  animals  between 
Member States. It could be argued – and it was indeed perceived by some stakeholders – that the ab-
sence of a conservation objective in the Circus Regulation could compromise achievement of the con-
servation objectives of the Zoos Directive and other conservation-oriented legislation. 

Article 2 of the Zoos Directive defines zoos for the purposes of the Directive, and circuses are explicit-
ly excluded from the scope of application. While circuses need to comply with the EU Wildlife Regu-
lations, there is no comprehensive EU legislation aimed at regulating the activities of circuses or the 
welfare of circus animals, other than Commission Regulation 1739/2005.  

The Circus Regulation was based on Article 23 of Directive 92/65/EEC, which empowered the Com-
mission  to  adopt  special  requirements  for  the  movement  of  circus  animals.  Similarly  to  Directive 
92/65/EEC,  the  Circus  Regulation  is  not  part  of  the  environmental  legislation  aimed  at  biodiversity 
conservation but, rather, aims to lay down animal health rules that will facilitate the intra-EU move-
ment of those animals. To this end, it requires the registration of circuses with the CA of the Member 
State where the circus has its legal residence, or where it is situated, and foresees checks to be carried 
out by the CA in order to control compliance with the animal health rules established in the Regula-
tion. Before the movement of a circus to another Member State, an official veterinarian in the Member 
State of departure is required to verify the accuracy of the animal passports and of the circus register, 
as well as being obliged to inspect all animals to ensure that they are clinically healthy. The obligation 
to ensure the ‘clinical health’ of the circus animals certainly does not go as far as the obligations im-
posed on zoo operators under the Zoos Directive, i.e. to accommodate their animals under conditions 
that satisfy the biological and conservation needs of the individual species, to provide species specific 
enrichment  of  the  enclosures,  and  to  maintain  a  high  standard  of  animal  husbandry.  Thus,  it  can  be 
argued that there is some inconsistency in the level of animal welfare requirements imposed on zoos 

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on the one hand, and circus operators on the other.  

From  a  legal  perspective  however,  given  the  clear  exclusion  of  circuses  from  the  scope  of  the  Zoos 
Directive, there is no interaction between the Directive and Regulation 1739/2005. Due to the different 
scopes of application and different objectives of the two acts, no coherence issues should be noted.    

Opinion of the wider public 

Even  though  the  coherence  analysis  is  mainly  a  legal  exercise,  responses  to  the  public  consultation 
provided a useful overview of public perceptions of the coherence and interactions between the Zoos 
Directive and other legal acts and policy documents. With regard to the public consultation, it should 
first be noted that the ratio of respondents who did not have an opinion on this matter was particularly 
high. This is understandable, as assessing coherence requires a familiarity with the targeted legal in-
struments and a certain level of technical and legal knowledge.  

Of those members of the public who expressed an opinion on the coherence questions, their responses 
showed some trends. The public considers there to be consistency and positive interaction between the 
Zoos  Directive  and  the  Nature  Directives,  Directive  92/65/EEC  laying  down  animal  health  require-
ments, and policy documents developed by EAZA and WAZA, such as the European Code of Conduct 
on zoological gardens and aquaria, and invasive alien species, and the WAZA conservation strategies.  

On  the  other  hand,  for  certain  instruments,  a  great  number  of  respondents  stated  that  there  are  gaps 
than those that noted  consistency. This is  clearest for the IAS Regulation, which  was  highlighted  as 
lacking consistency (gaps) by all types of stakeholders (mostly by zoo operators and businesses, but 
also public authorities and individuals). Regulation 1739/2005 on the movement of circus animals was 
also  mentioned,  mainly  by  NGOs  and  individuals,  as  not  being  coherent  with  the  Zoos  Directive. 
However, in view of the differences in scope between these instruments and the Directive, from a legal 
perspective they are not inconsistent.  

5.4.1.3  Summary and conclusions 

The Zoos Directive is coherent with the targeted legislation and is an important part of the EU frame-
work on biodiversity conservation.  The legal analysis of the Zoos Directive and the legal acts exam-
ined under this section indicates that their objectives and requirements are similar. There are several 
interactions between the Zoos Directive, the Nature Directives, the EU Wildlife Regulations, the IAS 
Regulation and Directive 92/65/EEC that could reinforce the achievement of the biodiversity conser-
vation objective embodied in most of these legal instruments. There is also potential for further syner-
gies, e.g.  between the Zoos Directive  and the Nature Directive  in  the development  of reintroduction 
programmes  for  native  species  and  the  design  of  educational  programmes.  Similarly,  synergies  be-
tween  the  different  inspection  procedures  to  check  the  compliance  of  zoos  with  the  EU  legislation 
applicable  to  them  (Zoos  Directive,  CITES  Regulation,  Directive  92/65/EEC,  Regulations  covering 
transport) should be considered  by the Member States when implementing  the relevant laws, as this 
would reduce administrative burden for zoos and CAs.  
The  findings  of  the  stakeholder  consultation  support  the  conclusions  of  the  legal  analysis,  with  the 
majority of respondents considering the Directive to be consistent and mutually supportive of the tar-
geted acts. Even though some stakeholders and responses to the public consultation pointed to incon-
sistencies between the Zoos Directive and both the IAS Regulation and Commission Regulation No. 
1739/2005 on the movement of circus animals, the legal analysis found no coherence issues.  

5.4.2  Coherence – EQ 13 

To what extent does the Directive support the EU internal market and the creation of a level playing 
field for economic operators, especially SMEs?  

The evaluation of coherence also seeks to examine the extent to which the Directive has supported the 
EU  internal market  and  the  creation  of  a  level  playing  field  for zoos  across  the  EU.  Answering  this 

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question requires an analysis of the following: 

  Legal basis of the Directive.  
  Common requirements it established for zoos across the EU.   
 

Practical implementation and enforcement of the Directive in the different Member States. 

Stakeholder opinions provided during the targeted consultation, on the benefits of the Directive insofar 
as it has established a common legal framework in the EU, are also taken into consideration.  

5.4.2.1  Applicable legal framework and implementation 

This section assesses the coherence between the Zoos Directive and the underlying principles of the 
EU internal market. The internal market is defined in the Treaty on the Functioning of the EU as an 
area without frontiers, in which the free movement of goods, persons, services and capital is ensured. 
This entails the elimination of trade barriers between Member States, inter alia through the adoption 
of  EU  legislation  establishing  harmonised,  common  rules  that  provide  a  clear  and  predictable  legal 
framework for business. In addition to clarity and legal certainty, the rules create a level playing field 
throughout  the  internal  market  for  economic  operators  by  applying  equally  to  all  competitors  in  the 
internal  market.  In  view  of  their  size  and  limited  resources,  it  is  harder  for  SMEs  to  respond  to  the 
costs of regulation, and it is important that the design of harmonised rules consider the differences in 
costs and benefits of regulation for companies of different sizes.  

The Zoos Directive is not among the EU acts creating internal market harmonisation. Trade and intra-
EU movement of animals is covered by different legislation to complete the internal market. However, 
the legal basis for the adoption of the Zoos Directive was Article 130s of the Treaty establishing the 
European Communities, providing for the competence of the then European Community to adopt non-
market related measures for preserving, protecting and improving the quality of the environment. The 
adoption of environmental regulations often imposes some regulatory burden on economic operators, 
and this is acceptable in view to the need to protect the environment. Even though zoos are economic 
operators  that  may  generate  significant  income  from  the  visits  of the  public,  and  trade  in  animals  is 
regulated under a series of EU acts adopted with the aim to complete the internal market, for the pur-
poses of the coherence analysis, the environmental legal basis of the Zoos Directive, its biodiversity 
conservation aim and the absence of an internal market harmonisation objective, must be emphasised.  

The Directive ensures that zoos across the EU are subject to certain harmonised requirements, includ-
ing the obligation to adopt the conservation measures of Article 3, to hold a licence and to be subject 
to inspections by the MSCAs. Prior to the adoption of the Zoos Directive, legislation regulating zoos 
existed in only some Member States thus, by establishing minimum requirements with which all zoos 
across the EU should comply, the Directive has contributed positively towards achieving a level play-
ing field for zoos.  

The establishment of a level playing field requires uniform implementation of EU legislation by the 
Member States. The implementation of the Zoos Directive shows that, in practice, there are discrepan-
cies in the level of obligations imposed on zoos across Member States. The  lack of details of the re-
quirements set by the Directive has given Member States a significant margin of discretion at the im-
plementation  stage.  This  has  resulted  in  a  situation  where  Member  States  have  adopted  legislation 
which varies significantly in terms of the obligations with which zoos must comply. The EU Zoo In-
quiry, which investigated the implementation and enforcement of the Directive in all Member States, 
concluded that ‘implementation of the Directive’s requirements is inconsistent across the EU and en-
forcement is largely lacking in the majority of EU Member States’ (Born Free 2012, p.12) (see Section 
5.1.3 for a detailed analysis of the implementation of the Directive).   

In view of the differences in implementation and enforcement of the Directive, the legal analysis indi-
cates that a level playing field has not yet been achieved for zoos. This conclusion is supported by the 
results  of  the  targeted  consultation,  as  well  as  the  views  of  zoo  operators  on  the  benefits  stemming 

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from  the  Directive  establishing  a  common,  EU-wide  legal  framework  and  a  level  playing  field  be-
tween  zoos  in  different  Member  States:  39%  of  the  respondent  zoos  reported  that  the  Directive 
brought no benefit or only minor benefits in this regard; 26% believed the benefits to be moderate; and 
only 8% considered the benefits major (the remaining 27% expressed no opinion/ did not give an an-
swer). Responses to the public consultation, however, suggested that the public had a different view. 
When  answering  the  relevant  question,  63%  of  the  respondents  considered  the  Directive  to  have 
brought  significant  or  crucial  benefits  in  ensuring  a  coherent  legal  framework  for  zoos  operating 
across the EU.  

In  addition  to  the  legal  framework,  the  similarities  or  differences  in  the  costs  borne  by  zoos  across 
Member States, as well as for zoos of different sizes, are important indicators in assessing the exist-
ence  or  absence  of  a  level  playing  field  in  the  EU.  From  the  results  of  the  targeted  consultation,  no 
evidence can be drawn as to the extent of differentiation among Member States in terms of costs and 
benefits faced by zoos.  

As to the economic impact of the Zoos Directive on zoos of different sizes, the results of the analysis 
suggest  that,  overall,  costs  are  not  thought  to  be  disproportionate  (Section  5.2.1).  However,  smaller 
zoos appear more likely to consider costs disproportionate. Similarly, the majority of the CAs (64%) 
considered it more difficult for small zoos to bear the costs of implementing Article 3 requirements. 
While the opinions of stakeholders could suggest a difference between small and large zoos in terms 
of  costs  and  benefits,  in  the  absence  of  detailed  information  no  conclusions  can  be  drawn  as  to  the 
contribution of the Directive to the creation of a level playing field for zoos that fall into the category 
of SMEs.  

5.4.2.2  Summary and conclusions 

The  information  gathered  indicates  that  the  Zoos  Directive  has  made  a  positive  contribution  to  the 
establishment of a level playing field for zoos across the EU. Prior to its adoption, there was no regula-
tion for zoos in some Member States, yet all zoos must now comply with the minimum requirements 
imposed by the Directive, such as the obligation to hold a licence and to implement the conservation 
measures listed in Article 3. However, the Directive’s requirements have not been implemented in a 
harmonised manner. Due to the framework nature of its requirements, there are significant discrepan-
cies in the obligations imposed on zoos, as well as in the enforcement of the Directive in the different 
Member States. This suggests that a true level playing field has not yet been achieved for European 
zoos.  

5.5  EU Added Value 

In line with the Better Regulation Guidelines, EU Added Value looks at the changes which can rea-
sonably be attributed to the EU intervention rather than any other factors (i.e. results of interventions 
initiated at regional or national levels by public authorities and the private sector).  

In assessing the EU Added Value of the Zoos Directive, there is a substantial lack of data on the base-
line and the changes produced (i.e. conservation measures implemented by zoos before and after the 
entering into force of the Zoos Directive), while estimating the effects of conservation measures pro-
moted by zoos on biodiversity is a complex task, one which has generated debate in literature and is 
outside the scope of this supporting study.  

In this context, the EU Added Value  analysis examines, from a qualitative perspective,  the extent to 
which the Zoos Directive has contributed to strengthening the role of zoos and promoting the adoption 
of conservation measures in a way that could not be achieved by Member States and other stakehold-
ers, and whether there is a need for continued EU action.  

More specifically, the following aspects are explored: 

  Which  results  can  be  attributed  to  the  Zoos  Directive  and  would  not  have  been  achieved 

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otherwise (Evaluation Question 14)? 

  Have Member States gone beyond the provisions of the Zoos Directive, and which is the level of 

harmonisation achieved (Evaluation Question 15)? 

  What  would  be  achieved  in  the  absence  of  the  Zoos  Directive,  given  the  developments  at  both 
national and international level (including actions promoted by private stakeholders) (Evaluation 
Question 16)?  

The analysis combines different sources, including the opinions expressed by stakeholders, and draws 
on  illustrative  cases  in  order  to  reflect  transformational  changes,  which  almost  certainly  would  not 
have happened without the Zoos Directive293. 

5.5.1  EU Added Value – EQ 14 

What  has  been  the  EU  added  value  of  the  Zoos  Directive  compared  to  what  could  be  achieved  by 
Member States at national and/or regional levels? 

This question focuses on the added value of the EU Zoos Directive compared to actions at internation-
al, national or regional levels. It firstly examines how and to what extent the Zoos Directive played a 
role in creating a legal framework regulating zoos and promoting the shift of all zoos towards biodi-
versity conservation. Secondly, it analyses how the Zoos Directive has contributed to the strengthened 
role  of  zoos  in  biodiversity  conservation,  compared  to  other  factors  (memberships  of  zoos’  associa-
tions  with  stringent  standards,  evolution  of  the  attitude  of  the  public,  and  individual  ambitions  of 
zoos).  

The  information  used  to  address  this  question  comes  from  desk  research,  including  the  legislative 
frameworks  existing  before  the  adoption  of  the  Zoos  Directive,  infringement  cases  launched  by  the 
European Commission against Member States, information gathered through the targeted surveys and 
opinions expressed through the public consultation.  

5.5.1.1  Role of the Zoos Directive in prompting the adoption of national legislation 

and establishing common minimum requirements across the EU 

The evolution of the role of zoos towards conservation-oriented entities started before the adoption of 
the Zoos Directive, as illustrated in the 1993 World Zoo Conservation Strategy (IUCN/CBSG 1993). 
Before  the  entering  into  force  of  the  Directive,  zoos’  organisations  also  required  their  members  to 
participate  in  activities  and  engage  in  conservation  measures  beyond  the  mere  display  of  animals, 
through standards such as the EAZA Research Standards, Education Standards, Conservation Stand-
ards (also referenced in the preamble of the Zoos Directive).  

Yet, in the majority of Member States examined under this study, no legal requirements addressed all 
aspects covered by the Directive, prior to adoption of the Directive. 

As  highlighted  in  Section  2.1.2.3,  only  four  of  the  14  selected  Member  States  (Belgium,  Denmark, 
France and Spain294) had some legislation  on the licensing of zoos before the entry into force of the 
Directive in 1999 (European Parliament 1993). The table below presents the legislation that applied in 
those countries at that time. 

293 A suggestion at the inception stage of the study was to assess differences in the results achieved in relation to the stage and/or quality of 
implementation in the different Member States (e.g. by comparing the results achieved in newer vs. older Member States, or in Member 
States considered to exhibit best practice vs. those with poor practices). However, the evidence collected suggests that such an approach 
would not produce meaningful results. Indeed, it has been not possible to find clear links between the implementation of the Directive in the 
Member States and the features of the national licensing and inspection systems on the one hand, and the results in terms of effective imple-
mentation of conservation measures by zoos on the other hand.  
294 Regarding the other countries that were members of the EU at the time of the adoption of the Directive, the UK also had legislation prior 
to the adoption of the Directive. The 1981 Zoo Licensing Act established a comprehensive licensing and inspection system for zoos. The 
government produced a list of authorised inspectors and detailed guidelines for the accommodation and care of animals in zoos. This legisla-
tion was considered one of the models on the basis of which the Zoos Directive was drafted. 

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Table 33: Legislation prior to the adoption of the Zoos Directive 

Country 
Belgium 

Legislation 
Royal  Order  of  14  August  1986  on  the  pro-
tection and well-being of animals 
Royal  Order  of  10  August  1998  on  the  li-
censing of zoological gardens 

Denmark  Act on Animal Welfare (1967) 

Act  on  State  subsidies  to  zoological  gar-
dens (1977, amended in 1980, 1983, 1985) 

France 

Spain296 

Law  of  10  July  1976  on  the  protection  of 
nature 
Amended  Ministerial  Order  of  25  October 
1995  on  the  implementation  of  the  control 
of  establishments  holding  non-domestic 
animal species 
Ministerial  Order  of  21  November  1997  de-
fining  two  categories  of  establishments 
than  establishments  practicing 
other 
breeding, sale and transit of game species 
for  which  hunting  is  allowed,  holding  non-
domestic animal species 
Decree  of  24  April  1975  and  Order  of  28 
July 1980 

Source: (European Parliament 1993). 

legislation  required 

Main provisions 
Belgian 
licences  for 
zoos,  animal  parks  and  private  collections. 
It  outlined  conditions  for  the  accommoda-
tion  of  wild  animals.  By  the  adoption  of  a 
Royal  Order  of  1998,  the  framework  was 
revised  in  1998  to  follow  the  proposal  and 
content of the Zoos Directive295 
Danish  legislation  required  zoos  to  hold 
authorisations issued by the police authority 
on  the  basis  of  information  (submitted  by 
the  applicant)  on  the  conditions  of  animal 
accommodations and inspections 
Zoos are regulated under the general legis-
lation  on  nature  protection,  complement-
ed  by  regulations  on  the  conditions  for 
keeping  wild  animals,  the  licensing  system 
and inspection of zoos 

Zoological  collections  must  be  authorised 
and registered by the Provinces 

The  legislation  existing  in  those  Member  States  prior  to  the  adoption  of  the  Directive  contained  at 
most:  (i)  requirements  for  licensing;  (ii)  requirements  for  inspection;  (iii)  conditions  for  animal  ac-
commodation; (iv) requirements for animal welfare. These pieces of legislation did not systematically 
include requirements for wider conservation measures, unlike Article 3 of the Zoos Directive297.  

The late transposition of the Zoos Directive, even in Member States where legislation regulating zoos 
was already in place, demonstrates how the adoption of the Directive induced changes to the existing 
legislative frameworks, especially regarding the inclusion of conservation measures as part of the li-
censing requirements of zoos298.  

Member States joining the EU more recently adopted national legislation on zoos shortly before their 
accession (see Section 4.1.4)299, suggesting that the existence of an EU Directive was the key driver 
behind national developments.  

Before the action taken by the EU and the adoption of the Zoos Directive, in the absence of national 
legislation requiring zoos to be licensed and inspected, only zoos that adhered to zoos’ federations had 
to undergo inspections, as part of their membership requirements (EAAM 2016, EAZA 2016). Since 
1994, EAZA applied standards on the accommodation and care of animals300. However, even in those 

295 Interviews with BE MSCAs. 
296 Spanish legislation was ruled as failing to satisfy the requirements of the Directive on the licensing system (Commission v. Spain 2010).  
297 Such as: participation in research, training or in exchange of information, captive breeding, repopulation or reintroduction of species into 
the wild; public education and awareness raising; keeping records of animal collections. 
298 Effective transposition of all the requirements of the Directive was late in Denmark, France and Spain (i.e. Member States that had legis-
lation in place prior to the adoption of the Zoos Directive). France transposed the legislation on time, while Belgian legislation was consid-
ered to be already aligned with the provisions of the Zoos Directive.  
299 Cyprus, Czech Republic, Lithuania and Poland adopted transposing legislations between 2002 and 2004, Bulgaria between 2003 and 
2006.  
300 Original Standards for the Accommodation and Care of Animals in Zoos, 1994 (based on information provided by EAZA).  

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cases, the implications of not complying with the requirements set up by the zoos’ federations  were 
not as severe as the consequences of a lack of compliance with legislation (i.e. mainly bilateral discus-
sion between EAZA and the failing member zoos to achieve compliance, suspension of participation 
in  EEPs  and  ESBs  programmes)301.  In  addition,  EAZA  standards  and  guidance  gradually  developed 
and  increased  their  focus  on  education,  research  and,  more  generally,  on  conservation  strategies  be-
tween 1994 and 2000s302.   

Besides this information on the legal framework applicable to zoos and the information gathered in the 
European Survey of Zoological Collections (Travers et Straton 1988), no quantitative information was 
available regarding the situation of zoos before the adoption of the Directive. 

Overall, the available evidence points to the fact that the Directive was the legal basis that led to the 
adoption  of  national  legislations  and  the  establishment  of  licensing  and  inspection  schemes  in  all  of 
the  Member  States,  forcing  all  zoos  to  take  part  in  conservation  activities,  including  minimum  re-
quirements  for  accommodation  and  animal  husbandry.  In  that  respect,  the  EU  intervention  induced 
important  changes  across  the  EU  Member  States,  by  providing  a  framework  applicable  to  all  zoos, 
including those outside zoos’ organisations. Even if standards and guidelines were provided by zoos’ 
federations such as EAZA prior to the adoption of the Directive, the limitations in terms of coverage 
(17% of licensed zoos are currently part of EAZA) and scope (mainly focused on accommodation and 
care of animals) should be acknowledged.   

EU action has, therefore, contributed to the creation of a common and coherent legal framework for 
zoos, one of most notable benefits  of the Zoos Directive recognised by the stakeholders through the 
public consultation303, interviews and discussions held during the Workshop on the REFIT evaluation 
of the Zoos Directive (Brussels, 16 May 2017)304. It also contributed to the promotion of the role of 
zoos as entities participating in the wider conservation of biodiversity. Additionally, most of the 
stakeholders participating in the public consultation also pointed to benefits in terms  of improved li-
censing  and  inspection  schemes  of  zoos305,  revealing  a  positive  perception  about  the  developments 
triggered by the Directive in this respect. Finally, stakeholders underlined that the cross-border nature 
of  conservation  issues  emphasise  the  need  for  coordinated  and  consistent  actions  at  supra-national 
level306. 

5.5.1.2  Strengthened role of zoos in the conservation of biodiversity: contribution 

of the Zoos Directive and other factors affecting developments  

While it is safe to say that the Zoos Directive triggered the adoption of national legislations on previ-
ously  unregulated  aspects  of  zoos  in  the  vast  majority  of  EU  Member  States,  it  is  more  difficult  to 
establish the extent to which  the new legal framework (rather than other factors) contributed to pro-
moting  widespread  implementation  of  measures  on  biodiversity  conservation  and  thus  strengthened 
the role of zoos in protecting wild fauna and conserving biodiversity.  

The ‘Effectiveness’ analysis underlined that, in line with Article 3 of the Zoos Directive and the re-
quirements of national licensing and inspection systems, many zoos have implemented several conser-

301 Interview with stakeholder. 
302 First EAZA Conservation Education Standards were adopted in 2001; EAZA Research Statutes in 2003; EAZA Conservation Standards 
in 2016 (based on information provided by EAZA). 
303 Based on the results of the public consultation and the interviews with zoos and zoos’ federations (See Section 5.2.1.2, on the benefits 
associated with the Zoos Directive). In particular, in the public consultation, 63% of respondents (1,457 out of 2,297) considered the Di-
rective to have brought significant or crucial benefits in that respect, 19% (426) attributed no benefit or minor benefits to the Directive, and 
18% (414) had no opinion.  
304 See Workshop Report, May 2017, available at: 
http://ec.europa.eu/environment/nature/legislation/refitzoosdirective/pdf/Workshop_report.pdf  
305 In the public consultation, 60% of respondents (1,391 out of 2,297) considered the Directive to have brought significant or crucial benefits 
in terms of coherent legal framework for zoos, 22% (508) attributed no benefit or minor benefits to the Directive, and 18% (408) had no 
opinion. 
306 See Workshop Report, June 2017, available at: 
http://ec.europa.eu/environment/nature/legislation/refitzoosdirective/pdf/Workshop_report.pdf 

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vation measures, have set up written conservation and education strategies, and ensure high standards 
of  animal  husbandry.  However,  the  Directive  is  not  necessarily  perceived  by  the  zoos  as  the  main 
driver behind the adoption of those measures. According to the results of the survey (and confirmed in 
interviews), many zoos that are members of federations were already engaged in conservation activi-
ties, or would have undertaken those measures, in the absence of the Directive. In particular, looking 
at the analysis of the costs implied by the Zoos Directive, only a few zoos attributed the costs occurred 
(investment and recurring expenses) directly to the Zoos Directive, as in most cases these were con-
sidered part of their operating costs and commitments (Section 5.2.1.1).  

These elements are mirrored in the opinions expressed by stakeholders in the targeted consultations. 
Broadly speaking, the majority of MSCAs and NGOs  agreed that EU intervention (i.e. the Zoos Di-
rective)  contributed  to  a  more  efficient  and  faster  implementation  of  the  conservation  measures,  as 
required  by Article 3, compared to national  law and non-legal initiatives (such as zoos’ federations’ 
requirements) (Figure 36). 

Figure  36:  Online  responses  to  the  question  ‘Do  you  think  that  the  EU  intervention  has  contributed  to  make  zoos 
adopt or implement the Article 3 conservation measures more efficiently or more quickly as compared to national law 
or non-legal initiatives?’ (Total number of respondents = 111) 

20

15

10

5

0

16 

12 

Yes

7 

0 

No

3 

2 

Don't know

0 

1 

NA

Source: Present survey of MSCAs, federations, NGOS and experts. 

MSCAs - Q114

NGOs & federations - Q74

Zoos give a more mixed picture, with most stating that the Zoos Directive has contributed to the im-
plementation of conservation measures only partly, or not at all. This trend is highly influenced by 
many  of  the  responding  zoos’  membership  of  a  zoo  organisation  (national  and/or  Europe-
an/international, including EAZA). As Figure 37 shows, half of zoos that are members of zoos’ asso-
ciations indicated that the Directive did not contribute to implementing new conservation measures in 
their zoo. Apparently, zoos that are members of such organisations implement conservation measures 
notwithstanding the national requirements introduced in compliance with the Zoos Directive. 

The effects of the legislation on inducing the implementation of conservation measures by zoos appear 
to be notable for those zoos not belonging to a zoos’ association (six respondents in this category).  

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Figure 37: Zoos’ online responses to question 108 ‘In your zoo, to what extent has the Zoos Directive contributed to 
implementing new conservation measures or improving the existing ones?’ (in %, out of 70 responding zoos in total; 
37 EAZA members; 16 other zoos’ federations; six no zoos’ federations; 11 undetermined)307  

NA

9,1 

27,3 

18,2 

45,5 

None

33,3 

33,3 

16,7 

16,7 

Other zoo association

EAZA

50,0 

51,4 

31,3 

12,5 

6,3 

32,4 

5,4 

10,8 

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

100%

Did not contribute

Somewhat contributed

Fully contributed

Don't know

NA

Source: Present survey of zoos 

The consultation reveals similar results in relation to the strengthened role of zoos. Although progress 
has generally been achieved towards the general and specific objectives of the Zoos Directive (as ar-
gued in Section 5.1.1), most of the stakeholders, across all groups, agreed that the Directive has only 
partly contributed to improving the role of zoos in conservation of biodiversity (see Figure 38 below). 

Figure 38: Online responses to the question ‘In your opinion, has the role of zoos in the conservation of biodiversity 
been strengthened over the last 15 years? Can this be attributed to the Zoos Directive?’ 

60

50

40

30

20

10

0

51 

2 

3 

2 

16 

10 

1 

4 

3 

0 

2 

2 

1 

0 

8 

0 

1 

4 

Yes, and it can be
fully attributed to
the Directive

Yes, and it can be
partly attributed
to the Directive

Yes, but it cannot
be attributed to
the Directive

No

No opinion

NA

MSCA - Q77

NGOs & federations - Q34

Zoos operators - Q71

Source: Present survey of MSCAs, federations, NGOS and experts, and zoos 

In  general  terms,  the  results  of  the  consultation  point  to  a  contribution,  although  limited,  of  the  Di-
rective in relation to the implementation of Article 3  measures and to  the  strengthened  role of zoos. 
This aspect emerged from the survey (as described), but also very often during the interviews with all 
stakeholder categories.  

This judgement is explained by several factors that have hindered or contributed to enhancing the con-
servation role of zoos, already discussed in Section 5.1.3, and briefly outlined below.  

On the one hand, two main factors appear to have partly diminished the contribution of the Zoos Di-
rective to a strengthened role of zoos. These factors are related to the  design of the Directive itself 

307 Article 3, first indent, ‘Participation in research and training, exchange of information, captive breeding, repopulation, or reintroduction of 
species into the wild’; Article 3, second indent, ‘Promotion of public education and awareness’; Article 3, third indent, ‘Animal accommoda-
tion that satisfy biological requirements and high standards of animal husbandry’; Article 3, fourth indent, ‘Preventing the escape of the 
animals and the intrusion of outside pests and vermin’; Article 3, fifth indent, ‘Keep appropriate records of the zoo's collection’. 

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and its provisions and, in turn, to the limits observed in its implementation. 
As highlighted by the literature,  the first factor that might limit the impact of the Zoos Directive on 
biodiversity conservation is the alternative means of compliance offered by Article 3, first indent, 
of the Directive (P. Rees 2005) (Born Free 2012) (Born Free 2016). Article 3, first indent, of the Zoos 
Directive  obliges  ‘participating  in  research  from  which  conservation  benefits  accrue  to  the  species 
and/or training in relevant conservation skills, and/or the exchange of information relating to species 
conservation and/or where appropriate, captive breeding, repopulation or reintroduction of species in 
the wild’. As underlined in the ‘Effectiveness’ analysis, the alternative wording of the Zoos Directive 
answers  to  the  need  to  take  into  account  the  varied  landscape  of  EU  zoos  and  accommodate  differ-
ences in capacities (see also Section 5.1.3.1). This wording, however, diminishes the potential of the 
Directive to force a shift in zoos, from entertainment facilities to centres more focused on biodiversity.  

A second factor is related to the absence of prioritisation for local, national or regional protected and 
threatened species (Born Free 2012) (Born Free 2016)308. It was reported that zoos devote only a small 
proportion of their capacity to conserving the most threatened species (D. F. Conde 2011). The lack of 
specific  provisions  on  this  aspect  in  the  Zoos  Directive  does  not  ensure  the  commitment  of  zoos  to 
prioritising threatened species and their conservation.  

Thirdly, other factors (independent from the Directive) have contributed to the shift in the role of zoos. 
It has been often argued that zoos contributing most significantly to wider conservation activities fol-
low either their individual ambitions or the requirements of zoos’ organisations of which they are 
members. In particular, as mentioned several times in this report, affiliation  with zoos’ organisations 
such as EAZA, EAAM or national organisations, is a key aspect in the implementation of conservation 
measures.  

EAZA guidelines for the care and accommodation of animals in zoos were already in place before the 
implementation of the Directive (and are mentioned in its preamble), as well as captive breeding pro-
grammes (such as the EEP and ESB). The work of this organisation has evolved over the years, sup-
porting the implementation of the Directive through standards, training, breeding programmes, aware-
ness-raising  activities  campaigns,  etc.  Similarly,  international  stakeholders  (e.g.  WAZA)  have  long 
been engaged in the definition of standards and guidelines related to the management of ex situ con-
servation309.  Currently,  EAZA  standards  are  generally  more  detailed  than  Article  3  of  the  Zoos  Di-
rective for conservation measures taken by zoos, as illustrated in Annex III. 

As  mentioned  and  further  discussed  in  EQ  16,  this  does  not  mean  that  the  same  results  would  have 
been achieved on the basis of the work done by zoos’ organisations or under international agreements, 
in the absence of the Zoos Directive. Affiliation with a zoo organisation remains voluntary, and only a 
limited number of zoos are part of federations (for example, the estimated share of EAZA zoos is 17% 
at EU level310). It has been pointed out that, by encouraging participation in research, captive breeding, 
repopulation  and  reintroduction,  the  Directive  also  had  a  role  in  extending  the  participation  in  pro-
grammes promoted by zoos’ federations (i.e. in the EAZA ESB and EEP programmes) beyond associ-
ated zoos311. Therefore, at least in some cases, it can be argued that the Zoos Directive and the stand-
ards and guidelines promoted by zoo’ federations have had a mutually reinforcing effect.   

The work done by zoo federations remains an important factor supporting increased attention to con-
servation activities among zoos, along with the requirements of the Zoos Directive.  

Finally, at the time of the adoption of the Directive, progressive zoos were already engaged in an im-
portant shift away from being entertainment centres towards taking a more active role in biodiversity 
conservation. There was also a change in visitors’ attitude and, in turn, in the perceptions of many zoo 

308 Further details in Section 5.1.3. 
309 For example, WAZA published its first Conservation Strategy in 1993.  
310 See Section 4.1 above.  
311 See Section 5.1.1.3. 

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owners (who take public opinion very seriously), leading to an increased focus on biodiversity conser-
vation and husbandry standards. By providing a common legal framework applicable to all zoos, the 
Directive followed and encouraged an emerging trend, at least to some extent.  

5.5.1.3  Summary and conclusions 

The analysis highlighted the following points in respect of the EU Added Value of the Directive: 

  The Zoos Directive’s main EU added value lies in the fact that it provides a common legislative 
framework,  with  minimum  requirements  applicable  to  all  zoos.  It  triggered,  in  most  Member 
States,  the  adoption  of  legislation  specific  to  zoos,  which  were  previously  unregulated,  and 
established licensing and inspection schemes. Even in Member States where previous legislation 
existed, the adoption of the Directive triggered amendments to the regulatory framework which 
brought about further emphasis on the conservation role of zoos.  

  According  to  the  results  of  the  targeted  consultation,  the  Zoos  Directive  mainly  impacted 
facilities  that  are  not  members  of  zoos’  federations.  Zoos  that  are  not  members  of  zoos’ 
associations  reported  a  stronger  impact  of  the  Directive  on  the  conservation  activities  that  they 
lead or participate in. For zoos that are members of zoos’ associations with stricter requirements 
than  the  European  or  national  legislation,  the  national  legislation  had  limited  or  no  impact. 
However, the requirements (e.g. codes of conducts, standards, etc.) of international, national and 
regional  zoos  organisations  alone  would  not  have  achieved  the  same  results,  because  of  their 
limited  coverage  of  the  total  number  of  zoos  and  their  non-binding  nature.  Moreover,  although 
EAZA guidelines for the care and accommodation of animals in zoos were already in place before 
the  implementation  of  the  Directive,  they  gradually  evolved,  increasingly  supporting  the 
implementation  of  the  Directive.  In  other  words,  the  Zoos  Directive  also  had  an  effect  on  the 
work carried out by zoo federations 
Strictly related to the point above, it is argued that both affiliation to zoos’ associations and the 
more  general  developments  ongoing  at international  level  in  terms  of  ex  situ  conservation  have 
contributed to the changes occurred.  
Finally, other factors related to the design and implementation of the Zoos Directive, might limit 
its  effects  in  terms  of  the  strengthened  role  of  zoos:  the  alternative  wording  of  Article  3,  first 
intent,  limiting  the  extent  of  conservation  measures  to  be  undertaken  by  zoos;  and  the  fact  that 
threatened  species  are  not  prioritised  in  the  Directive  and  are,  therefore,  not  necessarily  in  EU 
zoos. 

 

 

5.5.2  EU Added Value – EQ 15 

To what extent do the issues addressed by the Directive continue to require action at EU level? 
This question focuses on the implementation of the Zoos Directive at national level and the harmoni-
sation achieved across EU Member States. The question of the relevance of EU action in the light of 
international commitments, EU and global biodiversity needs is addressed under the relevance section. 
Drawing on the findings related to the effectiveness of the Directive and its implementation, the objec-
tive of this section is to highlight whether or not the provisions of the Zoos Directive have been trans-
lated into stricter requirements at national level, if they are considered necessary for the full achieve-
ment of the objectives, and whether EU action is still needed to overcome discrepancies among Mem-
ber States in addressing biodiversity issues.  

5.5.2.1  Additional 

requirements 
harmonisation achieved 

implemented 

in 

the  Member  States  and 

Some  Member  States  did  not  limit  their  transposition  to  the  wording  of  the  Directive.  As  described 
under  Section  5.1.3,  additional  requirements  were  included  by  several  Member  States  in  their  trans-
posing legislation to remedy the ambiguities experienced in interpreting the Directive.  

Examples  of  national  transposition  that  differs  from  the  framework  of  the  Directive  are  provided  in 
Table  6  of  the  Annex  III  to  this  report.  The  analysis  looks  at  three  key  aspects  on  which  Member 

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States’ transposition tended to depart from the wording of the Directive:  

  Understanding of ‘significant number of animals’ under the definition of zoos (Article 2). 
  Application  of  more  stringent  rules  on  the  establishment  and  enforcement  of  conservation 

measures as listed under Article 3, first indent. 

  Establishment  of  more  specific  requirements  on  animal  accommodations  under  Article  3,  third 

indent. 

As shown in Annex III, five out of 14 Member States covered by this study (Bulgaria, Czech Repub-
lic, Germany, Ireland and the Netherlands) highlighted that their national legislation lays down specif-
ic requirements on the ‘significant number of animals’ which determines whether or not a facility 
falls within the scope of the legislation.  

No country reported including substantial exemptions under Article 2 of the Directive312, while eight 
of the 14 (Belgium, Bulgaria, Cyprus, France, Italy, Portugal, Poland and Spain) underlined that their 
national legislation goes further than the requirements of the Zoos Directive on the establishment and 
enforcement of conservation measures as listed under Article 3, first indent313. Most notably, for 
five Member States (Bulgaria, France314, Italy, Poland and Portugal), zoos must implement more than 
one of the alternative options of Article 3, first indent.  

Finally, five of the 14 selected Member States (Belgium, Bulgaria, Italy, Lithuania and Poland) have 
adopted  national  legislation  that  sets  out  specific  requirements  for  animal  accommodation,  while  a 
few  others  have  adopted  non-binding  requirements  (Ireland  and  Germany).  It  appears  that  the  most 
common specifications in national legislations relate to accommodation requirements concerning en-
closure sizes for some species (e.g. dolphins in Italy and elephants in Ireland) or group of species (e.g. 
Belgium, Bulgaria, Lithuania and Poland).  

In addition to those aspects, the national legislation of Member States provided  practical precisions 
to ensure the enforcement of the applicable rules, such as the definition of penalties, frequency of 
inspections, validity of the licence or, as in the case of France, requirements related to zoo personnel 
(see the example in Box 16 below)  

Box 16: More stringent requirements - France 

The French transposing legislation goes further than the requirements of the Directive,  particularly 
on  requirements  of  conservation  measures  mentioned  in  Article  3,  first  indent.  Under  the  French 
legislation315, besides the alternative measures required by Article 3, first indent, zoos are required 
to: 

 

Participate in the exchange of animals that promote the conservation and management of captive animal 
populations, in order to ensure the genetic quality of hosted species. 

  Contribute to national and international breeding programmes and to keep animals of species involved in 

these programmes. 

  Contribute  to  the  breeding  of  non-domestic  species,  or  organisations  involved  in  the  conservation  of 
biodiversity, by sharing information concerning the breeding techniques of wild animals in captivity, and 
knowledge of their biology or knowledge relevant to the conservation of biological diversity. 

  Keep the corpses of animals at the disposal of scientific or training institutes, unless these are used for 

312 Article 2: ‘For the purpose of this Directive, “zoos” means all permanent establishments where animals of wild species are kept for exhi-
bition to the public for seven or more days a year, with the exception of circuses, pet shops and establishments which Member States ex-
empts from the requirements of this Directive on the grounds that they do not exhibit a significant number of animals or species to the public 
and that the exemption will not jeopardise the objectives of the Directive’. 
313 Article 3, first indent: ‘Member States shall take measures under Articles 4, 5, 6 and 7 to ensure all zoos implement the following conser-
vation measures: - participating in research from which conservation benefits accrue to the species, and/or training in relevant conservation 
skills, and/or the exchange of information relating to species conservation, and/or, where appropriate, captive breeding, repopulation or 
reintroduction of species into the wild […]’ 
314 For zoos that keep ‘conservation-sensitive’ species. 
315 Order of 25 March 2004. 

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the needs of the zoo.  

Qualifications and professional experience of zoo managers is also enshrined in the French legisla-
tion. The French Environmental Code requires zoo managers to hold a certificate of capacity (certif-
icat de capacité) for the proper care of non-domestic animals (Article L413-2 Environmental Code). 
The  conditions  for  granting  the  certificate  are  laid  down  in  legislation  and  further  specified  in  a 
circular issued by the Ministry316. The certificate requires that the applicant has successfully passed 
the tests on ‘applied sciences and technologies’ and ‘professional practices’ of the technical bache-
lor degree for ‘technician advisor in animal sales’. 

This  implies  that  a  significant  number  of  Member  States  went  beyond  the  requirements  of  the  Di-
rective, with specific provisions introduced to ensure the actual enforcement of the Directive and, in 
some cases, to specify the size of enclosures. This conclusion was also drawn by the Born Free 2011 
Zoo Inquiry (Born Free 2012). The broad requirements of the Zoos Directive, coupled with the intro-
duction  of  specific  requirements  by  Member  States,  hindered  the  achievement  of  harmonisation  and 
consistent implementation across the Member States. For example, as shown above, there are various 
degrees of interpretation in the different national legislations of the terms ‘significant number of spe-
cies’ considered by the Zoos Directive as a threshold for facilities to be qualified as ‘zoos’.  

For  enclosure  sizes,  no  harmonisation  took  place  under  the  framework  of  the  Directive  beyond  the 
non-binding  guidelines  of  the  Good  Practices  Document  (European  Commission  2015).  While  it 
would be unlikely to achieve consensus on this matter between the different groups of stakeholders, 
some  stakeholders  acknowledged  that  harmonisation  of  species-specific  requirements  for  animal  ac-
commodation and husbandry would be valuable317. 

The lack of monitoring or reporting requirements and the absence of coordinated action at EU level 
also affected the level of harmonization achieved. The Good Practices Document mentioned above has 
been  issued  in  order  promote  the  sharing  of  experience  across  EU  zoos,  but  its  late  publication  and 
lack of translation in national languages have diminished the possible impacts in terms of coordinated 
implementation. 

The ultimate consequence of the open framework provided by the Directive is that substantial differ-
ences still exist across zoos, depending on their sizes, their affiliation to zoos’ organisations and their 
geographical  location  (‘nationalities’).  Therefore,  although  the  creation  of  one  common  legislative 
framework applicable to all EU zoos is recognised by stakeholders as the key added value of the Di-
rective  (see  Section  5.5.1.1),  harmonisation  has  been  limited  to  minimum  requirements,  and  the  im-
plementation of conservation measures by zoos is expected to remain inconsistent across the EU. This 
has an impact on the level of protection of biodiversity which varies from a Member State to the other.  

Finally,  cooperation  and  exchange  of  information  on  species  conservation  among  zoos  and  across 
Member States is an important aspect that the EU Directive can boost with greater effect than initia-
tives at national level. Sixty-five out of 70 respondent zoos (92.8%) are engaged in the exchange of 
information,  usually  by  communicating  with  other  zoos,  or  through  participation  in  meetings  with 
other  regional  or  national  stakeholders  (e.g.  zoos’  federations,  national  authorities),  or  with  interna-
tional  stakeholders  (e.g.  IUCN,  EAZA).  It  is  also  worth  mentioning  that  a  significant  share  of  zoos 
(40, or 57.1%) uses ‘Species360’, a tool developed to facilitate international collaboration in the col-
lection  and  sharing  of  knowledge  on  wild  animals  in  zoos  and  aquariums  (counting  around  1,000 
members  across  90  countries318)  (see  Section  5.1.1.3).  The  participation  in  the  survey  of  many  zoos 
that  are  members  of  EAZA  or  other  national  federations  explains  this  high  shares  of  zoos,  which  is 
likely to be more limited among other zoos. This understanding was confirmed by stakeholders during 
the Workshop on the REFIT evaluation of the Zoos Directive (Brussels, 16 May 2017): most conser-

316 Order of 2 July 2009 on the simplified conditions in the context of which the certificate of capacity for the care of non-domestic animals 
can be delivered; Circulaire DNP/CFF N° 2008-03 of 11th of April 2008. 
317 Interviews and surveys addressed to federations, NGOs, zoos. 
318 http://www.species360.org/about-us/mission-history/ 

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vation and coordination activities were reported to take place through EAZA and other associations. A 
tremendous gap exists between zoos that are members of zoos’ associations and non-member zoos. In 
this respect, the Directive was reported as a critical instrument for bridging this gap by setting com-
mon minimum standards across all EU zoos319 .  

Against this background, the public consultation highlighted a strong consensus that EU-wide rules are 
needed on all matters currently regulated by the Zoos Directive (Figure 39).  

Figure 39: Answers to question 22 of the public consultation ‘How important do you think EU-wide rules on zoos are 
on the following matters?’ (in absolute numbers of respondents) 

0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%

22a. Protecting Europe's threatened species

101 

134 

487 

22b. Protecting globally threatened species

106 

131 

454 

1536 

1569 

22c. Captive breeding (i.e. breeding of animals outside their
natural habitats) of threatened species in Europe and globally

172 

459 

440 

1157 

22d. Reintroduction of species into the wild

111 

361 

381 

1409 

22e. Keeping animals under appropriate conditions with good
veterinary care

22f. Making zoos shift from pure exhibition to modern
conservation centres, where education, research, captive
breeding and reintroduction programmes are undertaken

79 

70 

178 

1943 

119 

119 

255 

1762 

22g. Avoiding the escape of animals

69 

136 

476 

22h. Increasing awareness of the wider public on biodiversity
and nature protection by offering education and information on
these topics

94 

113 

470 

1525 

1578 

22i. Keeping appropriate, shareable data records of the zoo's
animals

82 

107 

637 

1376 

No opinion

Not important

Partly important

Important

Very important

The  strongest  consensus  relates  to  ‘Keeping  animals  under  appropriate  conditions  with  good  veteri-
nary care’, which 1,943 respondents out of 2,297 (85%) consider to be very important and 178 (8%) 
important to have EU-wide rules on the subject. EU-wide rules are also considered important for other 
objectives, such as protecting European and global threatened species, as well as for increasing public 
awareness  of  biodiversity  and  nature  protection.  Zoos  that  participated  in  the  public  consultation 
demonstrated especially strong support for the existence of an EU framework in relation to all of the 
aspects listed above.  

5.5.2.2  Summary and conclusions 

This analysis highlights certain points in respect of the continued need for action at EU level: 

  The  Directive  sets  minimum  requirements  that  have  been  further  specified  at  national  level  to 
ensure  the  implementation  and  enforcement  of  the  EU  legislation.  Standards  across  the  EU  are 
harmonised in a minimum manner. As a consequence, although the Directive was instrumental in 

319 See Workshop Report, June 2017, available at: 
http://ec.europa.eu/environment/nature/legislation/refitzoosdirective/pdf/Workshop_report.pdf. 

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bridging gaps between members of zoos’ organisations and non-members, differences in the level 
of protection offered by zoos in different Member States are expected to remain.  

  Cooperation  and  exchange  of  information  is  an  important  element  of  the  Directive  that  can  be 
more effectively achieved through action at the EU level. The extent to which such cooperation 
happens among EU zoos that are not members of European organisations such as EAZA, remains 
unclear.  

  A strong consensus exists across all stakeholder groups that EU-wide rules are necessary for all 

topics currently regulated by the Directive. 

5.5.3  EU Added Value – EQ 16 

What would be the consequences of not having the Directive? 

The EU added value of the Directive should reside in the fact that its general and specific objectives 
(protect wild fauna and conserve biodiversity by strengthening the role of zoos in the conservation of 
biodiversity;  ensure  that  zoos  implement  conservation  measures)  could  not  be  achieved  under  other 
frameworks such as national legislation, participation in international agreements or memberships to 
zoos’ associations. This section examines the consequences of the removal of the Directive. 

5.5.3.1  Contribution  of  other  pieces  of  legislation,  policies  or  international 
agreements to achieve the Directive’s objectives, as well as membership 
of zoos’ associations 

The  Zoos  Directive  is  interlinked  with  several  European  and  international  conventions  (CBD  and 
CITES), as well as with other EU legislative acts (such as the Nature Directives, Council Regulation 
No 338/97 on the protection of species and wild fauna and flora by regulating trade, and the IAS Reg-
ulation)320.  

The Zoos Directive is the key implementation measure of the CBD, undertaken by the EU to fulfil its 
own  obligations  under  Article  9  of  the  Convention.  As  mentioned  in  Section  5.1.2.2,  the  Zoos  Di-
rective provides more detailed and practical requirements to strengthen the role of zoos as conserva-
tion centres through the conditions that zoos must fulfil to be granted a licence. The added value of the 
Directive compared to the CBD is thus twofold. Firstly, the Zoos Directive establishes a more precise 
framework  with  minimum  requirements  applicable  to  all  zoos,  thereby  narrowing  the  margin  of  EU 
Member  States  when  implementing  their  obligations  under  the  CBD.  Secondly,  the  Zoos  Directive 
establishes enforceable obligations through the compulsory granting of a licence for zoo operators.  

In parallel, the Zoos Directive contributes to achieving the overarching objectives pursued by CITES, 
in relation to the prohibition on displaying to the public certain species for commercial reasons, except 
if research and education purposes are pursued. In turn, it has been noted (Section 5.1.2.2) that CITES 
is also expected to contribute to the implementation of the Zoos Directive in relation to record-keeping 
systems321. However, overall, the Zoos Directive appears instrumental in ensuring the fulfilment of the 
EU’s  commitments  at  international  level,  while,  conversely,  international  conventions  such  as  the 
CBD  and  CITES  alone  do  not  appear sufficient  to  ensure  the  practical  implementation  and  enforce-
ment of measures for ex situ conservation across the EU.  

Individual membership of zoos’ associations is another critical factor contributing to an enhanced role 
of zoos in biodiversity conservation. EAZA guidelines and standards were explicitly mentioned in the 
Zoos Directive as an instrument that could ‘assist in the development and adoption of national stand-
ards’, and offer zoos a point of reference for the development of conservation measures by detailing 
practical  requirements.  For  each  element  listed  in  Article  3  of  the  Directive,  EAZA  has  developed 
more  extensive  standards,  namely  on  animal  accommodation  standards,  husbandry,  enclosures  and 

320 See EQ 2, Section 5.1.2. 
321 In some countries (e.g. Spain), the database of CITES is also to be used for record-keeping in zoos. 

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safety requirements, as well as education, conservation and research standards (see Annex III). EAZA 
and  equivalent  national  associations  are  also  instrumental  in  the  creation,  participation  and  manage-
ment of breeding programmes (EEPs and ESBs) followed by EAZA members and other zoos, under 
the conditions established by EAZA.  

Nevertheless, it remains questionable if membership requirements alone could ensure the application 
of  conservation  measures  among  EU  zoos  at  a  comparable  scale.  The  share  of  EAZA  zoos  reaches 
only around 17% (346) of licensed zoos in the EU-28322, although this share is expected to be higher if 
national  (and  global)  zoos’  federations  are  also  included.  Equally  importantly,  membership  of  zoos’ 
federations,  and  therefore  application  of  their  requirements,  remains  fully  voluntary.  These  factors 
represent limitations to the impact that could be achieved, should standards and guidelines from zoos 
federations be the only instrument promoting conservation efforts across EU zoos.  

Overall, although the principles of the Zoos Directive are common to other instruments, the binding 
nature of the Directive makes it an essential means of promoting the role of zoos in biodiversity con-
servation across the EU.  

The results from the stakeholder targeted surveys indicate that international conventions and/or mem-
bership of zoos’ federations could not (or could only partly) replace the Zoos Directive and achieve 
the same objectives (Figure 40)323. The main reasons for this assessment were probed during the inter-
views with stakeholders and revealed a strong consensus that the main EU added value of the legisla-
tion  relates to  its binding nature on all zoos, in contrast with all  other international  conventions and 
voluntary schemes.  

Figure 40: Online responses to the question ‘In your opinion, could the same objectives be partly or entirely achieved 
with the relevant existing international conventions, programmes or other instruments?’324 

60

50

40

30

20

10

0

19 

6 

9 

Yes, partly

1 
2 
Yes, fully

28 

17 

4 

No

13 

1 
2 

Don't know

8 

NA

MSCAs - Q118

NGOs & federations - Q78

Zoo operators - Q111

322 See Section 4.1 above.  
323 See EAZA Standards on Education, Training, Breeding, Conservation Programmes. 
324 Such instruments include the CBD with the Aichi Targets; the Birds Directive (Council Directive 79/409/EEC) and Habitats Directive 
(Council Directive 92/43/EEC); CITES; Council Regulation No 338/97 on the protection of species and wild fauna and flora by regulating 
trade; IAS Regulation; National species action plans in EU Member States; European code of conduct on zoological gardens and aquaria and 
invasive alien species (Council of Europe, Invasive alien Specialist Group, EAZA); European Endangered Species Programmes (EEP); 
IUCN technical guidelines for the management of ex situ populations for conservation; WAZA World Zoo and Aquarium Conservation 
Strategy. 

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Source: Present survey of MSCAs, federations, NGOS and experts, and zoos 

Additional  elements  were  explicitly  mentioned  by  a  substantially  smaller  number  of  stakeholders, 
namely increased trust and expectations of the public, increased awareness of the zoo community giv-
en the higher visibility and political engagement due to an EU intervention, improved animal welfare, 
and action on the prevention of escapes which would otherwise not be regulated at all. Furthermore, 
the Zoos Directive has promoted the uptake of programmes such as EEP and ESB (supported by EA-
ZA) among establishments that are not part of the federation: participation of non-EAZA zoos in these 
programmes has increased in recent years with almost 50% of zoos participating in these programmes 
in 2015 being non-EAZA facilities (see Section 5.1.1.3). 

5.5.3.2  Stakeholder  opinion  on  the  expected  developments  in  the  legislation  at 

Member State level  

Stakeholders underlined during the Workshop on the REFIT evaluation of the Zoos Directive  (Brus-
sels,  16  May  2017)  that  removing  the  Directive  would  have  largely  unpredictable  outcomes325.  The 
most  commonly  expected  outcome  reported  by  EU  stakeholders  and  NGOs  is  that  Member  States 
would abandon the regulation of zoos, and those zoos that are not members of associations would then 
lose the incentives (i.e. granting of a licence) to engage in conservation, cooperation and educational 
activities326. Born Free assessed that only  those Member States that limited their transposition to the 
minimum  requirements  of  the  Directive  might  abandon  the  regulation  of  zoos.  The  expected  conse-
quences  of  such  a  development  would  be  that  the  gaps  between  zoos  would  widen,  illegal  trade  of 
species  (and  species  products)  would  increase  and  animal  welfare  would  decrease327.  This  forecast 
however was not reflected in the answers from CAs, none of whom explicitly stated their expectation 
that their country would repeal its transposing legislation. The position of the interviewed CAs points 
more to the idea that the situation would, in practice, remain unchanged, although the consequences of 
the political message of repealing the Directive would be uncertain328.  

In general, stakeholders supported the opinion that not having the Zoos Directive would create nega-
tive  effects.  They  considered  that  the  EU  level  remains  the  most  appropriate  level  of  regulation.  In 
contrast with the mixed picture of the contribution of the Directive to the implementation of its Article 
3 measures (see Section 5.5.1.2), over half of responding zoos (39 out of 70) agree that an EU legisla-
tive act is necessary to ensure the implementation of the measures listed in Article 3. Similarly, NGOs 
are strongly in favour of an EU legislative act: 20 out of 26 (77%) answered that the EU legislative act 
is necessary. MSCAs displayed lower support for the need for an EU legislative act, with six out of 14 
stating that such act is not necessary (Figure 41).  

325 See Workshop Report, June 2017, available at: 
http://ec.europa.eu/environment/nature/legislation/refitzoosdirective/pdf/Workshop_report.pdf 
326 Interviews with zoo association, international and national NGOs.  
327 See Workshop Report, June 2017, available at: 
http://ec.europa.eu/environment/nature/legislation/refitzoosdirective/pdf/Workshop_report.pdf 
328 Interviews with MSCAs.  

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Figure 41: Online responses to the question ‘Do you think an EU legislative act is necessary to ensure that zoos 
implement Article 3 measures?’ 

50

40

30

20

10

0

39 

5 

20 

Yes

9 

6 

1 

No

15 

4 

5 

No opinion

7 

0 

0 

NA

MSCAs - Q116

NGOs & federations - Q76

Zoo operators - Q109

Source: Present survey of MSCAs, federations, NGOS and experts, and zoos 

No explicit explanation was provided by respondents to bridge the apparent inconsistencies between 
the responses of MSCAs and zoos to  the question on the contribution  of the Directive to the imple-
mentation of Article 3 measures and responses to the question on the necessity of a Directive. While, 
overall, MSCAs considered  the Directive  to  contribute to the implementation  of Article 3 measures, 
the majority stated that EU legislation is not necessary for this implementation. The reverse is true for 
zoos: a large share (between 30 and 35 out of 70 responding zoos) considered that the Directive did 
not contribute to the implementation of the Article 3 measures in their zoo, yet 39 out of 70 stated that 
an  EU  legislative  act  is  necessary.  A  potential  explanation  is  that  a  significant  share  of  respondents 
interpreted the question on the ‘necessity of an EU legislative act’ as the need for an additional EU 
legislative act or modified Directive. Another explanation of the answers from zoos is that an unrepre-
sentative share of zoos’ that are members of zoos’ associations replied to the survey, zoos for which 
the existence of a Directive did not particularly impact the implementation of measures such as those 
in Article 3, given that such measures are required for their voluntary membership to those zoos’ asso-
ciations (see Annex III on EAZA Standards). Open fields questions and interviews, however, showed 
that  these  zoos  believe  that  EU  legislation  is  necessary  to  force  more  zoos  to  shift  their  focus  from 
entertainment to conservation. 

The results of the public consultation showed that the public believes that the EU is unlikely to  fulfil 
its  global  commitments  on  biodiversity  without  the  Zoos  Directive:  1,356  out  of  2,297  respondents 
(59%) shared that opinion329. As Figure 42 illustrates, the public generally doubts that many activities 
induced by the Zoos Directive would take place without EU legislation on the matter. 

329 Public consultation, Answers to question 24 of the public consultation, ‘In your opinion, would the following activities take place without 
EU legislation on zoos? 24a. To fulfil EU’s global commitments on biodiversity’. 

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Figure 42: Answers to question 24 of the public consultation ‘In your opinion, would the following activities take place 
without EU legislation on zoos?’ (in absolute numbers of respondents) 

0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%

24a. To fulfil EU's global commitments on biodiversity

182 

457 

899 

580 

179 

24b.Captive breeding of threatened species (i.e. species
on European and global red lists)

132 

191 

620 

873 

481 

24c. Reintroduction of species into the wild

102 

408 

24d. Research on conservation issues

104 

487 

24e. Training on relevant conservation skills

142 

473 

772 

673 

580 

735 

280 

695 

800 

24f. Exchange of information relating to species
conservation

24g. Public education on and awareness of biodiversity
conservation and nature
24h. Public education on and awareness of conservation
of species, wild animals and habitats
24i.Provide information on exhibited species and their
habitats
24j.  Provide information on broader biodiversity and
nature protection topics

24k. Keeping animals under appropriate conditions with
good veterinary care
24l. Prevent escape of animals and intrusion of outside
pests and vermin
24m. Keeping appropriate, sharable data records of the
zoos' animals

122 

443 

523 

826 

107 

577 

578 

96 

439 

675 

675 

716 

99 

192 

377 

1151 

478 

111 

298 

901 

684 

303 

89 

608 

476 

738 

386 

126 

179 

382 

1130 

480 

172 

277 

861 

685 

302 

338 

302 

383 

360 

371 

No opinion

Not at all

Unlikely

Likely

Certainly

For nine points out of thirteen, more than 50% of respondents believed that activities are unlikely to 
take place without EU legislation. According to the public, the four activities that are likely to contin-
ue to be carried out are: (i) captive breeding of threatened species; (ii); exchange of information relat-
ing to species conservation; (iii); provision of information on exhibited species and their habitats; and 
(iv) prevention of escape of animals and intrusion of outside pests and vermin. 

The few public authorities (seven) that took part in the survey tended to have higher confidence than 
all  other  stakeholder  groups  in  the  continuation  of  these  activities  even  in  the  absence  of  EU-wide 
rules on the matter.  

Zoo operators, overall, shared  the views of public  authorities, albeit with some  exceptions330. They 
thought it more likely than the public authorities that, without EU rules, activities would take place on: 
(i) captive breeding of threatened species (i.e. species on European and global red lists); (ii) training 
on  relevant  conservation  skills;  (iii)  preventing  escape  of  animals  and  intrusion  of  outside  pests  and 
vermin; and (iv) keeping appropriate, sharable data records of the zoos' animals. Conversely, zoo op-
erators think it less likely than public authorities that, without EU rules, activities would take place on 
all other points.  

NGOs  demonstrated  the  least  confidence  that  those  activities  would  take  place  without  EU-rules331. 

330 Public Consultation Report (Annex VIII). 
331 Ibid.  

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Nine out of 36 NGOs (25%) think it certain that the EU’s global commitments on biodiversity would 
not be achieved, with an additional 19 out of 36 (52%) thinking it unlikely. For training on relevant 
conservation skills, 12 out of 35 NGOs (34%) think that these would not place at all without EU rules, 
with  another  13  (37%)  thinking  it  unlikely.  On  activities  on  public  education  on  and  awareness  of 
conservation of species, wild animals and habitats, eight out of 35 NGOs (23%) think that these would 
not take place at all without EU rules, with another 14 (40%) thinking it unlikely. 

5.5.3.3  Summary and conclusions 

Analysis of the desk research, public consultation, online surveys and interviews highlighted that: 

  The added value of binding EU legislation compared to other schemes (international agreements 
or  voluntary  memberships)  is  twofold.  Firstly,  compared  to  voluntary  memberships  to  zoos 
associations,  the  scope  and  binding  nature  of  the  Zoos  Directive  ensures  the  application  of 
minimum  requirements  to  all  zoos.  Secondly,  compared  to  international  agreements,  the  Zoos 
Directive provides precision and enforceability of standards. 
Stakeholders who responded to the targeted surveys and to the interviews indicated that the EU 
level  is  the  most  appropriate  level  of  regulation.  International  conventions  and  memberships  of 
zoos’  federations  would  not  enable  achievement  of  the  same  objectives  because  of  their  non-
binding nature and/or of the lack of specifics and detailed requirements. 

 

  EU  stakeholders  and  NGOs  fear  that  without  the  Directive,  Member  States  would  repeal  their 
national  legislations  and  deregulate  their  zoos.  This  was  reported  as  potentially  leading  to 
widening  the  gaps  between  zoos,  increasing  the  possibilities  of  illegal  trade  of  species  (and 
species products) and decreasing animal welfare. However, no CA expected such a repeal of their 
national legislation, instead highlighting the uncertain consequences of such a repeal message at 
EU level.  

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6  CONCLUSIONS 

6.1 

The Zoos Directive and its intervention logic 

Adopted in 1999, the Zoos Directive pursues the following objectives: 

 

Protect wild fauna and conserve biodiversity by strengthening the role of zoos in the conservation 
of biodiversity (general objective).  

  Ensure  that  zoos  implement  Article  3  conservation  measures  (i.e.  research  and  training  on 
conservation; exchange of information; captive breeding; repopulation or reintroduction into the 
wild;  promotion  of  public  education  and  awareness;  accommodation  of  animals  satisfying 
biological  and  conservation  requirements  and  a  high  standard  of  animal  husbandry;  prevent 
escapes  in  order  to  avoid  threats  to  indigenous  species  and  of  intrusion  of  outside  pest  and 
vermin;  keep  appropriate  records  of  the  zoo’s  collection)  and  that  closures  of  zoos  are 
appropriately handled (specific objectives). 

Based on the intervention logic of the Zoos Directive (Section 2.2), these objectives are expected to be 
achieved  through  obligations  placed  on  the  MSCAs,  which  are  required  to  set  up  inspection  and  li-
censing systems and thus ensure that all zoos implement Article 3 conservation measures as a condi-
tion of their operation and opening to the public. The setting up of adequate licensing and inspection 
systems and the implementation of conservation measures by zoos are expected to result in a strength-
ened role for zoos in biodiversity conservation, increased knowledge and public awareness of biodi-
versity conservation, and, ultimately, in the protection of wild species and prevention of biodiversity 
loss. 
The assessment of the performance of the Zoos Directive against each evaluation criterion was carried 
out in line with this intervention logic. 

6.2 

Limitations of the Analysis 

The analysis was constrained by the limited availability of information, in part due to the lack of re-
porting obligations for Member States (Section 3.5.1). Despite the extensive consultations with stake-
holders, which closed the main information gaps, some of the remaining issues limited the analysis:  

  The lack of information on the baseline scenario (i.e. the situation before the adoption of the Zoos 
Directive), which prevented the possibility for carrying out a quantitative analysis of the changes 
induced by the Zoos Directive; 

  The lack of reliable data on the performance of the licensing and inspection system (including the 
lack of historical data), which has only been partly offset through the targeted consultation with 
MSCAs;  

  The high representation of zoos belonging to zoos’ federations (particularly to EAZA) among the 
respondents to the targeted survey, which can lead to bias in the evidence collected on application 
of conservation measures by zoos; 

  The lack of independent analyses on the costs and benefits of the Zoos Directive, the paucity and 
low  quality  of  information  provided  by  stakeholders,  and  the  difficulty  of  attributing  costs  and 
benefits  to  the  Zoos  Directive  (rather  than  to  other  factors).  These  limitations  hindered  the 
possibility of quantifying the costs and benefits; 

  The influence of interest groups in the targeted and public consultations, although the impact on 

the overall results was limited. 

These issues limited the analysis especially in relation to ‘Effectiveness’, ‘Efficiency’ and ‘EU Added 
Value’. Nevertheless, the involvement of stakeholders, the combination of sources and triangulation of 
information allowed for general conclusions to be drawn. 

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6.3  Main Findings 

6.3.1  Effectiveness 

Effectiveness  assessed  the  extent  to  which  the  general  and  specific  objectives  of  the  Zoos  Directive 
have been achieved. 

Progress made in achieving the objectives of the Zoos Directive and remaining issues 

The Zoos Directive introduced a comprehensive approach to  ex situ conservation and systems for li-
censing and inspection, which  were absent in most of the Member States before its entry into force. 
Prior to the adoption of the Zoos Directive, only five of the twelve Member States had relevant legisla-
tion  on  the  subject,  although  not  focused  on  conservation  objectives332  and,  according  to  available 
evidence, only few zoos broadly met ‘the standards required by international guidelines of modern zoo 
practice in the areas of animal husbandry, species conservation and public education’333 (Section 2.1). 
In this context, the Zoos Directive represented an innovation.  

There were initial delays in transposing the Zoos Directive into national legislation and in the setting 
up operational licensing and inspection systems. Nearly all of the 14 Member States selected as case 
studies  licensed  most  or  all  of  their  existing  zoos  only  after  the  four-year  transitional  period  estab-
lished by the Zoos Directive. In three cases, no licence was issued within the four-year period (Section 
5.1.1.2).  These  delays  can  be  explained  by  the  introduction  of  a  completely  new  system  for  most 
Member  States,  which  implied  a  certain  effort  for  setting  up  the  inspection  regime,  identifying  the 
entities  to  be  subject  to  the  legislation  and  actually applying  new  rules.  In  some  cases,  a  number  of 
other factors contributed to slow down the process of licensing and inspection, notably the difficulty of 
mobilising the resources during the financial crisis, burdensome procedures and the tendency to favour 
dialogue with zoos and allow them to redeem deficiencies.  

However, Member States have gradually overcome their initial difficulties and have now established 
functional licensing and inspection systems in order to ensure that zoos implement Article 3 con-
servation measures (in line with the intervention logic, and the expected activities and output of the 
Zoos Directive334). Moreover, although not required by the Zoos Directive, in most of the 14 Member 
States,  inspection  forms  are  used.  They  cover  the  conservation  measures  of  Article  3  and  enable  a 
structured inspection, or offer detailed guidance for inspections in the legislation. Member States also 
often defer to external experts to ensure specialised knowledge during the inspection process.  A few 
Member States have also issued guidance documents for inspections, or are active in the organisation 
of workshops and training for inspectors335.  

The actions taken by the Member States are expected to translate into the implementation of Article 3 
conservation measures by all zoos (specific objectives of the Zoos Directive336). From that perspec-
tive, in practice, significant progress has been made over the implementation period in establishing 
operational licensing and inspection systems so as to ensure that all EU zoos implement all Article 3 
measures. However, several implementation and enforcement issues remain.   

Firstly,  national  licensing  and  inspection  systems  differ  widely  in  their  overall  organisation  (e.g. 
frequency  of  inspections,  bodies  in  charge  of  inspecting  zoos  and  granting  the  licence)  and  require-
ments (e.g. a few Member States require that all the conservation measures listed in Article 3 are ap-

332 Data referred to 1993. European Parliament. 1993. Second report of the Committee on the Environment, Public Health and Consumer 
Protection on the Commission proposal for a Council Directive laying down minimum standards for the keeping of animals in zoos (COM 
(91) 0177 final-C3-0340/91). Strasbourg: European Parliament. 
333 W Travers, et R Straton. 1988. European Survey of Zoological Collections. Zoo Check contract for EEC (contract 6681 (87) 07. 
334 See Section 2.2. 
335 The use of inspection forms, external experts and guidance documents by MSCAs are not requirements of the Zoos Directive. However, 
these elements have been investigated during the supporting study, as indicators to assess the adequacy of the licensing and inspection sys-
tems set up (Section 5.1.1.1).  
336 Specific Objectives from A to E (see Section 2.2). 

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plied, while most of the Member States consider these to be alternative options; a number of Member 
States have defined standards for animal accommodation to be respected by zoos). The Zoos Directive 
provides  a  framework  for  the  implementation  of  conservation  measures  but  it  does  not  provide  de-
tailed  indications  of  the  conservation  measures  listed  in  Article  3.  Although  most  of  the  Member 
States  use  inspection  forms  or  provide  details  in  the  national  legislation,  in  most  cases  there  are  no 
detailed criteria or indicators to assess zoos’ fulfilment of the requirements. Where criteria are defined, 
they are mainly related to animal accommodation and other aspects (such as safety of visitors) that do 
not have a direct relevance to the conservation objectives of the Zoos Directive. This approach is ex-
plained by the need to consider the wide differences among zoo collections, which make it difficult to 
define and apply standard criteria. However, there  is the risk  of  inconsistent application of the re-
quirements  on  conservation  measures,  both  across  Member  States  and  within  each  Member  State 
(when the inspection system is managed at local or regional level).  

Secondly, in the absence of detailed criteria, the quality of the inspection greatly depends on the level 
of knowledge of the inspectors; in that regard, the lack of specialised knowledge among MSCAs ap-
pears  to  be  an  important  issue.  More  generally,  evidence  suggests  that  the  full  effectiveness  of  the 
licensing  and  inspection  system  is  hindered  by  lack  of  resources  and  capacity.  Zoo  inspectors  are 
usually  responsible  for  the  enforcement  of  different  pieces  of  legislation  related  to  animal  welfare, 
trade of wild animals and endangered species (e.g. CITES). This broad range of responsibilities limits 
the resources that can be mobilised for zoo inspections, as well as has implications for the knowledge 
and understanding of the specifics of zoo establishments.  

Finally, closures of zoos represent a challenge for Member State authorities and have been rare in the 
14 Member States analysed for this study. Concerns have been raised by stakeholders about the actual 
closure of non-compliant zoos. The latest Born Free EU Zoo Inquiry 2016 (publication pending) ar-
gues that unlicensed, although operational, zoos remain and ‘a number of registered “exempt” facili-
ties appear to warrant a zoo license’337. These concerns are echoed by stakeholders consulted during 
the  study,  who  pointed  out  that  progress  here  should  not  be  overestimated.  The  implementation  of 
licensing and inspection requirements remains challenging for  MSCAs in terms of the resources and 
knowledge that must be mobilised, and there are still many non-compliant zoos in the EU, leading to 
unfair and unacceptable competition for high-performing and dedicated zoos338 (Section 5.1.1.2).  

These shortcomings in the implementation and enforcement of the Directive's requirements are likely 
to  hinder  the  achievement  of  the  specific  objectives  of  the  Zoos  Directive.  This  is  reflected  by  evi-
dence  presented  in  the  report  (Section  5.1.1),  showing  that  zoos  apply  Article  3  conservation 
measures in a variable way. On one hand, the targeted survey for instance shows that a majority of 
replying zoos is engaged in all Article 3 conservation measures. Also the public consultation indicates 
a  predominantly  positive  perception  among  the  general  public  of  the  promotion  of  conservation 
measures  by  zoos.  On  the  other  hand,  not  all  conservation  measures  are  equally  well  implemented: 
zoos’  activities  focus  mostly  on  information  exchange,  captive  breeding,  education  activities  for  the 
general  public  and  keeping  of  animals  under  appropriate  conditions.  Other  conservation  measures, 
such as research that benefits conservation, training activities and measures preventing the escape of 
IAS appear to receive less attention.  Moreover, despite the focus of Member States on requirements 
for animal accommodation, the public consultation indicates a negative perception on the conditions of 
animals kept in zoos: 53% of the respondents disagree with the fact that animals live in conditions that 
satisfy their needs (Section 5.1.1.3 and Section 5.1.1.4). 

In summary, although certain progress has been achieved, the specific objectives of ensuring that all 
EU zoos implement all Article 3 conservation measures are not yet fully achieved.  

337 Born Free 2016. 
338 See Workshop Report, June 2017, available at: 
http://ec.europa.eu/environment/nature/legislation/refitzoosdirective/pdf/Workshop_report.pdf. 

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Now, looking at the general objective of the Zoos Directive (protect wild fauna and conserve biodi-
versity by strengthening the role of zoos in the conservation  of biodiversity), evidence suggests that 
the role of zoos has been  strengthened, as compared with the situation before the entry into force of 
the Directive, when no comprehensive legislation pursuing this objective was in place339. The impact 
of this strengthened role was analysed as part of Section 5.1.2 on EQ2.  

Contribution of the Zoos Directive to the protection of biodiversity  

The analysis carried out on that point demonstrates that, while it can be safely assumed that zoos' con-
servation  activities  triggered  by  the  Zoos  Directive  have  a  positive  impact  on  the  protection  of  wild 
fauna  and  conservation  of  biodiversity,  it  is  not  possible  to  assess  the  extent  of  these  impacts.  As 
demonstrated in Section 5.1.2.1, there is no consensus on the contribution of zoos’ conservation activi-
ties to biodiversity among the sources  analysed (literature and stakeholders consulted for the study), 
and there is no evidence to allow for clear conclusions to be drawn on the magnitude of the im-
pact of zoos’ actions on biodiversity conservation.  

In spite these limitations, the Zoos Directive, within the wider framework of EU legislation on biodi-
versity conservation, contributes to the achievement the EU's Biodiversity Strategy  (Section 5.1.2.3) 
and  CBD  goals.  The  Directive  exerts  its  strongest  positive  effects  on  Aichi  Targets  1340  through  its 
education  programmes  and  on  Target  12341  which  is  supported  by  all  Article  3  activities  (Section 
5.1.2.2). 

Factors contributing to, or impeding, the achievement of the Directive’s objectives 

Several main factors were found to have influenced, either positively or negatively, the achievement of 
the Directive’s objectives (see Section 5.1.3 on EQ 3).  

Contributing factors 

Firstly, and most importantly, the approach  to transposition, implementation  and enforcement of the 
legislation  by  the  Member  States’  authorities  has  played  a  crucial  role  in  the  achievement  of  the 
Directive’s objectives.  

In relation to transposition, pre-existing legislation in some Member States facilitated the implemen-
tation of the Directive’s requirements. Similarly, additional requirements were provided in the trans-
posing legislation in some cases, to remedy the ambiguities experienced in interpreting the Directive 
(Section  5.5.2.1).  In  terms  of  implementation,  the  proactive  attitude  of  MSCAs,  in  particular  the 
preparation of guidance documents and organisation of training and workshops, has significantly con-
tributed  to  achieving  the  Directive’s  objectives.  In  respect  of  enforcement,  additional  enforcement 
activities, the use of external experts, guidance documents, training and the use of synergies with other 
acts, have all positively contributed to enforcement.     

In addition to Member States’ authorities, other key stakeholders active in the field have contributed, 
through their activities342, to the achievement of the Directive’s objectives: 

  Enforcement activities of the European Commission and its Good Practices Document, despite 
unsatisfactory distribution of the latter (low awareness and not translated) have played a positive 
role. 

339 See also Section 5.5.1 (Eu Added Value), about the opinion of stakeholders on strengthened role of zoos and the contribution of the Zoos 
Directive. 
340 By 2020, at the latest, people are aware of the values of biodiversity and the steps they can take to conserve and use it sustainably. 
341By 2020 the extinction of known threatened species has been prevented and their conservation status, particularly of those most in decline, 

has been improved and sustained. 

342 It should be mentioned that these activities has been driven not only by the Zoos Directive, but also by a general, global trend, towards a 

more conservation-oriented approach. 

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  Zoos’  and  aquarium  federations  have  taken  a  very  active  role  in  the  implementation  of  the 
Directive,  through  their  stringent  membership  requirements  and  standards,  by  educating  and 
disseminating  information  via  the  training  offered  to  their  members,  the  organisation  of 
workshops and conferences, and other public awareness-raising activities, but also through other 
activities, such as coordinating breeding programmes. 

  EU  and  national  NGOs  have  been  instrumental  in  monitoring  the  implementation  of  the 
Directive, flagging issues to the authorities, and informing the public (even though animal welfare 
NGOs put the focus on animal welfare rather than conservation). 
International  stakeholders  (the  IUCN,  WAZA)  have  published  key  documents  assisting  the 
implementation of the Directive. 

 

  Zoos  themselves  have  played  a  key  role  in  implementation,  as  have  academia,  practitioners 
(veterinarians)  through  research,  and  to  a  certain  extent,  the  media  in  terms  of  awareness-
raising.    

Hindering factors 

The nature of the Directive, and in particular the formulation in broad terms of Directive’s require-
ments,  has  in  some  instances  prevented  consistent,  and  effective  implementation  of  the  Directive 
across the Member States. Difficulties relate mainly to the definition of zoos, the alternative options 
provided under Article 3, first indent, (and/or) and the lack of detail and breadth of the requirements of 
Article 3.  

While the MSCAs generally played a positive role in the transposition, implementation and enforce-
ment of the Directive, problems were also observed in each of these various steps. For instance, issues 
in  relation  to  transposition  have  negatively  influenced  the  proper  achievement  of  the  Directive’s 
goals. Late transposition and non-conformity in a few countries (Section 5.1.3.1) resulted in delayed or 
poor implementation of the Directive.  

Implementation of the Article 3 and Article 6 measures in the Member States have proved to be par-
ticularly challenging for the stakeholders. Issues were identified primarily in relation to the: 

  Organisation of the Member States’ administration (division of competence, portfolio of MSCAs, 

absence of communication). 
Identification and inventory of establishments regulated under the Directive. 

 
  Closure of zoos, which represents a major difficulty due to the lack of rehoming possibilities or 

structures provided by the MSCAs. 

Some factors have also impeded proper enforcement. In particular, the lack of knowledge and training 
of enforcement authorities, the lack of resources (human and financial) to carry out enforcement effec-
tively, and inconsistencies in the level of enforcement across regions (see Section 5.1.1.2).  

Evidence also suggests that the Commission’s actions have contributed only to a limited extent to the 
achievement of the Directive’s objectives. The Commission does not have the legal means to monitor 
implementation, nor does it provide for a forum for  exchange between the MSCAs. Its enforcement 
activity is limited, funding difficult to obtain, and training nearly non-existent and non-inclusive.  

Finally, in relation to the role of zoos as economic actors, the impact of the 2008 economic crisis was 
mentioned as a negative factor impeding the proper implementation of the Directive by several zoos, 
especially  southern  ones343.  In  addition,  it  was  observed  by  various  stakeholders  that  the  economic 
weight of zoos at local level renders enforcement by local authorities more difficult (Section 5.1.3.3).  

Other positive and negative changes linked to the Directive 

343 Zoos questionnaire, answer provided by Spanish and Portuguese zoos.  

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According to the information collected, the Directive did not bring about significant negative effects. 
The only exception related to the lack of proper enforcement at national level, i.e. the Directive risks 
giving legitimacy to zoos that are not in line with the requirements and/or only bring a limited contri-
bution to conservation of biodiversity (Section 5.1.4).  
Additional positive effects, going beyond the stated objectives, have been identified in relation to: 

 

 

Increased  public  awareness  of  the  role  played  by  zoos  in  conserving  biodiversity:  the  Zoos 
Directive  has  created  a  common  framework  among  the  Member  States  and,  as  such,  has 
contributed  to  increasing  public  awareness  of  the  role  of  zoos  in  conserving  biodiversity.  The 
establishment  of  EU  legislation  in  this  field,  combined  with  changing  attitudes  among  visitors, 
has also amplified the possibility for NGOs to mobilise public opinion and other players, at both 
EU and national levels, in order to make sure that the improved role of zoos is actually achieved 
(Section 5.1.4.1). 
Increased standards for the welfare of animals kept in zoos, not covered by EU legislation on 
animal  welfare:  Article  3,  third  indent,  of  the  Zoos  Directive  requires  zoos  to  accommodate 
animals  under  conditions  which  ‘aim  to  satisfy  the biological  and  conservation  requirements  of 
the  individual  species’.  This  provision  represents  a  conservation  rather  than  a  welfare  measure, 
but it has contributed to increased attention by Member State authorities and better conditions for 
animals kept in captivity (Section 5.1.4.2). 

6.3.2  Efficiency 

Efficiency assessed the extent to which the range of regulatory costs implied by the implementation of 
the Directive is reasonable and proportionate to the benefits delivered. The analysis was based on the 
information collected through  stakeholder consultations (targeted surveys and interviews, and public 
consultation) in the selected 14 Member States.  

Costs and benefits of the Zoos Directive 

The  Directive’s  requirement  for  an  inspection  and  licensing  system  resulted  in  new  costs  for  both 
MSCAs  and  for  zoos.  The  requirement  for  MSCAs  to  enforce  national  level  legislation  that  imple-
ments the Directive has resulted in new or higher costs for all aspects of the licencing and inspection 
process (i.e. new enforcement costs for treating licence applications, preparing, carrying out and fol-
lowing-up  on  inspections).  The  extent  to  which  individual  MSCAs  have  experienced  an  increase  in 
their costs varies and, although information is limited and quantification not possible, this appears to 
be influenced by several factors. These include whether or not there was a licensing system or some 
relevant  infrastructure  in  place  (e.g.  for  IAS  Regulation,  CITES  enforcement),  and  the  nature  of  the 
licensing system now put in place. All of this means that inspectors have varying degrees of expertise 
and  requirements  placed  upon  them.  Interestingly,  only  half  of  the  Member  States  that  provided  in-
formation reported an increase in training costs. These data might be linked with the issues raised by 
stakeholders (including MSCAs) of the lack of appropriate knowledge of zoo inspectors, and the need 
for better, targeted training activities (Section 5.2.1.1, paragraph a). 

Regarding zoos, in most cases it was not possible to separate costs that were necessary under the Zoos 
Directive  from  costs  that  would  have been  incurred  anyway  as  part  of  routine  business  expenditure. 
Apparently, zoos found it difficult to disentangle the costs directly due to the requirements of the Zoos 
Directive from the developments they had financed as an essential part of their evolution as ‘modern 
zoos’. Only a minority of zoos that reported an increase stated that they considered these costs as di-
rectly attributable to the Directive. Between 21 and 30 zoos (out of 70 that supplied information) indi-
cated that they had increased capital investment, recurring expenditure or administrative costs because 
of the requirements of the Directive.. Where estimates of the costs attributable to the Zoos Directive 
are reported, the amount spent can be significant, especially where investments related to the renova-
tion of enclosures or annual expenditure for the education of staff are concerned. In other words,,. The 
Zoos Directive has triggered only part of the increase in costs recorded.  Zoos’ federations and other 

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stakeholders supported these findings during both surveys and interviews.  

Administrative  costs  have  also  been  introduced  along  with  the  licensing  and  inspection  system.  The 
introduction of the Zoos Directive has implied new efforts for zoos in relation to licensing and inspec-
tion  procedures  (i.e.  preparing  an  application  for  the  licence,  preparatory  work  for  the  inspection, 
sending documents to authorities, completing pre-inspection questionnaires, taking part in the visit of 
the  MSCAs,  providing  answers  to  the  inspection  report).  The  administrative  costs  arising  from  the 
inspection process that are incurred by zoos appear to vary between zoos and Member States, because 
of  differences  in  the  size  of  the  zoos  and  their  collection  and  differences  in  the  national    systems 
adopted  (e.g.  steps  followed  during  the  licensing  and  inspection  process,  use  of  inspection  proto-
cols/forms, involvement of zoos’ federations and/or other external experts, detail of Article 3 inspec-
tions) (Section 5.2.1.1, paragraph b). The responses obtained to both surveys and interviews from all 
stakeholders,  as  well  as  the  analysis  carried  out  under  ‘Effectiveness’  (Section  5.1.1),  suggest  that 
these differences can be considerable. However, zoos did not suggest that the requirements of Article 
3 were overly burdensome.  

Regarding the benefits, as discussed under Section 6.3.1, the analysis has been mainly based on stake-
holder opinions, and it has been constrained by the difficulty of expressing the benefits in quantitative 
or monetary terms. Although implementation and enforcement issues remain,  the Zoos Directive has 
ensured the setting up of the legal framework for licensing and inspection, has triggered the implemen-
tation of conservation measures among EU zoos and represents a key instrument for the achievement 
of the general objectives in terms of protection of wild fauna and conservation of biodiversity set at 
European and international level.   

In parallel, most stakeholders agreed that the Zoos Directive had brought benefits in terms of the con-
tribution  of  zoos  to  biodiversity  conservation.  These  benefits  arose  from  both direct  conservation  of 
species and the raising of public awareness of biodiversity conservation issues, as well as  improving 
the  husbandry  of  animals.  Some  zoos  and  zoos’  federations  felt  that  the  Zoos  Directive  gave  legal 
support  to  their  efforts  to  participate  in  species  (and  wider)  biodiversity  conservation  in  a  more  fo-
cused way (Section 5.2.1.2).  

Whilst these positive perceptions were widely held and were consistent across all stakeholder groups, 
it remains difficult to demonstrate the extent to which these benefits can be attributed to the implemen-
tation of the Zoos Directive as other external factors were involved (the evolution of zoos as institu-
tions, the change in expectations of the general public, the work of various stakeholders). Further to 
this, the extent of the Directive's impact on species and wider biodiversity conservation was impossi-
ble to measure.  

Despite this, the perceptions were strong, with neither MSCAs nor zoos suggesting that the costs of 
implementing the Directive were disproportionate to the benefits (Section 5.2.2.1). Some of the small-
er zoos did suggest that their more limited resources (funds and personnel) challenged their capacity to 
comply,  but  no  strong  evidence  that  smaller  zoos  have  faced  higher  difficulties  emerged  (Section 
5.2.1.3).  

In conclusion, although a comparison of costs and benefits in quantitative or monetary terms has not 
been feasible nor appropriate, the findings of the analysis suggest that the Directive has triggered lim-
ited costs, while benefits brought appear to be significant and encompass several dimensions: public 
education  and  knowledge  of  biodiversity,  improved  standards  for  animal  accommodation,  establish-
ment  of  a  coherent  legal  framework  across  the  EU,  implementation  of  conservations  by  zoos  which 
contribute to the protection of biodiversity. As such, in absence of evidence on disproportionate costs 
and as pointed out in the public consultation, a purely qualitative comparison suggests that there is a 
positive  balance,  with  important  benefits  brought  about  by  the  Zoos  Directive  exceeding  its  rather 
limited costs.  

Unnecessary burden and best practices 

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Overall, there was no evidence of unnecessary regulatory burden on either the zoos themselves or the 
regulatory bodies responsible for implementing the Directive. Administrative costs related to the Zoos 
Directive appear strictly related to the necessary procedures for obtaining (from the point of view of 
zoos) or issuing (from the point of view of MSCAs) the licence. Stakeholders consulted did not raise 
any specific issues of burdensome or complex requirements and/or procedures that could be avoided 
or reduced (Section 5.2.4.1). 
Significant variations exist between Member States in a wide range of factors, including legal, execu-
tive  and  operational,  that  seem  likely  to  influence  the  implementation  of  the  Directive,  its  costs  and 
benefits.  This  has  resulted  in  a  complex  picture,  where  the  variation  between  Member  States  means 
that definitive conclusions cannot be drawn about each aspect of the implementation of the Directive 
and  its  attendant  costs  and  benefits.  Insights  on  possible  best  practices  and  needs  for  simplification 
were drawn from responses to the survey. These suggested that variation between Member States in 
the  licensing  and  inspection  system  are  mainly  associated  with  the  capacity  of  the  national  inspec-
torates (resources, skills and competences) rather than with specific requirements of the national legis-
lation. Moreover, stakeholders suggested that the licensing process works well in countries where the 
lines of responsibility are clear and all available expertise is used.  Best practices suggested by stake-
holders related to improved guidance and involvement of external experts in the inspection process (in 
order to provide specialised expertise during the inspections)344, and elimination of possible duplica-
tions due to controls carried out under different legislative acts (i.e. under Regulation (EC) No 338/97 
on  the  protection  of  species  of  wild  fauna  and  flora  by  regulating  trade  therein,  and  Directive 
92/65/EEC on animal health requirements for trade in and imports into the EU) (Section 5.2.3.1). 

6.3.3  Relevance 

The Zoos Directive was  adopted in 1999 and has been  in force for 16 years without further amend-
ments.  Relevance  assessed  the  extent  to  which  the  objectives  set  at  the  time  of  adoption  of  the  Di-
rective still correspond to the current legal, policy and scientific situation.  

The  analysis  relied  mostly  on  scientific  sources  and  relevant  legal  and  policy  documents.  This  was 
completed  by  information  gathered  through  the  stakeholders’  consultations  (survey,  interviews  and 
public consultation).   

In answer to EQ 9 (Section 5.3.1), the analysis demonstrated that the objectives of the Directive still 
support  the  current  needs  in  terms  of  protection  of  biodiversity  conservation  within  the  EU  and 
globally.  

Scientific evidence attests to the deteriorating status of conservation (both in terms of species and hab-
itats). For instance, whereas in 2000 8,5 % of species were listed as threatened, this share increased to 
nearly 30% of the 80,000 species assessed on the IUCN red list in 2016 (see Section  5.3.3.1). It also 
shows improvements in understanding the status of conservation, especially in terms of protection of 
threatened species and of public awareness of biodiversity conservation issues (Section 5.3.1.2).  

Therefore, the priority given to biodiversity conservation in the Directive is still relevant.  

Relevance of the Directive’s objectives against current objectives at EU and global level 

The need to protect biodiversity conservation is significantly greater now than at the time of the adop-
tion  of  the  Directive,  and this  evolution  is  reflected  in  the  changes  in  policy  objectives  at  EU  and 
international level (Section 5.3.2 - EQ 10). The Zoos Directive was framed as a response to the CBD 
but the targets set to achieve the Convention’s objectives have evolved markedly over the past decade, 
as  have  other  EU  and  international  instruments.  The  global  biodiversity  conservation  community’s 

344 The involvement of external experts and multidisciplinary teams in the inspection process is also consistent with the findings of the EC 
Good Practices Document (VetEffecT 2015). 

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understanding of both the scale of biodiversity deterioration and the pressures driving it is now much 
sharper and there is a clear emphasis on halting extinctions and reducing threats. This is, for instance, 
demonstrated by the EU Biodiversity Strategy (Section 5.3.2.1).  

Policy,  scientific  and  technical  developments  now  provide  a  more  structured  context  for  zoos  to 
contribute to the needs of biodiversity that have been identified, and to offer guidance on how this can 
be done. In policy terms, there are now quite specific targets for biodiversity in both the CBD and the 
UN SDGs and they include both halting extinctions and raising public awareness of the importance of 
biodiversity. They also demonstrate the importance of biodiversity to the attainment of other develop-
ment targets established in the SDGs. 

These elements are well covered in the Directive, and the targeted survey showed that a majority of 
respondents  consider  the  Directive  to  contribute  to  CBD  Aichi  Targets  relating  to  public  awareness 
(Target 1) and avoiding species extinctions (Target 12) (see graphs in Section 5.3.2.2).  

The evolution of international instruments from general aspirations to focused targets has resulted in 
more specific objectives in relation to the conservation of biodiversity,  to which ex situ management 
can contribute. While these more specific objectives and indicators facilitate the implementation of the 
Zoos Directive's framework provisions, there is a general need to be more explicit about where ex situ 
management is most needed and could have the biggest impact in achieving conservation objectives. 
This criticism is supported by previous reports345 and stakeholders in the present survey (zoo opera-
tors, federations) pointed to the need for a more targeted approach to ex situ conservation to meet the 
new, more specific objectives set at EU and international level.  

Scientific and technical developments 

There have been many scientific and technical developments in the field of biodiversity conservation 
since 1999, in  particular in the areas of population management,  identification of species in  need  of 
conservation action, and determination of the actions needed for threatened species (Section 5.3.3.1). 

More specifically, in relation to scientific and technical developments in the field of  ex situ manage-
ment, considerable progress has been made since the adoption of the Directive in relation to the inter-
action  between  in  situ  and  ex  situ  conservation  (Section  5.3.3.2).  This  interaction  is  for  instance 
illustrated by the increasing participation of EU zoos to in situ conservation projects (Section 5.1.2.1 
and 5.1.2.2).   

Due to its broad scope and formulation, the Directive does not contain any outdated requirements in 
relation  to  these  developments,  and  the  results  of  stakeholders’  consultations  supported  this  conclu-
sion.  The  majority of  stakeholders  responding  to  the  targeted  surveys  (82%)  considered  that  the  Di-
rective remains appropriate in light of subsequent technical and scientific developments. There is a 
strong sense that it is particularly well adapted given scientific and technical progress in the field of 
biodiversity generally.  

Stakeholders nevertheless also indicated that the interaction between  in situ and ex situ conservation 
could be significantly enhanced in the Directive. Indeed, some respondents to the survey felt that such 
strengthening is happening outside of the Directive, such as through the WAZA (Section 5.3.3.3).    

6.3.4  Coherence 

The  coherence  analysis  focused  on  the  role  of  the  Zoos  Directive  in  the  wider  EU  policy  and  legal 
framework  in  relation  to  biodiversity  conservation  and  animal  welfare  issues.  It  evaluated  how  well 

345 LIFE preventing species extinction, Safeguarding endangered flora and fauna through ex situ conservation, European Commission 2011, 
at: 
http://ec.europa.eu/environment/life/publications/lifepublications/lifefocus/documents/reintroduction.pdf  

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the Directive works with the other instruments existing at EU level, by providing evidence of syner-
gies  and  complementarities  that  could  reinforce  the  achievement  of  common  objectives,  but  also  by 
looking at potential inconsistencies and overlapping obligations that could lead to inefficiencies. The 
evaluation  of  coherence  also  sought  to  examine  the  extent  to  which  the  Directive  supported  the  EU 
internal market and the creation of a level playing field for zoos across the EU.  

The results of the supporting study in relation to coherence relied primarily on legal analysis, but were 
also complemented by stakeholders’ consultations. 

Complementarity and interactions with other EU instruments  

As demonstrated in Section 5.4.1 in relation to EQ 12, the Directive is coherent with the EU legal and 
policy framework on biodiversity conservation and animal welfare. The coherence analysis focused on 
the  legal  examination  of  the  strategic  objectives  and  specific  provisions  of  the  targeted  legislation, 
with a view to assessing their consistency with the Zoos Directive. The legislation examined includes: 

  Directive  2009/147/EC  on  the  conservation  of  wild  birds  (Birds  Directive)  and  Directive 
92/43/EEC  on  the  conservation  of  natural  habitats  and  of  wild  fauna  and  flora  (Habitats 
Directive) (together, the Nature Directives). 

  Regulation  (EC)  No  338/07  on  the  protection  of  species  of  wild  fauna  and  flora  by  regulating 

trade therein (EU Wildlife Regulation). 

  Regulation (EU) 1143/2014 on invasive alien species. 
  Directive  92/65/EEC  laying  down  animal  health  requirements  for  trade  in  and  imports  into  the 

EU of animals, semen, ova and embryos not subject to other specific rules. 

  Regulation (EC) 1739/2005 laying down animal health requirements for the movement of circus 

animals between Member States. 

The legal analysis revealed no inconsistencies between the Zoos Directive and the legislation exam-
ined. On the contrary, there are examples of positive interactions that strengthen the achievement of 
their  shared  objectives.  Biodiversity  conservation  is  not  only  the  primary  objective  of  the  Zoos  Di-
rective,  but  also  of  the  Nature  Directives,  the  EU  Wildlife  Regulation  and  the  IAS  Regulation.  The 
mechanisms  are  well  articulated,  for  instance  with  the  use  of  cross-references  (EU  Wildlife  Trade 
Regulation and Nature Directives) and derogations (EU Wildlife Trade Regulation). The requirements 
are also consistent, as illustrated by the regulatory requirements regarding the escape of animals in the 
IAS  Regulation,  or  the  record-keeping  required  under  Directive  92/65/EEC.  Synergies  can  also  be 
observed  in  the  implementation  of  the  Zoos  Directive  and  other  EU  instruments,  for  instance  in  the 
field  of  education  (e.g.  zoos  informing  the  public  on  invasive  alien  species),  but  also  in  the  use  of 
funding  (in  particular  via  LIFE  funding  for  conservation  projects  carried  out  by  zoos  (see  Section 
5.1.2.3).  

Taken  together,  these  instruments  establish  a  comprehensive  system  for  biodiversity  conservation  in 
the EU, and contribute to the compliance of the Union with its obligations under the CBD.  

At the same time, there is scope for further synergies in order to reinforce the effectiveness of the legal 
framework  applicable  to  zoos  and  their  contribution  to  biodiversity  conservation.  For  instance,  the 
organisation of joint inspection procedures to ensure compliance with the different pieces of legis-
lation applicable to zoos was observed as a good practice to prevent inefficiencies and the duplication 
of the work required from zoos and CAs to prepare and carry out the inspections.  

Certain stakeholders and members of the wider public participating in the public consultation pointed 
to some inconsistencies between the Zoos Directive and Regulation No. 1739/2005 on the movement 
of  circus  animals  (Circus  Regulation),  as  well  as  the  IAS  Regulation.  However,  the  legal  analysis 
found  no  coherence  issues.  With  regard  to  the  Circus  Regulation,  it  should  be  noted  that  given  the 
clear exclusion of circuses from the scope of the Zoos Directive, there is no interaction between the 
two acts. Concerning the IAS Regulation, even though zoos are required to ban the keeping and breed-

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ing of IAS, this is fully in line with the biodiversity conservation objectives embodied in the Zoos 
Directive and the IAS Regulation, in view of the particularly negative impact that a spread of inva-
sive alien species may have on local biodiversity. While it is acknowledged that zoos are not the main 
pathways for invasive alien species, there is evidence that they can operate as such pathways, thereby 
justifying the strict approach of the IAS Regulation. There are, therefore, no inconsistencies between 
the two acts. 

Level playing field among EU economic operators 

In answer to EQ 13 (see Section 5.4.2), the coherence analysis also examined the extent to which the 
Zoos Directive has supported the EU internal market and the creation of a level playing field for zoos 
across the EU, which is particularly important with regard to SMEs. Prior to the adoption of the Di-
rective,  not  all  Member  States  had  legislation  in  place  to  regulate  the  activities  of  zoos.  By  making 
zoos in the EU subject to certain harmonised requirements, such as the obligation to hold a licence, to 
be subject to inspections, and to adopt the conservation measures provided in Article 3, the Zoos Di-
rective established a coherent legal framework for all EU zoos.  

However, there are still significant discrepancies both in the obligations imposed on zoos (see Section 
5.1.3.1 and Section 5.5.2.1) and in the level of enforcement in the different Member States (see Sec-
tion 5.1.1). These discrepancies prevent the full achievement of a level playing field among Euro-
pean zoos.  

This partial completion of the level playing field is reflected in the nuanced results of the targeted con-
sultation,  where  53%  of  stakeholders  who  expressed  an  opinion  believed  that  the  Directive  has 
brought no benefits or only minor benefits through establishing a level playing field between zoos in 
different Member States.  

6.3.5  EU added value 

The criterion of EU Added Value aims to examine, from a qualitative perspective, the extent to which 
the  Zoos  Directive  has  contributed  to  strengthening  the  role  of  zoos  and  promoting  the  adoption  of 
conservation  measures  in  a  way  that  could  not  have  been  achieved  by  Member  States  on  their  own 
and/or by other stakeholders. It also examined the need for continued EU action.  

Analysing the added value of the Directive in line with the intervention logic of the Directive (Section 
2.2) and the evaluation framework (Section  3.2) was impaired by two critical limitations in the data 
available. Firstly, due to the absence of an impact assessment prior to the adoption of the Directive, 
only limited information was available to understand the situation in the Member States before entry 
into force of the Directive. To overcome this lack of information, a baseline was defined by analysing 
the  legislative  frameworks  applicable  in  Member  States  in  1992,  by  reviewing  the  1988  European 
Survey of Zoological Collections, and by interviewing experts in biodiversity conservation involved in 
the adoption of the Zoos Directive. The second data limitation concerned the lack of monitoring and 
reporting requirements under the Directive. Such data would have helped  to provide a full picture of 
the evolution in the implementation of the Directive across Member States. Information to understand 
this  evolution  was  instead  gathered  through  the  targeted  surveys,  in-depth  interviews  and  the  public 
consultation.  

The  results  of  the  analysis  indicate  that  the  Zoos  Directive  has,  to  some  extent,  achieved  more  than 
could have been reasonably expected to occur from individual actions of Member States, and is per-
ceived as a necessary instrument for continued EU action in the field of ex situ conservation. 

Creation of a common legal framework 

The EU added value of the Directive mainly resides in the creation of a common legal framework 
at the EU level, setting binding rules and, as such, prompting the adoption of conservation measures 

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among  all zoos (see Section  5.5.1.1 on the added value of the Directive compared to what could be 
achieved  by  Member  States  at  national  and/or  regional  level).  It  is  unlikely  that  this  overall  result 
would  have  been  achieved  under  national  legislation,  through  participation  in  international  agree-
ments, or based on the membership requirements of zoos’ federations. Before the adoption of the Zoos 
Directive, national legislation was absent in most Member States. Where national rules were in place 
(Belgium, Denmark, France, Spain, and the UK), they included requirements for licensing and inspec-
tion, but were mainly concerned with conditions for animal accommodation and animal welfare, with-
out any wider focus on conservation objectives.  

Standards and guidelines were provided by zoos’ federations (such as EAZA) prior to the adoption of 
the Directive. Still, the limitations in terms of coverage (approximately 17% of licensed zoos are part 
of EAZA), scope (in the early 90s, mainly focused on accommodation and care of animals) and their 
non-binding nature are all factors that would have hindered the promotion of conservation measures 
among EU zoos, at least at a scale comparable with the Directive’s objectives. The Zoos Directive has, 
therefore, played a crucial role in setting the legal framework for the implementation of conservation 
measures among all zoos.  

However, the Zoos Directive has contributed only partly, and jointly with other external factors, to the 
implementation of conservation measures and to a strengthened role of zoos as revealed by the results 
of the consultation targeting zoo operators. Also, the extent of the Directive's contribution to the con-
servation of biodiversity and protection of wild fauna remains unclear.  

On the other hand,  factors independent from the Directive have  contributed to the uptake of con-
servation measures among some zoos. As already mentioned, the work done by zoos’ federations 
(i.e. definition of guidance and standards) remains an important element behind the increased efforts in 
conservation activities among zoos. Not surprisingly, around 50% of zoos (26 out of 53) replying to 
the targeted consultation and belonging to a zoo federation, declared that the Zoos Directive did not 
contribute to implementing new conservation measures or improving the existing ones. The message 
given is that these zoos would have implemented conservation measures in any case, as part of federa-
tions’  membership  requirements.  In  parallel,  the  broader  changes  concerning  the  role  of  zoos  and 
the attitude of visitors ongoing at global level, and the ambitions of zoo owners, taking public opin-
ions seriously, had a role in shaping the shift towards an increased conservation focus. Unlike the Zoos 
Directive  that  prompted  changes  applicable  to  all  zoos,  these  factors  apply  mainly  to  zoos  that  are 
either part of zoos’ federations or led by conservation-oriented managers. This aspect is corroborated 
by survey answers from zoo operators and discussions held during the Workshop on the REFIT evalu-
ation of the Zoos Directive (Brussels, 16 May 2017), which reflected that the Zoos Directive mainly 
impacted  facilities  that  are  not  members  of  zoos’  federations,  thus  contributing  to  bridging  the  gap 
between members and non-members of zoos’ federations. 

Overall, the Zoos Directive has prompted the establishment of a legislative framework applicable 
to all zoos although, in practice, the adoption of conservation measures by all zoos is still hampered 
by implementation issues. While the concurrence of other factors and broader trends should also 
be considered  when examining  the general changes  observed, the same results would  not  have been 
achieved on the basis of national legislation or of other instruments of non-binding nature (e.g. stand-
ards  of  zoo  federations).  The  Directive  has  therefore  demonstrated  added  value  in  promoting  the 
adoption of conservation measures among zoos, although with limitations in the realisation of its po-
tential, and together with other and interlinked factors.  

Need for continued EU intervention 

Looking onwards to the need for EU action (EQ 15, see Section 5.5.2), several elements suggest that 
there is still a need for EU intervention. Firstly, the objectives of the Directive have only been partly 
achieved  (see  section  5.1).  Secondly,  harmonisation  across  EU  Member  States  only  happened  to  a 
limited extent. The minimum requirements set by the Directive have been further specified at national 
level to ensure the implementation and enforcement of the EU legislation. As a consequence,  differ-

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ences  in  national  systems  for  implementation  and  enforcement  exist,  but  also  inconsistencies  be-
tween  zoos  in  different  Member  States  remain  and  hinder  overall  harmonisation.  More  coordinated 
implementation  supported  by  initiatives  at  EU  level  (such  as  the  translation  of  the  Good  Practices 
Document) was reported as desirable by stakeholders during the Workshop on the REFIT evaluation 
of the Zoos Directive. 

In parallel, it has been recognised that existing international conventions (CBD and CITES) and non-
legislative instruments (standards and guidelines of zoos’ federations)  could contribute to enhancing 
the  role  of  zoos  as  conservation  centres.  However,  these  instruments  would  not  enable  the  full 
achievement of the objectives of the Zoos Directive. Firstly, the Zoos Directive is instrumental to the 
practical implementation of the principles enshrined in international agreements such as the CBD and 
CITES. Secondly, standards and guidelines defined by zoos’ federations can contribute only to a cer-
tain extent. These instruments lack the key feature of the Zoos Directive: its binding value. As such, 
the  Directive  remains  important  for  promoting  and  ensuring  the  implementation  of  conservation 
measures by zoos.  

The need for continued EU action in this field has been largely recognised by stakeholders. EU-wide 
rules  in  relation  to  different  aspects  of  ex  situ  conservation  (e.g.  keeping  animals  under  appropriate 
conditions,  promoting  education,  protecting  threatened  species)  are  considered  important  by  a  large 
majority of the respondents to the public consultation (on average, more than 80% of the respondents). 
While zoos and public authorities agreed that most of the activities currently promoted by zoos would 
continue even in the absence of the Directive, other stakeholder categories (including individuals and 
NGOs) were less confident (on average, less than half of the respondents believed that activities would 
continue).   

Finally, as considered under EQ 16 (Section 5.5.3), should the Zoos Directive be removed, although 
CAs would not expect national legislation to be repealed, concerns remain about the consequences of 
such a message at EU level. Additional concerns highlighted in stakeholders’ consultations were the 
risks of widening existing gaps between zoos that are members of organisations and zoos that are not, 
as well as an increase in illegal trade and a decrease in animal welfare. 

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Questions of the con-
sultation tools 
Zoos Questionnaire:  
Question 25 – 44. 

Interview  questions: 
1,2,4. 

ANNEX I – EVALUATION FRAMEWORK 

Table 34: Effectiveness 

Evaluation question 

Sub-questions 

Indicators 

Success criteria 

Sources of information 

EQ  1  What  progress 
has  been  made  over 
time  towards  achiev-
ing  the  objectives  set 
out in the Directive? 
To  what  extent  is  this 
progress  in  line  with 
initial expectations?  
In  particular,  what 
progress  has  been 
made to achieve the 
conservation 
measures  set  out  in 
Article 3?  
To  what  extent  have 
adequate 
licencing 
inspection  sys-
and 
tems  been  put 
in 
place?  

EQ  1.1  What  progress 
has  been  made  to 
ensure  that  zoos  im-
plement  the  conser-
vation  measures  set 
out 
in 
in  Article  3, 
relation  to  the  follow-
ing requirements: 
A.  To  participate  in 
research, 
train-
ing,  exchange  of 
information,  cap-
breeding, 
tive 
repopulation 
and/or 
reintro-
duction  of  spe-
cies into the wild 
To  promote  pub-
education 
lic 
aware-
and 
ness/provide 
in-
formation  about 
species  exhibited 
and their habitats 
accommo-
date  animals  un-
der 
conditions 
which aim to sat-
isfy the biological 
and conservation 
requirements and 
maintain 
high 
standard  of  ani-

C.  To 

B. 

  Majority of surveyed zoos 
participating  in  activities 
related to objective A.  
  Animals bred in surveyed 
zoos  re-introduced 
into 
the wild.  
Species  downgraded  in 
red  lists/taken  off  red  lists 
because  of  zoos  conser-
vation projects.  

 

 
 
 

Literature  
‘Grey literature’ 
Interviews 
CAs  and 
representatives 
 
Targeted survey 
  Annual  reports  of 

with 
zoos’ 

zoos 

Indicators  related  to  the  spe-
cific objective A: 
 

Proportion  of  zoos 
sur-
veyed  (in  the  selected 
MS)  involved  in  research 
projects. 

 

involved 

  Main areas of research. 
 
sur-
Proportion  of  zoos 
veyed  (in  the  selected 
MS) 
in  training 
programmes on conserva-
tion skills, by type of target 
audience (zoo staff, veter-
inarians,  volunteers,  etc.) 
over  the  implementation 
period. 
sur-
Proportion  of  zoos 
veyed  (in  the  selected 
MS)  participating  in  infor-
mation  sharing  activities, 
between  zoos  and  with 
other  stakeholders,  over 
the  implementation  peri-
od. 
Proportion  of  zoos 
sur-
veyed  (in  the  selected 
in  con-
MS)participating 
pro-
servation 
grammes/projects, 
such 
as EEPs and ESBs. 

 

Indicators  related  to  the  spe-
cific objective B: 

  Adoption  of  information 
strategies and awareness 

 
 

Literature  
‘Grey literature’ 

Zoos  Questionnaire: 
Question 45 – 50.  

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Evaluation question 

Sub-questions 

Indicators 

Success criteria 

Sources of information 

Questions of the con-
sultation tools 

Interview  questions : 
1,2,4. 

Zoos  Questionnaire: 
Question 54 – 61. 

Interview  questions : 
1,2,4. 

with 
zoos’ 

Interviews 
CAs  and 
representatives 
Targeted survey 
Public  consulta-
tion 

 
 

  Annual  reports  of 

zoos 

 
 
 

Literature  
‘Grey literature’ 
Interviews 
CAs  and 
representatives 
 
Targeted survey 
  Annual  reports  of 

with 
zoos’ 

zoos 

 

 

mal husbandry 
D.  To  prevent  es-
cape  of  animals 
intrusion  of 
and 
outside pests and 
vermin 
To  keep  records 
of  the  zoo's  col-
lection? 

E. 

Proportion  of  zoos 
sur-
veyed  (in  the  selected 
MS)undertaking 
public 
education programmes. 
Proportion  of  zoos 
sur-
veyed  (in  the  selected 
MS)having  defined  an  
and awareness raising ac-
tivities. 

 

 

Indicators  related  to  the 
specific objective C: 
  Number  of  Member  State 
authorities  having  estab-
lished  mandatory  mini-
mum  standards  for  ani-
accommodation, 
mals’ 
species specific. 
Proportion  of  zoos 
sur-
veyed  (in  the  selected 
in  environ-
MS)investing 
mental 
enrichment 
measures. 
Proportion  of  zoos 
sur-
veyed  (in  the  selected 
minimum 
MS)applying 
standards  for  accommo-
dation  of  animals  issued 
by  authorities  or  other  or-
ganisations. 
Proportion  of  zoos 
sur-
veyed  (in  the  selected 
MS)with  special  educa-
tional requirements for an-
imal caretakers. 
Proportion 
zoos 
surveyed  (in  the  selected 

of 

 

 

 

raising  activities 
veyed zoos.  

in  sur-

 

  Majority  of  zoos  visitors 
who  participated  in  the 
public  consultation  con-
firm 
in-
they're  well 
formed,  take  part  in  ed-
im-
ucation  activities, 
prove 
their  knowledge 
on biodiversity.  

in 

  Majority  of  the  Member 
sample 
States 
have  established  man-
datory  minimum  stand-
ards. 

the 

  Majority of surveyed zoos 
investing  in  environmen-
tal enrichment measures. 
  Majority of surveyed zoos 
minimum 
applying 
for  accom-
standards 
modation  of  animals  is-
sued  by  authorities  or 
other organisations.  
  Majority of surveyed zoos 
with  special  educational 
requirements  for  animal 
caretakers. 

  Capacity  to  ensure  pre-
ventive  and  curative 
health 
programmes 
generally in place.  

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Sub-questions 

Indicators 

Success criteria 

Sources of information 

Questions of the con-
sultation tools 

MS)  with  preventive  and 
curative 
health 
capabilities  (e.g.  hygiene 
plans,  nutrition  and  health 
programmes,  in-house  or 
external 
qualified 
veterinarians). 

 

Limited  number  of  es-
capes from zoos over the 
implementation period. 

  Majority of surveyed zoos 
have  plans  to  prevent 
both  intrusion  of  outside 
pests and vermin.. 

  Majority of surveyed zoos 
in  the  sample  have  es-
tablished  a  record  keep-
ing  system  with  the  mini-
mum features described. 
  Majority  of  EU  and  inter-
national 
stakeholders 
agree  on  the  improved 
availability  and  quality 
(or  accuracy)  of  availa-
ble records. 

 
 
 

Literature  
‘Grey literature’ 
Interviews 
CAs  and 
representatives 
 
Targeted survey 
  Annual  reports  of 

with 
zoos’ 

zoos 

 
 
 

Literature  
‘Grey literature’ 
Interviews 
CAs  and 
representatives 
 
Targeted survey 
  Annual  reports  of 

with 
zoos’ 

zoos 

Zoos  Questionnaire: 
Question 62 - 64. 

Interview  questions : 
1,2,4. 

Zoos Questionnaire:  
Question 65-67. 

Interview  questions: 
1,2,4. 

Indicators  related  to  the  spe-
cific objective D: 
  Number  of  escapes  of 
species  hazardous  to  in-
digenous 
from 
zoos  over  the  implemen-
tation period.  
Proportion  of  zoos  having 
established  a  formal  plan 
to prevent intrusion of out-
side pests and vermin. 

species 

 

Indicators  related  to  the  spe-
cific objective E: 
 

a 

Proportion  of  zoos  that 
established 
record 
keeping  system  with  the 
following 
features:  Elec-
tronic record keeping, col-
lection  of  individual  rec-
ords,  complete  coverage 
of  the  zoo  collection,  in 
line  with  main  national 
trade 
international 
and 
regulations  (e.g.  Council 
Regulation  338/97,  and 
Commission 
Regulation 
865/2006). 

EQ 1.2 To what extent 
have  adequate 
li-
censing  and  inspec-

  Number of MS in the sam-
ple  that  have  designated 
a  competent  authority  for 

  MS  in  the  sample  have 
designated  and  clearly 
identified  a  competent 

 
 
 

Literature  
‘Grey literature’ 
Interviews 

with 

Question-

MSCAs 
naire:  
Question 7 – 73. 

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sultation tools 

NGOs&Federation 
Questionnaire:  Ques-
tion 39 – 43.  

Zoos: 76 - 77.  

Interview  questions: 
7-8. 

Public  consultation: 
Question 25 

Evaluation question 

Sub-questions 

Indicators 

Success criteria 

Sources of information 

tion systems been put 
in  place  in  the  Mem-
ber States? 

the implementation of the 
Directive.  

 

 

to  verify 

  Number  of  zoos  licensed 
within  four  years  since  the 
entering  into  force  of  the 
Directive, in relation to the 
number  of  zoos  licensed 
after the four years period, 
in the selected MS. 
Estimated  number,  and 
trend  over  the  implemen-
tation  period,  of  licensed 
in 
and  unlicensed  zoos 
the selected MS (if availa-
ble),  by  status  of  the  pro-
cedure. 
Proportion  of  MS  that  de-
fined  specific  criteria  and 
guidelines 
the 
implementation  of  Article 
3 measures by zoos. 
Frequency  of  regular  in-
spections  in  the  selected 
MS. 
Proportion  of  MS  in  the 
sample having established 
rules  for  the  effective  re-
location  of  animals  under 
appropriate 
conditions, 
following  the  closure  of  a 
zoos (specific objective F).  
Proportion  of  Member 
States  in  the  sample  hav-
ing  established  national 
action  plans,  rescue  cen-
tres/sanctuaries,  and/or 
collaboration projects with 
NGOs,  in  case  of  closure 

 

 

 

zoos’ 

CAs  and 
representatives 
 
Targeted survey 
  Annual  reports  of 

 

 

 

zoos 
Records  of  num-
ber of licenses 
Records  of  num-
ber  of  inspections 
and  frequency  of 
the  inspections  in 
the MS 
Records  of  zoo 
closures 

 

authority  for  the  imple-
mentation  and  applica-
tion of the Directive.  
  Most  of  the  zoos  in  the 
selected  MS  have  been 
licensed  within  the  four 
years transition periodf.  
Increasing  number  of 
licensed  zoos  over  the 
implementation  period, 
compared  to  the    esti-
mated  number  of  unli-
censed  zoos  (including 
pending procedurs). 
  Most  of  the  MS  in  the 
sample  conduct  inspec-
tions  on  the  basis  of  de-
fined  criteria  and  guide-
lines.  
Inspections  planned  at 
regular  intervals  and  in 
line  with  the  good  prac-
tices identified during the 
evaluation. 

 

  Majority 

in 

of 

of  Member 
States 
sample 
the 
have established specific 
procedures,  action  plans 
and  projects  in  case  of 
closure 
a 
zoo/relocation  of  ani-
mals. 
The  majority  of  stake-
holders  consider  penal-
ties  effective,  propor-
tionate and dissuasive. 
Breaches  are  detected 
and  closures  are  enact-

 

 

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Sub-questions 

Indicators 

Success criteria 

Sources of information 

Questions of the con-
sultation tools 

of  a  zoo/relocation  of  an-
imals  (specific  objective 
F). 

 

  Number  of  breaches  to 
the legislation detected in 
the selected MS. 

ed.  
The  staff  dedicated  to 
inspections  is  considered 
to  have  an  adequate 
background,  and  multi-
disciplinary teams are es-
tablished. 

 

  Number  of  closures  of 
zoos  as  a  sanction  as  per 
Article  6  of  the  Zoos  Di-
rective, 
in  the  selected 
MS. 
stakeholders 
Share  of 
considering  that  the  pen-
alties  defined  are  effec-
tive,  proportionate  and 
dissuasive. 
Level of quality of the staff 
in  charge  of  zoo  licensing 
and inspections. 

 

 

  Number  of  MS  having 
taken  actions  to  improve 
the  licensing  and  inspec-
tion system.  
Perception  of  the  ade-
quacy  of  the  systems  set 
up  by  the  MS  to  ensure 
that the zoos meet the re-
quirements  of  the  Zoos  Di-
rective (Art. 3).  
Perception  of  the  role  of 
zoos in the conservation of 
biodiversity.  

 

  Majority  of  the  selected 
MS  have  taken  action  to 
reinforce 
licensing 
the 
and inspection system. 

  A  majority  of  respond-
ents  considers  the  sys-
tems set by the MS as ef-
in  ensuring  the 
fective 
implementation  of 
the 
legislation.  

  A  majority  of  respond-
ents  considers  that  con-
the  pro-
tribution  of 
grammes 
im-
to 
proved protection of wild 
fauna  and  biodiversity  is 
high. 

the 

  A  majority  of  respond-

 
 
 

 
 

with 
zoos’ 

Literature  
‘Grey literature’ 
Interviews 
CAs  and 
representatives 
Targeted survey 
Public  consulta-
tion 

  Annual  reports  of 

 

zoos 
Statistics/records 
collected  by  the 
zoos 

Zoos  questionnaire: 
Question 68-72.  

MSCAs 
Question-
naire:  Question  74  – 
78.  

NGOs&Federation 
Questionnaire:  
Question 31 – 35.  

Public  consultation: 
Q.20, 21, 22. 

EQ  1.3  Is  progress  in 
line with expectations 
strengthened 
of  a 
role  of  zoos  in  the 
conservation  of  bio-
diversity? 

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Sub-questions 

Indicators 

Success criteria 

Sources of information 

ents  has  a  positive  per-
ception  of  the  role  of 
zoos  in  the  conservation 
of biodiversity. 

  A  majority  of  respond-
ents  considers  that  ani-
mals  are  accommodat-
ed  under 
satisfactory 
conditions. 
Zoos  activities  contribute 
to  the  conservation  of 
biodiversity. 

 

 

 

There  are  positive  inter-
the 
actions  between 
Zoos  Directive  and  rele-
vant  strategies,  policies 
and regulations. 
Indicators 
the 
achievements in relevant 
areas  of  the  Zoos  Di-
rective  show  a  positive 
trend. 

on 

EQ 2 What is the con-
tribution  of  the  Di-
rective  towards  en-
suring  the  protection 
of wild fauna and the 
conservation  of  bio-
diversity in the EU and 
globally  (including  its 
im-
to 
contribution 
plementing 
the  EU 
Biodiversity  Strategy 
and  EU  commitments 
international 
under 
conventions  such  as 
the  Convention  on 
Biological Diversity)? 

EQ  2.1  Does  ex  situ 
conservation 
con-
tribute  to    conserva-
tion of biodiversity? 

EQ  2.2  What  is  the 
the 
contribution  of 
to-
Zoos  Directive 
wards  ensuring 
the 
protection  of  wild 
fauna  and  the  con-
servation  of  biodiver-
sity  in  the  EU,  in  rela-
tion to implementing: 
 
the  EU  biodiversi-
ty strategy 

  Council  Regula-
tion No 338/97 on 
the  protection  of 
species  and  wild 

 

 

 

Evidence  of  the  role  of 
zoos  in  biodiversity  con-
servation  and  protection 
of wild fauna. 
Proportion  of  species  ex-
hibited that are on Global 
and/or 
European  Red 
Lists. 
Impact  of  measurs  of  Arti-
cle  3  undertaken  by  zoos 
in conservation.  

 

  Mapping  of  the  links  be-
tween  the  Zoos  Directive 
and 
relevant  strategies, 
policies and regulations. 
Indicators  related  to  the 
effectiveness  of  the  Zoos 
Directive  in  achieving  its 
specific objectives (in par-
ticular,  specific  objective 
A-  E),  in  areas  also  ad-
dressed  by  other  EU  poli-
cies. 

 

  Analysis  of 
the 
relevant 
interna-
tional documents  
with 
Interviews 
CA,  EU  and  inter-
national 
stake-
holders 
Literature review 
Public  consulta-
tion 

 
 

 

  Analysis  of 
the 
interna-
relevant 
tional documents  
Interviews 
with 
CA,  EU  and  inter-
national 
stake-
holders 
Targeted survey 

 

Questions of the con-
sultation tools 
Interview  questions: 
1,2,4. 

Mainly  based  on 
desk research, and 
Zoos  questionnaire: 
20-28, ; 
Question 
Question 36-39.  

Mainly  based  on 
desk research. 
See  EQ.  12  and  EQ. 
13.  

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Sub-questions 

Indicators 

Success criteria 

Sources of information 

Questions of the con-
sultation tools 

 

flo-

fauna  and 
ra346 
If  relevant,  other 
EU biodiversity re-
lated 
policies 
and legislation? 

EQ  2.3  What  is  the 
the 
contribution  of 
to-
Zoos  Directive 
wards  ensuring 
the 
protection  of  wild 
fauna  and  the  con-
servation  of  biodiver-
sity  at  the 
interna-
tional  level  in  relation 
to  the 
implementa-
tion of: 
 

the  Convention 
on  Biological  Di-
versity  (and  the 
Aichi Target 1) 
the  Convention 
on 
International 
Trade  in  Endan-
gered  Species  of 
Wild  Fauna  and 
Flora (CITES)347 
If  relevant,  other 
international 
agreements? 
EQ 3.1 How transposi-
tion,  implementation 
and  enforcement  by 

 

 

 

  Mapping  of  the  interac-
tions between the Zoos Di-
rective  and  other  interna-
tional agreements. 
Level  of  collaboration 
between CAs for zoos and 
the 
implementing 
CAs 
other 
international 
agreements.  
Indicators  related  to  the 
effectiveness  of  the  Zoos 
Directive  in  achieving  its 
specific objectives (in par-
ticular,  specific  objective 
A-  E),  in  areas  also  ad-
dressed  by  other  interna-
tional agreements.  

 

Mainly  based  on 
desk 
research  and 
interviews.  

  Analysis  of 
the 
relevant 
interna-
tional documents  
Interviews 
with 
CA,  EU  and  inter-
national 
stake-
holders 

 

T 

 

There  are  positive  inter-
actions  between 
the 
Zoos  Directive  and  other 
international 
agree-
ments. 

  Collaboration  between 

 

CAs is observed. 
Indicators  related  to  the 
effectiveness  of  the  Zoos 
Directive  in  achieving  its 
specific  objectives 
(in 
particular,  specific  ob-
jective A-  E)  in  areas  ad-
dressed  by  other  EU  poli-
cies. 

  Number  of  EU  court  cases 
related  to  Member  States 
infringements in relation to 

  Correct 

transposition, 
effective implementation 
and  enforcement  of  the 

 

Interviews with CA 
and  national  and 
EU stakeholders 

Zoos  Questionnaire: 
Questions 76 - 78.  

EQ3  Which  main  fac-
tors  (e.g.  implemen-
tation  by  Member 

346 Requiring the availability of adequate facilities for the accommodation and care of live specimens before their importation into the Community is authorised (Article 4 of the Council Regulation No. 338/97). 
347 Findings will be mainly extrapolated on the basis of the analysis of the contribution of the Zoos Directive to the  
above). 

Council Regulation No 338/97 on the protection of species and wild fauna and flora (mentioned 

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Evaluation question 

Sub-questions 

Indicators 

Success criteria 

Sources of information 

States,  action  by 
have 
stakeholders) 
contributed 
to  or 
stood  in  the  way  of 
achieving  these  ob-
jectives? 

Member  States  con-
tributed  to/impeded 
the  achievement  of 
the  objectives  of  the 
Zoos Directive? 

transposition, 

the 
imple-
mentation  and  enforce-
ment  of 
the  Zoos  Di-
rective,  and  underlying 
reasons. 

  Number of issues raised by 
stakeholders  in  relation  to 
the implementation of the 
Zoos Directive. 

  Number 

guidance 
of 
documents  by  MSCAs  in 
relation  to  the  Zoos  Di-
rective.  
Effective  system  for  licens-
ing  and  inspection  (indi-
cators under EQ 1.2). 

 

EQ  3.2  Have  specific 
actions  by  the  stake-
holders  contributed 
to/impeded 
the 
achievement  of  the 
objectives of the Zoos 
Directive? 
Which 
other  factors  had  a 
positive  or  negative 
effect? 

EQ4  Beyond 
these 
if 
objectives,  what, 
any,  other  significant 
changes  both  posi-

EQ  4.1  Are  there  sig-
nificant  environmen-
tal, social or econom-
ic  changes  (positive, 

  Adequate 
conservation 
measures 
implemented 
by  zoos  and  appropriate 
management 
(indicators 
under EQ 1.1). 

  Number  of  education 
programmes  and  public 
awareness  campaigns  (B) 
developed  with  the 
in-
volvement  of  stakehold-
ers. 
  Number 

guidance 
of 
documents  by  stakehold-
ers  in  relation  to  the  Zoos 
Directive. 

Stakeholder’s  opinion  on  the 
changes  linked  to  the  Zoos 
Directive. 

Zoos Directive. 

  Clear  provisions  of  the 
Zoos Directives/ no or lim-
ited  difficulties  linked  to 
the 
implementation  of 
the  Zoos  Directive  and 
corresponding factors. 

 
 

Targeted survey 
Public  consulta-
tion 

  Analysis  of  case 

law 
Literature 

 

  Guidance 

documents 
have been adopted and 
used  by  MSCAs    in  rela-
tion to the Zoos Directive. 
Effective  system 
li-
censing and inspection. 

for 

 

 

Interviews with CA 
and  national  and 
EU stakeholders 
 
Targeted survey 
 
Literature 
  Analysis  of 

rele-
vant  policies  and 
legislations 

 

  Adequate measures and 
appropriate  manage-
ment adopted by zoos.  
Stakeholder involvement, 
e.g. 
in  education  pro-
grammes  and  public 
awareness 
campaigns 
(B). 

  Guidance 

documents 
have been adopted and 
used  by  stakeholders  in 
relation  to  the  Zoos  Di-
rective. 

Questions of the con-
sultation tools 

Question-

MSCAs 
naire:  
Question  9-10 ;  Ques-
tion 17 ; Questions 23-
24 ;  Question  123  – 
125.  

NGOs&Federation 
Questionnaire:  Ques-
tion  39-43 ;  Question 
44-45.    

Public  consultation: 
Q. 25  

Interview  questions:  
6, 10. 

Zoos  Questionnaire: 
Question  25  –  42 ; 
Question 107 – 115.  

MSCAs 
Question-
naire:  Question  112  – 
126. 

Interview question: 3. 

identify  posi-

Stakeholders 
tive/negative/neutral 
changes  linked  to  the  Zoos 
Directive. 

 

 

Interviews 
with 
CAs  and  practi-
tioners 
Targeted survey 

Zoos  Questionnaire: 
Question 73 - 75.  

MSCAs 

Question-

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Evaluation question 

Sub-questions 

Indicators 

Success criteria 

Sources of information 

tive  and  negative 
can  be  linked  to  the 
Directive? 

neutral  or  negative) 
not  intended  or  fore-
seen? 

 

Public  consulta-
tion 

Questions of the con-
sultation tools 
naire:  Question  79- 
81. 

NGOs&Federation 
Question 36 - 38.  

Public  consultation: 
25 

Interview  question:  5, 
26. 

Table 35: Efficiency 

Evaluation question 

Sub-questions 

Indicators 

Success criteria 

Sources of information 

To be assessed in relation 
to  the  benefits  of  the 
Directive  (EQ  5.2)  and  in 
terms  of  differences  be-
large 
tween  small  and 
zoos (EQ 5.3).  

EQ  5.1  What  are  the 
costs  for  zoos  and  MS 
authorities  associated 
with 
implementa-
tion of the Directive? 

the 

EQ 5 What are the costs 
and  benefits  (monetary 
non-monetary) 
and 
associated  with 
the 
implementation  of  the 
Directive  for  the  differ-
ent 
stakeholders,  at 
local,  national  and  EU 
level?  Where  possible, 
an  estimate  of  costs 
broken  down  by  size  of 
enterprises 
(mi-
cro/small/medium-sized 
enterprises)  should  be 
provided. 

regulatory 
Estimates  of 
costs  (where  available), 
broken-down  according 
to  the  following  catego-
ries:  
I.  Substantive  Compli-
ance  costs  for  zoos  (re-
current  and/or  one-off), 
associated with:  
  Overall  implementa-
tion,  management 
and  monitoring  of 
the  compliance  with 
legislation  (e.g.  hu-
man 
to 
manage,  plan  and 
monitor  the  applica-
tion  of  the  EU  Di-
rective); 
Recurrent  costs  or 
investments 
one-off 

resources 

 

 
 
 

Literature  
‘Grey literature’ 
Interviews  with  CAs 
and 
repre-
zoos’ 
sentatives 
Targeted survey 
Public consultation  
reports  of 

 
 
  Annual 
zoos 

Questions of the consul-
tation tools 

Zoos 
Question 80-99.  

Questionnaire: 

MSCAs  Questionnaire: 
Question 86 – 100.  

NGOs&Federation 
Questionnaire: Question 
48-58. 

Public  consultation:  Q. 
27  

Interview  question :  11-
13. 

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Evaluation question 

Sub-questions 

Indicators 

Success criteria 

Sources of information 

Questions of the consul-
tation tools 

for  the  implementa-
tion  of  measures  as 
per  Article  3  of  the 
Directive  (a)  conser-
vation  research  and 
training;  b)  public 
education 
and 
awareness;  c)  ac-
commodating  ani-
mals  under  satisfac-
tory  conditions;  d) 
preventing  escape 
ecological 
and 
threats  and  e)  rec-
ord keeping). 

II. Administrative burdens 
for: 
 

(reporting  on 
zoos 
the  compliance  to 
the  legislation,  infor-
mation obligations to 
MS and related data 
collection, 
stocking 
of  documentation) 
and 

  MS  authorities  (e.g. 
costs  for  maintaining 
management  bod-
ies,  preparation  and 
review  of  strategies, 
management  plans, 
reporting  to  the  EC; 
costs 
licencing 
procedures including 
costs  for  personnel, 
training)  due  to  the 
Directive.  

for 

III.  Costs  of  enforcement 

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Evaluation question 

Sub-questions 

Indicators 

Success criteria 

Sources of information 

EQ  5.2  What  are  the 
benefits associated with 
the  implementation  of 
the Directive?  

by  MS  authorities  (costs 
of  inspections  including 
costs  for  personnel,  train-
ing,  costs  related  to  the 
closure of zoos).  
 

Trends  in  education-
al visits to zoos. 
Positive 
impact  of 
zoo  programmes  on 
biodiversity  (number 
of  zoo  conservation 
programmes 
in  situ 
and  ex  situ,  amount 
spent  on  conserva-
tion  in  situ  and  ex 
situ, staff involvement 
in  conservation)  and 
animal conditions. 
Recreation  opportu-
nities/wellbeing. 
Positive  impacts  on 
economic  aspects, 
such  as  creation  of 
employment,  attrac-
tion 
increase 
numbers of visitors.  

of 

 

 

 

EQ  5.3  Are  costs  and 
benefits associated with 
the  implementation  of 
the  Directive  propor-

 

Relative  differences 
between  small  and 
large zoos in terms of 
costs and benefits. 

 

 

 

 

 

 

 

Increasing number of 
educational 
visits 
(e.g. 
school  chil-
dren). 
Stakeholders  agree-
ing  on  the  fact  that 
major  or  significant 
benefits  have  been 
created  by  the  Zoos 
Directive, 
including 
economic benefits. 
Increasing  trends 
in 
the  number  of  edu-
cation  and  aware-
ness programmes. 
Increased  engage-
ment  in  conservation 
programmes 
over 
the 
implementation 
period. 
Better  accommoda-
for 
tion  conditions 
animals. 
Increased  wellbeing 
of  citizens  because 
of  better  quality  of 
recreation opportuni-
ties  (qualitative  as-
sessment).  
The extent of benefits 
small 
achieved  by 
and 
is 
comparable/ 

large  zoos 

Questions of the consul-
tation tools 

Zoos 
Question-
naire:Question 80 - 99.  

MSCAs  Questionnaire: 
Question 86 – 100.  

NGOs&Federation 
Questionnaire: Question 
48-58. 

Public  consultation:  Q. 
25 

Interview  question :  14  -
15. 

 
 
 

Literature  
‘Grey literature’ 
Interviews  with  CAs 
repre-
zoos’ 
and 
sentatives 
Targeted survey 
Public consultation 

 
 
  Annual 
zoos 
Records  of  visitors 
and  different  pro-
grammes. 

reports  of 

 

 
 
 

Literature  
‘Grey literature’ 
Interviews  with  CAs 
repre-
zoos’ 
and 

Zoos 
Question 94-95.  

Questionnaire: 

MSCAs  Questionnaire: 

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Evaluation question 

Sub-questions 

Indicators 

Success criteria 

Sources of information 

tionate  to  the  size  or 
kind of zoos? 

deemed  not  signifi-
cantly different. 

EQ 6 To what extent are 
the  costs  associated 
with  the  Directive  pro-
portionate to the bene-
fits that it has brought? 

EQ  6.1  Are  the  costs 
proportionate 
the 
benefits? 

to 

 

 

Proportion  between 
costs  and  benefits 
estimated 
(qualita-
tive comparison). 
Perception  of  stake-
holders 
regarding 
the  proportionality  of 
costs vs benefits rela-
tion 
imple-
mentation  of  the  Di-
rective. 

the 

to 

  Costs  do  not  exceed 
benefits  incurred  by 
implementation 
the 
of 
Directive 
the 
(qualitative  compari-
son).   

  A  majority  of  stake-
holders 
consider 
costs  proportionate 
to benefits.  

EQ  7  What  factors  influ-
the  efficiency 
enced 
the 
with 
which 
achievements 
ob-
served  were  obtained? 
In  particular,  what, 
if 
any, good or bad prac-
tices can be identified? 
If  there  are  significant 
cost/benefit  differences 
between 
Member 
States,  what  is  causing 
them? 

EQ  7.1  What 
factors 
influenced  the  efficien-
the 
cy  with  which 
achievements  of 
the 
Zoos  Directive  were 
obtained?  

 

 

EQ  7.2 
In  particular 
what,  if  any,  good  or 
bad  practices  can  be 
identified?  If  there  are 
significant  cost/benefit 
differences 
between 
Member  States,  what  is 
causing them? 

Level  of  discrepan-
cies/  differences 
in 
cost  drivers  across 
the selected MS. 
by 
Identification 
stakeholders of good 
and  bad  practices 
relating to  (variations 
in) efficiency levels.   

 

Identification 
of 
good  practices  that 
may  be 
replicated 
across  MS  and  of 
bad  practices  than 
should be avoided to 
enhance efficiency. 

 

 

Questions of the consul-
tation tools 

Question 98-99.  

sentatives 
Targeted survey  

 
  Annual 
zoos 

reports  of 

NGOs&Federation 
Questionnaire: Question 
54-55.  

  Outcome of EQ 5 
 

Interviews  with  CAs 
and 
repre-
zoos’ 
sentatives  
Targeted survey 

Interviews  with  CAs 
and 
repre-
zoos’ 
sentatives 
Targeted survey  

reports  of 

 
  Annual 
zoos 

Interview  question :  14  -
15. 
Zoos 
Question 91-93. 

Questionnaire: 

MSCAs  Questionnaire: 
Question 92-94. 

NGOs&Federation 
Questionnaire: Question 
51-52. 

Public  consultation:  Q. 
27 

Interview question : 16. 
Zoos 
Question 96.  

Questionnaire: 

MSCAs  Questionnaire: 
Question 100. 

NGOs&Federation 
Questionnaire :  Ques-
tion 53.   

Interview  question :  14  -
15 ; 17. 

EQ  8  Taking  account  of  EQ 8.1 Is there evidence 

  Qualitative  compari-

  All  provisions  of  the 

 

Interviews  with  CAs  Zoos 

Questionnaire: 

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Evaluation question 

Sub-questions 

Indicators 

Success criteria 

Sources of information 

there 

objectives  and 
the 
benefits  of 
the  Di-
rective,  what  evidence 
it  has 
that 
is 
caused 
unnecessary 
regulatory  burden  or 
complexity?  What  fac-
tors  identify  this  burden 
or  complexity  as  un-
necessary or excessive? 

that  the  Zoos  Directive 
has  caused  unneces-
sary  regulatory  burden 
or complexity?  

EQ  8.2  What 
factors 
identify  this  burden  or 
complexity  as  unneces-
sary or excessive? 

repre-

zoos’ 

and 
sentatives 
Targeted survey 

 

Directive are needed 
to achieve the bene-
fits that it seeks. 
Elements  that  create 
a  regulatory  burden 
have  a  precise  ra-
tionale  behind  and 
directly  contribute  to 
producing  benefits 
for stakeholders. 
limited 

in-
stances  of  excessive 
burden  observed  by 
stakeholders. 

  No  or 

son  between  the  el-
ements  that  create 
administrative 
bur-
den and the benefits 
brought. 

 

  Overlaps  in  require-
ments  between  the 
legislation 
transpos-
ing this Directive and 
other 
legal  require-
ments  in  the  select-
ed  Member  States 
resulting  in  increased 
administrative 
bur-
den.  
Stakeholder views on 
factors  that  identify 
an  excessive  burden 
of the Directive. 

 

Table 36: Relevance 

Evaluation question 

Sub-questions 

Indicators 

Success criteria 

Sources of information 

EQ  9  How  well  do  the 
(original) objectives (still) 
correspond 
the 
needs within the EU and 
globally? 

to 

EQ 9.1 Do the objectives 
of  protection  of  wild 
fauna  and  conservation 
of  biodiversity  corre-
spond  to  the  current  EU 
and global needs? 

  Degree  of  align-
ment  between  the 
current  trends  and 
issues  in  terms  of  bi-
odiversity  conserva-
tion,  and  the  issues 
addressed  by 
the 
Directive.  
  erception  of 

the 
adequacy  between 
the objectives of the 
the 
Directive  and 
in 
current  needs 

 

The  scope  of  the 
Directive  matches 
with  the  current  is-
sues arising from the 
evidence  available 
on  biodiversity  and 
zoos  role,  and  the 
stakeholders’  opin-
ions.  

  A  majority  of  stake-
holders/the  public 
perceive(s)  the  ob-
jectives  as  ade-

 
 
 

 
 

Literature  
‘grey literature’ 
Interviews  with  CAs 
and 
repre-
zoos’ 
sentatives 
Targeted survey 
Public consultation 

Questions of the consul-
tation tools 

Question 94-96.   

MSCAs  Questionnaire: 
Question 98-100. 

NGOs&Federation 
Questionnaire: Question 
53-55. 

Interview question : 16. 

Questions of the consul-
tation tools 

Zoos 
Question 102-103.  

Questionnaire: 

MSCAs  Questionnaire: 
Question 109. 

NGOs&Federation 
Questionnaire:  Question 
65-66. 

Public  consultation:  Q. 
22 

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Evaluation question 

Sub-questions 

Indicators 

Success criteria 

Sources of information 

EQ  10  How  relevant  is 
the  Directive  to  achiev-
ing 
legal  and  policy 
biodiversity objectives at 
EU and global levels? 

EQ  10.1  Have  EU  and 
global  biodiversity  ob-
jectives  and 
targets 
evolved since the adop-
tion of the Directive? 

EQ  10.2  How  has  imple-
mentation  of 
the  Di-
rective  kept  pace  with 
the evolution of relevant 
objectives and targets? 

EQ  11.1  Is  the  Zoos  Di-
rective  adapted 
to 
technical  and  scientific 
progress? 

11 

EQ 
How  well 
adapted is the Directive 
to 
tech-
nical  and  scientific  pro-
gress? 

(subsequent) 

Questions of the consul-
tation tools 

Interview question: 18. 

As above.  

 

 

terms  of  e)  record 
keeping. 
Level of evolution of 
EU  and  global  bio-
diversity  objectives 
and 
i.e. 
targets, 
adoption  of  new 
legislation 
at 
EU/global level. 
The 
relevance  of 
the  Directive  to  cur-
rent  priorities 
of 
global  conventions, 
goals and targets. 

 

 

quate to the needs.  

Evidence  of  evolu-
tion of EU and glob-
al  biodiversity  ob-
jectives and targets, 
i.e. adoption of new 
legislation 
at 
EU/global level. 
The Directive still has 
a  value  in  contrib-
uting  to  global  bio-
targets 
diversity 
(e.g.  Aichi 
targets 
and  the  SDG  tar-
gets)  and  support-
ing  other  policy 
processes. 

(EU 

  Analysis  of  docu-
and 

ments 
global policies) 
Literature  
‘grey literature’ 

 
 
  Annual 
zoos 
Interviews  with  CA 
and 
repre-
zoos’ 
sentatives 
Public consultation  

reports  of 

 

Evidence  of  adaptation 
to 
scientific  progress 
contained  in  the  Zoos 
Directive. 

 
 
 

 

Literature  
‘Grey literature’ 
Interviews  with  CAs 
repre-
zoos’ 
and 
sentatives 
Targeted survey 

Zoos 
Question 104-106. 

Questionnaire: 

MSCAs  Questionnaire : 
Question 107-108. 

NGOs&Federation 
Questionnaire:  Question 
67-69. 

Interview question: 19. 

  Observation 

of 
technical and scien-
tific  progress  over 
the  implementation 
period  and  level  of 
adequacy  between 
progress  observed 
and requirements of 
the Directive.  
Stakeholders 
per-
ception on the level 
of  adequacy  be-
tween  progress  ob-
re-
served 
and 
quirements  of 
the 
Directive. 

 

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Table 37: Coherence 

Evaluation question 

Sub-questions 

Indicators 

Success criteria 

Sources of information  Questions of the consul-

EQ  12  To  what  extent 
does  the  Zoos  Directive 
complement  or interact 
with  other  EU  sectoral 
policies  affecting  biodi-
versity 
conservation 
relevant  animal 
and 
welfare  issues  at  Mem-
ber States and EU levels, 
in  particular  as  regards 
wild  animals  kept 
in 
for  commer-
captivity 
cial 
(notably 
circuses)  and  how  do 
these  policies  affect 
positively  or  negatively 
the  implementation  of 
the Zoos Directive?   

reasons 

the  EU 

EQ  13  To  what  extent 
does  the  Directive  sup-
port 
internal 
market  and  the  crea-
tion  of  a  level  playing 
field  for  economic  op-
erators, 
especially 
SMEs? 

EQ  12.1  To  what  extent 
does  the  Zoos  Directive 
complement  or interact 
with  other  EU  sectoral 
policies  affecting  biodi-
conservation 
versity 
relevant  animal 
and 
welfare  issues  at  Mem-
ber  States  and  EU  lev-
els?  

  Main 

interactions 
between  the  Zoos 
Directive  and  key 
sectoral EU policies. 
  Number  of  cases  of 
and/or 

conflicts 
synergies.  

further 

prevent 

EQ  12.2  Are  there  con-
requirements 
flicting 
the 
that 
achievement  of 
the 
objectives  of  the  Zoos 
Directive,  or  synergies 
reinforcing 
for 
Zoos  Directive’s 
the 
objectives 
LIFE 
(e.g. 
programmes)?  
EQ  13.1  To  what  extent 
the  Zoos  Directive  cre-
level  playing 
ated  a 
in 
field  among  zoos 
different 
Member 
States,  and  particularly 
among smaller zoos? 

EQ  13.2  If  obstacles  are 
observed,  what  are  the 
stakeholders affected? 

 

  Degree  of  harmoni-
zation  brought  by 
the  Zoos  Directive 
across  the  Member 
States. 
Level  of  discrepan-
cies/  differences  in 
the costs and bene-
fits  observed  across 
Member 
States 
and/or  zoos  of  dif-
ferent  size  (based 
on  EQ  5.3  and  EQ 
7.1).  
Stakeholders’  and 
SMEs  perception  on 

 

 

 

Examples  of  positive 
interactions  with  the 
other sectoral policies.  
Limited  examples  of 
cases  of 
conflicts 
and/or  several  cases 
of synergies. 

 

 

The Zoos Directive has 
been  implemented  in 
a harmonized manner 
Member 
among 
States  (in 
terms  of: 
definition  of  zoos;  ex-
emptions  as  per  Arti-
cle  2;  definition  of 
provi-
additional 
sions/requirements; 
li-
cencing  fees;  extent 
of the penalties).  
differentiation 
Low 
among 
Member 
States in terms of costs 
and benefits. 

 
 

 
 
 

 
 

 
 
 

Literature review 
Interviews  with  CAs 
repre-
zoos’ 
and 
sentatives 
(includ-
ing at EU level) 
Targeted survey 
Public consultation 
Policy analysis 

tation 
Questionnaire: 

Zoos 
Question 100-101. 

MSCAs  Questionnaire: 
101 – 106. 

NGOs&Federation 
Questionnaire: Question 
59-63. 

Public  consultation:  Q. 
28  

Interview questions : 20 - 
21. 

Literature review 
Interviews  with  CAs 
repre-
and 
zoos’ 
(includ-
sentatives 
ing at EU level) 
Targeted survey 
Public consultation 
Policy analysis 

Zoos 
Question 79, 97-99. 

Questionnaire: 

MSCAs  Questionnaire: 
Question 88-89. 

NGOs&Federation 
Questionnaire: Question 
56-58. 

Public  consultation:  Q. 
25 

Interview question: 22. 

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Evaluation question 

Sub-questions 

Indicators 

Success criteria 

Sources of information  Questions of the consul-

tation 

level  of  support  of 
the  Zoos  Directive 
to  the  EU  internal 
the 
market  and 
creation  of  a  level 
playing field. 

 

 

Low 
differentiation 
between  small  and 
large  zoos  in  terms  of 
costs and benefits. 
Positive  perception  of 
stakeholders 
in  gen-
eral  /SMEs  in  particu-
lar  on  the 
level  of 
support  of  Zoos  Di-
rective  to  the  EU  in-
ternal market and  the 
creation  of  a 
level 
playing  field  for  eco-
nomic operators. 

Table 38: EU Added Value 

Evaluation question 

Sub-questions 

Indicators 

Success criteria 

Sources of information 

EQ  14  What  has  been 
the  EU  added  value  of 
the  Zoos  Directive  com-
pared to what could be 
achieved  by  Member 
States 
national 
at 
and/or regional levels? 

EQ  14.1  How  and  to 
what  extent  the  Zoos 
Directive  contributed  to 
strengthen  the  role  of 
zoos in  the  conservation 
of  biodiversity,  through 
the  objectives  stated  in 
Art. 3 thereof? 

EQ  14.2  Could 
these 
objectives  be  achieved 
by  Member 
States 
through  national  legisla-
tion?  
Are 
there  certain  as-
instances 
pects 
where  MS-level  regula-
tion  would  provide  bet-

or 

  Number  and  share 
interviewed 
of  the 
stakeholders  stating 
the  Zoos  Directive 
contributed  to  the 
implementation  of 
conservation 
measures  and  to  a 
strenghtened 
the 
role of zoos.  

to 

  Number  of  other 
that,  ac-
factors 
cording 
the 
stakeholders,  have 
contributed 
to 
the 
achieve 
changed observed. 
  Number  of  Member 

  Majority  of 

zoos 
state  that  the  Di-
rective strongly con-
tributed  to  the  im-
plementation  of  the 
conservation 
measures  and  to  a 
strengthened role of 
zoos, more than any 
other factors.  
The  Zoos  Directive 
prompted 
the 
adoption  of  nation-
al  legislations  relat-
ed  to  the  role  of 
zoos  in  the  conser-
vation  of  biodiversi-
ty. 

 

 
 
 

Literature  
‘grey literature’ 
Interviews  with  CAs 
and 
repre-
zoos’ 
sentatives 
Targeted survey 
Public consultation  

reports  of 

 
 
  Annual 
zoos 

  National  reports  to 
the  CBD  on  ex-situ 
conservation. 

Questions of he consul-
tation 
Zoos 
Questionnaire: 
Question  71;  Question 
107 – 108.   

MSCAs  Questionnaire: 
Question  77;  Question 
112 - 115.  

NGOs&Federation 
Questionnaire:  Question 
34; Question 70 – 75. 

Public  consultation:  Q 
22, 23, 24  

Interview question: 1,2,4, 
23. 

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Evaluation question 

Sub-questions 

Indicators 

Success criteria 

Sources of information 

Questions of he consul-
tation 

ter results with respect to 
the  objectives  stated  in 
Art.  3  of  the  Zoos  Di-
rective?  

EQ 15 To what extent do 
the  issues  addressed  by 
the  Directive  continue 
to  require  action  at  EU 
level? 

EQ  15.1  Are  there  sub-
stantial 
derogations 
from  the  Zoos  Directive 
in  the  Member  States? 
specific 
Are 
there 
re-
and/or  additional 
quirements, 
and/or 
more stringent rules than 
those  envisaged  by  the 
Directive?  What  are 
they  –  do  they  lead  to 
achievement  of  better 
results  in  terms  of  effec-
tiveness  or  efficiency  of 
achievement  of 
the 
objectives  as  stated  in 
Art.  3  of  the  Zoos  Di-
rective? 

States  that  had  a 
legislation 
national 
recognizising 
the 
role  of  zoos  in  pro-
tecting  biodiversity 
before  the  entering 
into 
the 
force  of 
Zoos Directive. 
  Number  and  share 
of  the 
interviewed 
stakeholders  stating 
that  the  EU  level  is 
the  most  appropri-
ate level to regulate 
ex-situ  biodiversity 
conservation 
and 
reasons  for  such  an 
(also  ad-
opinion 
dressed in EQ16.3). 

  Number  of  MS  with 
substantial  deroga-
tions,  additional  or 
specific 
require-
ments  and/or  more 
stringent rules. 
  Degree  of  differen-
among 
tiation 
Member  States 
in 
the  implementation 
of the Directive.  
  Degree  of  differen-
tiation  among  EU 
Member  States  and 
issues 
for 
economic 
opera-
tors,  if  any  (see  indi-
cators under EQ 13). 

implied 

 

EU  level  seen  as  the 
most 
appropriate 
level  for  regulation 
of  biodiversity  con-
servation 
(also  addressed 
EQ16.3). 

ex-situ.  
in 

 

 

that 

Low  number  of  cas-
es  where  MS  intro-
duced  derogations 
or 
implemented 
more  stringent  regu-
lations than the rules 
envisaged  by 
the 
Zoos  Directive  indi-
cating 
the 
Member  State  legis-
lation  largely  relies 
the  Zoos  Di-
on 
rective. 
The  Zoos  Directive 
has  been 
imple-
mented 
in  a  har-
monized  manner 
across 
Member 
States. 

MSCAs  Questionnaire: 
Question 7 – 23.  

 
 
 

 
 
 

Literature  
‘grey literature’ 
Interviews  with  CA, 
zoos’ 
representa-
tives and NGOs 
Targeted survey 
Public consultation  
Results of monitoring 
of zoos 

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Evaluation question 

Sub-questions 

Indicators 

Success criteria 

Sources of information 

Questions of he consul-
tation 

EQ  16  What  would  be 
the  consequences  of 
not  having 
the  Di-
rective? 

EQ  15.2  Which  are  the 
remaining discrepancies 
among  Member  States? 
Is  there  a  level  playing 
field  among  economic 
operators  or 
is  further 
action needed? 
EQ 16.1 Which would be 
the  expected  develop-
ments  in  the  legislation 
at Member States level? 
the 
What  would  be 
consequences  in  terms 
of  ex  situ  biodiversity 
conservation? 

EQ  16.2  To  what  extent 
the  objectives  of  the 
Zoos  Directive  could  be 
achieved  through  the 
participation  in  interna-
tional 
agreements 
and/or  requirements  of 
international, 
national 
and  regional  zoos  or-
ganizations? 

EQ  16.3  What  would  be 
the consequences at EU 
level  of  not  having  the 
Directive, 
in  particular 
with  regards  the  obliga-
tion  of  the  EU  under 
Article  9  of  the  Conven-
tion  of Biological  Diversi-
ty? 

 

 

Synergies  and  over-
laps with other legal 
acts,  policies  or  in-
ternational  agree-
ments.  
Feedback  of  stake-
holders  about  con-
sequences  that  the 
absence  of  the  EU 
would 
legislation 
bring.  

  Number  and  share 
of  the 
interviewed 
stakeholders  stating 
that  the  EU  level  is 
the  most  appropri-
ate level to regulate 
ex-situ  biodiversity 
and 
conservation 
reasons  for  such  an 
opinion. 

 

  Not  having  the  Zoos 
Directive  leading  to 
negative  effects  in 
at  least  some  MS  in 
relation  to  the  ob-
jectives stated in the 
Art. 3 of the Zoos Di-
rective. 
The  objectives  pur-
sued  with  the  Zoos 
Directive  would  not 
be 
cov-
ered/addressed  at 
EU  level  with  other 
pieces of legislation, 
policies  or  interna-
tional agreements. 
Positive  and  nega-
tive  effects  of  not 
having  the  Zoos  Di-
rective  reported  by 
the stakeholders. 
EU  level  seen  as  the 
most 
appropriate 
level  for  regulation 
of  biodiversity  con-
servation ex-situ. 

 

 

 
 
 

 
 
 

Literature  
‘grey literature’ 
Interviews  with  CAs, 
zoos’ 
representa-
tives and NGOs 
Targeted survey 
Public consultation  
Results of monitoring 
of zoos 

Zoos 
Question 111-116.   

Questionnaire: 

MSCAs Questionnaire:  
Question  7  –  23 ;  Ques-
tion 114 -122. 

NGOs&Federation 
Questionnaire:  Question 
76 – 82. 

Public  consultation:  Q 
22, 23, 24 

Interview  question:  24  - 
25. 

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ANNEX II – COUNTRY FICHES 

Country fiche – Belgium 

National system 

 

Prior to the entry into force of Directive 1999/22/EC, four legislative measures on zoos were in 
place at federal level (see section 2 on transposition of the Directive). This legislation has been 
enacted by the Federal Public Service for Public Health, Food Safety and Environment (Service 
Public Fédéral Belge 2016). Even though the legislative competence has been transferred to the 
Regions (Flemish Region, Walloon Region, Region of Brussels Capital) in 2014, federal legisla-
tion remains in place until the regional governments have adopted new legislation on the matter 
(Agentschap  Informatie  Vlaanderen  n.d.)  (Service  public  de  Wallonie  n.d.).  At  the  time  of  the 
drafting  of this fiche,  it seems that none of the Regions has adopted  such rules. The legislation 
has not been modified after the entry into force of the Directive. According to the Born Free 2011 
Zoo Inquiry the federal law does not transpose all concepts of Directive 2014/17/EU (Born Free 
Foundation 2011, 39).  

  Definitions of ‘circuses’, ‘travelling expositions’ and ‘commercial establishments for animals’ are 
not included in the federal law, meaning these establishments fall outside the scope of transposing 
legislation (Born Free Foundation 2011, 5).  

  The procedure to obtain a Zoo permit is as follows. One must send an application to the Service 
Animal welfare. After being inspected by the Zoo commission, Service Animal welfare will ad-
vise the Minister of the Department Environment, Nature and Energy on whether or not to pro-
vide a license. This procedure costs €250 for collection displaying either mammals or birds and 
€125 if the collection contains only animals other than mammals or birds. The Minister can re-
voke, partly or wholly, the Zoo permit, when the establishment does not meet the legal require-
ments  anymore  (Agentschap  Informatie  Vlaanderen  n.d.).    The  Zoo  Commission  is  the  expert 
board,  which  will  also  be  consulted  on  drafting  zoo-specific  legislation  (Dienst  Dierenwelzijn 
n.d.) . If an applicant has not been informed regarding the status of the application for a zoo per-
mit within 180 days after application thereof, he/she will obtain the permit automatically (“lais-
sez-faire”  approach).  Furthermore,  the  permit  is  issued  for  an  unlimited  period,  but  has  re-
strictions regarding the number of animals kept (Born Free Foundation 2011, 15). 

Main achievements (successes reported in literature and/or by stakeholders contacted): 

  Belgium  has  adopted  legislation  concerning  minimum  standards  for  the  keeping  of  animals  in 
zoos (Born Free Foundation 2012, 19). This also includes minimum standards for keeping ceta-
ceans (Born Free Foundation 2012, 5 and 32). 

  Two Belgian zoos have adopted a  ‘no kill-policy’, namely the zoos Antwerp and Planckendael. 
This means that surplus animals, which do not fit in the zoo and cannot be placed at another facil-
ity, may not be killed (BELGA 2016). 

Main challenges that remain to be addressed/ key issues  

The  Born  Free  2011  Zoo  Inquiry  reported  that  Belgium  had  incorrectly  transposed  Directive 
1999/22/EC on several points: 

  The Belgian Government did not adopt the objective ‘the role of zoos in the conservation of bio-

diversity’, as referred to in Art. 1 of the Directive.  

  The Belgian Government has adopted only one conservation option, namely ‘the participation in 

international cooperative captive breeding’ of Art. 3 of the Directive. 

  Art. 4(4) of Directive 1999/22/EC concerning on-site inspection of zoos prior to a renewal of the 

license or changed condition, has not been transposed in Belgian legal order.  

  Art. 4 of Directive 1999/22/EC regarding the regularity or procedures of zoo inspections, appears 

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not to be transposed (Born Free Foundation 2011, 40). 

  Art. 6 of the Directive on zoo closures and contingency plans for the animals, has not been trans-

posed (Born Free Foundation 2012, 17 and 40). 

The Born Free 2011 Zoo Inquiry underlined additional issues: 

  The  laissez-faire  approach  implies  that  zoos  are  considered  licensed  without  systematically  re-
quiring that any checks or inspections are carried out. This may be in violation of Art. 4 of Di-
rective 1999/22/EC. 

 

  The enforcement of Directive 1999/22/EC  might be ineffective: the Belgian authority acknowl-
edges  that  zoo  inspectorates  need  more  resources.  Furthermore,  zoo  inspectorates  act,  due  to 
workload, in accordance with complaints and notifications rather than inspecting zoos on a regu-
lar basis, as required by Directive 1999/22/EC. 
It  appears  that  Belgian  zoos  and  dolphinaria  in  general  fail  to  comply  with  national  legislation 
(Born Free Foundation 2011, 20-31). To point out a few issues: Belgian zoos are not committed 
to  contribute  to  species  conservation  (Born  Free  Foundation  2011,  5-6  and  43-44),  the  public 
could come in direct contact with animals and no behavioural (Born Free Foundation 2011, 5-6 
and 42-43) or the enclosures were not suitable for the animals (Born Free Foundation 2011, 5-6 
and 46-47). 

MAPPING OF NATIONAL CONTEXT 
1.1

  Total number of zoos 

1.2

  Types of zoos in the country 

There  are  40  zoos  in  Belgium,  further  details  on  the  evolution  of 
the number of zoo was not available. 
Private: 

1.  Aquarium de Bruxelles 
2.  NV Plopsaland S.A. 
3.  Boudewijn Seapark  
4.  Serpentarium (NGO) 
5.  National Sealife Blankenberge 
6.  N.V. Bellewaerde Park S.A. 
7.  Familiepark Harry Malter 
8.  Olmense Zoo 
9.  Zoo Antwerpen (NGO) 
10.  Dierenpark Planckendael (NGO) 
11.  Aquatopia  
12.  Noordzeeaquarium  (given  the  e-mail  address  it  might 
be  public.  Not  sure  at  all,  since  the  website  does  not 
appear to be made by the authorities) 

13.  De Zonnegloed 
14.  Parc "Les Onays" 
15.  La grange à papillons 
16.  Parc animaler de Bouillon "La Crête des cerfs" 
17.  Parc animaler de La Ried 
18.  Parc Mont Mosan 
19.  Pairi Daiza 
20.  Parc à Gibier de La Roche 
21.  Télécoo 
22.  Wolf Conservation Association 
23.  Entre Ferme et Forêt 
24.  Monde sauvage 

Public 

1.  Recreatiedomein "De Brielmeersen" (since 01-01-2015) 
2.  Domein Eendenkooi (not sure) 
3.  Provinciedomein Huizingen 
4.  NAVIGO - Nationaal Visserijmuseum  
5.  Musée d'Histoire Naturelle 
6.  Aquarium - Museum de l'Université de Liège 
7.  Réserve d'Animaux sauvages de Han-sur-Lesse 
8.  Parc à Gibier de Saint-Hubert 
9.  Museum des Sciences Naturelles 

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1.3

  NGOs active at national level  

1.4

  Associations  of  zoos  profession-

als 

1.5

  Brief market overview 

TRANSPOSITION OF THE DIRECTIVE 
1.1 

Transposition of the directive 

10.  Domaine de Champalle (given the name) 
11.  Le parc zoologique du Castel Saint Pierre 
12.  Hexapoda insectarium (at a uni) 

Not identified: 

1.  Centre Carapace 
2.  Base 1 Wing (military plane) 
3.  Crusoe 
4.  BIAVA (Pêcherie) 

The main NGOs active in the field:  
  GAIA (animal welfare) ; 
  Dauphin libre (against captivity of dolphins). 

Natuurpunt and Natagora are two NGOs active on environmen-
tal matters in general. 
IVDB -  Flemish association of veterinarians348 
Savab  -  Flemish  association  of  veterinarians  (for  domestic  ani-
mals)349 
VDV - Flemish Association of veterinarians 350 
Ordre vétérinaires - Walloon Association of veterinarians 351 
UPV - Walloon association of veterinarians 352 
In  2015,  Belgium  had  11,209,044  inhabitants  (Algemene  Directie 
Statistiek 2015, 6). 

No aggregate  information  was  publicly available  regarding  the 
total  number  of  visitors  or  the  turnover  of  Belgian  zoos.  Some 
information  was  nonetheless  collected  from  certain  big  zoos  or 
institutions: 

  Aquarium  -  Museum  de  l'Université  de  Liège  mentions 
the  amount  of  visitors  until  2010  of  the  Aquarium  Muse-
um (Aquarium-Museum van Luik n.d.).353 

  A general overview of  tourism in Flanders is available. It 
states  the  amount  of  visitors  over  the  years  2011-2015 
(reports  of  previous  years  are  also  available).354  Please 
note:  zoos  and  amusement  parks  are  one  category,  so 
the  figure  includes  both  visitors.  This  report  does  not  in-
clude  all  zoos.  In  the  province  of  Antwerp,  2,930,391 
people  visited  zoos,  fun  fairs  and  amusement  parks 
(Vlaanderen  is  toerisme  n.d.,  14).  In  the  province  of 
West-Flanders,  2,488,258  people  visited  zoos,  fun  fairs 
and amusement parks (Vlaanderen is toerisme n.d., 26). 
  Annual  reports  for  the  Zoos  of  Antwerpen  and  Planken-
dael  from  2012-2015  are  available355.  The  reports  men-
tion  the  amount  of  visitors  and  revenues.  In  2015,  ZOO 
Antwerpen welcomed 862,000 visitors and Planckendael 
was visited by 911,000 people (Koninklijke Maatschappij 
Dierkunde  Antwerpen  vzw  n.d.,  14).  Together  the  two 
(Koninklijke 
zoos  have  a 
Maatschappij Dierkunde Antwerpen vzw n.d., 14). 

turn-over  of  €36,700,00 

Competence  to  enact  legislation  is  no  longer  a  federal  matter. 
Federal  legislation  will  apply,  until  other  regional  legislation  has 
been  enacted.  None  of  the  Regions  have  yet  adopted  such 
rules. The following federal legislation is hence still applicable: 

348 http://www.ivdb.be/  
349 http://www.savab.be/  
350 http://www.vladiver.org/  
351 http://www.ordre-veterinaires.be/  
352 http://www.upv.be/  
353 The amount of visitors are: 500,000 in May 1981, 1,000,000 visitors in October 1991, 1,500,000 in August 1998 and 2,000,000 visitors in 
October 2004. 
354 http://www.toerismevlaanderen.be/sites/toerismevlaanderen.be/files/assets/documents_KENNIS/cijfers/2011-2015_attractieaanbod.pdf.  
355 http://www.zooantwerpen.be/nl/jaarverslag.  

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 

 

Law  of  14  August  1986  on  the  protection  and  the  well-
being  of  animals  (Loi  du  14  aout  1986  relative  à  la  pro-
tection  et  au  bien-être  des  animaux),  14.08.1986, 
01.01.1988, M.B. 03.12.1986. 
Royal Order of 10 August 1998 on the recognition of zoos 
(10  Août  1998  -  Arrêté  royal  relative  à  l’agrément  des 
parc  zoologiques  /  10  augustus  1998.  –  Koninklijk  besluit 
betreffende de erkenning van dierentuinen), 10.08.1998, 
01.01.1999–  01  January  1999,  M.B.  13.11.1998,  (“Royal 
Order 1998”). 

  Ministerial Order of 3 May 1999 on setting minimum crite-
ria for keeping mammals in zoos (Arrêté ministériel fixant 
des  norms  minimales  pour  la  detention  de  mammifères 
dans 
les  parcs  zoologiques  /Ministerieel  besluit  tot 
vaststelling  van  minimumnormen  voor  het  houden  van 
zoogdieren in dierentuinen), 3.05.1999– - 19.08.1999, M.B. 
19.08.1999, (“Royal Order 1999”). 

  Ministerial Order of 7 June 2000 on setting minimum crite-
ria  for  keeping  birds  in  zoos  (Arrêté  ministériel  fixant  des 
norms  minimals  pour  la  detention  des  oiseaux  dans  les 
parcs  zoologiques  /  Ministerieel  besluit  tot  vaststelling 
van  minimumnormen  voor  het  ouden  van  vogels  in  di-
erentuinen), 7.06.2000 – 5.09.2000, 5.09.2000, (“Royal Or-
der 2000”). 

  Ministerial Order of 23 June 2004 on setting minimum cri-
teria  for  keeping  reptiles  in  zoos  (23  Juin  2004  –  Arrêté 
ministériel  fixant  les  norms  minimales  pour  la  detention 
des  reptiles  dans  les  parcs  zoologiques  /  Miniosterieel 
besluit  tot  vaststelling  vna  minimumnormen  voor  het 
houden  van 
in  dierentuinen),  23.06.2004, 
1.02.2005, 27.07.2004, (“Royal Order 2004”). 

reptielen 

1.2 

1.3 

Eu infringement cases  

National case-law 

There are no infringement cases against Belgium on the basis of 
Directive 1999/22/EC. 
There  is  no  case  law  on  the  transposing  measures  of  Directive 
1999/22/EC. 

Country fiche – Bulgaria 

Key features of the national system: 

  The  Directive  has  been  effectively  transposed  through  the  Biodiversity  Act  (SG  77/09.08.2002 
Amended),  which  is  implemented  through  secondary  legislation:  Regulation  No.1  (SG 
43/26.05.2006) and Ordinance No.6 (SG 105 / 2.12.2003, amended by SG 44 / 12.07.2009). The 
Directive came into force in Bulgaria in January 2007 (Bornfree, 2011)(our study) 

  The competent authority is the Ministry of Environment and water.  
  According to the CA, the number of zoos in Bulgaria is as follows. There were 20 licensed and 
not licensed zoos in 2010 , and 21 in 2015 (MS CA Survey). According to Born Free, in 2011, 
there  were  19  zoos  in  Bulgaria,  of  which  16  were  licensed  and  3  were  closed  (Born  Free 
Foundation 2011).  

  Municipalities own and operate all the licensed zoos in Bulgaria. They do not appear to have suf-
ficient  resources  for  ensuring  the  effective  implementation  and  enforcement  of  the  Biodiversity 
Act.  Mayors  defend  the  existence  of  local  zoos  yet  were  reported  to  take  little  action  to  ensure 
that the zoos meet the required standards (Born Free Foundation 2011)(our survey) 

  No official data is available on the number of visitors for all Bulgarian zoos. As a means of illus-
tration, the Sofia Zoo, which is the largest zoo in the country, attracts annually around 400.000-
500.000 visitors (Focus 2011). 

  According to the Supplementary provisions to the Biodiversity Act, a zoo “shall be any perma-
nent establishment where animals of wild species are kept for exhibition to the public for seven or 

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more days a year, with the exception of circuses, pet shops and other establishments which do not 
exhibit a significant number of animals or species to the public”.  

  Exemptions in line with Article 2 of the Directive are provided in the Supplementary Provisions 
of Regulation No 1 from 9 May 2006 2 as follows "Significant number of animals or species" are 
more than 5 wild species with more than 5 specimens of each species. 

  Concerning costs, there is no official data on costs related to the implementation of the Zoos Di-
rective.Two full time (equivalent) staff in the Ministry and one in each Regional inspection are 
dedicated  to  zoos  inspections.  The  duration  of  one  inspection  procedure  (including  reviewing 
documents, inspection form, inspection visit, and inspection report) is estimated to be 1-5 days, 
depending on the zoo. Regional inspectorsare doing at least 1 inspection per year and  1 or max. 2 
zoos annually (our study).  

  The BG CA issues guidelines for keeping animals in zoos as decribed in Regulation No 6 from 23 
October 2003. These guidelines contain minimum requirements for keeping animals in zoos and 
in the keeping and breeding centers for protected animal species. The Annexes of the regulation 
are laying down standards and special conditions of each animal group or species concerned (our 
study). 

  Licences  are  issued  by  the  Ministry  of  Environment  and  water,  with  support  of  the  Institute  of 
Biodiversity and Ecosystem Researches of the Bulgarian Academy of Science. The Institute con-
tributes  to  the  assessment  of  animals’  enclosures.    Zoos  are  inspected  by  the  Ministry  of  Envi-
ronment and Water, the Ministry of Agriculture and Food Regional Inspectorate of Environment 
and Water, the Regional Veterinary Office and a representative of the Bulgarian Academy of Sci-
ences are members of the Commission for license. After the licensing, the Regional Inspectorates 
of Environment and Water are responsible for conducting regular inspections in zoos,. The repre-
sentatives of Ministry of Agriculture and Food and Regional Veterinary Office are responsible for 
the veterinary  legislation, the representative of the Bulgarian Academy of Sciences contributes to 
the process as an external expert. 

  The  first  license  has  a  set  duration  of5  years.  Every  consecutive  license  could  be  issued  under 
certain conditions for a 5 year period or for 10 years. The cost of applying for a 5-years-license is 
500 euro. In case of non-compliance, Art. 126, (3) of the Biodiversity Act provides penalties for 
running a zoo without an appropriate license. The penalties range  from 500 to 5.000 euro for in-
dividuals  and between 1.000 to 12.500 euro in the cases of legal persons sole traders (our study). 
  Bulgaria has no national zoo association and only 1 of its 19 zoos (Sofia Zoo) is a candidate for 
EAZA membership. This illustrates that BG zoos are likely not meet the standards required for 
EAZA membership (our study). 

  There is one NGO active at national level, called: ‘Four Paws Bulgaria’ (Vier Pfoten Internation-
al).  This NGO is actively promoting animal welfare and has raised concern about big cats in cap-
tivity in Eastern Europe (Four Paws Bulgaria 2016) 

  Zoos in Bulgaria have a history of regular escape of wild animals. In the period 2006 – 2016, a 
total of 6 escapes (i.e. jaguar, tiger, bear, golden Jackal, wolf) occurred (our study) . As example, 
in 2014 a tiger has escaped from its cage from the Sofia zoo. Visitors were evacuated and the zoo 
was  closed.  A veterinarian was  called  to  sedate  and  catch  the  animal356.  In  2015,    a wolf fled 
the zoo in Blagoevgrad,  Southwestern  Bulgaria.  Visitors  were  immediately  evacuated  after  staff 
members noticed the animal's cage was empty. Police and fire brigade teams were sent to the site. 
This was the second incident with an animal escaping the zoo, after two bears did the same ten 
years ago. Also in 2015, a bear managed to leave its cage in the zoo of Pleven, northern Bulgar-
ia357.  A  paper  on  escape  of  wolfes  illustrates  bad  housing  conditions  as  frequent  cause  for    es-
capes (Mihaylov 2015). 

Main achievements: 

  The licensing system is operational, and many zoos are licensed (our study).  

In 2015: 356 http://www.novinite.com/articles/165259/Tiger+Flees+Cage+at+Sofia+Zoo 
357 http://www.novinite.com/articles/170914/Wolf+Flees+Zoo+in+Bulgaria's+Blagoevgrad 

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  Two zoos (Sofia Zoo and Dorich Zoo) are involved in in-situ conservation projects regarding the 
European Lynx and European birds of prey. Other Zoos in Bulgaria are not involved in conserva-
tion or biodiversity and cannot do rehabilitation for wild fauna (our study, NGO Interview). 
  A good example can be seen regarding a breeding center for bears, which had no license. The zoo 
was closed and all the bears were trans-located to other EU countries. Also, the ministry facilitat-
ed and organized workshops for zookeepers to educate and help them take better care of their an-
imals (NGO Interview). 
In the beginning, the licensing went very slowly but with time the situation gradually improved, 
especially during the last 2-3 years (NGO Interview). 

 

  Before the EU Zoo Directive, the zoos in Bulgaria were very bad. The Directive had a good im-

pact and helped guidings the zoo and ministry.   

Main challenges: 

  Almost all zoos in Bulgaria are publicly  owned and lack the money to be involved in research, 
conservation or education programs. After the Directive was implemented in national law, zoos 
attempted and many started to (re)build better enclosures in order to retain their license. 

  The  lack  of  resources  keeps  limiting  the  progress  to  provide  adequate  housing    conditions  in 
many of the municipal zoos in Bulgaria. Better housing conditions require large investments giv-
en the need for complete renovation and modernization of current facilities. As an example, Sofia 
zoo required a 700.000 euros investment for renovating and enlarging carnivores’ enclosures, and 
a 900.000 euros investment for renovating and enlarging the primates’ enclosures. Those changes 
are  planned  for  early  2017.  Another  150.000  -  200.000  euros  was  spent  in  bringing  up  to  date 
some zoo alleys, benches, the mesh in some fences around enclosures, etc. (Zoo interview). 
  Only one zoo (Sofia zoo) is a candidate to EAZA. Most zoos lack support and guidance for im-

proving their facilities and animals’ accommodations (our study). 

MAPPING OF NATIONAL CONTEXT 
1.1

  Total number of zoos 

1.2
1.3

  Types of zoos in the country 
  NGOs active at national level  

1.4
1.5

  Associations of zoos professionals 
  Brief market overview 

TRANSPOSITION OF THE DIRECTIVE 
1.1 

transposing 

List  of  national 
legislation 

In 2010: 20 licensed and not licensed zoos  (MS CA Survey)  
In 2015: 21 licensed and not licensed zoos  (MS CA Survey) 
In  2011,  there  were  19  zoos  in  Bulgaria,  of  which  16  were  li-
cenced and 3 were closed (Born Free Foundation 2011).  

No  information  could  be  obtained  with  regards  to  the  number 
of zoos in Bulgaria when the EU Directive entered into force.  
All zoos in Bulgaria are publicly owned zoos  (Bornfree, 2011) 
There  is  one  NGO  active  at  national  level,  called:  ‘Four  Paws 
Bulgaria’  (Vier  Pfoten  International).    This  NGO  is  actively  pro-
moting  animal  welfare  and  has  raised  concern  about  big  cast 
in captivity in Eastern Europe (Four Paws Bulgaria 2016) 
No associations of zoo professionals could be identified. 
In  2015,  the  total  population  of  Bulgaria  was  7,1  million inhabit-
ants. (Country Meters 2016) 
With  regards  to  the  number  of  zoo  visitors  each  year,  no  infor-
mation could be found with regards to the total number of visi-
tors. However, Sofia Zoo, which is the largest zoo in the country, 
attracts annually around 800,000 visitors. (Focus 2011) 

The Zoos Directive was transposed in the Biodiversity Act (Закон 
за биологичното разнообразие) published in the Official Ga-
zette; Number: 77; 2002-08-09 (Biodiversity Act).  Adoption: 9 
August 2002 Entry into force:  9 August 2002.  

The Biodiversity Act was amended by Ordinance № 6, October 
23, 2003 (НАРЕДБА № 6 ОТ 23 ОКТОМВРИ 2003 Г. ЗА 
МИНИМАЛНИТЕ ИЗИСКВАНИЯ И УСЛОВИЯ ЗА ОТГЛЕЖДАНЕ 
НА ЖИВО) describing minimum requirements and conditions for 
keeping animals in zoos, which was published in the Official 

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Gazette; Number: 105 on 2003-12-02.  

The Biodiversity Act was further amended by Ordinance No 1 
from 9 May 2006 issuing conditions for zoo licensing [Наредба 
№ 1 от 9.05.2006 г. за условията и реда за лицензиране на 
зоологическите градини, издадена от министъра на 
околната среда и водите (ДВ, бр. 43 от 26.05.2006)(Ordinance 
Nr 1) Adoption: 26.05.2006. Entry into force:  26.05.2006; amend-
ed by SG 44 / 12.07.2009) 
None identified 
None identified 

1.2 
1.3 

Eu infringement cases  
National case-law 

Country fiche – Cyprus 

Key features of the national system: 

 

 

In Cyprus, zoos existed before 1999, but no zoo-specific legislation was in place. In Cyprus the 
Zoos Directive is transposed in Regulation 81/2002 on Animal Protection and Welfare (Keeping 
of Wild Animals in Zoos). This law entered into force on 11Fevruary 2002.  
In 2010 and 2015, there were 4 licensed zoos in Cyprus (this survey). According to Born Free, 
there were about 10 zoos in 2011, of which only one was licensed (BornFree, 2011). The number 
of annual visitors is not published. None of the zoos are member of EAZA.  

  The responsibility for the implementation of the Zoos Directive lies within the Ministry of Agri-
culture, Natural Resources and Environment, and its Department of Veterinary Services. There is 
neither a zoo directorate nor full time staff specifically dedicated to zoos inspections. The respon-
sibilities of the zoo inspector vary depending on the District Veterinary Office where he/she is lo-
cated. Because zoo inspectors are regular Veterinary Officers or Veterinary Inspectors, they have 
various other responsibilities such asanimal welfare (farms, transport, slaughter, pets, etc) or food 
safety, animal health, etc. According to the CA, the workload for inspection is one day for one 
zoo inspection (routine inspection) which is carried out once per year (per zoo) (our survey).  
  There is a central zoo database with results/documents of licencing/inspections. It however cannot 

be accessed by all local and regional authorities dealing with the Zoos Directive.  

  Cyprus  has  no  national  legislation  defining  exemption  according  to  Article  2  of  the  Zoos  Di-
rective defining a “significant number of animals”: criteria on determining the term “significant” 
have not been established. Each case is examined individually on the basis of the number and the 
species (this survey). 
Provisions in national law that go beyond those of the Zoos Directive are:  1. The applicant for a 
zoo license must not be convicted for animal abuse; 2. The zoo license is valid for 5 years; 3. The 
facilities must be built following a town planning permit; 4. Before amending either the number 
of animals or the animal species or the enclosures, the zoo must obtain an approval by the compe-
tent authority; and 5. Zoos must be inspected twice per year.  

 

  Costs of a license are 34,17 euro for the examination of the application and 512,58 euro for the 
issuance of the license. Administrative fine imposed by the Director of Veterinary Services which 
can be up to 5.000 euros per non compliance. Furthermore, in case of conviction by the court, the 
sanctions can be a monetary penalty up to 1.700 euros and/or imprisonment up to one year (in the 
case of a first conviction) or a monetary penalty up to 3.400 euros and/or imprisonment up to two 
years (in case of a second or subsequent convictions). (this survey). According tot he local NGO 
ARC zoos are licensed but do not meet requirements of Art  3 of the Zoos Directive.  

  There  are  two  NGOs  active  at  national  level.  Animal  Party  Cyprus  (Κόμμα  για  τα  Ζώα 
Κύπρου)promotes  animal  protection  in  general.  The  organisation  is  a  political  party  promoting 
animal welfare. ARC (Animal Responsibility Cyprus), is actively promoting animal welfare, and 
has been involved in the closure of the Limassol Zoo. 

  The CA considers that there should be a clearer definition of zoo and wild species (Article 2) and 
clearer  criteria  for  exemption  from  the  requirements  of  the  Directive  (Article  2).  The  Zoo  Di-
rective is considered too general. There are overlaps regarding the approval of bodies, institutes 

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or centres (Directive 92/65/EEC) and zoos (Directive 1999/22/EC). Although not legally based, a 
new practice is currently in place in Cyprus, which requires zoos to provide the Veterinary Ser-
vices with the standards they will apply for the accommodation of new species added to the zoo 
collection. The standards must be based on available scientific material (e.g. husbandry manuals). 
Furthermore, a centralised system of record keeping on inspections has been put in place. Also, 
following  the  publication  of  the  EU  Zoos  Good  Practices  Document,  new  legislation  has  been 
drafted aimed to address many problematic areas of the current legislation (e.g. zoo closure, es-
tablishment of an advisory committee, use of expert advice, clarification of the current legal re-
quirements,  increased  penalties,  etc).  The  new  legislation  is  currently  under  discussion  (our 
study).  

Main achievements: 

  The  licensing  system  in  Cyprus  is  operational  and  zoos  are  licensed.  However,  the  Born  Free 
Foundation and ARC heavily criticised the implementation of the licensing and inspection system 
by the CA, arguing that severe deficiencies exist regarding compliance with Art. 3 requirements 
(Born Free Foundation 2010)(this survey).  

  The closure of the Limassol Zoo, and reopening after it improved animal housing conditions, is 

considered the main effect of the Zoos Directive in Cyprus (our survey).  

Main challenges: 

 

In  2004  and  2009,  the  European  Commission  opened  infringement  procedures  against  Cyprus 
following a series of complaints about the inconsistent application of the Zoos Directive, in rela-
tion to the Limassol Zoo. 

  The implementation of the Zoos Directive in Cyprus is facing challenges, in particular concerning 
licensing, and there are no records of the contribution of the zoos regarding biodiversity or con-
servation (Born Free Foundation 2010)(interview with NGO) 

MAPPING OF NATIONAL CONTEXT  
1.1

  Total number of zoos 

1.2

  Types of zoos in the country 

1.3

  NGOs active at national level  

1.4
1.5

  Associations of zoos professionals 
  Brief market overview 

TRANSPOSITION OF THE DIRECTIVE 
1.1 

List  of  national  transposing  legis-
lation 

2010: 4 (licensed and not licensed)(our survey) 
2015: 4 (licensed and not licensed) (our survey) 
There  is  no  public  register  of  zoos  in  Cyprus.  According  to 
NGOs, there are more zoos.  The estimated number of zoos in 
the country was 10 (Born Free Foundation 2010) 
There  are  4  zoos  licensed  by  the  competent  authority  in  the 
country, which are privately owned zoos  (our survey).  
There  are  two  NGOs  active  at  national  level.  Firstly,  Animal 
Party  Cyprus  (Κόμμα  για  τα  Ζώα  Κύπρου),  which  promotes 
animal  protection  in  general.  The  organisation  is  a  political 
party promoting animal welfare. 
Secondly,  ARC  (Animal  Responsibility  Cyprus),  is  actively  pro-
moting animal welfare, and has been involved in the closure 
of Limassol Zoo. 
No associations of zoo professionals could be identified.  
In 2015, the overall population in Cyprus  was  847.008 (EU sd). 
With  regards  to  the  number  of  zoo  visitors  each  year,  no  in-
formation  could  be  found  concerning  the  total  number  of 
visitors.  

  Cyprus  Animal  Protection  and  Welfare  Act  (46(1),  1994; 
94(1), 1997; 75(1), 2000) under Article 32, which is referred 
to as Regulation 81/2002: the Animal Protection and Wel-
fare  Act  (Keeping  of  Wild  Animals  in  Zoos)  (Οι  περί 
Προστασίας και Ευημερίας των Ζώων (Διατήρηση Άγριων 
Ζώων  σε  Ζωολογικούς  Κήπους)  Kανονισμοί  του  2002), 
Adoption:  11/2/2002  Entry 
force:  11/2/2002 
(Veterinary Services Cyprus sd) 

into 

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1.2 

Eu infringement cases  

1.3 

National case-law 

Country fiche – Czech Republic 

Key features of the national system: 

Case  2004/164:  due  to  malfunctioning  of  Limassol  Zoo  in-
fringement procedure was started. 
Case 2009/2285: As Limassol Zoo was not closed but expand-
ed, a new infringement procedure  was opened. In 2012,  the 
case was closed. 
None identified 

  The Czech Republic entered  the EU in May 2004, in  this regard. The special National Act No. 
162/2003 Coll. (hereafter the “Act on Zoological Gardens”), transposing the EU Zoo Directive, 
was adopted in 2003 (our study).  

  Data on zoos is only available in paper-version of administrative documents.  
  The first zoological garden was established in 1919 in the city of Liberec. Since this time until the 
year 2003, 15 zoological gardens were established. All of these zoos were (and still are) owned 
and operated by the municipalities or regional governments. There was no private zoo until 2004. 
In 2004, all of these “older” zoos were considered in line with the conditions for issuing licenses 
for the operation of zoological gardens that have been set by the Act. Followed this process, a li-
cence for an indeterminate period of time has been issued to all of these zoos. Regular checks (in-
spections) are carried out by the Ministry (our study).All of these 15 zoos are members of the Un-
ion of Czech and Slovak Zoological Gardens (member of IUCN), members of EAZA, as well as 
members of the World Association of Zoos and Aquaria (WAZA) and of many other federations.  
In 2006, there were 16 zoos (licensed and not licensed), in 2010, this number increased to 19 and 
to  25  in  2015  (MS  CA  Survey).  Half-way  during  the  implementation  period  of  EU  Directive 
1999/22/EC  there  were  16  zoos  in  the  country  (Eurogroup  for  Wildlife  &  Laboratory  Animals 
2006). 

 

  With regards to the number of zoo visitors each year, no official information could be found con-
cerning the total number of visitors. However, the biggest zoos in CZ, i.e. Prague Zoo, had more 
than 1,3 million visitors in 2011 (Zoo Prague 2016). 

  The responsible competent authority for zoological gardens is the Ministry of the Environment, 
more specifically the Department of the Species Protection and the Implementation of the Interna-
tional Commitments. This Department has the responsibility for the issuing of licenses and for the 
following checks to verify whether zoos comply with their obligations. In this purpose, the spe-
cial advisory body called the Commission for Zoos is established under the Ministry of the Envi-
ronment (our study).   

  The Competent Authority for the area of animal welfare and for the proper checks of its condi-
tions  is  the  State  Veterinary  Administration  within  the  Ministry of  the  Agriculture.  Both  of  the 
above mentioned Competent Authorities work together with the members of the Commission for 
Zoological gardens and for other relevant stakeholders and professional associations (our study). 
  The Commission for Zoological gardens operates as an advisory body of the Ministry of the En-
vironment. Members of the Commission are nominated by the Ministry of Agriculture, the State 
Veterinary  Administration,  the  Union  of  Czech  and  Slovak  Zoological  Gardens  and  the  Czech 
Environmental Inspectorate. The Commission plays an essential role in the process of issuing  the 
licence, especially during the inspection check of the facility. All findings and recommendations 
are described in the Commission´s Report that provides key input to the whole licence granting 
procedure.  Other  key  inputs  are  the  reports  of  the  Regional  Veterinary  Administration  and  the 
Regional  Department  of  the  Czech  Environment  Inspectorate  that  carry  out  regular  controls  in 
line with other relevant national law (veterinary, CITES)(our study).  
Staff  involved  with  licensing  and  inspections  is  as  follows:  1  full  staff  and,  2  inspectors  at  the 
central  level  (who  are  responsible  for  all  ZOOs  and  who  are  members  of  the  Commission  for 
ZOOs)  and  1  or  2  inspectors  in  the  each  region,  who  are  responsible  for  regular  checks  of  the 
CITES  regulations).  The  duration  of  one  inspection  procedure  including  reviewing  documents, 
inspection form, inspection visit, report  is usually one day for on-site inspection and a few days 
for the report. Regular inspection is covered by one or two experts from the Ministry of the Envi-

 

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ronment, the members of the Commission for ZOOs, an invitation to participate in the inspection 
is also sent to  the local  municipality, regional  veterinary administration, regional department of 
the  Czech  Environmental  Inspectorate  and  regional  government.  Usually  12  -  18  people  from 
these institutions are present (MS CA interview). 

  The  CA  supports  zoos  as  follows:    operators  of  licensed  zoos  can  apply  for  subsidies  from  the 
state budget or from the budgets of the territorial self-governing units, in particular for a) breed-
ing species of wild animals protected pursuant to the special legal regulations; b) keeping breed-
ing  registers  of  species  of  wild  animals  protected  pursuant  to  the  special  legal  regulations  and 
processing information on the breeding thereof in electronic form and providing access thereto; c) 
support for the participation of the operator in nature conservation projects in the Czech Republic; 
d) support for cooperation of the operator in the framework of international programs; e) support 
for care for animals that are protected and taken according to the special legal regulations; f) sci-
entific and research projects; and g) projects in the area of enlightenment, educational and cultural 
activities.  The  Ministry  of  the  Environment  provides  specific  program  “Subsidy  for  Zoological 
Gardens”  supporting  all  of  above  mentioned  activities  and  providing  in  total  more  than  15  mil 
CZK (approx. 500.000 euro) per year (our study).  

  The definition of zoos as in Act on Zoological Gardens is as follows: ‘zoological garden means a 
permanent facility in which wild animals and/or also domestic animals are bred and exhibited to 
the public for 7 or more days in the calendar year.’  The definition of ‘animal of wild species’ is : 
‘a domestic animal means an animal that belongs to a biological species that arose as a result of 
human  activity  through  domestication  and  that  lives  primarily  in  direct  relation  to  human  care, 
and/or secondarily wild animals that were originally a domesticated species or subspecies,  a wild 
animal  means  an  individual  of  an  animal  species  whose  population  is  maintained  or  was  main-
tained, for animals that are missing or extinct in nature, naturally in nature; this may consist in an 
individual bred in human care or dependent on human care, a species means a systematic species 
or subspecies or geographically separated population (our study). 

 

  There are exemptions according to Article 2 as follows: A zoological garden shall not mean: the 
aquariums and terrariums and other exhibition facilities that do not keep more than 20 species of 
wild mammals and birds and whose main activity does not consist in exhibition of wild animals 
for the public; facilities for breeding and maintenance of wild animals, that keep less than 20 spe-
cies of wild mammals and birds, where these animals are exhibited to the public free-of-charge, 
particularly for the purpose of public education (our study). 
Provisions in national law that go beyond those of the Zoos Directive are the more precise defini-
tions of zoological garden ; Conditions for the Operation of Zoological Gardens; Application for 
a  License  and  related  obligations;  License  including  the  Cancelling  and  Expiry  of  the  License; 
Control;  Support  for  Operators;  Closing  Zoological  Gardens  to  the  Public;  Misdemeanours  and 
Other Administrative Torts; Authorizing and Transitory Provisions. 
Since 2004, new zoos operated by private subjects have been established. The operators of these 
zoos (owners) have a different legal subjectivity (e.g. corporate body, private business body). Ac-
cording to the Act, a license shall be issued for an indeterminate period of time or, in line with § 
6(3), for a limited period of two years. Most of these new zoos got a licence for a limited period 
and then, after a new licence proceeding, a license for an indeterminate period was issued.  

 

  The  Act  implemented  all  the  requirements  of  licensing  and  control  (inspection)  and  also  solve 

 

other issues related to the zoos management .  
Inspections are done by the Ministry of the Environment within the Commission for Zoological 
gardens, the Czech Environmental Inspectorate, State Veterinary Administration (and/or Regional 
Veterinary  Administration).  The  Czech  Environmental  Inspectorate,  as  well  as  State  Verinary 
Administration,  has  regional  departments,  coordinated  by  the  central  authority.  Regarding  the 
Zoo legislation and related licencing, each of these institutions has one specialist/person who co-
ordinates all related matters. 

  The CZ CA does not issue minimum standards, for animal accommodation/enclosure (our study) 
  On licensing: when an applicant is not capable of fulfilling any of the conditions pursuant to par-
agraph  2  (a),  (4)  and  (5)  of  the  National  Act  as  of  the  date  of  submitting  the  application,  but 
demonstrates that he will be capable of fulfilling these conditions at the latest two years from the 
date  of  submitting  the  application,  and  failure  to  fulfil  these  conditions  does  not  endanger  the 

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purpose of zoological gardens, a license may be issued to him, however for a maximum of two 
years.  According  to  the  Act,  licenses  are  issued  for  an  indeterminate  period  of  time  or,  in  line 
with  §  6(3),  for  a  limited  period  of  two  years.  Re-inspections  are  carried  out  after  a  licence  is 
granted once per two years (biennial regular inspections). The costs of zoo license is 10.000 CZK 
(370 euro) (our study). 

  There is one association of zoos professionals: The Union of Czech and Slovak Zoological Gar-
dens (UCSZOO - Unie českých a slovenských zoologických zahrad z.s.; UCSZOO. They defend 
the  interest  of  the  19  members  (2016)  which  are  zoos  in  Slovakia  and  Czech  Republic.  The 
UCSZOO  is  member  of  IUCN,  EAZA  and  WAZA  (Unie  českých  a  slovenských  zoologických 
zahrad z.s 2016). 

  There are three NGOs active at national level. Svoboda zvířat (Freedom for Animals), founded in 
1994is  a  nation-wide  nonprofit  organization  engaged  in protection  of  animals and  associating 
people who support its aims (Svoboda zvířat 2016).Nadace na ochranu zvířat (Foundation for the 
Protection  of  Animals),  is  a  non-profit,  non-governmental  organisation  with  the  statutes  of  a 
foundation. Aiming at the protection of animals  predominantly in the Czech Republic. They are 
members of international organisations such as RSPCA (Royal Society for the Prevention of Cru-
elty to Animals), WSPA (World Society for the Protection of Animals), and Eurogroup for Ani-
mal Welfare and also participate at international projects and campaigns to improve animal wel-
fare globally (Nadace na ochranu zvířat 2016). 

  A  third  NGO  is  the  Derbianus  Czech  Society  for  African  Wildlife  (Derbianus  Conserva-
tion (former Derbianus CSAW), founded by a group of experts from the Institute of Tropics and 
Subtropics, Czech University of Live Sciences Prague, in 2010 to continue a series of the projects 
of Czech-Senegalese cooperation running from 2000. The main activities of Derbianus Coserva-
tion are focused on the conservation programme of Western Derby Eland (Taurotragus derbianus 
derbianus) in Senegal. (Derbianus Conservation 2016). 

Main achievements: 

 

For  CZ,  the  Zoos  Directive  helps  to  set  specific  conditions  and  standards  resulting  in,  together 
with  appropriate  conditions  set  in  national  act  and  with  system  of  zoos  licencing,  better  provi-
sions for  zoos management, including the programmes regarding the conservation of biodiversity 
(our study). 

  The  Ministry  of  the  Environment  has  set  up  a  working  system  of  licensing  and  inspection  (our 

study). 

  The Ministry of the Environment consider the Zoos Directive and the following national legisla-
tion as a useful tool for improving the standards of ZOOs and therefore for creating of better con-
ditions for conservation programmes and ex-situ conservation (our study). 

Main challenges 

For  CZ,  the  number  of  zoos  is  limited  to  25  licensed  zoos  (2015),  and  the  inspection  and  licensing 
system is well established, with inspection forms, and guidance materals for inspectors and zoos. The 
main challenge is the gap observed by the CA between the Zoos Directive and the new EU IAS regu-
lation, meaning that some species on the IAS list may not be kept in zoos. However, at the national 
level the adaptation of the national law on the EU Regulation is in progress and it is not possible at this 
moment to assess properly what the implication might be. 

MAPPING OF NATIONAL CONTEXT  
1.1

  Total number of zoos 

1.2

  Types of zoos in the country 

In 2010: 19 licensed and not licensed zoos  (MS CA Survey)  
In 2015: 25 licensed and not licensed zoos  (MS CA Survey) 
Half-way  during  the  implementation  period  of  EU  Directive 
1999/22/EC  there  were  16  zoos  in  the  country  (Eurogroup  for 
Wildlife & Laboratory Animals 2006).  
The  majority  of  zoos  in  CZ  are  public  zoos.  In  June  2014  there 
were  24  governmentally  licensed  ZOOs  in  the  country.  Only  15 
of  them  were  the  members  of  The  Association  of  Czech  and 

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1.3

  NGOs active at national level  

1.4

  Associations of zoos professionals 

1.5

  Brief market overview 

TRANSPOSITION OF THE DIRECTIVE 
1.1 

transposing 

List  of  national 
legislation 

1.2 
1.3 

Eu infringement cases  
National case-law 

Slovak  Zoological  Gardens  (ACSZG,  now  called  USCOO) 
(ACSZG  Annual  Report,  2012).  These  zoological  gardens  were 
supported  and  dependent  on  the  public  sector,  being  it  city, 
regional  or  national  budgets.  The  other  9  zoos  in  the  Czech 
Republic were private ones (Martina Chalupova 2014). 
Svoboda zvířat (Freedom for Animals) 

Nadace na ochranu zvířat (Foundation for the Protection of 
Animals)  

Derbianus Czech Society for African Wildlife (Derbianus Conser-
vation (former Derbianus CSAW) 
Union of Czech and Slovak Zoological Gardens (UCSZOO - Unie 
českých a slovenských zoologických zahrad z.s.; UCSZOO. The 
UCSZOO is member of IUCN, EAZA and WAZA (Unie českých a 
slovenských zoologických zahrad z.s 2016).  
In 2015, the total population of Czech Republic was 10,5 million 
inhabitants (Country Meters 2016) 

With regards to the number of zoo visitors each year, no infor-
mation could be found concerning the total number of visitors. 
However, the biggest zoos in CZ, Prague Zoo, had more than 
1,3 million visitors in 2011 (Zoo Prague 2016). 

Act on Conditions for the Operation of Zoological Gardens and 
amending some Acts (Zákon č. 162/2003 Sb., o podmínkách 
provozování zoologických zahrad a o změně některých zákonů 
(zákon o zoologických zahradách), (Act on Zoological Gar-
dens) No. 162/2003 Coll. Adoption: 18 April 2003. Entry into 
force: July 1, 2003.  
None identified 
None identified 

Country fiche – Denmark 

Key features of the national system: 

 

 

In  Denmark,  the  Zoos  Directive  was  adopted  with  slight  delay  in  2003.  Later  the  law  was 
changed  and  the  Zoos  Directive  is  now  contained  under  Order  1397  (2015).  However,  in  Den-
mark conservation and biodiversity were already incorporated in national policies, and the Zoos 
Directive did not particularly add to that. The national law provides for exemption for  circuses, 
pet shops and pet kennels. In Denmark, zoos already needed a government approval before adop-
tion of the Zoos Directive, and there were about 55 approved zoos at that time. Many of the zoos 
that were closed were very small zoos, that mainly needed a government approval to be able to 
trade wild animals. The Zoos Directive imposed more requirements, which the small zoos were 
not willing to adopt. A consequence of the transposition of the Zoos Directive in Denmark is that 
only bigger zoos remained (DAZA 2016) (Eurogroup for Wildlife & Laboratory Animals 2006). 
In 2010, there were 21 zoos, and in 2015 there were 31 Zoos in Denmark, which are all licensed 
(Danish Veterinary and Food Administration 2016). The yearly number of visitors to Danish zoos 
is estimated at min. 4 million (DAZA 2016). 

  The responsible competent authority for implementation is the Danish Veterinary and Food Ad-
ministration, that also executes the inspection of zoos and issues the licenses. The focus is on an-
imal welfare and prevention of escape.  

  There is no information about costs during the initial period when the Zoos Directive was adopt-
ed. Inspections take place every year on 32 licensed zoos. In 2016, costs for the MS CA in Den-
mark  is  related  to  5-6  staff  that  part-time  work  on  zoo  inspection  and  licensing.  One  inspector 
may be responsible for 3 hours per zoo license for 11 applications or amendments per year. In to-
tal for 32 zoos, staff inputs are equal to approximately 32 x 4 hours with in addition a few new 

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applications and thus mount at 150 hours per year of MS CA office hours spent or 4 weeks for 1 
fte (0,07 fte/year) (DK MS CA Consultation). 

  A zoo license has an indefinite validity. There are no charges for zoos to obtain a license in DK. 
The Denmark CA makes use of external experts for licensing. Initially in Denmark there was a 
council  of  zoo  experts  paid  by  the  MS  CA  to  assist  officials  in  licensing  processes.  However, 
since 2016 zoos need to present an expert report for licensing procedures, and pay for that them-
selves. This mounts to approximately 5000 DK (675 euro). For smaller zoos this can be a burden. 
DAZA  members  have  no  such  costs  as  DAZA  supports  their  members  with  expert  assistance 
(DAZA 2016). 

  The MS CA has no evidence of synergies between the Zoos Directive and other EU legislation, 

 

other than the relevance of the Balai Directive for Zoos (DK MS CA Consultation). 
In  Denmark  there  is  a  zoo  federation  DAZA  (Danish  Association  of  Zoological  Gardens  and 
Aquaria). DAZA has 16 members which represent the biggest zoos in Denmark (DAZA 2016).  

  Noteworthy, Denmark attracted the world attention in 2014 by publicly killing and dissecting a 
young Giraffe at Copenhagen Zoo (Huffington Post 2015). One year later, the same happened by 
publicly killing and dissecting a lion in Odense Zoo. In both cases this provoked international de-
bate on zoos killing animals that were considered redundant, where several animal welfare groups 
fiercely opposed the killing, and EAZA explained that due to lack of space or risk of inbreeding 
not all animals could be kept in the zoos (New York Times 2015).  

Main achievements: 

  Key benefits of the Zoos Directive in Denmark are the competences of the CA to prevent escape 
of wild animals, and improved  animal accommodations. The directive has strengthened the posi-
tion  of  “good”  zoos  with  proper  housing  and  animal  welfare  conditions,  and  led  to  closure  of 
“bad” zoos  (DK CA Consultation).  

  According to the DK CA, licensing works properly, at the time of drafting (Nov 2016) 32 zoos 
were licensed, the register is available on-line. DK legislation requires zoos also to become ap-
proved under the Balai Directive when they apply for a zoo license (checked are own  procedures, 
animal  welfare, public education,  participation  research, and annex A-B  and C in EU  Directive 
92/65) (DK MS CA Consultation).  

Main challenges: 

  According to the DK CA an issue is the alternative wording of Article 3, first indent, of the Zoos 
Directive.This allows  zoos to choose which topic they will take up. "Exchange of information" 
seems the easiest topic which will allow zoos to fulfill the requirements. The DK MS CA did not 
set more stringent requirements, because there are alerady many zoos who are very active in the 
field  of  conservation  programmes,  supported  by  (inter-)national  zoo  federations  (DK  MS  CA 
Consultation). 

  The CA considers that its staff does not have sufficient knowledge in all related fields. It requires 
that zoos involve external experts  when they apply for a license or want to amend the license (for 
new housing facilities etc). Before January  2016 external advise was born as expense by the CA, 
since then the zoos have to pay for the external expertise.  The experts are advising the zoos inter 
alia  on  accommodating  their  animals  under  conditions  which  aim  to  satisfy  the  biological  and 
conservation requirements of the individual speciesand on providing species specific enrichment 
of the enclosures (DK MS CA Consultation). 

  According to the CA, there is a clear discrepancy between IAS and the Zoos Directive: zoos are 
not considered as ex-situ conservation sites under IAS, however, under the Zoos Directive Zoos 
are expressly required to act as an ex-situ conservation site. This is considered to be utterly con-
tradictory.  Also,  exhibition  of  IAS  species  to  the  public  can  greatly  increase  awareness  of  the 
public for the issues of IAS, and exhibition of such species is in line with the requirements of the 
Zoos Directive but is now forbidden under the IAS (DAZA 2016). 

  There is an issue with zoo size: small zoos have less visitors and therefore less financial means to 
contribute in wildlife conservation. Another issue is the documentation of ex-situ activities. This 

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is difficult to control for authorities (DK MS CA Consultation). 

MAPPING OF NATIONAL CONTEXT  
1.1

  Total number of zoos 

1.2
1.3
1.4

  Types of zoos in the country 
  NGOs active at national level  
  Associations of zoos professionals 

1.5

  Brief market overview 

TRANSPOSITION OF THE DIRECTIVE 
1.1 List  of  national  transposing  legisla-

tion 

1.2 Eu infringement cases  

1.3 National case-law 

Country fiche – France 

Key features of the national system: 

2010: total 21, licensed 21 
2015:  total  31,  licensed  31  (Danish  Veterinary  and  Food 
Administration 2016) 
Nearly all private owned 
 
  Danish  Association  of  Zoological  Gardens  and  Aquaria 

(DAZA) 

Overall population in the country: 5,7 million 
Visitors  2015:  4  million  (of  which  175000  children)  in  all    DAZA 
zoos covering 16 major DK zoos (DAZA 2016) 

-Zoo  Order  (Bekendtgørelse  om  zoologiske  haver;  Order  no. 
1023; 1/1/2003 (Retsinformation DK sd), followed by  Zoos Order 
1397 on zoos; 02/12/2015  (Zoos Order 1397) 
-Related  laws:  Order  no.  1494  of  10/12/2015  on  holding  and 
showing  of  animals  in  circuses  (Bekendtgørelse  om  hold  og 
fremvisning af dyr i cirkus mv) (Retsinformation DK sd) 
-Order  no.  1365  of  30/11/2015  on  commercial  trade  with  ani-
mals  (Bekendtgørelse  om  erhvervsmæssig  handel  med  dyr) 
(Retsinformation DK sd) 
-Order  no.  1463  of  07/12/2015  on  commercial  trade  with  and 
breeding  of  dogs,  and  dog  kennels  (Bekendtgørelse  om 
erhvervsmæssig  handel  med  og  opdræt  af  hunde  samt  hun-
depensioner og hundeinternater ) (Retsinformation DK sd) 
In  June  2002,  the  European  Commission  issued  a  letter  of  for-
mal  notice  for  Denmark’s  failure  to  notify  its  transposing 
measures within the timeframe imposed by the Directive. It was 
followed  by  a  Reasoned  Opinion  in  October  2002.  In  January 
2003  Denmark  notified  its  transposing  measure  and  the  case 
was closed.  
NA 

 

France transposed the provisions of Directive 1999/22/EC. However, the national measures effec-
tively implementing the Directive were adopted after the official transposition deadline (9 April 
2002).  

  The  main  national  implementing  measure  is  the  Order  of  25  March  2004.  This  Order  has  been 
amended  several  times  since  its  adoption.  Overall,  it  covers  all  the  provisions  of  Directive 
1999/22/EC.  

  Other national measures have completed the Order of 25 March 2004, most notably the Order of 
10 August 2004 establishing the conditions for the detention of animals of certain non-domestic 
species  in  establishments  practicing  the  breeding,  sale,  rental,  transit  or  public  presentation  of 
non-domestic animal species. Since zoos are also establishments practicing the breeding of non-
domestic animals, they enter in the scope of the Order of 10 August 2004. 
In order to operate, zoos must obtain an authorization (autorisation d’ouverture) (Art L413-3 of 
Environmental Code) and a competence certificate (certificat de  capacité) (Art L413-2 of Envi-
ronmental Code). The competence certificate is personal. The local authorities (Prefect at French 
department level) issue the authorization and the competence certificate. 

 

  The non-respect of these requirements can lead to both criminal and administrative penalties (in-

cluding the closure of the zoo) (see Art L413-5, Art L415-3 of Environmental Code).  

  Local authorities are competent to ensure the enforcement of the rules applying to zoos. Inspec-
tions of zoos are done by regional veterinary services (Directions départementales de la protec-

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tion des populations), in coordination with the national office of hunting and wildlife (Office na-
tional de la chasse et de la faune sauvage). 

  Although there is no formal information on the exact number of zoos in France, there seems to be 
between 300 (info of Ministry of Environment) and 400 zoos in France (info of Les Zoos dans le 
Monde) 358 as of October 2016. Furthermore, the number of visitors of zoos was of approximately 
20 million in 2010 (for a population of 66 million as of 1st January 2016).  
France  has  both  associations  defending  the  interests  of  French  zoos  (eg  Association  Française  
des Parcs Zoologiques) or zoo workers (eg Association Française des Vétérinaires de Parcs Zo-
ologiques), and NGOs focusing on nature conservation and animal welfare (eg One Voice ; Fon-
dation Droit Animal, Ethique et Science). Code Animal deals specifically with animals in captiv-
ity (zoo; circus).  

 

Main achievements: 

  Overall, all the provisions of Directive 1999/22/EC are covered by French law. Relevant provi-

sions can be found in the Environmental Code and the Rural Code (Born Free 2010, 32). 

  Directive  1999/22/EC  has  contributed  to  the  modernisation  of  zoos  structures  and  activities, 

switching the focus of zoos from entertainment to public education on biodiversity.  

Main challenges: 

 

 

 

It is difficult to estimate the number of zoos in France. In 2010, the French Ministry of Environ-
ment  estimated  that  there  were  300  licenced  French  zoos.  However,  another  source  found  that 
943 zoos operated in France, a higher number than the one provided by the French Ministry of 
Environment.  French  NGOs  believe  that  a  majority  of  zoos  operate  without  licencing  and  are 
therefore not regulated by French law (Born Free 2010, 32). 
French NGOs have pointed out that the French law applying to zoos is not specific enough. As a 
result, French zoos would have much leeway to implement conservation activities or animal wel-
fare measures (Garric 2012). 
French  NGOs  have  pointed  out  that  there  is  a  lack  of  consistency  in  the  implementation  of  the 
French  law  applying  to  zoos  on  the  French  territory.  The  French  law  transposing  Directive 
1999/22/EC is implemented  mainly by local actors.  For instance, the Prefect,  at the department 
level,  is  the  competent  authority  to  issue  zoos’  authorization  and  competence  certificate  (Art  L 
413-3 Environmental Code). Despite the regular publication of circulars by the French Ministry 
of  Environment,  the  French  law  applying  to  zoos  is  unequally  applied  throughout  the  country 
(Born Free 2010, 33). 

MAPPING OF NATIONAL CONTEXT  
1.1

  Total number of zoos 

There is no exact data on the number of zoos in France. Sev-
eral sources (French Ministry of Environment, NGOs, and web-
sites) cite different numbers.  
In 2010, the NGO Born Free inventoried three sources of infor-
mation,  each  offering  different  numbers  (Born  Free  2010, 
13;19):359  
- French Ministry of Environment: 300 licenced zoos;360 
- Zoonaute: 233 zoos; 
- Eurogroup: 417 zoos;  
- Les Zoos dans le Monde: 943 zoos. 
In 2016, the author found the following numbers: 
-  French  Ministry  of  Environment:  300  zoos  (Ministère  de 
l'Environnement, de l'Energie et de la Mer 2016); 

358 However, this number could be much higher depending on the criteria used to search for zoos.  
359 Born Free explains that this discrepancy is the result of general inconsistency in the implementation of the relevant French law at local 
level (departmental). This discrepancy can also be explained by other factors, such as the absence of definition of “zoos” under French law; 
the criteria used by different stakeholders to define “zoos”; or whether the census of zoos include non-licenced zoos. 
360 Born Free cited that, according to the French Ministry of Environment, there were 300 licenced zoos in France in 2010. 

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1.2

  Types of zoos in the country 

1.3

  NGOs active at national level  

1.4

  Associations of zoos professionals 

1.5

  Brief market overview 

- Code Animal: 200 zoos (Code Animal s.d.); 
-  Les  Zoos  dans  le  Monde:  347 zoos  (Les  Zoos  dans  le  Monde 
2016).361 
According  to  Born  Free,  most  French  zoos  appear  to  be  pri-
vately  owned  (Born  Free  2010,  19).  Out  of  10  zoos  that  re-
sponded  to  the  questionnaire,  5  were  private  zoos,  3  were 
public zoos, 1 was a charity, and 1 was another type of estab-
lishment.   
The  following  NGOs  are  active  in  the  fields  of  nature  conser-
vation and biodiversity: 
- Société Nationale de Protection de la Nature 
- Noé  
- Conservation Nature 
The following NGOs are active in the field of animal welfare: 
- Code Animal 
- One Voice 
- Animal Cross 
- Fondation Droit Animal, Ethique et Science (LFDA) 
- Fondation Brigitte Bardot 
Some  of  the  abovementioned  animal  welfare  NGOs  have 
lead  campaigns  and/or  activities  on  animal  welfare  in  zoos 
(eg  Animal  Cross).  Code  Animal  deals  specifically  with  ani-
mals in captivity (zoo; circus) (Code Animal s.d.). 
NGOs have different roles/activities: 
-  advocacy  (political  lobbying  ;  consultation  with  policy-
makers); 
-  public  education  and  awareness  raising  (spreading  infor-
mation about specific animal welfare issues); 
- targeted individual actions. 
The following associations defend the interests of French zoos: 
- Association Française  des Parcs Zoologiques (AfdPZ) 
- Union des Conservateurs d’Aquarium  
The following associations defend the interests of zoo workers: 
- Association Francophone des Soigneurs Animaliers 
- Association Française des Vétérinaires de Parcs Zoologiques 
(AFVPZ) 
These associations have different roles : 
- protection of their members’ interests ; 
- representation before national and international instances ;  
- consultation on ethical or legal issues; 
- exchange of knowledge (AFVPZ 2008).362 
As  of  1st  of  January  2016,  according  to  INSEE,  the  overall 
population in France was 66 627 602 inhabitants (INSEE 2016). 
There  is  no  official  data  on  the  number  of  zoo  visitors  in 
France.  However,  according  to  Zoonaute,  approximately  20 
million visitors went to zoos in France in 2010 (Zoonaute 2016). 
INSEE  provides  for  the  turnover  value  index  (indice  de  chiffre 
d'affaires  en  valeur)  for  botanical  and  zoological  gardens  as 
well  as  natural  reserves.  In  1999,  the  average  index  was  52.4 
(INSEE 1999); in 2006, the average index was 74.6 (INSEE 2006); 
and in 2015, the average index was 123.6 (INSEE 2015). 

TRANSPOSITION OF THE DIRECTIVE 
1.1  List of national transposing legisla-

On Eur-Lex : 

tion 

361 The author’s research of zoos in France in 2016 included zoos, aquariums, specialized parks (although farms were excluded), and mono-
specific parks.  
362 For instance, Article 2 of the Statuts de l’Association Française des Vétérinaires de Parcs Zoologiques provides that the “association aims 
to gather veterinaries working in zoos to promote technical professional exchanges, ensure their representation before national and interna-
tional instances and intervene on an advisory basis in areas that are under its competency (ethics, regulation, protection of non-domestic 
animals…). Its means of action are to organise periodic working meetings and assemblies, organise events and any other initiatives which 
support the realization of the purpose of the organisation.” (author’s translation)  

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Order  of  25  March  2004  laying  down  the  rules  of  operation 
and  the  general  characteristics  of  facilities  of  zoological  es-
tablishments  of  fixed  and  permanent  nature,  presenting  the 
public  with  live  specimens  of  local  or  foreign  wildlife  under 
heading  21-40  of  the  nomenclature  of  facilities  classified  for 
environmental protection (Arrêté du 25/3/2004 fixant les règles 
générales  de  fonctionnement  et  les  caractéristiques  gé-
nérales  des  installations  des  établissements  zoologiques  à 
caractère  fixe  et  permanent,  présentant  au  public  des 
spécimens  vivants  de  la  faune  locale  ou  étrangère  et  rele-
vant de la rubrique 21-40 de la nomenclature des installations 
classées pour la protection de l'environnement), Adoption : 25 
March 2004, Entry into force : 2 April 2004, JORF n°78 of 1 April 
2004, pp. 6401-6408, text n°68 (Order of 25 March 2004) 

Decree  No.  2002/266  of  22  February  2002  on  establishments 
holding non-domestic animal species and amending Article R 
213  of  the  Rural  Code  (Décret  n°  2002/266  du  22/02/2002 
relatif  aux  établissements  détenant  des  animaux  d'espèces 
non  domestiques  et  modifiant  l'article  R  213  du  code  rural), 
Adoption: 22 February 2002, Entry into force: 27 February 2002, 
JORF n°48, p. 3629, text n°54 (Decree of 22 February 2002) 

Ministerial Order of 21 November 1997 defining two categories 
of establishments other than establishments practicing breed-
ing,  sale  and  transit  of  game  species  for  which  hunting  is  al-
lowed, holding non-domestic animal species (Arrêté ministéri-
el  du  21  novembre  1997  définissant  deux  catégories  d'é-
tablissements  autres  que  les  établissements  d'élevage,  de 
vente  et  de  transit  des  espèces  de  gibier  dont  la  chasse  est 
autorisée,  détenant  des  animaux  d’espèces  non  domes-
tiques),  Adoption :  21  November  1997,  Entry  into  force :    6 
February 1998, JORF n°30 of 5 February 1998, p. 1866 (Ministe-
rial Order of 21 November 1997)  

Amended Ministerial  Order of 25  October  1995 on  the  imple-
mentation  of  the  control  of  establishments  holding  non-
domestic  animal  species  (Arrêté  ministériel  du  25  octobre 
1995  modifié  relatif  à  la  mise  en  œuvre  du  contrôle  des 
établissements détenant des animaux d'espèces non domes-
tiques),  Adoption :  25  October  1995,  Entry  into  force :  11  No-
vember  1995,  JORF  n°262  of  10  November  1995,  p.  16543 
(Amended Ministerial Order of 25 October 1995) 

Arrêté  ministériel  du  21  août  1978  fixant  les  caractéristiques 
auxquelles  doivent  satisfaire  les  installations  fixes  ou  mobiles 
des  établissements  présentant  au  public  des  spécimens  vi-
vants  de  la  faune  locale  ou  étrangère  (Abrogated  by  Order 
of 18 March 2011) 

Arrêté  ministériel  du  21  août  1978  relatif  aux  règles  générales 
de fonctionnement et contrôle des établissements présentant 
au public des spécimens vivants de la faune locale ou étran-
gère (Abrogated by Order of 18 March 2011) 

Not on Eur-Lex : 

Order of 19 May 2009 amending the Order of 25 March 2004 
laying down the rules of operation and the general characte-
ristics  of  facilities  of  zoological  establishments  of  fixed  and 
permanent  nature,  presenting  the  public  with  live  specimens 
of local or foreign wildlife under heading 21-40 of the nomen-
clature  of  facilities  classified  for  environmental  protection 

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(Arrêté  du  19  mai  2009  modifiant  l'arrêté  du  25  mars  2004 
fixant  les  règles  de  fonctionnement  et  les  caractéristiques 
générales  des  installations  des  établissements  zoologiques  à 
caractère  fixe  et  permanent,  présentant  au  public  des  spé-
cimens vivants de la faune locale ou étrangère et relevant de 
la rubrique 2140 de la nomenclature des installations classées 
pour  la  protection  de  l'environnement),  Adoption :  19  May 
2009,  Entry  into  force :  14  June  2009,  JORF  n°0135  of  13  June 
2009, p. 9708, text n°11 (Order of 19 May 2009) 

Order  of  10  August  2004  establishing  the  conditions  for  the 
detention of animals of certain non-domestic species in esta-
blishments  practicing  the  breeding,  sale,  rental,  transit  or  pu-
blic  presentation  of  non-domestic  animal  species  (Arrêté  du 
10  août  2004  fixant  les  conditions  d'autorisation  de  détention 
d'animaux  de  certaines  espèces  non  domestiques  dans  les 
établissements d'élevage, de vente, de location, de transit ou 
de  présentation  au  public  d'animaux  d'espèces  non  domes-
tiques), Adoption : 10 August 2004, Entry into force : 1 October 
2004,  JORF  n°228  of  30/09/2004,  text  n°36,  p.  16821  (Order  of 
10 August 2004) 

Amended by : 
Order of 5 March 2008 amending the orders of 10 August 2004 
laying  down  general  rules  for  the  functioning  of  accredited 
breeding establishments of non-domestic animal species and 
of 10 August 2004 establishing the conditions for the detention 
of  animals  of  certain  non-domestic  species  in  establishments 
practicing  the  breeding,  sale,  rental,  transit  or  public  pre-
sentation  of  non-domestic  animal  species  (Arrêté  du  5  mars 
2008  modifiant  les  arrêtés  du  10  août  2004  fixant  les  règles 
générales  de  fonctionnement  des  installations  d'élevage 
d'agrément  d'animaux  d'espèces  non  domestiques  et  du  10 
août  2004  fixant  les  conditions  d'autorisation  de  détention 
d'animaux  de  certaines  espèces  non  domestiques  dans  les 
établissements d'élevage, de vente, de location, de transit ou 
de  présentation  au  public  d'animaux  d'espèces  non  domes-
tiques),  Adoption :  5  March  2008,  Entry  into  force :  19  May 
2008, JORF n°0115 of 18 May 2008, text n°5, p. 8105 (Order of 5 
March 2008) 
AND 
Order  of  24  March  2005  amending  the  order  of  10  August 
2004 laying down general rules for the functioning of accredi-
ted  breeding  establishments  of  non-domestic  animal  species 
and the order of 10 August 2004 establishing the conditions for 
the  detention  of  animals  of  certain  non-domestic  species  in 
establishments  practicing  the  breeding,  sale,  rental,  transit  or 
public  presentation  of  non-domestic  animal  species  (Arrêté 
du  24  mars  2005  modifiant  l'arrêté  du  10  août  2004  fixant  les 
règles  générales  de  fonctionnement  des  installations  d'éle-
vage  d'agrément  d'animaux  d'espèces  non  domestiques  et 
l'arrêté du 10 août 2004 fixant les conditions d'autorisation de 
détention  d'animaux  de  certaines  espèces  non  domestiques 
dans les établissements d'élevage, de vente, de location, de 
transit ou de présentation au public d'animaux d'espèces non 
domestiques),  Adoption :  24  March  2005,  Entry  into  force :  24 
April 2005, JORF n°95 of 23 April 2005, text n°43, p. 7117 (Order 
of 24 March 2005) 
On 6 June 2002, the Commission sent a letter of formal notice 
to France for non-communication of the national implement-
ing  measures  transposing  Directive  1999/22/EC.  On  31  July 
2002  and  5  August  2002,  France  sent  the  list  of  transposing 
measures.  This list revealed that  transposition had been com-

1.2  Eu infringement cases  

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1.3  National case-law 

pleted by the time of the transposition deadline (9 April 2002). 
The 
infringement  case  was  therefore  closed  (European 
Commission 2002). 

However, it should be pointed out that the main national im-
plementing  law  effectively  transposing  Directive  1999/22/EC 
was enacted in 2004, meaning 2 years after the official trans-
position deadline (see Order of 25 March 2004)  

  Cass (crim), 4 October 2011, n°11-80198 (Jaworski 2012) 
  Criminal  complaint  against  the  Strasbourg  Zoo  for  viola-
tion  of  Order  of  25  March  2004  and  Directive  1999/22/E 
(2013) (Code Animal 2013) 

responsabilité 

  CAA  Nancy,  22  January  2015,  Société  coopérative  de 
production  à 
«  Parc  Zoo 
d’Amnéville  »  (Régime  fiscal  d’un  abri  pour  orangs-
outans 2015) 
Tribunal  Administratif  de  Limoges,  11  February  2016,  M. 
A…, n° 130085 

limitée 

 

Country fiche – Germany 

Key features of the national system: 

  The  Zoos  Directive  has  been  transposed  with  a  framework  provision:Art  10  para  2  No.  19  and 
Art.  51  of  the  Federal  Nature  Conservation  Act    (Gesetz  über  Naturschutz  und  Land-
schaftspflege). Adoption: 2002 Entry into force:  2002.  Subsequently the Federal States enacted 
implementing laws in their States (see Table below). Full transposition and implementation of the 
Directive in all 16 Federal States was not fully achieved until 2004, following intervention by the 
European  Commission  (legal  case  C-339/03).  In  2009  a  new  Federal  Nature  Conservation  Act   
was established after Federal Reform in which the framework provisions were replaced with a set 
of  provisions  on  the  Federal  Level  which  were  directly  applicable  without  additional  Federal 
States  regulations  Adoption:  29  July  2009  (BGBl.  IS.2542).  Entry  into  force:  1  March  2010 
(BNatSchG).  Article 42 (Zoos) and 43  (Tiergehege) refer in particular to the transposition of the 
Zoos Directive (our Study, (Born Free Foundation 2011). 

  The  Federal  Government  does  not  maintain  a  central  register  of  licensed  zoos  in  Germa-
ny.Official information on the number of licensed zoos in the country is however derived from in-
formation from the federal states. In 2015, there were 364 licensed and unlicensed zoos (MS CA 
survey).  From other sources, the estimated number of zoos in Germany differs from 600  (Born 
Free Foundation 2011), to 865  (zoo-infos.de 2016).  There are more than 200 zoos, animal and 
wildlife parks member of the Association of Zoological Gardens (VdZ), the German Animal Park 
Society (DTG) and the German Game Reserve Association (DWV). In addition, there are more 
than  500  publicly  available  establishments  for  wild  animals,  such  as  small  zoos,  animal  enclo-
sures, bird parks, aviaries, reptile zoos, aquaria, of which about 400 may be considered as "zoo" 
according  to  the  definition  of  the  EU  Zoos  Directive  (Verband  der  Zoologischen  Gärten  VdZ 
2016).  

  There  are  no  official  figures  on  zoos  visitors  in  Germany.  The  estimated  number  of  visitors  in 
Germany  are  visitors  to  zoos  that  are  member  of  the  zoos  federations:  visitors  to  zoos  that  are 
members  of  the  Association  of  Zoological  Gardens  (Verband  der  Zoologischen  Gärten-VdZ) 
were 33.4 million (2014); visitors to the animal and wildlife parks that are member of the German 
Animal Park Society (Deutschen Tierpark-Gesellschaft-(DTG) and of the German Game Reserve 
Association (Deutschen Wildgehege-Verband-DWV) counted 12 to 13 million visitors. With visi-
tors  of  the  other  institutions  estimated  at  20  million,  in  total,  the  number  of  visitors  to  German 
zoos  mount  to  more  than  65  million  per  year    (zoo-infos.de  2016)  (Verband  der  Zoologischen 
Gärten VdZ 2016) 

  Germany is a Federal State and the Federal Ministry for the Environment, Nature Conservation, 
Building and Nuclear Safety is responsible for the Zoos Directive at the Federal Level. The Zoo 

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Directive is transposed into national law by the Federal Nature Conservation Act,  which is appli-
cable  throughout  Germany.  The  implementation  of  the  relevant  provisions  on  the  ground   rest 
with the Federal States. It is also for the Federal States to determine the competent authorities for 
decisions and inspections with regard to the rules of the Directive as well as the procedures (our 
survey). 
In the German law zoos are defined as‘permanent facilities in which living animals of species that 
live in the wild are kept for purposes of display, for a period of at least seven days of a year’.  
  Exemptions according to Article 2 exist for: 1.circuses; 2.pet shops, and 3.enclosures for keeping 
no more than five species of hoofed game listed in the Federal Hunting Act (Bundesjagdgesetz) 
or facilities in which no more than 20 animals of other wild species are kept (our study). 

 

  There  is  no  information  about  CA  costs  during  the  initial  period  when  the  Zoos  Directive  was 
adopted or for today’s expenditure. The number of zoos is limited and does not justify full time 
staff dedicated to zoos inspections. The duration of one inspection is subject to the relevant cir-
cumstances. It varies from several hours to a few days per zoo, depending on the size and com-
plexity of the zoo (our study). Generally the number of zoos to be covered by one inspector (per 
year) varies from one to three zoos (our study). 

  The  CA  issues  guidelines  for  housing  and  accommodation  Invalid  source  specified..  The  EU 
Zoos Directive Good Practice document is useful, but would have a wider impact when available 
in German (our study). 

  According  to  the  German  central  CA,  the  validity  of  a  zoo  license  in  most  cases  is  unlimited. 
However, the licence can be repealed if the conditions are not met or the conditions changes. The 
intervals  between  inspections  vary  subject  to  the  numbers  of  animals  kept  and  specific  circum-
stances (e.g. shortcomings or other irregularities have been observed). They may take place once 
or several times per year. Anyone who establishes a zoo without permission, expands it, or signif-
icantly  changes  its  operation,  commits  an  administrative  offense  (§  69  para.  3  no.  18  of  the 
BNatSchG)  and  may  receive  in  accordance  with  section  §  69  a  fine  of  maximum  10,000.  euro 
(our study).  

  Costs for licenses for zoos depend on the federal state (see table). 
  The are many synergies between the Zoos Directive EAZA, WAZA, IUCN guidelines which are 
more important documents to guide large zoos  towards conservation measures than the Zoos Di-
rective (NGO interview). 

  The following associations defend the interests of German zoos: Association of Zoological Gar-
dens  (Verband  der  Zoologischen  Gärten  -VdZ);  German  Animal  Park  Society  (Deutschen 
Tierpark-Gesellschaft-(DTG);  German  Game  Reserve  Association  (Deutschen  Wildgehege-
Verband -DWV).  

  The following two association represent professionals from the zoo sector: German Zoo Educa-

tors Association VZP; Union of Zookeepers (Berufsverband der Zootierpfleger -BdZ). 

  The following NGOs are active at national level in Germany: BMT (Bund gegen Missbrauch der 
Tiere) (BMT (Bund gegen Missbrauch der Tiere) 2016) The BMT carries out awareness and pub-
lishes opinion papers on animals in captivity, and contributes to the public debate. Animal Public 
e.V. carries out activities to improve animal protection and animal rights (our study). 

  A remarkable event occurred in 2009 with the commercial success due to the birth of a  polar bear 
(Knut) that boosted zoos visitor numbers. It indirectly caused a legal case between the Berlin Zoo, 
where the bear was born in 2006, and the Neumünster zoo, which claimed a share of the estimat-
ed 10 million euro in entrance fees and merchandising revenue that Knut has earned363.  
In  2016,  escape  of  a  lion  from  the  Leipzig  zoo  attracted  widespread  attention  as  German 
zookeepers shot dead the animals after two escaped from their enclosure 364. 

 

Main achievements: 

  With the implementation of the Directive the quality of the zoos has improved overall in Germa-

363 https://www.theguardian.com/environment/2009/may/19/german-zoos-fight-over-knut 
364 http://www.abc.net.au/news/2016-09-30/lion-motshegetsi-shot-dead-at-german-zoo-after-escape/7891472?pfmredir=sm 

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ny. The Zoo directive has strengthened the efforts in Zoos to improve and satisfy especially the 
biological and requirements of the individual species. In practice, the implementation of the Zoo 
directive is mostly focused on animal welfare. Only in big zoos adequate conditions exist for sig-
nificant ex-situ measures (our study, CA VdZ questionnaire).  

  The increased impact of modern zoos in the conservation of global biodiversity, public education, 
research and animal husbandry is mainly due to the efforts of each individual zoo as well as the 
exchange with zoo associations, wildlife-experts from the zoo community and in-situ colleagues, 
scientists  and  other  conservation  related  NGOs  as  well  as  donors.  The  EU  Directive  has  been 
partly  important  by  providing  the  legal  framework  for  this  impact.  Furthermore,  harmonising 
standards across Europe has been found helpful for the extensive cooperation between European 
zoos (Verband der Zoologischen Gärten VdZ 2016)365 

  The Zoo directive achieved to some extent the greatest benefit in the field of species appropriate 
husbandry.  Significant  improvements  were  achieved  in  nearly  all  zoos.  The  smallest  benefit 
seems to be gained in the field of biodiversity within the Zoos and in the attitude of the people 
(our study).  
For Zoos the certification implies a sort of Quality label More efforts of the facilities in respect to 
husbandry conditions, closure of Zoos with unfavourable husbandry conditions, improvement of 
education skills of different Zoos. Improvement of public education and awareness in relation to 
the conservation of biodiversity, providing information about the species exhibited and their natu-
ral habitats (our study). 

 

  Many big zoos already were active in conservation of biodiversity before the Zoos Directive was 
adopted. Big Zoos also have the manpower, the financial capacities and the scientific knowhow, 
to meet the legal requirements of Art. 3 of the Zoo directive. For little zoos, it is the exact oppo-
site. They hardly can cope with the implementation of the legal requirements mainly for financial 
reasons. In consequence they often lose their license (our study).  

Main challenges: 

  Because the implementation of the Zoos Directive is delegated to the Federal States and does not 
follow national guidelines, The Born Free study concluded that the inspection and licensing ap-
peared not to be applied in a uniform manner across the country (Born Free Foundation 2011).  
  Lack of financial capacities and space for smaller zoos and zoos in cities limit efforts for imple-
menting the requirements of the zoo directive for smaller zoos notably on activities for conserva-
tion of biodiversity (our study).  
In view of the European Commission Zoos could hardly get an exemption from Art. 7 IAS regu-
lation to hold and breed IAS of European concern; thus they cannot promote public education and 
awareness in relation to the danger to these animals (our study). 

 

  The  Directive  refers  to  the  state  of  the  art  of  conservation.  It  has  no  procedure  for  adapting  to 

technical and scientific progress (Verband der Zoologischen Gärten VdZ 2016). 

  EAZA did not allow that her guidelines were used by the authorities in Bayern and also did not 
give access to non zoo experts working on the expert opinion on minimum requirements for the 
keeping  of  mammals  of  the  Bundesministerium  für  Ernährung  und  Landwirtschaft.  The  new 
(2015) EU Good  Practice  document  is  useful,  but would be better used if in German  language. 
Access ought to be easier. At the moment a lot of searching is necessary to retrieve relevant doc-
uments (Regional CA Interview). 

MAPPING OF NATIONAL CONTEXT  
1.1

  Total number of zoos 

There is no a central register of licensed zoos in Germany but 
official information on the number of licensed zoos in the 
country is derived from information from the federal states:   
2010: 319 licensed and unlicensed zoos (MS CA survey) 
2015: 364 licensed and unlicensed zoos (MS CA survey) 
From other sources, the estimated number of zoos in Germany 

365 The VDZ will come with a separate position paper via EAZA of which she is a member. 

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1.2

  Types of zoos in the country 

1.3

  NGOs active at national level  

1.4

  Associations of zoos professionals 

1.5

  Brief market overview 

TRANSPOSITION OF THE DIRECTIVE 
1.1  List of national transposing legisla-

tion 

1.2  Eu infringement cases  

differs  from  600  (Born  Free  Foundation  2011),  to  865  (zoo-
infos.de 2016).  
Nearly  all  zoos  are  privately  owned,  particularly  smaller  zoos 
(Born Free Foundation 2011) 
The following NGOs are active at national level in Germany: 
 

BMT (Bund gegen Missbrauch der Tiere) (BMT (Bund gegen 
Missbrauch der Tiere) 2016) The BMT carries out awareness 
and publishes opinion papers on animals in captivity, and 
contributes to the public debate 

  Animal Public e.V. carries out activities to improve animal 

protection and animal rights.   

The  following  associations  defend  the  interests  of  German 
zoos: 
  Association  of  Zoological  Gardens  (Verband  der  Zoolo-

gischen Gärten -VdZ) 

  German  Animal  Park  Society 

(Deutschen 

Tierpark-

Gesellschaft-(DTG) 

  German  Game  Reserve  Association  (Deutschen  Wildge-

hege-Verband -DWV) 

The following two association represent professionals from the 
zoo sector: 
  German Zoo Educators Association VZP 
  Union  of  Zookeepers  (Berufsverband  der  Zootierpfleger  -

BdZ)  

Overall population in the country: 81  million ( (Country Meters 
2016)) 
There  are  no  official  figures  on  zoos  visitors  in  Germany.  The 
estimated  number  of  visitors  in  Germany  are  visitors  to  zoos 
that  are  member  of  the  Zoo  Federations:  visitors  to  zoos  that 
are  member  of  the  Association  of  Zoological  Gardens  (Ver-
band  der  Zoologischen  Gärten-VdZ)  were  33.4  million  (2014); 
visitors to the animal and wildlife parks that are member of the 
Tierpark-
German  Animal 
Gesellschaft-(DTG) and of the German Game Reserve Associ-
ation  (Deutschen  Wildgehege-Verband-DWV)  counted  12  to 
13 million visitors. With visitors of the other institutions estimated 
at  20  million,  in  total,  the  number  of  visitors  to  German  zoos 
mount  to  more  than  65  million  per  year    (zoo-infos.de  2016) 
(Verband der Zoologischen Gärten VdZ 2016) 

(Deutschen 

Society 

Park 

The Directive has been transposed with a framework provision 
(Art 10 para 2 No. 19 and Art. 51 of the Federal Nature Con-
servation Act  (Gesetz über Naturschutz und Land-
schaftspflege) (‘BNatSchG’). Adoption: 2002 Entry into force:  
2002. Subsequently the Federal States enacted implementing 
laws in their States. Full transposition and implementation of 
the Directive in all 16 Federal States was not fully achieved 
until 2004, following intervention by the European Commission 
(legal case C-339/03)(see Table below). In 2009 a new Federal 
Nature Conservation Act   was established after Federal Re-
form in which the framework provisions were replaced with a 
set of provisions on the Federal Level which were directly ap-
plicable without additional Federal States regulations Adop-
tion: 29 July 2009 (BGBl. IS.2542). Entry into force: 1 March 2010 
(BNatSchG).  Article 42 (Zoos) and 43  (Tiergehege) refer in 
particular to the transposition of the Zoos Directive (our Study, 
(Born Free Foundation 2011).  
On June 2002 the Commission issued a letter of formal notice 
to  the  German  Government  regarding  its  transposition  of  the 
Directive.  A  main  act  was  already  in  place  (ie  BNatSchG) 
transposing  Articles  3(4),  3(5)  and  4.  The  other  articles  had  to 
be transposed by the different Landers. Only three (out of 16) 

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landers  had  done  so.  In  October  2002  the  Commission  issued 
a Reasoned Opinion. Two other landers transposed the legisla-
tion.  In  August  2003  the  Commission  referred  the  case  to  the 
ECJ.  In  the  course  of  the  procedure  additional  eight  landers 
transposed the Directive. On 14 October 2004 the Court ruled 
in  Case  C-339/03  that  Germany  had  failed  to  transpose  the 
Directive (Commission v. Germany 2004). In January 2005 only 
Bavarian  transposition  was  missing.  Before  the  Commission 
issued  Letter  of  Formal  notice  for  failure  to  comply  with  the 
judgment  of  the  Court  (Art.  260  TFEU),  Germany informed  the 
Commission  that  Bavaria  had  transposed  the  legislation  in 
August  2005.  Transposition  was  hence  considered  complete 
and the case closed. 
NA 

1.3  National case-law 

Country fiche – Ireland 

Key features of the national system: 

  The  competent  authority  for  zoos  in  Ireland  is  the  Minister  for  Arts,  Heritage,  Regional,  Rural 
and Gaeltacht Affairs. The application of the Directive is carried out by the National Parks and 
Wildlife  Service  which  is  a  Division  of  the  Department  of  Arts,  Heritage,  Regional,  Rural  and 
Gaeltacht Affairs (our study).  

  The  Republic  of  Ireland  did  not  have  any  statutory  licensing  and  inspection  arrangements  on 
zoos. The Zoos Directive was transposed as European Communities (Licensing and Inspection of 
Zoos)  Regulations  2003,  S.I.  No.  440/2003  of  19/09/2003.  Irish  Statute  Book  (Office  of  the 
Attorney General 2016). Adopted: 19th September, 2003  Entry into force: April 2005 (Licensing 
and Inspection of Zoos) 

  There was one EU  Court case when in  June 2002 a Letter of formal notice  was  sent to Ireland 
concerning the non-transposition of the Directive into national law. This was followed by a Rea-
soned Opinion in October 2002, which in turn was followed by Saisine in June 2003. Ireland re-
sponded  in  September  2003  with  European  Communities  (Licensing  and  Inspection  of  Zoos) 
Regulations 2003, S.I. No. 440/2003. The case was then withdrawn. 

  There are no official records of the number of zoos in Ireland. In 2010 the EU Zoo Inquiry report 
for Ireland inventoried 10 licensed zoos, although the report considered that there were 27 collec-
tions that may satisfy the Directive’s definition of a zoo (BornFree 2011). For the present study, 
17  zoos  were  identified  by  the  authors.  According  to  the  MS  CA,  the  number  of  zoos  was  un-
known  in  2010,  and  mounted  to  approximately  30  in  2015,  pending  assessment  of  unlicensed 
premises (our study) 

  There are no official records of the number of visitors. As an indication, Dublin Zoo, Fota Wild-
life  Park  and  Dingle  Oceanworld  present  the  following  information  on  visitor  numbers.  Dublin 
Zoo attracts more than 1 million visitors a year Invalid source specified.; Fota Wildlife Park at-
tracts 440,000 visitors a year Invalid source specified. 

  The  National  Parks  and  Wildlife  Service  issues  licences  for  the  Minister  for  the  Department  of 
Arts, Heritage, Regional, Rural and Gaeltacht Affairs who is the sole competent authority for the 
Zoos Directive in Ireland. The zoo licence inspectorate is appointed on a contract basis by the Na-
tional Parks and Wildlife Service of the Department of Arts, Heritage, Regional, Rural and Gael-
tacht Affairs. 

  Zoos  are  defined  as  in  the  Zoos  Directive.  In  addition,  the  Irish  Zoo  Licence  Guidance  notes  - 
GN03 contains exemption criteria and application advises that a collection will be considered ex-
empt from the zoos legislation if, among other things which are also set out in the guidance doc-
ument, it does not normally exceed 100 specimens.  

  The  CA  does  issue  guidelines  as  minimum  standards  set  by  law,  for  animal  accommoda-
tion/enclosure size, mentioned in Appendix 9 of the Irish Standards of Modern Zoo Practice that 
sets  out  specific  sizes  for  elephant  enclosures  both  indoor  and  outdoor.  Enclosure  sizes  are  not 
specified for any other animal or category of animal or species Invalid source specified.(our sur-

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vey).  

  A  first  licence  lasts  2  years  and  subsequent  licences  for  3  years.  Legislation  allows  for  up  to  5 
years for a licence. Inspections are carried out annually of licenced zoos. No charge applies for a 
zoo licence in Ireland. Zoos are scheduled to be inspected once a year after a licence is granted. 
Summary offences can be penalised in the Courts with a fine of up to 3000 euro or 6 months im-
prisonment or both (our study). 

  The  British  and  Irish  Association  of  Zoos  and  Aquariums  (BIAZA),  presents  IAZA  and  is  the 
British and Irish Association of Zoos and Aquariums; the professional body representing the best 
zoos and aquariums in Britain and Ireland. The Federation implemented a zoo inspection process 
to ensure the highest levels of animal welfare were achieved, and created a community that en-
couraged its members to share expertise and best practice with the aim of continuously improving 
standards Invalid source specified.  

  The Association of British and Irish Wild Animal Keepers (ABWAK) is a membership organisa-
tion  for  those  interested  and  involved  in  the  keeping  and  conservation  of  wild  animals, which 
seeks  to  achieve  the  highest  standards  of  excellence  in  animal  welfare  through  communication, 
cooperation, training and development Invalid source specified. 

Main achievements: 

  Born Free consider that the transposing legislation is largely good, with some (relatively minor) 

issues (BornFree 2011). 

  The  MS  CA  has  produced  a  Zoos  Standards  document  and  enhanced  the  licensing  process,  in-
cluding  questionnaires  and  allows  stronger  interaction  between  zoos  and  inspectors.  Inspection 
teams have a greater breadth of experience. Absence of ZD would not have given the framework 
to go through this (Zoo Federation Interview)  

  Especially  husbandry  in  zoos  has  improved,  that  can  be  attributed  to  the  Zoos  Directive  (Zoo 

Federation Interview). 

  The Directive required that a law was implemented for the education and conservation of biodi-
versity. Operators understand the potential role they can play and as such have grown responsibly 
in the most part (MS CA interview) 

  The approach in IE has been to encourage zoos to comply rather than take a confrontational ap-
proach and force compliance. The emphasis, therefore, has been on raising standards in zoos over 
a number of years, from a situation where, pre-Zoos Directive, there were no agreed standards. 
The context within zoos operate in the country is now strengthened and there is publicly available 
guidance in existence that spells out expectations. There was no zoo licensing regime in IE before 
the  Zoos  Directive  entered  into  force.    Bringing  a  consistent  approach  to  the  regulation  of  this 
sector across the Union is a worthy aim and is being successfully achieved in this Member State 
(MS CA interview) 

Main challenges: 

  Challenging  issues  are:  the  application  of  the  definition  of  zoos  and,  therefore,  the  number  of 
establishments  to  which  the  Directive  applies;  the  extent  of  enforcement  requires  clarification; 
and although it has only just appeared (ie 13 years after the transposing legislation and 17 years 
after the Directive), Irish Standards of Modern Zoo Practice Invalid source specified. appears to 
be a strong guide to the application of the Directive, based in large part on the UK framework for 
zoo standards and licensing. 

  There is little analysis of the wider context within zoos operate and so there appears little synthe-
sis of either the achievements or of the challenges that remain to be faced (apart from understand-
ing enforcement) from the literature consulted. Ireland has only three zoos that are members of 
BIAZA and two of those are also members of EAZA. Therefore, the national contribution of zoos 
to conservation programmes must be understood within that context.  

  Definition of zoos is tricky. In UK, definition is very broad and includes many institutions that 
many would not see as zoos, Some other organisations are not covered e.g mobile zoos. IE is ex-
ploring how to include these as zoos. Definition of zoo is barrier (Zoo Federation Interview)  

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 

IAS is a real issue and zoos recognize that this is a significant concern, but there should be a more 
thoughtful  and  systematic  approach  to  understanding  which  are  the  problem  species.  Zoos  are 
regulated and have to adjust their practices in the light of IAS.  Pet ownership is not regulated, 
however, and is, perhaps not adjusting to the concerns of IAS as readily. Zoo license already says 
that animals are not allowed to escape (our study). 

  The most frequent compliant about the Directive comes from small operators who have difficulty 
with  all  the  administrative  paperwork  and  zoo  inspection  process  which  is  time  consuming  for 
them and a drain on often scarce resources (our study). 

MAPPING OF NATIONAL CONTEXT  
1.1

  Total number of zoos 

1.2

  Types of zoos in the country 

1.3

  NGOs active at national level  

1.4

  Associations of zoos professionals 

1.5

  Brief market overview 

TRANSPOSITION OF THE DIRECTIVE 
1.4  List of national transposing legisla-

tion 

1.5  Eu infringement cases  

In  2010  the  EU  Zoo  Inquiry  report  for  Ireland  inventoried  10 
licensed  zoos,  although  the  report  considered  that  there 
were  27  collections  that  may  satisfy  the  Directive’s  defini-
tion of a zoo (BornFree 2011). For the present study, 17 zoos 
were identified by the authors. 
According to the MS CA, the number of zoos was unknown 
in  2010,  and  mounts  to approximately 30 in  2015,  pending 
assessment of unlicensed premises (our study)  
Zoos  appear  to  be  a  mixture  of  public  ownership,  with 
charitable  status,  and  privately  owned,  some  as  commer-
cial enterprises, others as scientific establishments (BornFree 
2011). 
No NGOs identified that are in particular active for Zoo 
animals 
The British and Irish Association of Zoos and Aquariums (BIA-
ZA), presents IAZA and is the British and Irish Association of 
Zoos and Aquariums; the professional body representing 
the best zoos and aquariums in Britain and Ireland. The 
Federation implemented a zoo inspection process to en-
sure the highest levels of animal welfare were achieved, 
and created a community that encouraged its members 
to share expertise and best practice with the aim of con-
tinuously improving standards Invalid source specified.  

The Association of British and Irish Wild Animal Keepers 
(ABWAK) is a membership organisation for those interested 
and involved in the keeping and conservation of wild ani-
mals, which seeks to achieve the highest standards of ex-
cellence in animal welfare through communication, coop-
eration, training and development Invalid source 
specified. 
According to the most recent national statistics, Ireland has 
4,797,476 inhabitants Invalid source specified.. 
Dublin  Zoo,  Fota  Wildlife  Park  and  Dingle  Oceanworld  are 
members  of  BIAZA  and  the  first  two  are  also  members  of 
EAZA  (BornFree  2011).  They  present  the  following  infor-
mation on visitor numbers. 
Dublin Zoo attracts more than 1 million visitors a year Invalid 
source specified. 
Fota  Wildlife  Park  attracts  440,000  visitors  a  year  Invalid 
source specified. 
Invalid  source  specified.  contains  no  information  on  visitor 
numbers for Dingle Oceanworld. 

European Communities (Licensing and Inspection of Zoos) 
Regulations 2003, S.I. No. 440/2003 of 19/09/2003. Irish Stat-
ute Book (Office of the Attorney General 2016). Adopted: 
19th September, 2003  Entry into force: April 2005 (Licensing 
and Inspection of Zoos) 
June  2002:  a  Letter  of  formal  notice  was  sent  to  Ireland 
concerning  the  non-transposition  of  the  Directive  into  na-

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tional  law.  This  was  followed  by  a  Reasoned  Opinion  in 
October 2002, which in turn was followed by Saisine in June 
2003. Ireland responded in September 2003 with European 
Communities  (Licensing  and  Inspection  of  Zoos)  Regula-
tions 2003, S.I. No. 440/2003. The case was then withdrawn.  
None identified 

1.6  National case-law 

Country fiche – Italy 

Key features of the national system: 

 

  The EU Directive 1999/22/EC (hereinafter ‘Zoo Directive’) was transposed in Italy only in 2005 

through the Legislative Decree 21 March 2005 n. 73366.  
In 2006, the Legislative Decree 73/2005 (implementing the Zoo Directive)  was amended twice, 
firstly by the Decree of the Ministry of the Environment 4/2006, and subsequently by the Legisla-
tive Decree n. 192/2006. In particular, the first modification brought by the Decree of the Minis-
try of the Environment 4/2006367 abolished a specific requirement related to the timing for the re-
quest of a license. This objective was obtained by deleting the sentence "within 180 days from the 
date of entry into force of this Regulation" from the Annex 4 A) 1 of the Italian Legislative De-
cree 73/2005. The second modification, which was brought by the Legislative Decree n. 192 of 4 
April  2006368,  modified  the  definition  of zoos  as  originally  contained  in  the  Article  2  of  Italian 
Legislative Decree n. 73/2005. 

  Combined together, the two modifications of the Legislative Decree 73/2005 (implementing the 
zoo Directive), had the effect of discouraging the zoos to protect the fauna and safeguard the bio-
logical diversity, as well as requesting a license. This scenario was considered as a breach of the 
Zoo Directive by the European Commission which started an infringement procedure against the 
Italian Republic (Infringement procedure 2007/2179).  
In order to comply with the request of the European Commission the Italian Republic amended 
the  Legislative  Decree  73/2005  with  the  Law  n.  101/2008369.  The  Law  n.  101/2008  in  fact  re-
established the original definition of zoo (as it was written in the first version of art. 2 of the Leg-
islative Decree n. 73/ 2005) and the system of licenses. 

 

  The Italian Ministry of Environment is the Competent Authority in charge of implementing the 
Directive, 1999/22/EC and  the Italian  Legislative Decree 73/2005  which give effects to the Di-
rective. The Ministry of Health and the Ministry of Agriculture and Forestry cooperate with the 
Ministry of Environment in the implementation of the Directive (particularly, in relation to the in-
spection for the issuance of the license and for subsequent controls). The State Forestry Corps act 
as enforcement authority by detecting, and referring to the Competent Authority, establishments 
that could qualify as zoos and should be, therefore, subject to the legislation370. 

Main achievements: 

366 Decreto Legislativo 21 marzo 2005, n. 73, ‘Attuazione della direttiva 1999/22/CE relativa alla custodia degli animali selvatici nei giardini 
zoologici’, (GU n. 100 del 2-5-2005), available at: 
 http://www.minambiente.it/sites/default/files/archivio/allegati/biodiversita/dlgs_21_03_05_n73.pdf (accessed October 2016). 
367 Decreto 18 gennaio 2006 del Ministero dell'ambiente e della tutela del territorio, Modifica all'allegato 4 del decreto legislativo 21 marzo 
2005, n. 73, recante attuazione della direttiva 1999/22/CE relativa alla custodia degli animali selvatici nei giardini zoologici (GU n. 26 del 1-
2-2006), avaible at:  
http://www.ambientediritto.it/Legislazione/Fauna%20e%20Flora/2006/dm_18gen2006.htm (accessed October 2016). 
368 Decreto Legislativo 4 aprile 2006, n. 192, ‘Disposizioni correttive del decreto legislativo 21 marzo 2005, n. 73, recante attuazione della 
direttiva 1999/22/CE relativa alla custodia degli animali selvatici nei giardini zoologici’, (GU n. 121 del 26 -5 -2006), available at: 
http://www.camera.it/parlam/leggi/deleghe/06192dl.htm (accessed October 2016). 
369 Legge 6 giugno 2008, n. 101, ‘Conversione in legge, con modificazioni, del decreto-legge 8 aprile 2008, n. 59, recante disposizioni urgen-
ti per l'attuazione di obblighi comunitari e l'esecuzione di sentenze della Corte di giustizia delle Comunità europee’, (GU n. 132 del 7-6-
2008), availalbe at: http://www.camera.it/parlam/leggi/08101l.htm (accessed October 2016). 
370 Italian Legislative Decree n. 73/2005, art. 6, available at: 
 http://www.minambiente.it/sites/default/files/archivio/allegati/biodiversita/dlgs_21_03_05_n73.pdf (accessed October 2016). 
http://www.minambiente.it/sites/default/files/archivio/allegati/biodiversita/dlgs_21_03_05_n73.pdf (accessed October 2016). 

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 

Some of the requirements applicable to zoos in Italy are more stringent than those required by the 
Directive371. Additional minimum standards concerning animal care, welfare, health and hygiene, 
include: 
 
 

‘The health conditions of animals should be checked daily by zoo staff’; 
‘Shows,  concerts,  art  exhibitions  and  amusements  can  only  be  sited  in  special  areas,  away 
from animal enclosures (…) so as not to disturb the animals’; 
‘Animals should be housed in an enclosure (or tanks if aquatic animals) that provide appro-
priate  space  and  environment,  allowing  the  animals  to  exercise,  according  to  the  require-
ments of the species’; 
‘Animals  may not be induced to perform unnatural  behaviours for the interest  of the audi-
ence’; 
‘The temperature, light and ventilation of the enclosures shall be suitable for the comfort and 
welfare of animals at all times.’ 
‘The outdoor enclosures must be prepared to protect animals from excessive rain or sun’; 
‘The animal enclosures or tanks must  be enriched depending on the needs of the host spe-
cies, with bedding materials, branches, rope, dens, nest boxes, baths and in the case of aquat-
ic species, materials such as plants, small stones or other suitable furnishings’;  
‘Food and drink must meet, both in terms of nutritional value and quantity, the needs of each 
single species and every individual of that species’372 

 

 

 

 
 

 

 

Specific minimum standards are defined for the keeping of Dolphins (Tursiops truncatus) in zoos. 
The standards deal with the size of the pools, medical treatments, food, the prohibition of contact 
with the visitors, prohibition of training to unnatural behaviour. 
  The majority of zoos appear to participate in educational activities373. 

Main challenges: 

  Before the entering into force of the Directive (and the related national legislation), there were no 
rules specifically addressed to zoos and no licensing and inspection system was set up. Moreover, 
the EU Directive was transposed in the national legislation with some delays, and subsequent re-
views have further delayed the actual establishment of an operational system374.  

  Other  issues  raised  by  stakeholders  are  related  to  the  effective  enforcement  of  the  legislation. 
Stakeholders have argued that it should be ensured, through effective enforcement, that all zoos 
(as defined by the Directive) abide by the requirements of national zoo law, the minimum stand-
ards in the Annexes to LD73/2005. Furthermore, existing available penalties (Articles 4(2)b and 8 
of LD73/2005) should be applied to zoos that fail to meet their legal obligations375. 

  The capacity of inspectors appear another element to be improved, in order to ensure that all na-
tional and regional enforcement personnel and veterinarians involved in the inspection and regu-
lation  of  zoos  are  equipped  with  relevant,  regular  training  and  skills  pertaining  to  the  care  and 
welfare of wild animals in captivity376. 

MAPPING OF NATIONAL CONTEXT  
1.1

  Total number of zoos 

1.2

  Types of zoos in the country 

In Italy there are currently 23 licensed zoos377.  
Further  details  on  the  evolution  of  the  number  of  zoo  were 
not easily available. 
98%  of  zoos  are  estimated  to  be  private  (interview  with  UIZA 

371 Born Free Foundation, 2011, ‘The EU Zoo Inquiry, An evaluation of the implementation and enforcement of the EC Directive 1999/22, 
relating to the keeping of wild animals in zoos – ITALY’, p.2 available at: http://www.bornfree.org.uk/zooreports/Italy-
en/pages/ITALY_SUMMARY_AND_RECOMMENDATIONS_ENGLISH.pdf (accessed October 2016). 
372 Italian Legislative Decree n. 73/2005, annex I, available at:  
http://www.minambiente.it/sites/default/files/archivio/allegati/biodiversita/dlgs_21_03_05_n73.pdf (accessed October 2016). 
373 Born Free Foundation, op. cit. 
374 Based on interviews with national stakeholders.  
375 Born Free Foundation, op. cit. 
376 Born Free Foundation, op. cit. 
377 Information provided by the Competent Authority.  

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1.3

  NGOs active at national level  

1.  LIDA  (Lega  Italiana  dei  Diritti  dell’Animale)    aim: 

and national competent authority).  

2.  OIPA 

protecting the rights of the animals. 
Internazionale 
(Organizazzaione 
Protezione  Animali)    aim:  protecting  the  rights  of 
the environment and animals 

Italia 

1.4

  Brief market overview 

TRANSPOSITION OF THE DIRECTIVE 

1.7  List  of  national  transposing  legis-

lation 

3.  Borne  Free  Italia  -  non-profit  organization    aim:  of-
fering specialized care and the right habitats for an-
imals. 

4.  Associazione  Animalisti  Italiani  -  non-profit  organisa-

tion  aim: defending the rights of animals. 

5.  LAV (Lega Anti Vivisezione) non-profit organisation  

aim: defending the rights of animals. 

Overall population in Italy: 59,801, 906378. 
Information concerning the number of zoos visitors per year in 
Italy seems not available. 

1.The  EU Directive 1999/22/EC has been transposed in Italy 
only in 2005 through the Legislative Decree 21 March 2005 
n. 73 (published on the Official Gazette n. 100, 02/05/2005): 
"Implementation of the Directive 1999/22/ EC relating to the 
keeping of wild animals in zoos" 

English  translation:  Legislative  Decree  21  March  2005  n.  73 
(Official  Gazette  n.  100,  02/05/2005):  ‘Implementation  of 
the  Directive  1999/22/  EC  relating  to  the  keeping  of  wild 
animals in zoos’. 

Act in orginal language: Decreto Legislativo 21 Marzo 2005, 
n.73  (pubblicato nella Gazzetta  Ufficiale n. 100 del 2 mag-
gio 2005)“Attuazione della direttiva 1999/22/CE relativa alla 
custodia degli animali selvatici nei giardini zoologici379”. 

The  legislative  Decree  73/2005  has  been  subsequently 
modified and integrated: 

2.English  translation:  Decree  of  the  Ministry  of  Environment 
18  January  2006  (Official  Gazzette  n.  26,  01/02/2006) 
“Amendment  of  Annex  4  of  the  Legislative  Decree  21 
March  2005  n.  73  implementing  the  Directive  1999/22/  EC 
relating to the keeping of wild animals in zoos”  

in  original 

Act 
language:  Decreto  del  Ministero 
dell’Ambiente 18 gennaio 2006  (pubblicato nella Gazzetta 
Ufficiale n. 26 del 1° febbraio 2006), “Modifica all’allegato 4 
del decreto legislativo 21 marzo 2005, n. 73, recante attua-
zione della direttiva 1999/22/CE relativa alla custodia degli 
animali selvatici nei giardini zoologici”380. 
3.  English  translation:  Legislative Decree  4 April 2006 n. 192 
(Official Gazzette n. 121, 26/05/2006) “Amending provisions 
of  the  Legislative  Decree  21  March  2005  n.  73,  implement-
ing the Directive 1999/22/ EC relating to the keeping of wild 
animals in zoos " 

Act  in  orginal  language:  Decreto  Legislativo  4  aprile  2006, 
n.  192  (pubblicato  nella  Gazzetta  Ufficiale  n.  121  del  26 
maggio 2006) "Disposizioni correttive del decreto legislativo 

378 http://www.worldometers.info/world-population/italy-population/ (accessed October 2016). 
379 Decreto Legislativo 21 marzo 2005, n. 73, ‘Attuazione della direttiva 1999/22/CE relativa alla custodia degli animali selvatici nei giardini 
zoologici’, (GU n. 100 del 2-5-2005), available at: 
 http://www.minambiente.it/sites/default/files/archivio/allegati/biodiversita/dlgs_21_03_05_n73.pdf (accessed October 2016). 
380 Decreto 18 gennaio 2006 del Ministero dell'ambiente e della tutela del territorio, Modifica all'allegato 4 del decreto legislativo 21 marzo 
2005, n. 73, recante attuazione della direttiva 1999/22/CE relativa alla custodia degli animali selvatici nei giardini zoologici (GU n. 26 del 1-
2-2006), avaible at:  
http://www.ambientediritto.it/Legislazione/Fauna%20e%20Flora/2006/dm_18gen2006.htm (accessed October 2016). 

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21  marzo  2005,  n.  73,  recante  attuazione  della  direttiva 
1999/22/CE relativa alla custodia degli animali selvatici nei 
giardini zoologici"381.  
4.  English  translation:  Law  n.  101  June  2008  (Official 
Gazzette  n.132,  07/06/2008),  “Converting  into  law  with 
amendments the law decree 8 April 2008 n. 59, concerning 
urgent  measures  for  the  implementation  of  EU  obligations 
and execution of judgments of the European Court of Jus-
tice ". 

Act  in  orginal  language:  Legge  n.  101  del  6  giugno  2008 
(pubblicata  nella  Gazzetta  Ufficiale  n.  132  del  7  giugno 
2008), “Conversione in legge, con modificazioni, del decre-
to-legge 8 aprile 2008, n. 59, recante disposizioni urgenti per 
l'attuazione di obblighi comunitari e l'esecuzione di senten-
ze della Corte di giustizia delle Comunità europee"382. 

1.8  Eu infringement cases  

Case C-302/03 (Commission v. Italy), 07/08/2004 

1.9  National case-law 

On 10 June 2004, the Court found that the Italian Republic 
failed  to  adopt  the  laws,  regulations  and  administrative 
provisions  necessary  to  implement  Directive  1999/22,  and 
was ordered to pay the costs of the trials383. 
Infringement Procedure 2179/2007 

The European Commission initiated in 2007 an infringement 
procedure  against  the  Italy  as  the  latter,  having  modified 
the  Legislative  Decree  n.  73/2005  through  the  Ministerial 
Decree  of  18  January  2006  and  the  Legislative  Decree 
192/2006 had breached the Directive 1999/22/CE.  

In order to solve the situation, the Italian Republic changed 
again its legislation by issuing in 2008 the Law n. 101 which 
re-establishes  the  original definition  of zoo as  it  was  written 
in the first version of art. 2, legislative decree n. 73/ 2005. 

2  case  law  concerning  the  transposition  of  the  have  been 
found: 

1.  Case  220/2008  –  Italian  Government  (representing 

the Italian State) vs Valle d’Aosta Region384 
Dispute: In Italy the Directive 1999/22 has been transposed 
and  implemented  by  the  legislative  decree  21  March  n. 
73/2005. 

The Valle d’Aosta Region - which is an autonomous region 
with  special  statute  and  powers  -  was  also  implementing 
the  Directive 1999/22  with  a  regional  act:  The  regional  act 
n. 34/2006. 

The  issue  at  stake  was  to  verify  whether  the  Valle  d’Aosta, 
being  a  special  region,  had  a  competence  to  also  imple-
ment a European piece of legislation. 

According  to  the  Italian  government,  the  Valle  d’Aosta 
Region,  despite  the  special  powers  recognised  by  the  Ital-
ian  constitution,  had  no  competences  to  implement  a  Eu-
ropean directive whose general aim is the protection of the 

381 Decreto Legislativo 4 aprile 2006, n. 192, ‘Disposizioni correttive del decreto legislativo 21 marzo 2005, n. 73, recante attuazione della 
direttiva 1999/22/CE relativa alla custodia degli animali selvatici nei giardini zoologici’, (GU n. 121 del 26 -5 -2006), available at: 
http://www.camera.it/parlam/leggi/deleghe/06192dl.htm (accessed October 2016). 
382 Legge 6 giugno 2008, n. 101, ‘Conversione in legge, con modificazioni, del decreto-legge 8 aprile 2008, n. 59, recante disposizioni urgen-
ti per l'attuazione di obblighi comunitari e l'esecuzione di sentenze della Corte di giustizia delle Comunità europee’, (GU n. 132 del 7-6-
2008), availalbe at: http://www.camera.it/parlam/leggi/08101l.htm (accessed October 2016). 
383 ECLI:EU:C:2004:368,  
http://curia.europa.eu/juris/document/document.jsf?text=&docid=49283&pageIndex=0&doclang=EN&mode=lst&dir=&occ=first&part=1&c
id=1394853 (accessed October 2016).  
384 Corte Costituzionale Italiana, Sentenza n. 220/2008, Pubblicazione in G. U. 25/06/2008  n. 27, available at: 
http://www.cortecostituzionale.it/actionSchedaPronuncia.do?anno=2008&numero=220 (accessed october 2016). 

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environment. The latter being in fact a state competence, 
and not a regional one. 

In  the  end,  the  constitutional  judge  did  not  decide  on  the 
matter, since the Italian government failed to specify which 
division  of  powers  between  state  and 
regions  were 
breached by the regional act of Valle d’Aosta. 

2.  Case  25  November  2008,  n.  387  -  Italian  govern-

ment vs Provincia di Bolzano385 

Dispute: 

In Italy the  Directive  1999/22  has  been  transposed  and im-
plemented  by  the  Italian  legislative  decree  21  march  n. 
73/2005. The province of Bolzano - which is an autonomous 
province with special statute and powers - was also imple-
menting  the  Directive  1999/22  with  a  provincial  act:  the 
provincial act n. 10/2007. 

According to the Italian government, some articles of the 
act issued by the province of Bolzano were not in line were 
the provisions of the Italian legislative decree n.73/2005, 
and consequently with the Directive.  

The issue at stake was to verify whether the province of 
Bolzano, being a special region, had a competence to 
legislate in matters such as environment and zoos. 

According to the constitutional judge, the State is the only 
territorial entity which has competence to legislate in mat-
ter of environment and zoos, therefore the articles of the 
provincial at n. 20/2007 not in line with the Italian legislative 
decree 73/2005 were declared invalid. 

Country fiche – Lithuania 

Key features of the national system: 

  The  Zoos  Directive  was  mainly  transposed  by  the    2002  Law  of  the  Republic  of  Lithuania  on 
Wild Fauna Rules on licences to establish the zoos and on management and control of zoos  
  Lithuania has only one major Zoo –Lithuanian Zoo (formerly: Kaunas Zoo), which is an EAZA 
member and as such is obliged to comply with EAZA standards. The total number of zoos was 
reportedly 6 (Eurogroup for Wildlife & Laboratory Animals 2006). From the MS CA survey, in 
2010 2 licensed zoos existed, and in 2015 5 licensed zoos (MS CA survey). 

  The responsible competent authority is the Ministry of Environment of the Republic of Lithuania. 
  The zoo definition  provided  in the Law on Wild Fauna is: ‘a place with permanent and special 
facilities, where wild animals forming a zoological collection are regularly kept for exhibition to 
the public for 7 or more days a year with the exception of circuses, pet shops and establishments.  
  The national  law does include exemptions according  to Article 2  of the Directive for establish-
ments with less than 10 species of wild animals and not more than 50 animals and when the zoo 
does not raise a threat to wildlife and biodiversity.’ (our study) 

  Licensed are granted by the Nature Protection Agency. The authorization has no time limit (expi-
ration  time).  cost  of  a  license  for  an  applicant  is  145  euro.  After  a  license  is  granted,  re-
inspections are scheduled to take place once in two years or when a complaint is received. Non-
compliances may lead to penalties from 28 to 579 euro (our study). 

  Zoo inspections are performed by staff of the Nature Protection Agency and the Regional Envi-

ronmental Protection Department.  

  An advisory body  (Zoos inspection commission ) supports the licensing and inspections.  

385 Corte Costituzionale Italiana, Sentenza n. 387/2008, Pubblicazione in G. U. 03/12/2008  n. 50, available at: 
http://www.cortecostituzionale.it/actionSchedaPronuncia.do?anno=2008&numero=387 (accessed October 2016). 

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  Guidelines in the form of minimum standards for animal accommodation/enclosure that are spe-
cies specific are set in the Annex 4 in the Rules on Use of Wild Animals, approved by Order No 
D1-533/B1-310;  Order  No.  346,  27/06/02  (Keeping  Wild  Animals  in  Zoos)  of  the  Minister  of 
Environment  and  the  Director  of  State  Food  and  Veterinary  Service  ,  as  last  amended  on  24 
.4.2014 (our study)  

Main achievements: 

  The  following  achievements  were  noted  by  the  MS  CA:  the  requirement  for  providing  infor-
mation about animals was strengthened for educational purpose; legal acts on minimal standards 
for keeping wild animals in captivity were improved; and public awareness was raised 

Main challenges: 

  The definition of the “zoo” the Directive is not very clear because of the term “significant num-

ber” which leaves much discretion. 

  The Born Free Foundation investigated  five zoos in Lithuania in 2011. Despite a largely accurate 
transposition  of  the  Directive  into  the  Wildlife  Protection  Act,  overall  findings  revealed  incon-
sistency in its application, failure to identify facilities that require a zoo licence, ineffective en-
forcement of the legislation and substandard conditions in all zoos included in the investigation.  
The  findings  of  this  investigation  revealed  significant  inconsistencies  in  the  application  of  the 
Lithuanian  zoo  law,  particularly  in  relation  to  the  definition  and  identification  of  a  ‘zoo’  (Born 
Free Foundation 2011) 

MAPPING OF NATIONAL CONTEXT  
1.1

  Total number of zoos 

1.2

  Types of zoos in the country 

1.3

  NGOs active at national level  

1.4
1.5

  Associations of zoos professionals 
  Brief market overview 

TRANSPOSITION OF THE DIRECTIVE 
1.10  List of national transposing legisla-

tion 

2010:2 licensed zoos (MS CA survey) 
2015:5 licensed zoos (MS CA survey) 
 There  are  6  zoos  reported  in  Lithuania  –  half-way  during  the 
implementation period of EU Directive 1999/22/EC there were 
4  zoos  in  the  country  (Eurogroup  for  Wildlife  &  Laboratory 
Animals 2006).  
The  zoos  in  Lithuania  are  a  mix  of  publicly  and  privately 
owned zoos (Born Free Foundation 2011) 
There  are  no  NGOs  active  at  national  level  with  regards  to 
animals in zoos. 
No associations of zoo professionals could be identified.  
The  total  population  of  Lithuania  was  2,8  million  inhabitants 
(Country Meters 2016) 
With  regards  to  the  number  of  zoo  visitors  each  year,  no  in-
formation  could  be  found  concerning  the  total  number  of 
visitors.  As  an  indication,  Kaunas  Zoo  had  13,5  million  visitors 
since its start in 1938 ( (Way 2 Lithuania 2016). 

The Zoos Directive was transposed by following legislations:  

Law  of  the  Republic  of  Lithuania  on  Wild  Fauna  Rules  on  li-
cences  to  establish  the  zoos and  on  management  and  con-
trol of zoos, approved by Order No 298 of the Minister of Envi-
ronment (DĖL LIETUVOS RESPUBLIKOS APLINKOS MINISTRO 2002 
M. BIRŽELIO 4 D. ĮSAKYMO NR. 298 „DĖL LEIDIMŲ ZOOLOGIJOS 
SODAMS  ĮKURTI  IŠDAVIMO  IR  ZOOLOGIJOS  SODŲ  TVARKYMO 
IR  KONTROLĖS  TVARKOS  PATVIRTINIMO“  PAKEITIMO),  as  last 
amended  on  18.2.2014.  Adoption:  4  June  2002.  Entry  into 
force: 4 June 2002. (Wild Fauna Rules) 

in 
Order  No.  346,  27/06/02 
Zoos)(SAKYMASDĖL LAUKINIŲ GYVŪNŲ LAIKYMO ZOOLOGIJOS 
SODUOSE  STANDARTIZAVIMO  PROGRAMOS  PATVIRTINIMO) 
Adoption: 27 June 2002  Entry into force: 21 Aug 2002 (Keep-

(Keeping  Wild  Animals 

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ing Wild Animals in Zoos) 

Order No.  250/224, 16/05/02  (Taking of Wild Animals from the 
Wild  to  Form  Zoological  Collections  and  on  Registration  of 
Zoological  Collections)  (DĖL  LAUKINIŲ  GYVŪNŲ  NAUDOJIMO 
TAISYKLIŲ  PATVIRTINIMO)  Adoption:  30  June  2011    Entry  into 
force:  30 June 2011   
None identified 
None identified 

1.11  Eu infringement cases  
1.12  National case-law 

Country fiche – Netherlands 

Key features of the national system: 

 

Prior to the adoption of measures transposing the Directive in 2002 through the Animal Act (Di-
erentuinbesluit), there were no licensing or inspection procedures for zoos. Subsequently the law 
has  been  incorporated  in  2011  in  the  Article  4.1-4.13  in  the  new  Animal  Law  (Wet  Dieren) 
(Overheid.nl 2015).   

  The policy-legislation is under responsibility of the Ministry of Economic Affairs. The  Secretary 
of State of Economic Affairs grants the licenses. The Netherlands Enterprise Agency (RVO.nl) is 
appointed to grant the license on behalf of the Secretary of State. Inspection and enforcement is 
under responsibility of the Food and Consumer Product Safety Authority (NVWA). The licensed 
zoos are published on internet386; it contains application nr., license nr, zoo name and date of li-
cense. 

  The Dutch legal definition of zoos is “a permanent establishment where animals of wild species 
are kept for exhibition to the public for at least seven days a year, with exception of circuses and 
petshops.” Under the definition, dolphinaria are included in the national zoo law. Exemptions ac-
cording to Art. 2 of the Zoos Directive are included in the law and related to the number of spe-
cies exhibited: at least 10 species must be exhibited, with exception of species that are protected 
under the Flora and fauna act. There are no minimum standards set by law for animal accommo-
dation  or  enclosures  size.  Dutch  law  beyond  the  Zoos  Directive  regulates  trade  of  animals  by 
zoos, according to Directive 92/65/EEG. 

  According  to  national  law,  zoos  can  choose  from  Article  3  requirements  of  the  Zoos  Directive 

between captive breeding and research/training, in order to obtain a license. 

  A Dutch zoo license has an indefinite duration, and no costs are charged for a zoo to apply for a 
license.  Inspections carried out after a licence is granted about once every three years, and are 
risk based. Main reasons for inspections are: open for the public without a license and exhibiting 
species without approval of this alteration in the license. EAZA/NVD members are inspected by 
EAZA/NVD  inspectors, which is a private initiative. They send the reports to RVO.nl. RVO.nl 
decides if NVWA inspectors need to do further inspections. In 2016, 22 inspectors were full-time 
available for nature conservation/CITES, 10 inspectors carry out zoo inspections part-time. They 
also carry out inspections at animal shelters. About 20 zoos are inspected yearly. When inspecting 
zoos  also animal welfare, animal identification and registration, Regulation 1143/2014 (invasive 
alien species), and CITES is addressed. 
Initially a large team of inspectors (exact figures unknown) was set up to start with licensing of 
33  zoos  present  after  adoption  of  the  Zoos  Directive,  in  2010  there  were  85  zoos,  of  which  47 
were licensed and 37 for which a license was refused, and in 2015 there were 107 zoos, of which 
54 were licensed and 47 for which a license was refused, due to non-compliance with the law. In 
such cases, the authorities instruct the zoos to redeem the observed shortcomings. Today the li-
censing  team  is  small  and  also  involves  external  support:  The  Netherlands  Enterprise  Agency 
(RVO.nl) works with an advisory board (visitatiecommissie dierentuinen). The role of the board 
is to advise in granting licenses. The chairman and the secretary are staff of the Netherlands En-

 

386 http://www.rvo.nl/sites/default/files/2015/05/Overzicht%20verleende%20vergunningen%20dierentuinen.pdf 

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terprise  Agency  (RVO.nl).  Other  members  are    veterinarians  of  the  NVWA  (Netherlands  Food 
and Consumer Products Safety Authority) and external zoo experts. For each visit the chairman 
appoints a team of two, three or four persons. Also members can be asked for advice in case of 
single issues. This addresses the fact that the government staff has insufficient knowledge and ex-
perience across the enormous wide variety of issues related to the many different animals species 
housed  in  zoos  and  aquaria.  The  costs  involved  for  external  zoo  expert  advice  in  licensing  are 
born by the government. The  Dutch Association of Zoos and Aquaria (Nederlandse Vereniging 
van Dierentuinen, NVD) is involved in this provision of professional zoo expertise. 
For  cases  of  non  compliance,  there  are  monetary  penalties:  1.  administrative  fine;  €  1500,-  for 
non  compliances  in  rules  and  restrictions,  way  of  keeping  animals,  way  of  caring  for  animals, 
monthly administration, transfer documents, saving documents for five years, information about 
species and habitat, in case of transfer of animals information about the new situation, policy pro-
tocol; 2. administrating fine € 2500,- for non compliance in administration of the adequate infor-
mation of the animals in the zoo; 3. penalties,  in case of non-compliance is a possibility in case 
of recidive. 

 

  Zoo closure is the ultimate penalty that however occurs seldom:  between 1998-2016 in the Neth-
erlands only one zoo was closed in 2014.  The MS CA cannot easily decide to close a zoo, mainly 
because it is difficult to relocate animals. If a zoo is forced to close, the onus of relocating the an-
imals remains with the zoo. In situations where immediate action is necessary, i.e. neglect of ani-
mals, animals will be placed in licenced shelters. All costs will be hailed on the perpetrator.  
  Art 3 issues from the Zoos Directive are also addressed by other non-legal instruments: the EAZA 
Standards  for  the  Accommodation  and  Care  of  Animals  in  Zoos  and  Aquaria;  EAZA  Research 
Standards; EAZA Conservation Standards; EAZA Conservation Education Standards; and EAZA 
Best Practice Guidelines (formerly called Husbandry Guidelines), support these aspects for EA-
ZA members fully in line with the Zoos Directive (Zoo  and Zoo Federation Consultation).  
  The Zoos Directive only sets as objective to participate in research on biodiversity and/or  captive 
breeding programmes, but does not specify any objective of those programmes. That is done by 
CITES; Convention on Biodiversity (MS CA, Zoos and Zoos federation consultation).  

Main achievements: 

  The Zoos Directive in the Netherlands improved housing conditions for the animals, and stimu-
lated  better  education  and  awareness  activities  for  the  public.  According  to  the  Dutch  CA  the 
main concerns for licensing zoos are safety for the visitors (and therefore there is special attention 
for proper biosecurity and prevention of escape), and good welfare for the animals (and therefore 
there is special attention for adequate housing conditions). This is also the main interest for ani-
mal welfare organisations.  However, it is difficult to assess to what extent the improved housing 
conditions and animal welfare can be attributed to the Zoo Directive, as it is a requirement from 
many zoo federations, and animal welfare is addressed by the national laws and supported by ac-
tive  NGOs.  In  the  Netherlands  education  and  information  of  the  public  is  a  very  important  de-
mand when licensing a zoo, together with exhibiting animals in the natural context, as far as pos-
sible. The aim is to improve awareness of the people for the importance of wild life (MS CA con-
sultation). 

  Costs were studied in 2008 (Panteia Research voor beleid 2008). Estimated costs for administra-
tive  burden  for  zoos  were  estimated  at  €4537  for  applying  for  zoo  license,  and  €1361  annual 
costs;  and  costs  for  CA  were  estimated  at  €2807  per  zoo  per  year.  Costs  for  closure  are  not 
known, closures occur seldom. 
Public attention is mostly directed on animal welfare: there have been several protests, especially 
by  the  NGO  Dolphinmotion387,  against  the  Dolphinaria  in  Harderwijk,  where  animal  welfare 
groups asked to close the site388. Also  noteworthy, the Secretary of State in the Netherlands de-
cided in 2015 that circuses were no longer allowed to keep, display and use wild animals for en-

 

387 http://www.dolphinmotion.nl/home/ 
388 http://buitenland.eenvandaag.nl/tv-items/65491/nieuwstrend_dolfinarium_harderwijk_onder_vuur 

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 

 

tertainment any longer, as the adequate animal welfare could not be ensured389.   
In the Netherlands there is Dutch Association of Zoos and Aquaria (Nederlandse Vereniging van 
Dierentuinen, NVD). They had 13 members in 2016, and all NVD members and NVD itself are 
members of the word wide database Species360; the global zoo animal database.  All NVD mem-
bers  are  members  of  EAZA  and  they  follow  the  EAZA  guidelines.  According  to  the  NVD,  the 
Zoos Directive has been important as it provided the legal framework for strengthening the role of  
zoos in biodiversity conservation. The Directive creates an environment for zoos across the Union 
to  harmonise  their  conservation  focus,  standards  and  routines  (Zoo  Federation  Consultation).   
Examples  of  positive  changes  that  can  be  attributed  to  the  Directive  are  that  the  quality  of  the 
zoos in some countries in the EU has improved, international cooperation is easier and the EAZA 
has  even  more  reason  to  be.  The  recently  published  'EU  Zoos  Directive  Good  Practices  Docu-
ment' they consider a good example in this regard. However, concerning the licensing and inspec-
tion  system,  it  has  taken  a  long  time  for  some  Member  States  to  implement  the  Directive  and 
some have not implemented it at all. For the NVD, they are able to link and relate their member-
ship conditions to the Directive, thereby helping to make the Directive accessible and understood 
by its members. The NVD is also using the guidance provided in the Directive to be pro-active in 
achieving the requirements, for example developing conservation standards, running biodiversity 
campaigns, EEPs, etc. The NVD has also a role in supporting the licensing by the CA in provid-
ing professional zoo expertise.   In that respect, current standards of professional zoo associations  
are often more progressive than national legal standards based on the Zoo Directive. Sector driven 
standards would achieve better implementation than ones set in national legislation. National Au-
thorities should put more pressure on zoos that fail to meet the standards of professional zoo as-
sociations (Zoos and Zoo Federation Consultation) 
In the Netherlands there also is an organisation for Dutch and Belgian zoo workers: Stichting De 
Harpij390. She has no members, but issues every quarter a journal with mostly information related 
to housing and animal welfare conditions for zoo animals. The Stichting Aap391 is a rescue centre, 
that adopts animals from different sources, including from zoos that are close, and aims to pro-
vide long-term solutions for improving the welfare of exotic, non-domesticated animals. 

Main challenges: 

  The Zoos Directive is considered useful to ensure that licensing and inspection of zoos is done by 
the  CA,  and  regularly  new  zoos  are  applying  for  a  license.  However,  participation  in  breeding 
programmes can be difficult, especially for smaller zoos. All zoos can include education activities 
do in some form. Although not all zoos have the ability to be engaged in breeding programmes 
for biodiversity, most can instead engage in education and research programmes.  

  According to consulted stakeholders,  an inconsistency exists between the Zoos Directive and the 
Regulation of Invasive Alien Species (IAS) (1143/2014): the IAS regulation does not appropriate-
ly address the conservation role of zoos and makes a direct -but unfounded and disproportionate- 
connection between animals held in zoos and the problems with Invasive Alien Species. One of 
the major problems is the lack of scientific process and appropriate risk analyses. Species belong-
ing on the list (e.g. American mink) are politically banned from being listed whilst zoos can no 
longer keep species that are listed for which there is no connection between zoos and the IAS is-
sue in place. This hampers conservation, education programmes tailored to the IAS problem and, 
as  species  continue  to  be  listed,  will  negatively  impact  the  biodiversity  of  zoo  collections  (MS 
CA, Zoo and Zoos federation consultation). 

MAPPING OF NATIONAL CONTEXT  
1.1

  Total number of zoos 

2010: total 85, licensed 47 
2015: total 107, licensed 54 

389 http://nos.nl/artikel/2008752-wilde-dieren-in-het-circus-binnenkort-verboden.html 
390 http://www.deharpij.com/ 
391 https://www.aap.nl/nl 

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1.2
1.3

  Types of zoos in the country 
  NGOs active at national level  

1.4

  Associations  of  zoos  profes-
sionals 

1.5

  Brief market overview 

TRANSPOSITION OF THE DIRECTIVE 
1.13  List  of  national  transposing 

legislation 

1.14  Eu infringement cases  

1.15  National case-law 

Country fiche – Poland 

Key features of the national system: 

Nearly all private owned 
The  following  NGOs  are  active  at  national  level  in  the 
Netherlands: 
  Stichting Aap (“Monkey Foundation”)-Rescue centre 
  Nederlandse  Dierentuin  Vereniging  (Dutch  Associa-

tion of Zoos and Aquaria)  

  Stichting  de  Harpij  (The  Harpy  Foundation)  (organi-

zation for Dutch and Belgian zoo employees) 
Overall population in the country: 17 million (CBS) 
1999: 10,4 million visitors 
2013: 10 million  
2015: 9,8 million (Rides 2014) 

Zoos Law (Dierentuinenbesluit) 19 April 2002; amended 
in 2014 in new regulation: Animal Act (Wet Dieren) 
(Overheid.nl 2015). The Animal Act is a law comprising 
all previous animal laws, including the Zoos law.  

Animal Act (Wet Dieren) Animal holders, and Govern-
mental decree (Besluit houders van Dieren), July 2014; 
The zoo has to include in the protocol the aim of breed-
ing and of education. Also the Flora- en fauna Act (Flo-
ra- en fauna Wet) is applicable to Zoos. 
In 2002 the European Commission issued a Letter of For-
mal  Notice  to  the  Netherlands  regarding  its  failure  to 
notify  the  measures  transposing  the  Directive.  Later  in 
2002 the Netherlands notified the transposing measures. 
The case was closed.  
NA 

 

 

In Poland, the Zoos Directive was adopted in 16 April 2004 with the Nature Protection Act. The 
current  definition  for  zoos  is:  ‘Zoo  is  an  organised,  managed  area  with  technical  infrastructure 
and  functionally  related  buildings  where  living  animals  of  wild  species  are  kept  and  displayed 
publicly for at least 7 days per year, excluding circuses, pet shops and establishments where no 
more than 15 such species and no more than 50 individuals of reptiles, birds or mammals are dis-
played.“(our survey). Poland has introduced exemptions according to Article 2 by amending the 
Nature Protection Act in 2011 defining "significant number of animals" as follows: “no more than 
15 species and no more than 50 individuals of reptiles, birds or mammals."  
Poland  has  set  minimum  standards  by  law,  for  animal  accommodation/enclosure  (RZ12/2004): 
Animals kept in zoos should be provided with conditions appropriate for their biological needs. 
The  conditions  for  breeding  and  keeping  animals  in  zoos  are  specified  in  the  ordinance  of  the 
Minister  of  the  Environment  of  20  December  2004  on  the  conditions  for  breeding  and  keeping 
particular groups of animal species in zoos (Dz.U. of 2005 No. 5, item 32). The ordinance speci-
fies  the  necessary  rooms  and  technical  equipment  for  the places  where  animals  stay,  as well  as 
minimum spatial conditions for breeding and keeping animals of particular species or groups of 
species, as well as the necessary conditions for reproducing animals (our survey). 

  The  number  of  licensed  zoos  was  18  in  2010  and 24  in  2015,  which  are  a  mix  of  publicly  and 
privately owned zoos (our survey). Apart from the licensed zoos there are at least about 10 other 
animal enclosures (Born Free Foundation 2011). Poland has 11 Zoos that are member of EAZA 
and also the Board of Directors of Polish Zoos and Aquariums is an EAZA Associate Member, 
which helps to regulate and apply the legislation (eaza.net). The yearly number of visitors mounts 

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 

to at least 4 million (Angelika Habel 2015) 
In Poland, the authority responsible for the implementation of the Zoos Directive is the Minister 
of  the  Environment.  However  the  authority  responsible  for  licensing  of  zoological  gardens  and 
supervision of regional directorates for environmental protection (competent to carry out a zoo in-
spection) is the General Director for the Environmental Protection. Zoo inspections are adminis-
tered  by  the  Regional  Directorate  for  Environmental  Protection  (our  survey,  Born  Free,  2011). 
Zoos are licensed through the General Directorate for Environmental Protection, in consultation 
with the Regional Directorate for Environmental Protection, the relevant municipality and repre-
sentatives of an association of zoos (Zoos Council) (Article 67(2) NPA). The permit is issued af-
ter consultation with the Regional Director for Environmental Protection competent for the loca-
tion of the zoo and after an opinion from the association of representatives of zoos is obtained. In 
Poland, the zoo representatives are associated under the Council of Directors of Polish Zoos and 
Aquaria. Licences have an indefinitive duration (our survey). The costs of obtaining a license is 
76 PLN (approx. 17 euro). There might be additional costs for the applicant originating from ob-
taining documentation required to be presented along with the application for a licence, but these 
can vary greatly and depend on a number of factors, thus no total cost or approximation can be 
provided. After a license is granted, inspections should not take place less frequently than every 3 
years (our survey). 

  The non-respect of these requirements can lead to detention or a fine (20-5000 PLN; approx. 5-

1000 euro) (our survey). 

  Recent  studies and NGO report occurrence of animal welfare problems in  Polish zoos. This re-
mains  an  area  of  increased  public  concern  (Teresa  Gardocka,  Agnieszka  Gruszczyńska,  Robert 
Maślak, Agnieszka Sergiel 2014) (BASTA! 2016) 

Main achievements: 

 

 

In Poland the licensing and inspection has a solid legislative basis, and provisions are included in 
the legislation on minimal standards for housing and accommodation. The Council of Directors of 
Polish Zoos and Aquaria, of which most members are also EAZA Member, is involved in licens-
ing which helps the CA. Inspection and licensing are implemented  
Some Polish zoos contribute to conservation of biodiversity and research programmes, and this is 
particularly the case for zoos of the EAZA-associated zoos (our survey). 

Main challenges: 

 

In 2011, Born Free Foundation and EndCap presented in the European Parliament the results of a 
report based on observations in eight zoos in Poland, none of which did meet the conditions of the 
Zoo Directive. According to this report, 59% of zoos do not meet even the basic requirements of 
the Polish zoo law (which is much less restrictive than the EU rules) relating to animal welfare 
(Born Free Foundation 2011). These findings not only raise serious concerns about the enforce-
ment  of  NPA  but,  further  but  also  question  the  level  of  activities  by  national  and  regional  en-
forcement personnel to effectively identify and license zoos, apply the law and penalize substand-
ard zoos (Bornfree, 2011). Also recently animal welfare problems in zoos are identified (BASTA! 
2016), this seems the main issue at the moment. 

  The role of Polish zoos in conservation of biodiversity is an area to developed, as there was no 

clear evidence found of a strong contribution of Polish zoos in that field. 

MAPPING OF NATIONAL CONTEXT  
1.1

  Total number of zoos 

1.2

  Types of zoos in the country 

2010: 18 licensed zoos  
2015: 24 licensed zoos (our survey)  
In  2016,  there  are  25  zoos  listed  on  the  website  of  the 
(Generalna  Dyrekcja  Ochrony 
(General 
Directorate  for  Environmental  Protection  2016).There  are 
about  10  wild  parks  that  operate  without  a  zoo  license 
(BASTA! 2016) 
According    to  Born  Free,  the  majority  of  zoos  in  Poland  are 

Środowiska) 

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1.3

  NGOs active at national level  

1.4

  Associations of zoos professionals 

1.5

  Brief market overview 

TRANSPOSITION OF THE DIRECTIVE 
1.16  List  of  national  transposing  legisla-

tion 

privately owned zoos,  but  several are owned by  the  munici-
pality  (Leszno,  Warsaw  and  Braniewo  zoos)  (Born  Free 
Foundation 2011).  
There  is  one  NGO  active  on  zoos  at  national  level,  called: 
‘Basta!’.  They  runned  a  campaign  entitled  “I  don’t  go  to  a 
zoo (nie chodze do zoo) (BASTA! 2016).  
One  relevant  association  has  been  identified:  ‘Board  of  Di-
rectors of Polish Zoos and Aquariums’. The Board is an associ-
ation  and  forms  a  network 
  for  Polish  zoos  to  share 
knowledge, and discuss any zoos issues (Board of Directors of 
Polish Zoos and Aquariums 2016)  
In  2015,  the  overall  population  in  Poland  was  38,6  million  in-
habitants (Country Meters 2016). 
The number of visitors in Polish zoos mount to nearly 4 million / 
year (Angelika Habel 2015) 

Nature  Protection  Act, 
‘NPA’  (16/04/2004  amended  on 
16/06/2011)  (ustawa  z  dnia  16  kwietnia  2004  r.  o  ochronie 
przyrody),  Adoption:  16  April  2004,  Entry  into  force:  16  April 
2004,  Journal  of  Laws  No.92,  item  880,  publication  date 
30/04/2004 (Nature Protection Act 2004).  

In addition there are two relevant Regulations:  
Regulation of the Minister of the Environment of 16 April 2003 
on the detailed conditions for the breeding and husbandry of 
respective  groups  of 
zoological  gardens 
species 
(Rozporządzenie Ministra Środowiska z dnia 16 kwietnia 2003 r. 
w  sprawie  szczegółowych  warunków  dla  chowu  i  hodowli 
poszczególnych  grup  zwierząt  w  ogrodach  zoologicznych) 
(RZ04/2003). 

in 

Regulation of the Minister of the Environment of 20 December 
2004  on  the  conditions  for  the  husbandry  and  keeping  of 
respective  groups  of 
zoological  gardens 
species 
(Rozporządzenie Ministra Środowiska z dnia 20 grudnia 2004 r. 
w sprawie warunków hodowli i utrzymywania poszczególnych 
zoologicznym) 
grup  gatunków 
(RZ12/2004) (ISAP 2004). 
None identified 
None identified 

zwierząt  w  ogrodzie 

in 

1.17  Eu infringement cases  
1.18  National case-law 

Country fiche – Portugal 

Key elements of the national system: 

  The main transposing legislation is the Decree-Law No 59/2003 of 1 April, rectified by Decree-
Law  104/2012,  mostly  in  terms  of  procedures  and  formal  issues.  Due  to  difficulties  with  the 
transposition the initial transposition was delayed until 28 June2003. The competent authority re-
sponsible  for  the  implementation  of  D59/2003  is  the  national  veterinary  authority  –  the  Direc-
torate General of Veterinary Medicine (Direção Geral de Alimentação e Veterinária; DGV). Zoo 
licenses are granted by the Direção Geral de Alimentação e Veterinária  - D.G.A.V and Instituto 
da Conservação da Natureza e Florestas - I.C.N.F. They also inspect the zoos jointly using stand-
ard inspection lists. Shortly after the adoption of the Directive the licensing process was more dif-
ficult than today because it was new. According to national law, zoos can be involved but are not 
obliged  to  have  captive  breeding,  repopulation,  reintroduction  of  species  into  the  wild.  Instead, 
they are obliged to participate and made public awareness and related activities. Lack of specific 
expertise in zoo animal hampers implementation of the Zoos Directive, and despite trainings pro-
vided,  more  training  of  official  staff  would  be  welcomed.  Small  zoo  establishments  experience 
difficulties to hire staff able to fulfil all the necessary duties and sometimes experience financial 

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constraints (ex: when municipal zoos) (our study). 

  The law contains exemptions according to Article 2 of the Directive.  The zoos definition in the 
Zoos  Directive  is  considered  not  problematic  by  the  CA,  but  in  the  national  law  the  definition 
used is ''All permanent establishments where animals are kept for exhibition to the public for 7 or 
more days a year"'; but the PT national legislation has introduced exemptions as follows: Recov-
ery centres, reserves and hunting wildlife ponds, with regard to pedagogical and scientific actions 
as referred to in Annex to chapter IV of Decree Law (DL) n.º 104/2003 , as long as they are not 
open to the public; facilities where arising exclusively hunting activities, circuses, travelling ex-
hibitions and pet shops. These establishments fall under other national legislation. In addition, has 
the following provisions that go beyond the Zoos Directive: Decree Law nº 59/2003 and DL nº 
211/2009 that require necessity of CITES and marking of live specimens; Ordinance nº 07/2010: 
that requires obligatory registration scheme in CITES Management Authority and updating ani-
mal data collection, scientific and education projects annually; Ordinance nº 1226/2009: that re-
quires obligatory registration scheme in CITES Management Authority of listed “dangerous” an-
imals and updating data annually; and DL nº 565/99 on keeping exotic species, notably Invasive 
Alien Species (our study).  

  The  DGAV  (Direção  Geral  de  Alimentação  e  Veterinária)  has  2  staff  responsible  for  Zoos,  but 
they also have other tasks and can allocated on average approximately 1/4 of their time to Zoos. 
The ICNF (Instituto da Conservação da Natureza e Florestas) has also 2-3 staff members working 
on  the  Zoos Directive  (part-time).  They  can  ask  external  experts  for  assistance,  but  this  is on  a 
voluntary basis without payment. Extra costs for MS CA is related to inspectors costs. There are 
no specific data but approximate staff inputs can be estimated at 2 DGAV staff for 1/4 of their 
time and 2-3 ICNF staff at same inputs, or  5/4 FTE/year (our study). 
In 2000, 26 zoos were reported, out of which six zoos were unlicensed and six were improperly 
licensed  (Bron  Free  Foundation  2011).  In  2010  there  were  20  zoos  licensed  and  for  6  zoos  li-
censed were refused; and the same situation was reported for 2015: 25 licensed zoos and 6 licens-
es refused (our study). There is no official data on the number of zoo visitors in Portugal. As an 
indication,  at  Lisbon  Zoo  there  are  more  than  500.000  visitors  annually    (Anthony  D  Sheridan 
2010) (largest Zoo in Portugal) (Anthony D. Sheridan May 2010). 

 

Main achievements: 

  The  PT  CA  considers  that  the  Zoos  Directive  is  necessary  for  a  more  harmonised  approach  to 
zoos in EU, and to support that zoos will contribute to the conservation of biodiversity. Without 
the Zoos Directive there would be a less harmonised approach. 

  The key positive changes attributed to the Zoos Directive are the necessity for zoos to engage for 
a better management of the zoo´s collection , for better enclosures and animal husbandry, and to 
have educational and scientific projects approved by the authorities according  established crite-
ria. 

  Benefits are that the Zoos Directive provides an instrument to limit unregulated zoos with unsuf-
ficient resources to adequately provide good housing conditions for the animals. (Zoo federation 
Interview) 

  The impact of the Zoos Directive on objectives set out in the Directive and the related transposed 
national legislations is mainly to control widespread growth of zoos, rather than improve biodi-
versity or conservation. But the input and impact of zoos in relation to biodiversity is higher with 
a collective EU focus standard and the  Zoos directive has enabled more efficiency of cooperative 
efforts, and helps to focus development of zoos towards a common goal of biodiversity conserva-
tion, so partly contribution. (Zoo federation Interview) 
Several  of  the  zoos  that  replied  to  the  questionnaire  have  submitted  conservation  programmes, 
education programmes, and enrichment programmes (our survey). 
In  the  literature,  there  are  examples  of  Portuguese  zoos  being  engaged  in  conservation  and  re-
search  programmes,  as  evidence  for  contributions  to  biodiversity  (Claudia  Faria  2010)  (Carla 
Sousa-Santos 2013). 

 

 

Main challenges: 

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  Lack of specific expertise in zoo animal hampers implementation of the Zoos Directive, and de-
spite trainings provided, more training of official staff would be welcomed. Small zoo establish-
ments experience difficulties to hire staff able to fulfil all the necessary duties and sometimes ex-
perience financial constraints (MSCA interview). 
For  zoos  belonging  to  International  Associations,  there  were  no  costs  to  comply  with  the  Zoos 
Directive to obtain a license when the Zoos  Directive was adopted (2003), but for smaller zoos 
this was more difficult, however there are no economic data to support this (Zoos federation In-
terview). 

 

  According  to  stakeholders,  the  IAS  directive  conflicts  with  the  Zoos  Directive:  IAS  forbids  to 
house  certain  IA  species,  but  some  IAS  species  are  candidates  for  conservation  or  biodiversity 
programmes whereas the Zoos Directive requires to contribute to that. Licenced Zoos are able to 
guarantee security provisions to prevent escape of animal, and so they should be allowed to ac-
commodate IA species (MSCA ; Zoo Federation interview).  

  According to stakeholders the Zoos Directive overlaps with CITES and many EAZA guidelines  

(MSCA ; Zoo Federation interview) 

  Only  in  the  last  few  years  official  inspectors  received  training  from  Zoos  Federation  members. 
MS CA might save resources by recognising screening and accreditation of zoos by EAZA and 
focus on smaller non-EAZA members where problems mostly are bigger (Zoos federation Inter-
view). 

  According to BornFree (2011), the findings from the EU Zoo Inquiry indicate that licensed zoos 
in Portugal are not fully compliant with either the Directive or D59/2003, whilst others are oper-
ating, unlicensed. Individually, there is much variance between the zoos, with some meeting the 
majority of requirements whilst others do not (Bron Free Foundation 2011).  

  BornFree considers that zoos in Portugal do not appear to be making a significant contribution to 
species conservation. The majority of species exhibited being of low conservation priority. Of the 
Threatened species exhibited, 57% were participating in European captive breeding programmes. 
Findings  appear  to  contravene  the  requirements  of  Chapter  III,  Article  19(2)  in  the  Annex  to 
D59/2003 (Bron Free Foundation 2011). 

MAPPING OF NATIONAL CONTEXT  
1.1

  Total number of zoos 

1.2

  Types of zoos in the country 

1.3
1.4

  NGOs active at national level  
  Associations of zoos professionals 

1.5

  Brief market overview 

TRANSPOSITION OF THE DIRECTIVE 
1.19  List of national transposing legisla-

tion 

In  2000,  26  zoos  were  reported,  out  of  which  six  zoos  were 
unlicensed  and  six  were  improperly  licensed  (Bron  Free 
Foundation 2011). 
2010: 20 licensed and 6 licenses refused (our study)  
2015: 25 licensed and 6 licenses refused (our study) 
Mixed  –  public and  private,  in  the  Born  Free  Zoo Inquiry,  four 
of  ten  zoos  studied  were  managed  by  municipalities  and  6 
were privately owned (Bron Free Foundation 2011) 
None identified  
The  Association  of  Zoos  and  Aquariums  (Associacao  Portu-
guesa  De  Zoos  E  Aquaria ;  APZA)  represents  5  major  zoos  in 
Portugal    and  supports  their  representation,  management, 
promotion  and  defence,  in  the  economic,  scientific,  educa-
tional and conservation activities (Associação Portuguesa de 
Zoos e Aquários 2016). 
Total population (2016) 10.32 mil. (Country Meters 2016) 
There is no official data on the number of zoo visitors in Portu-
gal.  As  an  indication,  at  Lisbon  Zoo  there  are  more  than 
500.000  visitors  annually    (Anthony  D  Sheridan  2010)  (largest 
Zoo in Portugal) (Anthony D. Sheridan May 2010) 

  Decree-Law No. 59/2003 (Diaro da republica I serie-A No. 
77),  (D59/2003)  Adopted:  1st  of  in  April  2003.  Entry  into 
force 28/06/2003 

  Decree-Law  104/2012  rectified  (D59/2003).  Adopted:    16 
May  2012.  Entry  into  force:  16  May  2012  (Decree-Law 
104/2012) (DRE 2016) . 

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1.20  Eu infringement cases  

1.21  National case-law 

Country fiche – Spain 

Key elements of the national system: 

Case  2002/0306  -    June  2002:  a  Letter  of  formal  notice  was 
sent  to  Portugal  concerning  the  non-transposition  of  the  Di-
rective  into  national  law.  This  was  followed  by  a  Reasoned 
Opinion  in  October  2002,  which  in  turn  was  followed  by 
Saisine in April 2003. Portugal communicated the  transposing 
decree-law in April 2003. The case was then withdrawn. 
A pilot case that was launched in 2009 (PT-Pilot 278-09-ENVI). 
None identified 

  Directive 1999/22/EC was transposed into Spanish legislation by Law 31/2003. The transposi-
tion deadline was April 2002. However, Spain did not adopt the corresponding legislation un-
til 29 October 2003. Therefore, the lack of adoption of transposition measures by the Spanish 
authorities led to the launch of the first infringement procedure by the European Commission 
against  Spain  related  to  the  Directive  1999/22/EC.  There  was  also  a  complaint  filed  on  the 
same basis which was joined to the infringement procedure of the Commission.392 This proce-
dure was dismissed as Spain adopted Law 31/2003 as transposition measure. 

Main challenges: 

  Despite the entry into force of Law 31/2003, there have been reports on the no-compliance of 
legal obligations and undue treatment or mistreatment of animals in Spanish zoos.393 In fact, 
the European Commission filed a case against Spain before the CJEU394 concerning the non-
fulfilment of the obligations of licensing and inspection set in Article 4, sections 2 and 3, in 
certain  zoos  of several Autonomous Communities.395 Although Spain alleged  that  such zoos 
were  subject  to  alternative  licensing  procedures  under  the  legislation  previous  to  Law 
31/2003, it was not sufficiently proven that such procedures met the requirements of the Di-
rective. Consequently, the CJEU found Spain to be in breach of Article 4 of the Directive and 
condemned it to pay the costs of the proceedings. As a consequence of this procedure, since 
2010 the affected zoos should have adopted the necessary measures to meet the requirements 
of the Directive or be closed. According to one of the interviewed stakeholders, some of the 
infringing zoos were closed. However, it is unsure how many closures were due to the ruling 
of the CJEU.396 

  No relevant case-law has been identified at national level. However, different newspaper arti-
cles  report  on  investigations  carried  out  by  the  Service  for  the  Protection  of  Nature  of  the 
‘Guardia Civil’ (SEPRONA).397 This Service was created in 1988 after Organic Law 2/1986 
on National Security Forces398 entrusted the ‘Guardia Civil’ to ensure the preservation of na-

392 Infringement procedure A- 2002/0299 (see above point 2.2 in Table 2 in this document).  
393 For example, La Vanguardia, ‘The most reported zoos of Spain’ (Los zoos más denunciados de España), available at 
http://www.lavanguardia.com/natural/20160127/301708936926/denuncias-zoologicos-animales.html, 27 January 2016 (last accessed 11 
October 2016); Ecologistas en Acción, ‘Shameful state of zoos in Almuñecar’ (Lamentable estado de los zoológicos de Almuñercar), availa-
ble at http://www.ecologistasenaccion.org/article7751.html, April 2007 (last accessed 11 October 2016), 20minutos, ‘Spain will be reported 
[to the European Commission] for the state of its zoological gardens’ (Denunciarán a España por el mal estado de sus parques zoológicos), 
available at http://www.20minutos.es/noticia/165465/0/estado/parques/zoologicos/, 25 October 2006 (last accessed 11 October 2016). 
394 Judgment of the Court (Fifth Chamber) of 9 December 2010, Case C-340/09 European Commission vs. Kingdom of Spain, 
ECLI:EU:C:2010:758, available in Spanish at 
http://curia.europa.eu/juris/document/document.jsf;jsessionid=9ea7d2dc30d51218a8ce6d5c4beea013905d3fe16b15.e34KaxiLc3qMb40Rch0
SaxyKax50?text=&docid=83863&pageIndex=0&doclang=ES&mode=lst&dir=&occ=first&part=1&cid=1429980.  
395 Aragon, Asturias, Balearic Islands, Canary Islands, Cantabria, Castilla-Leon, Extremadura, Galicia and Valencian Community. 
396 Information collected through interview with national stakeholder (MAGRAMA, 17 October 2016). 
397 See Table 2, point 2.3 at the beginning of this document. 
398 Organic Law 2/1986, of 13 March, on National Security Forces (Ley Orgánica 2/1986, de 13 de marzo, de Fuerzas y Cuerpos de Seguri-
dad), State Gazette BOE-A-1986-6859, available in Spanish at https://boe.es/buscar/act.php?id=BOE-A-1986-6859.  

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ture and the environment.399 As part of this function, the SEPRONA has launched several in-
vestigations regarding, mainly, the illegal trade of protected species or the mistreatment of an-
imals in different zoological centres in Spain. 

  One of the root causes of the implementation problems in Spain is linked to the lack of proper 
definition of zoos. While the Law 2003 reinstates the Directive’s definition, it is too general 
and does not clarify the situation in Spain which suffers from the influence of the old law 75 
on zoological centres which involves zoos, species recovery centres and even farms. This has 
led to the development of a registry of zoological centres including farms. For example, Ad-
venture Park has an exhibition of predators and thus it is considered a zoo.  

  Another problem is related to the split of competences between the State and the Regions in 
Spain.  The  Spanish  Ministry  of  Environment  does  not  execute  a  real  control  of  the  level  of 
compliance of the Directive’s objectives by the regions. Its role is limited to coordination and 
technical assistance. There are no minimum standards for the implementation of the Directive 
(except for those established by the Federation of Zoos Aiza). Further there is no information 
gathered on the number of inspectors and the inspection reports delivered.  

  The Directives is the reason for requiring for the first time  ex situ conservation objectives in 
zoos. This has prompted authorities to take into account the zoos when developing the nation-
al strategies on endangered species conservation. Although there are species recovery centres 
and centres for captive breeding of the species, some specimens are sent to zoos to promote 
awareness raising activities (i.e. Jerez de la Frontera or Madrid)   

  Furthermore, according to the report of the NGO ‘Vidas Enjauladas’,400 presenting the situa-
tion in eight Spanish zoos,401 the enclosures where animals were kept were inappropriate, ei-
ther in size or in their maintenance conditions. The report found that, in general, the zoos had 
done  little  efforts  to  try  to  imitate  the  natural  habitat  of  animals.  This  unsuitable  conditions 
may  have  an  impact  in  the  health  of  animals  and  in  the  propagation  of  diseases.402  For  in-
stance, the investigation concluded that most of the wild animals in captivity suffer psycholog-
ical  disorders  evidenced  by  the  repetitive,  compulsive  or  monotonous  conduct  of  animals 
(such as those observed in the zoos of Barcelona and Seville.403 Another evidence of the poor 
health of animals is the hair or plumage loss and “contact injuries”  (e.g. fractures or wounds 
probably resulting from contact with other animals, the cage or the furnishing). Fights among 
caged  animals  seem  to  be  frequent  due  to  the  inappropriate  conditions  of  the  entourages, 
which should keep animals under control and safe. Investigators also observed specimens suf-
fering weight loss or loss of dental pieces, as well as ectoparasites.404  

  As to the educational work zoos should be carrying out, the investigators judged the quality of 
the  explanatory  notices  of  animals  displayed  in  zoos  on  the  basis  of  four  pieces  of  infor-
mation:  common  name,  scientific  name,  natural  habitat  and  biological  features.  The  report 
showed that most zoos provide insufficient or no information at all. Furthermore, in some cas-
es, even when there are explanatory notices, these are old and have suffered such an erosion 
that they are almost illegible.405   
In addition, no control of public behaviour or actions addressed to public education or aware-
ness regarding some negative attitude of visitors was also reported. In most zoos, visitors feed 
and/or  touch  the  animals,  tap  or  hit  the glassed  windows  of  animal  cages,  smoke  and  throw 
objects to animals. This has an impact in the psychological state of animals, who can suffer 
from stress due to these conducts.406 

 

399 Website of the ‘Guardia Civil’, ‘Institutional Information’, ‘Functions’, ‘Environment’, available in Spanish at 
http://www.guardiacivil.es/es/institucional/Conocenos/especialidades/Medio_ambiente/index.html (last accessed 17 October 2016). 
400 Vidas Enjauladas, 2011, ‘The zoos of Spain investigated by Igualdad Animal’ (Los Zoos de España investigados por Igualdad Animal), 
available in Spanish at http://www.vidasenjauladas.org/resumen_informe_zoos_2011.pdf (last accessed 20 October 2016). 
401 Zoo of Madrid (Madrid), zoo of Barcelona (Catalonia), Biopark (Valencian Community), Río Safari Park (Valencian Community), zoo of 
Castellar (Andalusia), zoo of Cordoba (Andalusia), zoo of Seville (Andalusia) and Botanic zoo of Jerez (Andalusia). 
402 Vidas Enjauladas, 2011, ‘The zoos of Spain investigated by Igualdad Animal’ (Los Zoos de España investigados por Igualdad Animal), 
pp. 9-10, available in Spanish at http://www.vidasenjauladas.org/resumen_informe_zoos_2011.pdf (last accessed 20 October 2016). 
403 Ibidem, pp. 21-22. 
404 Ibidem, pp. 34-35. 
405 Ibidem, p. 37. 
406 Ibidem, p. 40. 

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 

In an investigation carried out in 2012 covering 60 out of 83 Spanish zoos407 it was shown that 
only around 17% of the zoos meet the requirements of Article 3 of the Zoos Directive. These 
compliant zoos tend to be privately owned, with large zoological collections, located within or 
nearby metropolitan areas, and members of a zoo association (i.e. AIZA in Spain).408 Accord-
ing to the referred study, this could be due to the higher budget of those zoos and their mem-
bership to an association.409 The report also concluded that the main problem in the reviewed 
zoos was related to appropriate record keeping, which is lacking in around 70% of the zoos. 
This could be due to the fact that many of the sampled smaller centres need to update or set up 
an appropriate management system of their zoological collections. Software such as the Inter-
national Species Information System (ISIS) or the Zoological Information Management Sys-
tem  (ZIMS)  could  help  zoos  to  attain  such  purpose.  The  investigators  also  recommend  that 
professional zoo associations become stricter in their inspections regarding record keeping.410  
  The 2012 study also highlights the main problems for zoos achieving their conservation objec-
tives. Conservation is not the mere sustenance of wild animals in captivity.411 It was recom-
mended that local authorities in charge of inspection and authorization processes advise small-
er and more inexperienced zoos in the ways they can contribute to conservation. Zoo associa-
tions also play a relevant role to this regard.412 

  Another study, also from 2012 and by the same investigators,413 examined 63 out of 83 Span-
ish zoos to evaluate the benefits of naturalistic enclosures. A total 1,381 enclosures were eval-
uated, being classified between ‘naturalistic’ and ‘non-naturalistic’ depending on whether the 
enclosure  simulates  identiﬁable  parts  of  the  landscape  of  the  species’  habitat,  frequently 
through the use of natural elements in its design, including the simulation of physical and bo-
tanical surroundings similar to those found in the landscape of the species’ natural distribution 
(‘naturalistic’) or not (‘non-naturalistic’).414 The study concludes that such naturalistic enclo-
sures provide suitable housing conditions for the animals providing them with the necessary 
environmental resources to satisfy some of their main biological requirements. However, natu-
ralistic designs are not strictly indispensable to provide appropriate housing conditions for an-
imals.415 The report reveals that on the basis of the measurement aspects defined to assess the 
enclosures,416 less of half of the examined enclosures provide a suitable environment for their 
inhabitants.417 The study presents for the first time empirical data that confirms the adequate-
ness  of  naturalistic  designs  in  providing  environmental  resources  that  enable  the  animals  to 
fulﬁl  some  of  their  main  biological  needs,  instead  of  examining  the  welfare  of  the  animals 
held within.418 

  The same authors published a paper in 2010419 examining the appropriateness of the security 
measures  of  63  Spanish  zoos  to  assess  the  impact  that  zoos  have  on  the  release  of  non-
indigenous  species.  To  evaluate  the  security  of  enclosures,  two  factors  were  analysed:  the 
physical  barriers  of  the  enclosures  and  the  impossibility  for  the  public  to  release  the  ani-
mals420. The study revealed that 221 (14%) out of 1,568 of the total examined animal enclo-
sures were found to be non-secure against animal escape. A deficiency in the suitability of the 
physical  barrier  was  the  main  cause  for  lack  of  security.421  21  non-secure  enclosures  were 

407 Fàbregas, M.C., Garcés-Narrro, C., Guillén-Salazar, G., 2010, The risk of zoological parks as potential pathways for the introduction of 
non-indigenous species, Biological Invasions 12(10), pp. 55-70. 
408 Ibidem, p. 63. 
409 Ibidem, pp. 64-65. 
410 Ibidem, p. 66. 
411 Íbidem, pp. 66-67. 
412 Ibidem, p. 67. 
413 Fàbregas, M.C., Garcés-Narrro, C., Guillén-Salazar, G., 2012, Do naturalistic enclosures provide suitable environments for zoo animals?, 
Zoo Biology 31(3), pp. 362-73. 
414 Ibidem, pp. 364-365. 
415 Ibidem, p. 368. 
416 Ibidem, Appendix 1. 
417 Ibidem, p. 365. 
418 Ibidem, p. 367. 
419 Fàbregas, M.C., Garcés-Narrro, C., Guillén-Salazar, G., 2010, The risk of zoological parks as potential pathways for the introduction of 
non-indigenous species, Biological Invasions 12(10), pp. 3627-3636. 
420 Ibidem, pp. 3629-3630. 
421 Ibidem, p. 3630. 

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found to hold 17 species listed in the European Inventory of Alien Invasive Species. However, 
ten of those species had already established in some Spanish areas.422 The fact that these inva-
sive alien species (IAS) are not recognised as harmful for the human being could explain the 
lack of security.423 The study also revealed that zoos belonging to a professional association 
(i.e.  AIZA  in  the  case  of  Spain)  were  found  to  have  less  non-secure  enclosures  than  non-
members. This could be explained by the commitment of professional associations to global 
conservation goals and the thorough evaluation that zoos that apply to become a member of 
the association have to undergo. However, the paper recommends establishing stricter accredi-
tation processes to reduce the potential risk of zoos as introduction routes for non-indigenous 
species.424  
It could be concluded that zoos and the competent authorities should reinforce their licensing 
and inspection procedures, as well as improve their record keeping systems. 

 

MAPPING OF STAKEHOLDERS  
  Total number of zoos 
1.1

1.2

  Types of zoos in the country 

1.3

  NGOs active at national level  

There are currently 119 zoos in Spain.425 
No  information  was  available  on  the  number  of  zoos  at  the 
date of: 
(1) time of entry into force of the Directive;  
(2) half-way of the implementation period;  
(3) current time. 
This  information  is  not  available.  However,  from  the  name  of 
the parks,426 it can be deemed that the majority are public. 
  Animal 

(Igualdad 

Equality 

Animal) 

(www.igualdadanimal.org)  
Info zoos (www.infozoos.org)427 

 
  Action for the Animals (Acción por los Animales) (FAADA) 

1.4

  Associations of zoos professionals 

 

 

in 

(www.faada.org)  
Ecologists 
ción)(www.ecologistasenaccion.org)  
Iberian 
Zoos 
(www.aiza.org.es)  

Association 

action 

of 

(Ecologistas 

en 

ac-

and 

Aquaria 

  National  Association  for  the  Defence  of  Animals  (Asocia-
ción  Nacional  para  la  Defensa  de  los  Animales)  (ANDA) 
(www.andacentral.org) 
Iberian  Zookeepers  Association  (Asociación  Ibérica  de 
Cuidadores 
(AI-
CAS)(www.aicas.org) 

Animales 

Salvajes) 

de 

 

1.5

  Brief market overview 

TRANSPOSITION OF THE DIRECTIVE 
1.22  List of national transposing legisla-

tion 

The overall population in the country is 46.4 million.428 
Information  on  the  number  of  zoos  visitors  per  year  in  the 
country is not available.  

  Main  transposing legislation:  Law  31/2003,  of 27  October, 
of  wild  fauna  preservation 
in  zoological  parks  (Ley 
31/2003, de 27 de octubre, de conservación de la fauna 
silvestre  en  los  parques  zoológicos),  Law  31/2003,  pub-
lished  on  28  October  2003,  entered  into  force  on  29  Oc-
tober 2003, State Gazette BOE-A-2003-19800.429 

  Also relevant: 

422 Ibidem, p. 3631. 
423 Ibidem, p. 3633. 
424 Ibidem, pp. 3633-3634. 
425 Website of the Ministry of Agriculture and Environment (Ministerio de Agricultura y Medioambiente, MAGRAMA) available at 
http://www.magrama.gob.es/es/biodiversidad/temas/conservacion-de-especies/conservacion-ex-situ/ce-exsitu-zoos-informacion.aspx (last 
accessed on 10 October 2016).  
426 The name zoo, natural park or reserve (parque o reserva natural), research centre (centro de estudios), aquarium, museum is, in practice, 
only granted to public establishments.  
427 It has to be noted that Infozoos is a common project of three NGOs: ANDA, FAADA and Born Free. 
428 Data from 2016. Website of the National Statistics Institute (Instituto Nacional de Estadística, INE) available at 
http://www.ine.es/inebaseDYN/cp30321/cp_inicio.htm (last accessed on 10 October 2016). 
429 Available at https://www.boe.es/buscar/act.php?id=BOE-A-2003-19800&p=20031028&tn=1# (last accessed on 10 October 2016).  

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-  Law  42/2007,  of 13  December,  of Natural  Heritage  and  Bio-
diversity  (Ley  42/2007,  de  13  de  diciembre,  del  Patrimonio 
Natural  y  de  la  Biodiversidad),  Law  42/2007,  published  on  14 
December  2007,  entered  into  force  on  15  December  2007, 
State Gazette BOE-A-2007-21490.430 
-  Royal  Decree  1333/2006,  of  21  November,  regulating  the 
destination  of  the  seized  specimens  of  wild  fauna  and  flora 
protected  through  the  control  of  their  trade  (Real  Decreto 
1333/2006, de 21 de noviembre, por el que se regula el desti-
no de los especímenes decomisados de las especies amena-
zadas de fauna y flora silvestres protegidas mediante el con-
trol  de  su  comercio),  RD  1333/2006,  published  on  30  Novem-
ber 2006, entered into force 1 December 2006, State Gazette 
BOE-A-2006-20847.431  
-  Royal  Decree  479/2004  establishing  and  regulating  the  ge-
neral register of livestock farms (Real Decreto 479/2004 por el 
que  se  establece  y  regula  el  registro  general  de  explotacio-
nes ganaderas)432 
- Decree 1119/1975, of 24 April, on the authorisation and regis-
tration of zoological centres, establishments to practice horse 
riding, centres for the enhancement and care of companion 
animals  and  other  similar  centres  (Decreto  1119/1975,  de  24 
de  abril,  sobre  autorización  y  registro  de  núcleos  zoológicos, 
establecimientos  para  la  práctica  de  la  equitación,  centros 
para el fomento y cuidado de animales de compañía y simi-
lares),  D  1119/1975,  published  on  29  May  1975,  entered  into 
force  the  same  day,  State  Gazette  BOE-A-1975-11042.433  De-
veloped by Order of 28 July 1980.434 
  Case  2002/0299:  The  European  Commission  opened  an 
investigation against Spain due to the failure to transpose 
Directive  1999/22/EC  into  Spanish  legislation.  After  requir-
ing  the  Court  of  Justice  to  launch  a  case  against  Spain 
(Case C-298/03), Spanish authorities notified Law 31/2003 
as transposing legislation. The case was dismissed. 

  Case  2002/2086:  MP  Ms  Sornosa  Martinez  raised  to  the 
European  Commission  written  question  E-513/02  on  the 
failure  to  comply  Article  2  of  Directive  1999/22/EC  in  the 
Zoo  of  Valencia.  Due  to  the  lack  of  sufficient  evidence, 
the case was archived. 

  Case 2002/4621: Complaint based on the failure of Span-
ish  authorities  to  adopt  measures  to  transpose  Directive 
1999/22/EC. Re-directed to case 2002/0299 (see above). 

  Case  2006/4947:  Claim  of  the  ECJ  (Case  C-340/09)  that 
Spain  failed  to  fulfil  its  obligations  under  Articles  4(2),  (3), 
(4)  and  (5)  of  Directive  1999/22/EC  in  respect  of  certain 
zoos  in  certain  Autonomous  Communities.435  Spain  exe-
cuted  the  decision  of  the  ECJ,  adopting  the  necessary 
measures for compliance and the case was closed. 
The  Service  for  the  Protection  of  Nature  of  the  ‘Guardia 
Civil’ (SEPRONA) investigated between February and July 

 

1.23  Eu infringement cases  

1.24  National case-law 

430 Available at https://www.boe.es/buscar/act.php?id=BOE-A-2007-21490&p=20150922&tn=1# (last accessed on 10 October 2016). 
431 Available at https://www.boe.es/buscar/act.php?id=BOE-A-2006-20847&p=20061130&tn=1 (last accessed on 10 October 2016).  
432 Available at https://www.boe.es/diario_boe/txt.php?id=BOE-A-2015-710 (last accessed on 17 October 2016) 
433 Available at https://www.boe.es/diario_boe/txt.php?id=BOE-A-1975-11042 (last accessed on 20 October 2016). 
434 Order of 28 July 1980 providing rules on zoological centres, establishments to practice horse riding, centres for the enhancement and care 
of companion animals and other similar centres (Orden de 28 de julio de 1980 por la que se dan normas sobre núcleos zoológicos, esta-
blecimientos para la equitación, centros para el fomento y cuidado de animales de compañía y similares) published and entered into forcé 11 
September 1980, State Gazette BOE-A-1980-19645, available at https://www.boe.es/diario_boe/txt.php?id=BOE-A-1980-19645 (last ac-
cessed on 20 October 2016). 
435 Aragon, Asturias, Balearic Islands, Canary Islands, Cantabria, Castilla-Leon, Extremadura, Galicia and Valencian Community. 

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 

 

 

2016 in Zaragoza the mistreatment of animals in the zoo of 
Fraga (Huesca).436 
The SEPRONA arrested two people in August 2011 for the 
alleged commission of a crime of illegal trade of protect-
ed animals.437 
In  2009,  the  SEPRONA  dismantled  a  small  private  zoo  in 
Castilla-León where 91 animals were being held.438 
In  July  2003,  the  SEPRONA  investigated  a  man  for  the 
alleged  commission  of  illegal  trade  in  a  zoo  in  Tenerife 
(Canary Islands).439 

436 Ministry of Interior (Ministerio de Interior), ‘The ‘Guardia Civil’ investigates five people as alleged perpetrators of a crime of animal 
mistreatment’ (La Guardia Civil investiga a cinco personas como presuntas autoras de un delito de maltrato animal), available at 
http://www.magrama.gob.es/es/actuaciones-seprona/noticias/opchiraseprona_tcm7-426282.pdf (last accessed 10 October 2016).  
437 Diario de Cádiz, ‘The SEPRONA investigates a zoo for a supposed illegal sale of primates’ (El Seprona investiga un zoo por una sus-
puesta venta ilegal de primates), 9 August 2011, available at 
http://www.diariodecadiz.es/article/provincia/1038750/seprona/investiga/zoo/por/una/supuesta/venta/ilegal/primates.html (last accessed 10 
October 2016). 
438 Infozoos, ‘The Guardia Civil dismantles a small private zoo in a ranch’ (La Guardia Civil desmantela un pequeño zoo privado en una 
finca), 28 September 2009, available at http://www.infozoos.org/ver_noticia.php?not_id=48 (last accessed 10 October 2016). 
439 El Dia.es, ‘SEPRONA locates 23 protected animals in a zoo in Los Cristianos’ (El Seprona localiza 23 animales protegidos en un zoo de 
Los Cristianos), 5 July 2003, available at http://web.eldia.es/sucesos/2003-07-05/0-Seprona-localiza-animales-protegidos-zoo-Cristianos.htm 
(last accessed 10 October 2016). 

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Definition of ‘zoo’ 

Criteria for exemptions 

ANNEX III – ADDITIONAL INFORMATION  

EFFECTIVENESS 

Table 39: Overview of the definition of zoos in the 14 selected Member States440  

MS 
BE 

BG 

CY 

CZ 

A ‘zoo’ is defined as ‘all establishments open to the public, where live animals of 
non-domesticated species are kept and exhibited, that include animal parks, safari 
parks, dolphinariums, aquariums and specialized collections, but exclude circuses, 
travelling expositions and commercial establishments for animals’ (Chapter I, Article 
1, royal Decree of 10 August 1998 on the authorization of zoos). 
 § 1 (point 21) of the Supplementary provisions of the Biodiversity Act: 
21. "Zoo" shall be any permanent establishment where animals of wild species are 
kept for exhibition to the public for seven or more days a year, with the exception 
of circuses, pet shops and other establishments which do not exhibit a significant 
number of animals or species to the public. 
Zoo means a permanent establishment where animals of wild species are kept for 
exhibition to the public for 7 or more days a year 

A zoological garden means a permanent facility in which wild animals and/or also 
domestic animals are bred and exhibited to the public for 7 or more days in the 
calendar year (see the definiton in the national Act) 

DE 

Zoos are permanent facilities in which living animals of species that live in the wild 
are kept for purposes of display, for a period of at least seven days of a year. The 
following are not considered as Zoos: Circuses, pet Shops, and enclosures for keep-
ing no more than species of hoofed game listed in the federal hunting act or facili-
ties in which no more than 20 animals of other wild species are kept. 

440 On the basis of information provided in the MSCAs survey. 

NA 

According to Supplementary Provisions of Regulation No 1 from 
9 May 2006  
2. "Significant number of animals or species" are more than 5 wild 
species with more than 5 specimens of each species. 

Criteria on determining the term ‘significant’ have not been 
established.  
Each case is examined individually on the basis of the number 
and the species of animals concerned. 
A zoological garden shall not mean: 
- aquariums and terrariums and other exhibition facilities that do 
not keep more than 20 species of wild mammals and birds and 
whose main activity does not consist in exhibition of wild animals 
for the public; 
-facilities for breeding and maintenance of wild animals, that 
keep less than 20 species of wild mammals and birds, where 
these animals are exhibited to the public free-of-charge, par-
ticularly for the purpose of public education 
The following are not considered zoos: 
1.circuses, 
2.pet shops, and 
3.enclosures for keeping no more than five species of hoofed 
game listed in the Federal Hunting Act (Bundesjagdgesetz) or 

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DK 

ES 

FR 

IE 

IT 

LT 

NL 

PL 

'zoos' means all permanent establishments where animals of wild species are kept 
for exhibition to the public for 7 or more days a year, and which is own by a legal or 
individual person. 
Article 2 of Law 31/2003 reads: "zoos mean: public or private establishments, that 
regardless of the days that are open to the public, are permanent and maintain 
wildlife live animals for exhibition. the provisions of this law are not applicable to the 
circus or establishments engaged in the purchase or sale of animals".  
Zoological establishments which stay on the spot and present to the public alive 
specimens of the local or foreign fauna during at least 7 days a year  
The term "zoo" has the same meaning in the Irish Transposing Regulations as it has in 
the Zoos Directive 

Article 2, paragraph 1, of the Legislative Decree 21 March 2005, n. 73 “Attuazione 
della direttiva 1999/22/CE relativa alla custodia degli animali selvatici nei giardini 
zoologici”: Zoos: all permanent establishments, public or private, open and adminis-
trated to the public at least 7 days a year, that keeps and exhibits live animal of 
wild species, also animals born and breed in captivity, that belong in particular, but 
not only, to the animal species object of the Annexes to the Council Regulation 
(EC) n. 338/97 of 9 December 1996 on the protection of species of wild fauna and 
flora by regulating trade therein, of the law n. 157 of the 11th February 1992, of the 
Decree of the President of the Italian Republic n. 357 of the 8th September 1997. 
Definition of the zoo provided in the Law on Wild Fauna: Zoo - a place with perma-
nent  and  special facilities,  where  wild animals forming zoological collection are 
regularly kept for exhibition to the public for 7 or more days a year with the excep-
tion of circuses, pet shops and establishments covered by the exemption because 
they keep  for exhibition to the public less than 10 species of wild animals and not 
more than 50 animals, and it does not raise a threat to wildlife and biodiversity (un 
official translation). 
Zoo: permanent establishment where animals of wild species are kept for exhibition 
to the public for at least seven days a year, with exception of circusses and 
petshops. 
Zoo is an organised, managed area with technical infrastructure and functionally 
related buildings where living animals of wild species are kept and displayed pub-
licly for at least 7 days per year, excluding circuses, pet shops and establishments 
where no more than 15 such species and no more than 50 individuals of reptiles, 
birds or mammals are displayed. 

facilities in which no more than 20 animals of other wild species 
are kept. 
NA 

NA 

NA 

Irish Zoo Licence Guidance notes - GN03 - Exemption criteria 
and application advises that a collection will be considered 
exempt from the zoos legislation if, among other things which 
are also set out in the guidance document, it does not normally 
exceed 100 specimens 
The significant number of animals is not defined, but evaluated 
case by case, in strong relation with the species of the animals 
and their conservation status. 

NA 

10 species with exception of species that are protected under 
the Flora and fauna act. 

No more than 15 species and no more than 50 individuals of 
reptiles, birds or mammals. 

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PT 

All permanent establishments where animals are kept for exhibition to the public for 
7 or more days a year.  

Recovery centers, reserves and hunting wildlife ponds, with re-
gard to pedagogical and scientific actions as referred to in 
chapter IV DLn.º 104/2003 annex , as long as they are not open 
to the public;  facilities where arising exclusively hunting activi-
ties, circuses, travelling exhibitions and pet shops - they have 
own legislation. 

Table 40: Existing definition of ‘animal of wild species’ provided by national law in the 14 selected Member States441  

MS 
CY 

CZ 

The national law provides for a definition of "wild animal" instead of "animal of wild species", as follows: 
"Wild animal" means an animal which due to its nature is destined to live in a free state without restriction or guidance imposed by man. 
- a wild animal means an individual of an animal species whose population is maintained or was maintained, for animals that are missing or extinct in na-
ture, naturally in nature; this may consist in an individual bred in human care or dependent on human care 
- a species means a systematic species or subspecies or geographically separated population, 

Definition of ‘animal of wild species’ 

DK  Wild species: animals, which are not domesticated. 
FR 
IE 

Specimens of local or foreign fauna 
The Irish Standards of Modern Zoo Practice (ISMZP) define "wild animal" as any animal not normally domesticated in Ireland 
https://www.npws.ie/sites/default/files/publications/pdf/ISMZP%202016.pdf 

LT  Wild animal - free-living or kept in captivity, wild animal species at any stage of the biological evolution of the individual. Animals under this act shall also 

be considered parts of animal or products made from them, as well as copies of the dead animals’ specimen. (Non official translation). 

NL  Wild animals: animals of species or categories of species which live in the wild by nature, with exception of species or categories of species, mentioned in 

annex II of this act, and dogs and cats. 

PL  Wild animal – animal: 
a) not from breeding, 
b) introduced into the environment to rebuild or restock a population. 

Table 41: Comparison of requirements under Article 3 of the Directive and EAZA Standards 

Article 3 Zoos Directive 
Member  State  shall  take  measures 
under  Articles  4,  5,  6  and  7  to  en-
sure  all  zoos  implement  the  follow-
ing conservation measures: 

EAZA Standards 
EAZA Research standards442 
In relation to this project the Zoo agrees to fulfil the following obligations: 

1. 

to  keep  requested  conditions  constant  (e.g.  not  to  change  the  study  group(s)  of  animals  unless  this  is  part  of  the 
study). Where circumstance render this impossible, the Zoo will ensure that the researcher/Institute is informed as soon 

441 On the basis of information provided in the MSCAs survey. 
442 EAZA, EAZA Research Standards, http://www.eaza.net/assets/Uploads/Standards-and-policies/EAZA-Research-Standards-2003.pdf? (last accessed on 07.03.2017). 

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Participating 
from 
which  conservation  benefits  ac-
crue to the species […], 

research 

in 

Participating  in  […]  training  in  rele-
vant  conservation  skills,  and/or  the 
exchange  of  information  relating 
to  species  conservation  and/or, 
where appropriate, captive breed-
ing,  repopulation  or  reintroduction 
of species into the wild 

2. 

3. 

4. 
5. 
6. 

7. 

8. 
9. 

as possible. 
to carry out the manipulations of the enclosure/animal/group of animals as in accordance with the agreed experi-
mental  protocol.  The  Zoo  will  ensure  that  the  animal  keepers  and  all  other  relevant  parties  are  informed  about  this 
project and will cooperate as required. 
to  supply  the  investigators  with  the  necessary  support  for  their  project  in  the  form  of  (circle  as  appropriate):  infor-
mation about animal/exhibit/diet etc.; maps/diagrams of enclosure; history of animal/exhibit; work space/computer; 
photocopy facilities; supervision of staff biologists. 
In relation to the same project, the Institute agrees to the following obligations: 
to ensure that the study is completed or to inform the Zoo as early as possible in the event that this is not possible. 
to inform and, where appropriate, discuss with the Zoo any changes to the study protocol which are deemed neces-
sary on the basis of on-going results.to ensure that the Zoo is provided with at least one copy of the report and any 
other publications arising out of the project. 
to inform the Zoo if the results of the study are to be published and to allow the above-named representative of the 
Zoo to see the manuscript prior to publication. 
to guarantee anonymity to the Zoo in any reports/publications if so requested. 
to acknowledge the Zoo in any publications resulting from the project (unless anonymity is requested) and, if appro-
priate, to include a zoo-representative as author to the publication. 

10.  to ensure that its representative observed the dress and behaviour codes of the Zoo. 

EAZA Conservation Standards443 
Recognising that the furtherance of wildlife conservation is one of the main objectives of the Association, members of EA-
ZA: 

1.  Engage in and support conservation endeavours that contribute to the long-term survival of species in natural eco-
systems and habitats, and allocate appropriate resources to such endeavours (refer to the ‘EAZA Guidelines on the 
definition of a direct contribution to conservation (2015) for examples of such activities); 

2.  Document their conservation efforts through the EAZA Conservation Database; 
3. 
Implement the WAZA Conservation Strategy (2015) to the best of their abilities. 
4.  Assist  the  wider  conservation  community  including  wildlife  agencies,  conservation  organisations,  governments  and 

research institutions in maintaining global biodiversity, 

5.  Have a special responsibility towards the conservation of species native to the EAZA region and participate in local or 

regional conservation initiatives wherever possible, in cooperation with relevant stakeholders. 

6.  Are encouraged to inform the relevant zoo and aquarium association(s) when leading conservation activities outside 

the EAZA region. 

7.  Attempt  to  evaluate conservation activities,  to measure  their impact  and demonstrate  their on-going effectiveness 

and make that information available; 

8.  Ensure  that  conservation  activities  take  relevant  guidelines  into  account  (for  example  the  IUCN  SSC  Guidelines  for 
Reintroductions and other Conservation Translocations (2013), IUCN Guidelines for the Placement of Confiscated An-
imals (2000), IUCN Species Survival Commission Guidelines on the Use of Ex-situ Management for Species Conserva-

443 http://www.eaza.net/assets/Uploads/Standards-and-policies/EAZA-Conservation-Standards-2016.pdf 

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tion (2014), etc.) and are endorsed by the relevant wildlife management agencies. 

9.  Communicate and promote the interest of wildlife conservation, biodiversity and animal welfare to colleagues and 

to society as a whole. 

10.  Participate as much as possible in EAZA Conservation Campaigns, to promote zoos as conservation-oriented institu-

tions 

11.  Proactively engage visitors in a range of conservation issues and projects; 
12.  Promote sustainable use of natural resources and will work towards reducing their carbon footprint. 

Promoting public education and 
awareness in relation to the con-
servation of biodiversity in particu-
larly by providing information 
about the species exhibited and 
their natural habitats. 

EAZA Conservation Education Standards444 
There is no single way to fulfil either EAZA’s or an individual zoo’s conservation education mission. Conservation education 
includes a broad range of purposes, methods of delivery, unique resources and messages. EAZA also acknowledges the 
diversity of zoos within its membership, and recognises that the scale of conservation education in each EAZA zoo should 
be proportional to the size of its operations and in line with individual country’s cultural expectations around conservation 
education in zoos. A summary of the Standards is listed below, followed by each of the Standards with further explanation 
to help guide Members. 

1. 
2. 

3. 

4. 

The conservation education role of the zoo must be reflected in its written mission statement. 
The  zoo  must  have  a  written  conservation  education  plan.  This  plan  must  outline  the  zoo’s  conservation  education 
activities, how they apply to different types of audiences and the strategic thinking behind the plan’s design. 
The zoo’s conservation education plan must make specific reference to how the zoo has integrated their mission and 
vision, as well as applicable national, regional and international policies into its conservation education programmes. 
The zoo must have at least one member of staff with the necessary experience and qualifications that are responsi-
ble for leading and implementing the zoo’s conservation education plan. 
The zoo must provide opportunities to learn about conservation within and outside the zoo site and online. 

5. 
6.  Conservation education in zoos should aim to raise awareness of biodiversity loss, connect people to nature and en-

courage sustainable behaviours 

7.  Conservation education in zoos should aspire to make conservation issues relevant  to visitors’ own lives and experi-

ences in order to inspire people to take action locally that can make a difference globally. 
The zoo must have appropriate facilities to deliver its conservation educational programmes. 

8. 
9.  Conservation education must be an integral part of exhibit design. 
10.  In the conservation education plan, there must be specific reference to applying measurable learning outcomes to 

all aspects of a zoo’s conservation education programmes. 

11.  The zoo should be able to demonstrate a range of delivery approaches in their conservation education programmes 

to cater for different zoo audiences and needs. 

12.  The zoo’s conservation education messages must be based on scientific facts. Where cultural, religious or alternative 

ideas are represented they must be clearly indicated as such. 

13.  The zoo must present accurate and relevant information about the species exhibited. 
14.  The zoo should educate their audiences about their own conservation work by demonstrating how their zoo makes 

direct and indirect contributions to conservation. 

444 EAZA, EAZA Conservation Education Standards, http://www.eaza.net/assets/Uploads/Standards-and-policies/EAZA-Conservation-Education-Standards-2016-09.pdf (last accessed on 07.03.2017). 

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15.  Zoos should support staff involved in conservation education in zoos to be actively involved in local, national, region-

al and international conservation education networks and meetings. 

16.  Zoos should support staff involved in conservation education in zoos with the appropriate continuous professional de-

velopment and training to be able to meet the aims of the zoo’s conservation education plan. 

17.  The zoo must have a range of evidence to demonstrate how it is carrying out its conservation education plan. 
18.  The zoo must evaluate its conservation education programmes using appropriate methods. 
19.  The zoo should aspire to conduct  a range of evidence based research to  demonstrate  the effects of conservation 

education in zoos has on people’s knowledge, attitude and behaviour towards the natural world. 

20.  20. The zoo should aspire to engage in partnerships with external organisations and academic institutions to conduct 

social research and evaluation projects. 

EAZA Standards for the Accommodation and Care of Animals in Zoos and Aquaria445 
The 13-pages document contains key requirements on the following items: 

1.  Animal care – welfare, health and hygiene 
1.1  Routine observation of the animals 
1.2  Accommodation – Space, Exercise and Grouping 
1.3  Accommodation - Comfort and Well-being 
1.4  Social group management 
1.5  Encouragement of natural behaviour and minimising of unnatural behaviour 
1.6  Furnishings within Enclosures 
1.7  Mixed exhibits 
1.8  Free ranging species 
1.9  Hand rearing 
1.10 Prevention of Stress or Harm to Animals 
1.11 Training (including animal training for husbandry purposes, animal training for public demonstrations446) 
1.12 Food and Drink 
1.13 Sanitation and control of disease 

Accommodating their animals 
under conditions which aim to 
satisfy the biological and conserva-
tion requirements of the individual 
species, inter alia, by providing 
species specific enrichment of the 
enclosures; and maintaining a high 
standard of animal husbandry with 
a developed programme of pre-
ventive and curative veterinary 
care and nutrition 

2.  Animal Care – Veterinary Aspects 
2.1  General Veterinary care 
2.2  Mutilation 
2.3  Post-Mortem Facilities 
3.  Population Management 

3.1  Reproduction 
3.2  Transfer and disposition of animals 
3.3  Euthanasia 

445 EAZA, Standards for the Accommodation and Care of Animals in Zoos and Aquaria http://www.eaza.net/assets/Uploads/Standards-and-policies/Standards-for-the-Accommodation-and-Care-of-Animals-2014.pdf 
(last accessed on 07.03.2017). 
446 Such training and use of animals in shows and demonstrations is supported by EAZA under several conditions, including that “1. The content of the display is educational and designed to demonstrate, and inspire 
respect for, the animals’ natural behaviour and abilities, 2. The content of the display does not demean or degrade the animal and is not detrimental to 
its welfare. […]”. 

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4.  Safety and security 

4.1  General provisions 
4.2  Enclosures 
4.3  Enclosure barriers 
4.4  Stand-off barriers 
4.5  Perimeter boundaries 
4.6  Warning signs 
4.7  Exits 
4.8  Drive-through enclosures 
4.9  Removal of animals from enclosures 
4.10 Escape of animals from their enclosures 
4.11 Safety of access for the public 

Preventing the escape of animals 
in order to avoid possible ecologi-
cal threats to indigenous species 
and preventing intrusion of outside 
pests and vermin 

5.  Miscellaneous 

5.1  Insurance against liability for damage or injury caused by animals 
5.2  Stock records 
5.3  Transportation and Movement of Live Animals 

EAZA Standards for the Accommodation and Care of Animals in Zoos and Aquaria447 

1.  Animal care – welfare, health and hygiene 

1.8 Free ranging species 
1. If animals are being kept free ranging in a zoo, the potential for containing them safely should always be avail-
able and the animals should be used to entering this enclosure for management purposes (e.g. veterinary exami-
nations and collection management). 
2. Escape into the wild and/or crossbreeding with local species must be avoided at all times. […] 
1.13 Sanitation and control of disease 
[…] 7. A safe and effective programme for the control of pests and, where necessary, predators to be established 
and maintained throughout the institution. Animals must not escape from the zoo or aquarium and create an eco-
logical threat for native wild species. 

4.  Safety and security 
4.2 Enclosures 
Other than when elsewhere in the control of authorised staff, animals kept for exhibition in the zoo to be kept at all 
times in enclosures or, in the case of free-running non-hazardous animals, within the perimeter of the zoo. 
4.3  Enclosure barriers 
Enclosure barriers to be designed, constructed and maintained to contain animals within the desired enclosures. 
4.10 Escape of animals from their enclosures 
1.  Zoo  operators  to  assess  whether  any  danger  may  arise  in  the  event  of  an  animal  escaping  from  its  enclosure 
and to consider the possible or likely attempted escape route within and from the institution if this were to happen. 

447 EAZA, Standards for the Accommodation and Care of Animals in Zoos and Aquaria http://www.eaza.net/assets/Uploads/Standards-and-policies/Standards-for-the-Accommodation-and-Care-of-Animals-2014.pdf 
(last accessed on 07.03.2017). 

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Keeping up-to-date records of the 
zoo’s collection appropriate to the 
species recorded 

2. In the case of the escape of animals emergency plans must be available and fully understood and practised by 
all staff. 
3. This emergency plan should include a member of staff to be readily available at all times to take decisions re-
garding escaped animals, including the use of firearms if needed. 
4. Every employee with tasks under the emergency procedures to undergo periodic refresher training and prac-
tice. 

EAZA Standards for the Accommodation and Care of Animals in Zoos and Aquaria448 

5.  Miscellaneous 

5.2 Stock records 
1. Animal records are to be kept on a computer system using the ARKS software, or Zoological Information Man-
agement System(ZIMS), and to be included on the global zoo animal database of ISIS, by means of which  infor-
mation can be quickly retrieved. 
2. Alternatively, records may be kept by means of an established and globally recognised and accepted record 
system and maintained in relation to all individually recognised animals and groups of animals. 
3. Where animals are disposed of or die, the records to be kept in the appropriate recording system as described 
in Article 95. 
4. The records should provide the following information - 
a. the correct identification and scientific name; 
b. the origin (i.e. whether wild or captive born, including identification of parents, where known, and previous lo-
cation/s, if any); 
c. the dates of entry into, and disposal from, the collection and to whom; 
d. the date, or estimated date, of birth; 
e. the sex of the animals (where known); 
f. any distinctive markings, including tattoo or freeze brands etc.; 
g. clinical data, including details of and dates when drugs, injections, and any other forms of treatment were giv-
en, and details of the health of the animal; 
h. the date of death and the result of any post-mortem examination; 
i. the reason, where an escape has taken place, or damage or injury has been caused to, or by, an animal to per-
sons or property, for such escape, damage or injury and a summary of remedial measures taken to prevent recur-
rence of such incidents. 
5. In addition to the individual records, an annual stock list of all animals to be kept preferably in the form given 
below. (Estimated numbers should be available for all fish and invertebrate species). 
a. Common and scientific names of the species 
b. Total in the collection at 1 January 
c. Number of arrivals into the collection from all sources during the year 
d. Number of births into the collection during the year 

448 EAZA, Standards for the Accommodation and Care of Animals in Zoos and Aquaria http://www.eaza.net/assets/Uploads/Standards-and-policies/Standards-for-the-Accommodation-and-Care-of-Animals-2014.pdf 
(last accessed on 07.03.2017). 

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e. Number which died within 30 days of birth 
f. Number which died older than 30 days after birth/hatching 
g. Number departed collection, including sales, breeding loans, etc. 
h. Total remaining in the collection at 31 December 
This  record,  giving  details  of  male/female/unsexed  animals  as  appropriate,  to  be  set  out  in  columns  for  ease  of 
compilation and reference, e.g.: [example table] 
6. All records can be kept in the local language or in the English language (in order to facilitate the international 
exchange of information and cooperation). 
7. Surplus animal stock only to be passed on to responsible facilities which have the appropriate facilities and ex-
pertise). 

EU ADDED VALUE 

Table 42: National requirements diverging and/or going beyond the Directive’s requirements 

MS 

Exemption under Article 2 and definition of 
“significant number of animals” 

BE449  NA 

BG450  A significant number of animals or species 
is more than 5 wild species with more than 
5 specimens of each species. 

CY451 

The  significant  number  of  animals  is  not 
defined,  but  evaluated  case  by  case, 
taking  into  account  the  specific  species 
and their number. 

Examples of more stringent rules on conservation 
measures 
National  legislation  is  complemented  by  veteri-
nary guidance; general legislation on animal wel-
fare regarding the liability of the owner of animals. 
Zoos are required to undertake all of the following 
requirements: participate in specific research and 
conservation  (…)  including  those  related  to  the 
introduction  of  wild  species  into  the  wild;  partici-
pate  in  ex  situ  conservation  programmes  for 
threatened species to retain genetic diversity and 
probability  for  reintroduction  into  the  wild  and 
exchange information with likeminded institutions.   
1.  The  applicant  for  a  zoo  license  must  not  be 
abuse. 
convicted 
2. 
for  5  years. 
The 
3. Before  amending either the number  of animals 
or  the  animal  species  or  the  enclosures,  the  zoo 

for 
license 

is  valid 

animal 

zoo 

Examples of specific requirements on animal accom-
modation 
Secondary  legislation  has  been  introduced,  which 
stipulates specific requirements (enclosure sizes) for the 
keeping of mammals, birds and reptiles. 
Minimum  requirements  on  animal  accommodation 
and husbandry in zoos and breeding centres apply.  

NA 

449 Royal Order of 10 August 1998 on the recognition of zoos (10 Août 1998 - Arrêté royal relative à l’agrément des parc zoologiques / 10 augustus 1998. – Koninklijk besluit betreffende de erkenning van dieren-
tuinen), Ministerial order of 3 May 1999 laying down minimum standards for the keeping of mammals in zoos; Ministerial order of 7 June 2000 laying down minimum standards for the keeping of birds kept in zoos; 
Ministerial order of 23 June 2004 laying down minimum standards for the keeping of reptiles in zoos. 
450 Biodiversity Act (Закон за биологичното разнообразие) 09 August 2002, Ordinance № 6, October 23, 2003 (НАРЕДБА № 6 ОТ 23 ОКТОМВРИ 2003 Г. ЗА МИНИМАЛНИТЕ ИЗИСКВАНИЯ И УСЛОВИЯ 
ЗА ОТГЛЕЖДАНЕ НА ЖИВО) describing minimum requirements and conditions for keeping animals in zoos. 
451 Animal Protection and Welfare Act (Keeping of Wild Animals in Zoos) (Οι περί Προστασίας και Ευημερίας των Ζώων (Διατήρηση Άγριων Ζώων σε Ζωολογικούς Κήπους) Kανονισμοί του 2002) 

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CZ452 

DE453 

The exemption regards the aquariums and 
terrariums  and  other  exhibition  facilities 
that do not keep more than 20 species of 
wild mammals and birds and whose main 
activity  does  not  consist  in  exhibition  of 
wild  animals  for  the  public;  facilities  for 
breeding  and  maintenance  of  wild  ani-
mals,  that  keep  less  than  20  species  of 
wild  mammals  and  birds,  where  these 
animals are exhibited to the public free-of-
charge,  particularly  for  the  purpose  of 
public education 
The  following  facilities  are  not  considered 
as  zoos:  enclosures  for  keeping  no  more 
than five species of hoofed game454; facil-
ities  in  which  no  more  than  20  animals  of 
other wild species are kept. 

ES456  NA 

FR458  NA 

must  obtain  an  approval  by  the  competent  au-
thority. 
4. Zoos must be inspected twice per year. 
NA 

NA 

NA 

More  detailed  requirements  exist  on  animal  wel-
fare  measures,  preventive  and  environmental 
programs,  specialized  personnel  and  material 
resources, register of species and specimens457. 
Besides  the  alternative  measures  of  Article  3,  first 
indent, zoos must: 

- 

in  order  to  ensure  the  genetic  quality  of 

Although  non-legally  binding,  federal  guidelines455 
exist  on  a.o.  the  keeping  of  mammals,  reptiles,  birds 
and  ornamental  fishes,  which  support  animal  owners, 
competent authorities and courts in deciding whether 
animal husbandry meets the requirements of the legis-
lation 
NA 

Zoos must ensure: 
-The  composition  of  groups  of  animals  is  determined 
by the space available, and the behaviour and physi-

452 Act on Conditions for the Operation of Zoological Gardens and amending some Acts (Zákon č. 162/2003 Sb., o podmínkách provozování zoologických zahrad a o změně některých zákonů (zákon o zoologických 
zahradách) No. 162/2003. 
453 Federal Nature Conservation Act  29 July 2009 (BGBl. IS.2542). 
454 As listed in the Federal Hunting Act (Bundesjagdgesetz). 
455 BMEL, Animal Welfare Guidelines and Reports, http://www.bmel.de/DE/Tier/Tierschutz/Tierschutzgutachten/_texte/GutachtenDossier.html%20-  
456 Chapter II (conservation measures) of Law 31/2003, of 27 October, of wild fauna preservation in zoological parks. 
457 Chapter II (conservation measures) of Law 31/2003, of 27 October, of wild fauna preservation in zoological parks. 
458 Order of 25 March 2004 laying down the rules of operation and the general characteristics of facilities of zoological establishments of fixed and permanent nature, presenting the public with live specimens of local or 
foreign wildlife under heading 21-40 of the nomenclature of facilities classified for environmental protection (Arrêté du 25/3/2004 fixant les règles générales de fonctionnement et les caractéristiques générales des 
installations des établissements zoologiques à caractère fixe et permanent, présentant au public des spécimens vivants de la faune locale ou étrangère et relevant de la rubrique 21-40 de la nomenclature des installations 
classées pour la protection de l'environnement). 

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-  Contribute 

hosted  species,  participate  in  the  ex-
change of animals that promote the con-
servation  and  management  of  captive 
animal  populations.  Contribute  to  nation-
al  and 
international  breeding  pro-
grammes and to keep animals of species 
involved in these programmes. 

to 

the  breeding  of  non-
domestic  species,  or  organisations 
in-
volved in the conservation of biodiversity, 
the sharing of information concerning the 
breeding  techniques  of  wild  animals  in 
captivity,  knowledge  of  their  biology  or 
knowledge  relevant  to  the  conservation 
of biological diversity. 
Keep  the  corpses  of  animals  at  the  dis-
posal of scientific or training institutes, un-
less  these  are  used  for  the  needs  of  the 
zoo.  

- 

Certificate  of capacity requested  for  zoo owners; 
qualification of the key staff. 

NA 

ology of the animals. 
- The welfare of animals and prevention of behaviour-
al  abnormalities  are  mainly  addressed  by  relevant 
improvements  to  breeding  conditions  appropriate  to 
the biological needs of each species. 
-  Animals  should  be  protected  from  predators  from 
outside the establishment. 
- Caring for animals includes reducing sources of stress, 
discomfort  and  the  risk  of  injury.  Any  interference  or 
disruption  needs  to  be  banned.  It  is  forbidden  to  pro-
voke/agitate  the  animals,  in  presence  or  absence  of 
the public.’ 
-  Enclosures  and  their  enrichment  should  be  adapted 
to  the  habits  of  each  species,  ensuring  that  the  ani-
mals are safe and can express their natural behaviour.  
- The facilities must allow them to escape the hostile or 
aggressive  behaviour  of  cage  companions,  allowing 
them to express normal behaviour relating to defence 
or escape. 
-  Animals  kept  in  outdoor  enclosures  should  have  ac-
cess  to  shelters  or  other  premises  to  allow  them  to 
avoid the negative effects of climate. 

Appendix 9 of the Irish Standards of Modern Zoo Prac-
tice (ISMZP)461 set out specific sizes for elephant enclo-
sures both indoor and outdoor. Enclosure sizes are not 
specified  for  any  other  animal  or  category  of  animal 
or species. 

Additional minimum standards concerning animal 
care,  welfare,  health  and  hygiene.  Specific  re-
quirements  applicable  to  bottlenose  dolphins  are 
included in the Ministerial Decree n.469 (2001). 

Minimum  standards  exist  only  for  the  keeping  of  dol-
phins  (Tursiops  truncatus)  in  zoos.  The  standards  deal 
with  the  measures  for  the  pools,  medical  treatments, 
food, the prohibition of contact with the visitors, prohi-
bition of training to unnatural behaviour. 

IE459 

IT462 

Exemption criteria and application advises 
that  a  collection  will  be  considered  ex-
empt  from  the  zoos  legislation  if,  among 
other  things  which  are  also  set  out  in  the 
guidance document, it does not normally 
exceed 100 specimens460.  
The  significant  number  of  animals  is  not 
defined,  but  evaluated  case  by  case, 
taking  into  account  the  specific  species 
and their conservation status. 

459 European Communities (Licensing and Inspection of Zoos) Regulations 2003, S.I. No. 440/2003 of 19/09/2003. Irish Statute Book (Office of the Attorney General, 2016). Adopted: 19th September, 2003  Entry into 
force: April 2005 (Licensing and Inspection of Zoos) 
460 Irish Zoo License Guidance notes - GN03 https://www.npws.ie/sites/default/files/publications/pdf/ZLGN%20GN03%20Exemptions%200516.pdf  
461 https://www.npws.ie/sites/default/files/publications/pdf/ISMZP%202016.pdf  
462 Legislative Decree 21 March 2005 n. 73 (Decreto Legislativo 21 Marzo 2005, n.73). 

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LT463 

NA 

NL464  A significant number of animals is defined 
as  10  species  with  exception  of  species 
that  are  protected  under  the  legislation 
on the protection of fauna and flora. 

PT465  Are  exempted  from  the  licensing  require-
ment establishments with no more than 15 
species  and  no  more  than  50  individuals 
of reptiles, birds or mammals. 

PT466  NA 

NA 

NA 

Minimum 
standards 
tion/enclosure are set in legislation. 
NA 

for  animal  accommoda-

-  The  species  threatened  with  extinction  in  the 
natural  environment  should  be  subject  to  ex  situ 
conservation  in  zoos’,  with  the  objective  ‘to  re-
store individuals of species to their natural habitat. 
The Minister of Environment also has the power to 
establish  a  list  of  species  demanding  additional 
protection  in  Poland,  as  well  as  establish  ex  situ 
programmes  for  endangered  species.  Further, 
zoos must: participate in scientific research, which 
benefits the species conservation; as well as keep 
and  breed  endangered  species  for  their  ex  situ 
conservation and their introduction to the natural 
environment. 

-  Zoos  are  required  to  undertake  all  the  following 
requirements: 
-  participate  in  research  that  benefit  the  conser-
vation  of  the  species,  without  prejudice  to  the 
welfare of the animals involved; 
-  captive  breeding  of  species  listed  by  IUCN  as 
extinct  or  endangered  in  the  wild  should  be, 
whenever  possible,  included  within  international, 
national  or  regional  cooperative  breeding  pro-
grammes; 

Zoos  must  only  keep  those  animal  species  which  can 
be  provided  conditions  that  meet  their  biological 
needs. 
The  conditions  for  breeding  and  keeping  animals  in 
zoos  are  specified  in  law  on  necessary  rooms  and 
technical  equipment  for  the  places  where  animals 
stay,  as  well  as  minimum  spatial  conditions  for  breed-
ing  and  keeping  animals  of  particular  species  or 
groups of species, as well as the necessary conditions 
for  reproducing  animals.  The  regulation  contains  de-
tails  on:  the  necessary  facilities  and  equipment  re-
quired  for  the  animal  by  species  and  species  groups; 
the minimum space conditions for breeding and keep-
ing of animals of each species or species groups; and 
the  necessary  conditions  for  the  reproduction  of  ani-
mals of species or species groups. 
Zoos  should  ensure  ‘housing  conditions,  reproduction, 
breeding,  maintenance,  accommodation,  travel  and 
keeping  of  animals  in  zoos  must  safeguard  the  ani-
mals’  welfare,’  continuing  with  ‘no  animal  shall  be 
detained in a zoo if [these] conditions are not guaran-
teed...’ 
Further requirements include: 
-Animals  whose  interrelationships  are  potential  causes 
of excessive stress and disruption should not be kept in 
close proximity. 

463 Annex 4 in the Rules on Use of Wild Animals, approved by Order No D1-533/B1-310 of the Minister of Environment and the Director of State Food and Veterinary Service, as last amended on 24 .4.2014 
464 Zoos Law (Dierentuinenbesluit) 19 April 2002; amended in 2014 in new regulation: Animal Act (Wet Dieren) (Overheid.nl, 2015); Animal Act (Wet Dieren) Animal holders, and Governmental decree (Besluit 
houders van Dieren), July 2014. 
465 Nature Protection Act, ‘NPA’ (16/04/2004 amended on 16/06/2011) (ustawa z dnia 16 kwietnia 2004 r. o ochronie przyrody); Regulation of the Minister of the Environment of 20 December 2004 on the conditions 
for the husbandry and keeping of respective groups of species in zoological gardens (Rozporządzenie Ministra Środowiska z dnia 20 grudnia 2004 r. w sprawie warunków hodowli i utrzymywania poszczególnych grup 
gatunków zwierząt w ogrodzie zoologicznym) (RZ12/2004) (ISAP, 2004). 
466 Decree-Law 104/2012 

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- zoos should also, where this is deemed appropri-
ate,  provide  training  in  conservation  techniques, 
exchange information related to the preservation 
of  species,  captive  breeding,  repopulation  or 
reintroduction of species into the wild. 

-  Any  direct  contact  with  the  public  should  be  done 
under  the  strict  supervision  of  staff  responsible...and 
subject  to  a  rotation  scheme.  Always  safeguarding 
public  health,  safety  and  welfare  of  people  and  ani-
mals. 
-  The  zoo  can  have  structures  for  public  recreation, 
providing these are  not likely to disturb  the  well-being 
of the animals, and that they are located in areas well 
away from [animal] housing. 
-  The  animals  must  have  adequate  space  to  display 
natural  behaviours  and  satisfy  their  physiological 
needs.  
-  The  handling  of  animals  must  be  done  so  as  not  to 
cause  them  any  pain,  suffering  or  unnecessary  dis-
turbance. 
-  The  accommodation  must  be  equipped  according 
to the specific needs of the animals. 

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ANNEX IV – BIBLIOGRAPHY 

2016. Accessed November 15, 2016. http://countrymeters.info/. 
AFVPZ. 2008. “Statuts de l'Association Française des Vétérinaires de Parcs Zoologiques.” 

Mulhouse, 16 October. Accessed October 24, 2016. 
http://www.afvpz.com/IMG/pdf/nouveaux_statuts_AFVPZ_oct_08-2.pdf. 

Agentschap Informatie Vlaanderen. n.d. Erkenning als dierentuin. Accessed October 4, 2016. 
http://www.vlaanderen.be/nl/natuur-en-milieu/dieren/erkenning-als-dierentuin. 

Algemene Directie Statistiek. 2015. Kerncijfers. Statistisch overzicht van België. Brussels: 

FOD Economie, K.M.O. Middenstand en Energie. 

Angelika Habel, Sławomir Mroczkowski. 2015. “The objectives and tasks of zoos[Cele i 

zadania ogrodów zoologicznych].” Journal of Education, Health and Sport 521-528. 
http://www.ojs.ukw.edu.pl/index.php/johs/article/download/2015%3B5(8)%3A521-
528/pdf_347. 

Anon. 2011. “(COM)2011) 244.” Our life insurance, our natural capital: an EU Biodiversity 

Strategy to 2020 ((COM)2011) 244). http://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX:52011DC0244. 

—. 2010. “Strategic plan 2011-2020, including Aichi Biodiversity Targets.” Accessed 11 30, 

2016. https://www.cbd.int/sp/default.shtml. 

Anthony D Sheridan. 2010. “Europe's Leading Zoological Gardens.” 24. 
Aquarium-Museum van Luik. n.d. Aquarium-Museum van Luik. De afdeling. Enkele cijfers. 

Accessed October 4, 2016. http://www.aquarium-
museum.ulg.ac.be/nl/institution/chiffres.php. 

Associação Portuguesa de Zoos e Aquários. 2016. Associação Portuguesa de Zoos e 

Aquários. http://www.apza.pt/home. 

Balmford, A, N Leader-Williams, G M Mace, A. Manica, O. Walter, C. West, and A. 

Zimmerman. 2007. “Message received? Quantifying the impact of informal 
conservation education on adults visiting UK zoos.” In Zoos in hte 21st centruy: 
Catalysts for conservation?, by A. Zimmerman, M. Hatchwell, L. A. Dickie and C. 
West, 120-136. Cambridge University Press. 

Balmford, A., and al et. 2005. “The convention on biological diversity’s 2010 target.” Science 

307, 212–213. 

Balmford, A., Mace, G.M., Leader-Williams, N. 1996. “Designing the ark: setting priorities 

for captive breeding. .” Conservation Biology 10: 719–727. 

Balmford, Andrew, Jeanette Kroshko, Nigel Leader-Williams, and Georgia Mason. 2011. 

“Zoos and Captive Breeding.” (Science) 332: 1149-1150. 

Barongi, R., F. A. Fisken, M. Parker, and M. (eds) Gusset. 2015. “Committing to 

Conservation: The World Zoo and Aquarium Conservation Strategy.” Edited by 
WAZA Executive Office. 
http://www.waza.org/files/webcontent/1.public_site/5.conservat. 

BASTA! 2016. ZOO W POLSCE. Accessed November 30, 2016. 

http://www.polskiezoo.info/. 

BELGA. 2016. De Morgen. Wetenschap. 8 April. Accessed October 4, 2016. 

http://www.demorgen.be/wetenschap/gezonde-surplusgiraf-aan-leeuw-voederen-nee-
zoo-antwerpen-en-planckendael-voeren-no-kill-beleid-in-b245ed0f/. 

BMT (Bund gegen Missbrauch der Tiere) . 2016. “Haltung von Tieren in zoologischen 
Einrichtungen aus der Sicht des Bund gegen Missbrauch der Tiere.” 3. 

Milieu Ltd  
Brussels  

Evaluation Study to support the evaluation of the Zoos Directive 
Annexes to Final Report – August 2017/ 291 

 
 
 
 
Boakes, EH, PJK McGowan, RA Fuller, Chang-qing D, NE Clark, K O'Connor, and et al. 

2010. “Distorted Views of Biodiversity: Spatial and Temporal Bias in Species 
Occurrence Data.” (PLoS Biology) 8 (6). doi:10.1371/journal.pbio.1000385. 
Board of Directors of Polish Zoos and Aquariums. 2016. Board of Directors of Polish Zoos 

and Aquariums. Accessed November 23, 2016. http://www.zoo.gda.pl/blog/rada-
dyrektorow-polskich-ogrodow-zoologicznych-i-akwariow. 

Born Free. 2010. “Enquête de 2011 sur les Zoos de l’Union Européenne : Une Evaluation de 
la Mise en Application et du Respect de la Directive CE 1999/22 Relative à la 
Détention d’Animaux Sauvages dans un Environnement Zoologique FRANCE.” 
Born Free Foundation. 2016. “Identifying the training needs of EU Member States Competent 

Authorities, Survey to assess implementation of Legislation and need for Training: 
wild animals kept in captivity.” 

Born Free Foundation. 2010. The EU Zoo Inquiry 2011 - country report cyprus. Born Free 

Foundation. 

Born Free Foundation. 2011. The EU Zoo Inquiry 2011 - Country Report Germany . Born 

Free Foundation. 

Born Free Foundation. 2011. The EU Zoo Inquiry 2011 - Country Report Poland. Born Free 

Foundation. 

Born Free Foundation. 2011. The EU Zoo Inquiry 2011. An evaluation of the implementation 
and enforcement of the EC Directive 1999/22, relating to the keeping of wild animals 
in zoos. Belgium. Horsham: European coalition ENDCAP. 

Born Free Foundation. 2011. “The EU Zoos Inquiry - Country Report Lithuania.” 
Born Free Foundation. 2011. The EU Zoos Inquiry 2011 - Country Report Bulgaria. Born 

Free Foundation. 

Born Free Foundation. 2012. The Zoo EU Inquiry 2011. An evaluation of the implementation 
and enforcement of EC Directive 1999/22, relating to the keeping of animals in zoos. 
Report findings and recommendations. Horsham: European coalition ENDCAP. 

Born Free. 2012. The EU Zoo Inquiry 2011. London: Born Free; Endcap. 
—. 2016. Zoo Assessment- Methodology and rationale. Accessed 12 06, 2016. 

http://www.bornfree.org.uk/campaigns/zoo-check/zoos/euzoos/methodology-and-
rational/. 

BornFree. 2011. “The EU Zoo Inquiry 2011.” 
Bowkett, Andrew E. 2014. “Ex situ conservation planning is more complicated than 

prioritising the keeping of threatened species in zoos.” Edited by The Zoological 
Society of London. Animal Conservation (17): 101-103. 

Bowkett, Andrew E. 2009. “Recent Captive-Breeding Proposals and the return of the Ark 

Concept to Global Species Conservation.” Edited by Society for Conservation 
Bioloogy. Conservation Biology 23 (3): 773-776. doi:10.1111/j.1523-
1739.2008.01157.x. 

Bowkett, Andrew E. 2009. “Recent Captive-Breeding Proposals and the return of the Ark 

Concept to Global Species Conservation.” Edited by Society for Conservation 
Bioloogy. Conservation Biology 23 (3): 773-776. doi:10.1111/j.1523-
1739.2008.01157.x. 

Bron Free Foundation. 2011. The EU Zoo Inquiry 2011 - Country Report Portugal. Born Free 

Foundation. 

Carla Sousa-Santos, Fatima Gil, Vitor C. Almada. 2013. “Ex situ reproduction of Portuguese 

endangered cyprinids.” Ichthyological Research.  

Carr, N, and S Cohen. 2011. “The public face of zoos: images of entertainment, education and 

conservation.” Anthrozoos 175-189. 

Milieu Ltd  
Brussels  

Evaluation Study to support the evaluation of the Zoos Directive 
Annexes to Final Report – August 2017/ 292 

 
 
 
CBD. 2010. “Strategic plan 2011-2020, including Aichi Biodiversity Targets.” Accessed 11 

30, 2016. https://www.cbd.int/sp/default.shtml. 

CBSG. n.d. Conservation Breeding Specialist Group- our mission . Accessed 12 6, 2016. 

http://www.cbsg.org/. 

CITES Secretariat and WAZA. 2011. “Memorandum of understanding between the 

Secretariat of the Convention on international trade in endangered species of wild 
fauna and flora and WAZA- the World Association of Zoos and Aquariums.” 
Accessed 12 12, 2016. https://cites.org/common/disc/sec/CITES-WAZA.pdf. 

Claudia Faria, Vıtor Carvalho Almada. 2010. “An Efficient Technique for the Captive 

Breeding of an Endangered Freshwater Fish Salaria fluviatilis.” J World Aquaculture 
Society 49-56. 

Code Animal. n.d. Les zoos en questions. Accessed October 24, 2016. http://www.zoo-de-

france.com/content/les-zoos-en-questions. 

—. n.d. Qui sommes-nous? Accessed October 24, 2016. http://www.code-animal.com/qui-

sommes-nous/. 

—. 2013. “Zoo de Strasbourg: Une Structure Archaïque en Echec.” Code Animal. 31 October. 

Accessed October 24 2016. http://www.code-animal.com/wp-
content/uploads/2015/09/cp_endcap_ok.pdf. 

Commission v. Germany. 2004. C-339/03 (Court of Justice of the European Union (Fourth 
Chamber), Official Journal of the European Union, 4.12.2004 14 October). 

Commission v. Spain. 2010. Case C-340-09 (Court of Justice of the European Union, 9 

December). 

Conde DA, Flesness N, Colchero F, Jones OR, Scheuerlein A. 2011b. “Zoos and captive 

breeding – response. .” Science 332: 1150–1151. 

Conde, D.A., Flesness, N, Colchero, F., Jones, O.R., Scheuerlein, A. 2011. “Zoos and Captive 

Breeding Response.” Science 1149-1151. 

Conde, Dalia A, N Flesness, F Colchero, O R Jones, and A Scheuerlein. 2011. “An emerging 

role of zoos to conserve biodiversity.” Science (Science) 331. 

Conde, Dalia A, N Flesness, F Colchero, O R Jones, and A Scheuerlein. 2011a. “An emerging 
role of zoos to conserve biodiversity.” Science (Science) 331: 331: 1390-1391. 

Conde, Dalia. 2011a. “Response to Zoos and captive breeding.” Science 1150-1151. 
Danish Veterinary and Food Administration. 2016. List of bodies, institutes and centres 

approved for intra-Community trade in animals . 
http://www.fodevarestyrelsen.dk/sdata/liste_til_nettet_zoologiske_anlaeg.pdf. 

DAZA. 2016. DAZA. http://www.daza.dk/about.html. 
Derbianus Conservation. 2016. Derbianus Conservation. http://www.derbianus.cz/. 
Dienst Dierenwelzijn. n.d. Dierentuinencommissie. Accessed October 24, 2016. 

https://www.lne.be/dierentuinencommissie. 

DRE. 2016. DIÁRIOS DA REPÚBLICA. https://dre.pt/application/file/552182. 
EAAM. 2016a. Accessed 12 6, 2016. http://www.eaam.org/species-conservation/eaam-

conservation-programmes/eaam-conservation-programmes/. 
—. 2016a. EAAM Conservation Programmes. Accessed 12 6, 2016. 

http://www.eaam.org/species-conservation/eaam-conservation-programmes/eaam-
conservation-programmes/. 

—. 2016. Standards and guidelines. Accessed 12 06, 2016. http://www.eaam.org/about-

eaam/standards-guidelines/standards-and-statements/. 
2016. EAZA . http://www.eaza.net/conservation/programmes/. 
EAZA Academy. 2016. EAZA Training courses. http://www.eaza.net/academy/. 
—. 2016. EAZA Training courses. http://www.eaza.net/academy/. 
EAZA. 2015. “Annual Report 2015.” 

Milieu Ltd  
Brussels  

Evaluation Study to support the evaluation of the Zoos Directive 
Annexes to Final Report – August 2017/ 293 

 
 
 
—. 2016. EAZA Conservation Programmes. http://www.eaza.net/conservation/programmes/. 
—. 2015. “EAZA Guidelines on the definition of a direct contribution to conservation.” 

EAZA.net. 30 April. Accessed 11 29, 2016. 
http://www.eaza.net/assets/Uploads/Position-statements/Contribution-to-conservation-
definition-2015-04-Revisions.pdf. 

EU. n.d. EU Member Countries. Accessed November 16, 2016. https://europa.eu/european-

union/about-eu/countries/member-countries_en. 

Eurogroup for Wildilfe & Laboratory Animals. 2006. Report on the implementation of the zoo 

Directive. Eurogroup for Wildilfe & Laboratory Animals. 

Eurogroup for Wildlife & Laboratory Animals. 2006. Report on the implementation of the zoo 

Directive. Eurogroup for Wildilfe & Laboratory Animals. 

European Commission. 2015. “Better Regulation "Toolbox".” http://ec.europa.eu/smart-

regulation/guidelines/toc_tool_en.htm. 

European Commission. 1995. “Communication from the Commission to the Council and 
Proposal for a Council Recommendation relating to the keeping of wild animals in 
zoos COM (95) 619.” 

European Commission. 2015. EU Zoos Directive Good Practices Document. Luxembourg: 

European Commission. 

—. 2002. “Infringement fiche for France 2002/0225 (internal document).” 
European Commission. 2015. LIFE and new partnerships for nature conservation. 

Publications Office of the European Union. 

European Commission. 2011. LIFE preventing species extinction- Safeguarding endangered 

flora and fauna through ex-situ conservation. European Commission. 

European Council. 1992. “European Council in Edinburgh, Conclusions of the Presidency.” 
European Parliament. 2011. “(COM)2011) 244.” Our life insurance, our natural capital: an 

EU Biodiversity Strategy to 2020 ((COM)2011) 244). http://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX:52011DC0244. 

European Parliament. 2010. Reflection Paper on the concept of European Added Value. 

Brussels: European Parliament. 

European Parliament. 1993. Second report of the Committee on the Environment, Public 

Health and Consumer Protection on the Commission proposal for a Council Directive 
laying down minimum standards for the keeping of animals in zoos (COM(91)0177 
final-C3-0340/91). Strasbourg: European Parliament. 

Fa, J. E., M. Gusset, N Flesness, and D A Conde. 2014. “Zoos have to unveil theri full 

conservation potential.” Animal Conservation (The Zoological Society of London) 
(17): 97-100. 

Fa, J., S. Funk, and D O'Connell. 2011. Zoo Conservation Biology. Cambridge University 

Press. 
Fabregas et al. 2012. 
Fàbregas MC, Guillén-Salazar F, Garcés-Narro C. 2012. “Unraveling the complexity of the 

zoo community: identifying the variables related to conservation performance in 
zoological parks.” 

Fàbregas MC1, Guillén-Salazar F, Garcés-Narro C. n.d. “Unraveling the complexity of the 

zoo community: identifying the variables related to conservation performance in 
zoological parks.” 

Focus. 2011. Sofia Zoo gives shelter to 8 new penguins, attracting more visitors. 6 March. 

http://focus-fen.net/opinion/0000/00/00/2512/. 

Four Paws Bulgaria. 2016. Big cats in zoos: the issue in Eastern Europe. http://www.vier-

pfoten.bg/bulgaria/en/fourpawsgowild/fourpawsgowild-big-cats-in-zoos/big-cats-in-
zoos-the-issue-in-eastern-europe/. 

Milieu Ltd  
Brussels  

Evaluation Study to support the evaluation of the Zoos Directive 
Annexes to Final Report – August 2017/ 294 

 
 
 
Garric, Audrey. 2012. “Les zoos français protègent-ils assez les animaux ?” Le Monde, 5 

May. Accessed October 24, 2016. 
http://www.lemonde.fr/planete/article/2012/05/05/les-zoos-francais-protegent-ils-
assez-les-animaux_1693904_3244.html. 

General Directorate for Environmental Protection. 2016. List of zoological gardens. Accessed 
November 30, 2016. http://www.gdos.gov.pl/wykaz-ogrodow-zoologicznych-w-
polsce. 

Gertler, P.J., Martinez, S., Premand, P., Rawlings, L.B., Vermeersch, C.M. 2011. Impact 

Evaluation in Practice. The World Bank. 

Gusset, Mark, and G Dick. 2010. “Building a Future for Wildlife? Evaluating the contribution 

of tthe world zoo and aquarium community to in situ conservation.” Edited by The 
Zoological Society of London. International Zoo Yearbook (44): 183-191. 
Gusset, Markus, and Gerald Dick. 2011. “The global reach of zoos and aquariums in visitor 
numbers and conservation expenditures.” Zoo Biology (Wiley Periodicals) (30): 566-
569. 

Hoffman, M et al. 2010. “The Impact of Conservation on the Status of the World’s 

Vertebrates.” Science 330 (6010): 1503-1509. 

Hoffmann, M., C: Angulo, A HIlton-Taylor, S.H.M. Butchart, and et al. 2010. “The Impact of 

Conservation on the Status of the World’s Vertebrates.” Science 330 (6010): 1503-
1509. 

Huffington Post. 2015. Danish Zoos: Serial Animal Killers. 10 Oct. 

http://www.huffingtonpost.com/bernie-shine/danish-zoos-serial-
animal_b_8274944.html. 

Hutchins, Willis, and Wiese. 1995. “Strategic Collection Planning: Theroy and practice.” Zool 

Biology 14: 5-25. 

INSEE. 1999. Indice de chiffre d'affaires en valeur - Gestion des jardins botaniques et 

zoologiques et des réserves naturelles(NAF rév. 2, niv. classe poste 91.04) - Série 
CVS-CJO - Base 100 en 2010. Accessed October 24, 2016. 
http://www.bdm.insee.fr/bdm2/affichageSeries?periodeDebut=1&anneeDebut=1999&
periodeFin=12&anneeFin=1999&recherche=criteres&codeGroupe=1802&idbank=00
1777258. 

—. 2006. Indice de chiffre d'affaires en valeur - Gestion des jardins botaniques et 

zoologiques et des réserves naturelles(NAF rév. 2, niv. classe poste 91.04) - Série 
CVS-CJO - Base 100 en 2010. Accessed October 24, 2016. 
http://www.bdm.insee.fr/bdm2/affichageSeries?periodeDebut=1&anneeDebut=2006&
periodeFin=12&anneeFin=2006&recherche=criteres&codeGroupe=1802&idbank=00
1777258. 

—. 2015. Indice de chiffre d'affaires en valeur - Gestion des jardins botaniques et 

zoologiques et des réserves naturelles(NAF rév. 2, niv. classe poste 91.04) - Série 
CVS-CJO - Base 100 en 2010. Accessed October 24, 2016. 
http://www.bdm.insee.fr/bdm2/affichageSeries?periodeDebut=1&anneeDebut=2015&
periodeFin=12&anneeFin=2015&recherche=criteres&codeGroupe=1802&idbank=00
1777258. 

—. 2016. Population totale par sexe et âge au 1er janvier 2016, France. Accessed October 
24, 2016. http://www.insee.fr/fr/themes/detail.asp?reg_id=0&ref_id=bilan-
demo&page=donnees-detaillees/bilan-demo/pop_age2b.htm. 

ISAP. 2004. Online Database of Polish Legislation. 

file:///C:/Users/Gebruiker/Dropbox/162_DG%20ENV%20Zoos%20Directive/2Output
/22Activities/Country%20Data/PL/PL_Ordinance_zoos_20Dec2004_D20050032.pdf. 

IUCN. 2016. Species. Accessed 12 07, 2016. 

Milieu Ltd  
Brussels  

Evaluation Study to support the evaluation of the Zoos Directive 
Annexes to Final Report – August 2017/ 295 

 
 
 
IUCN/CBSG. 1993. The World Zoo Conservation Strategy: the Role of the Zoos and Aquaria 

of the World in Global Conservation. Chicago: Chicago Zoological Society. 
IUCN/SSC. 2014. Guidelines on the Use of Ex situ Management for Species Conservation. 

Version 2.0. . Gland, Switzerland.: IUCN Species Survival Commission. 

IUDZG/CBSG. 1993. The world zoo conservation strategy: the role oof zoos and aquaria of 

the world in global conservation. Brookfield, Illinois: Chicago Zoological Society. 

Ivy, J. A. 2016. “Ameliorating the loss of genetic diversity in captive wildlife populations. .” 

Anim Conserv, 19: 112–113. doi:10.1111/acv.12271. 

Jaworski, Véronique. 2012. “Espèces protégées.” Revue juridique de l’environnement 37 (4): 

730-731. 

Jensen, E. 2014. “Evaluating children's conservation biollogy learning at the zoo.” 

Conservation Biology 28: 1004-1011. 

John Reagan Associates Ltd. 2007. The EU and Europe's Zoos.  
Johnson, S. 2015. Stanley, I Resume: Further recollections of an exuberant life. The Robson 

Press. 

Jule, K.R., Leaver, L.A., Lea, E.G. 2008. “The effects of captive experience in reintroduction 

survival in carnivores: a review and analysis.” Biological Conservation 355-363. 

2016. JZAR. Accessed 11 28, 2016. http://www.jzar.org/index/about. 
Kear, J. 1990. “Man and Wildfowl.” Edited by Poyser. T. and A.D.  
Keulartz, Jozef. 2015. “Agricultural Environmental Ethics.” Agricultural Environmental 
Ethics (28): 335-351. http://link.springer.com/article/10.1007/s10806-015-9537-z. 

Koninklijke Maatschappij Dierkunde Antwerpen vzw. n.d. 2015 Jaarverslag & 

Duurzamheidsverslag. Antwerpen: Koninklijke Maatschappij Dierkunde Antwerpen 
vzw. 

Lacy, R. C., J. D. Ballou, and J. P. Pollak. 2012. “PMx: software package for demographic 

and genetic analysis and management of pedigreed populations.” Methods in Ecology 
and Evolution 3: 433–437. doi:10.1111/j.2041-210X.2011.00148.x. 

Lacy, R.C. 2013. “Achieving True Sustainability of Zoo Populations.” Zoo Biology 32: 19–

26. doi:10.1002/zoo.21029. 

Lees C & Wilcken, J. 2009. “Sustaining the Ark: the challenges faced by zoos in maintaining 

viable populations.” International Zoo Yearbook 43: 6–18. 
Les Zoos dans le Monde. 2016. Zoos. Accessed October 24, 2016. 

http://www.leszoosdanslemonde.com/cartographie.php. 

Let it grow. 2016. Let it grow campaign.  
Mace GM, Cramer W, Díaz S, Faith DP, Larigauderie A, Le Prestre P, Palmer M, Perrings C, 
Scholes RJ, Walpole M, Walther BA, Watson JEM, Mooney HA. 2010. “Biodiversity 
targets after 2010.” Current Opinion in Environmental Sustainability 2, 3–8. 
Mace, G. M., Collar, N. J., Gaston, K. J., Hilton-Taylor, C., Akçakaya, H. R., Leader-
Williams, N., Milner-Gulland, E.J. and Stuart, S. N. 2008. “Quantification of 
Extinction Risk: IUCN's System for Classifying Threatened Species.” Conservation 
Biology 22:1424–1442. doi:10.1111/j.1523-1739.2008.01044.x. 

Mace, G.M. and Lande, R. 1991. “Assessing extinction threats: toward a re-evaluation of 
IUCN threatened species categories.” Conservation Biology 5: 148-157. 

Mace, GM. 2014. “Whose conservation?” Science (345): 1558-1560. 
Marino, L, S Lilienfeld, R Malamud, N Nobis, and R Broglio. 2010. “Do zoos and aquariums 

promote attitude change in visitors? A critical evaluation of the American Zoo and 
Aquarium study.” Soc. Anim. (18): 126-138. 

Martin, T E, H Lurbiecki, JB Joy, and A O Mooers. 2014. “Mammal and bird species held in 
zoos are less endemic and less threatened than their close relatives not held in zoos.” 
Animal Conservation (17): 89-96. 

Milieu Ltd  
Brussels  

Evaluation Study to support the evaluation of the Zoos Directive 
Annexes to Final Report – August 2017/ 296 

 
 
 
Martina Chalupova, Jan Voracek, Frantisek Smrcka, Petra Kozakova. 2014. “Dynamic 

Modelling of ZOO Management: from Challenge to Opportunity.” ECMLG. Zagreb. 
https://www.researchgate.net/publication/273125985_Dynamic_Modelling_of_ZOO_
Management_from_Challenge_to_Opportunity. 

McGowan, P.J.K., K. Traylor-Holzer, and K. Leus. 2016. “IUCN Guidelines for Determining 
When and How Ex Situ Management Should Be Used in Species Conservation.” 
Conservation Letters. doi: 10.1111/conl.12285. 

Mihaylov, Radoslav. 2015. “Cases of animal escapes from zoos (Subject of area: Zoo 
animals).” International Journal in Physical & Applied Sciences 40-45. 
http://ijmr.net.in/download.php?filename=acMD1aTCEVZIAbu.pdf&new=IJPAS5Jun
e3124.pdf. 

Ministère de l'Environnement, de l'Energie et de la Mer. 2016. La faune sauvage captive. 31 

August. Accessed October 24, 2016. http://www.developpement-
durable.gouv.fr/Tout-savoir-sur-les-zoos.html. 

Moss, A, M Esson, and D Francis. 2010. “Evaluation of a 3rd generation zoo exhibit in 

relation to visitor behaviour and interpretation use.” Journal of Interpretation 
Research (15): 11-28. 

Moss, Andrew, Eric Jensen, and Markus Gusset. 2015. “Evaluating the contribution of zoos 

and aquariums to Aichi Biodiversity Target 1.” Conservation Biology (Society for 
Conservation Biology) 29 (2): 537-544. 

Moss, Andrew, Eric Jensen, and Markus Gusset. 2014. “Evaluating the contribution of zoos 

and aquariums to Aichi Biodiversity Target 1.” Conservation Biology (Society for 
Conservation Biology) 29 (2): 537-544. 

Moss, Andrew, Eric Jensen, and Markus Gusset. 2016. “Probing the Link between 

Biodiversity-Related Knowledge and Self-Reported Proconservation Behavior in a 
Global Survey of Zoo Visitors.” Conservation Letters.  

Nadace na ochranu zvířat . 2016. Nadace na ochranu zvířat. 

http://www.ochranazvirat.cz/czech/. 

New York Times. 2015. Zoo’s Public Dissection of Lion Makes Denmark Again a Target of 

Outrage. 15 October. http://www.nytimes.com/2015/10/16/world/europe/denmark-
lion-zoo-dissection.html?_r=1. 

Office of the Attorney General. 2016. S.I. No. 440/2003 - European Communities (Licensing 

and Inspection of Zoos) Regulations 2003. 29 September. 
http://www.irishstatutebook.ie/eli/2003/si/440/made/en/print#article1. 
Overheid.nl. 2015. Wet Dieren. http://wetten.overheid.nl/BWBR0030250/2015-02-01. 
Panteia Research voor beleid. 2008. Evaluatie van het diertentuinbesluit. 20 november. 

https://www.rijksoverheid.nl/binaries/rijksoverheid/documenten/rapporten/2009/04/01
/evaluatie-van-het-dierentuinenbesluit-eindrapport/20090401-dl-2009-3357-
bijlage1.pdf. 

Penning, M., G. McG. Reid, H. Koldewey, G. Dick, B. Andrews, K. Arai, P. Garratt, et al. 

2009. Turning the Tide: A Global Aquarium Strategy for Conservation. Bern: WAZA. 

Pritchard, Diana J, John E. Fa, Sara Oldfield, and Stuart R Harrop. 2011. “Bring the captive 
closer to the wild: redifning the role of ex-situ conservation.” (Fauna and Flora 
International) (Oryx 46(1) 18-23). 

Redford, K. H., D. B. Jensen, and J. J. Breheny. 2012. “Integrating the captive and the wild.” 

Science, November: 338: 1157-1158. 

Redford, K., and D. B. Jensen. 2012. “Integrating the captive and the wild.” Science, 

November. 

Rees, P.A. 2005. “The EC Zoos Directive: A Lost Opportunity to Implement the Convention 
on Biological Diversity.” Journal of International Wildlife Law & Policy 51-62. 

Milieu Ltd  
Brussels  

Evaluation Study to support the evaluation of the Zoos Directive 
Annexes to Final Report – August 2017/ 297 

 
 
 
Rees, Paul A. 2005. “Will the EC Zoos Directive increase the conservation value of zoo 

research?” Edited by FFI. Oryx (39(2)): 128-131. 

Rees, Paul A. 2005a. “The EC Directive: A lost opportunity to impement the Convention on 

Biological Diversity.” Journal of International Wildlife Law and Policy 8: 51-62. 

2015. “Régime fiscal d’un abri pour orangs-outans.” La Lettre de La Justice Administrative. 

no. 37. January. Accessed October 24, 2016. http://www.conseil-
etat.fr/content/download/38228/332174/version/3/file/LJA-37-web.pdf. 

Retsinformation DK. n.d. retsinformation. 

https://www.retsinformation.dk/Forms/R0710.aspx?id=175918. 

Rides. 2014. Dierentuinen nieuws. 8 januari. http://www.rides.nl/nieuws/3183/dierentuinen-

blikken-tevreden-terug.html. 

Secretariat of the CBD. 2010a. Global Biodiversity Outlook 3. . Secretariat of the Convention 

on Biological Diversity, Montréal, 94 pages. Available at 
https://www.cbd.int/gbo3/default.shtml. Downloaded on 28 October 2016. 
—. 2010b. COP 10 Decision X/2. . Secretariat of the Convention on Biological Diversity. 

Available at https://www.cbd.int/decision/cop/?id=12268. Downloaded on 28 October 
2016. 

—. 2014. Global Biodiversity Outlook. Secretariat of the Convention on Biological Diversity, 
Montréal, 155 pages. Available at https://www.cbd.int/gbo4/. Downloaded on 28 
October 2016. . 

Secretariat of the CBD. 2006. Global Biodiversity Outlook 2. Montreal, 81 + vii pages. 

Available at https://www.cbd.int/gbo2/default.shtml. Downloaded on 28 October 
2016.: Secretariat of the Convention on Biological Diversity,. 

Service public de Wallonie. n.d. Bien-être animal - Zoo. Accessed October 4, 2016. 

http://www.wallonie.be/fr/bien-etre-animal-zoo. 

Service Public Fédéral Belge. 2016. La sixième réforme de l’Etat. Accessed October 4, 2016. 
http://www.belgium.be/fr/la_belgique/connaitre_le_pays/histoire/la_belgique_a_partir
_de_1830/constitution_de_l_etat_federal/sixieme_reforme_etat. 

Snyder, N. F. R., Derrickson, S. R., Beissinger, S. R., Wiley, J. W., Smith, T.B. and Toone, 

W. D. and Miller. B. 1996. “Limitations of captive breeding in endangered species 
recovery.” Conservation Biology 10:338–348. 

Soulé, M., M. Gilpin, W. Conway, and T. Foose. 1986. “The millennium ark: how long a 
voyage, how many staterooms. how many passengers?” Zoo Biology 5: 101-113. 

Svoboda zvířat. 2016. Svoboda zvířat. http://www.svobodazvirat.cz/en-section/about-

freedom-for-animals.htm. 

Teresa Gardocka, Agnieszka Gruszczyńska, Robert Maślak, Agnieszka Sergiel. 2014. The 

Welfare of Animals in Zoos and EU Legal Standards. Warsaw: Eclipsa. 

Tittensor, DP et al. 2014. “ A mid-term analysis of progress toward international biodiversity 

targets. .” Science 346: 241-244. 

Traill LW, Bradshaw CJA, Brook BW. 2007. “Minimum viable population size: a meta-
analysis of 30 years of published estimates.” Biol Conserv 139:159–166. 

Traill LW, Brook BW, Frankham RR, Bradshaw CJA. 2010. “Pragmatic population viability 

targets in a rapidly changing world. .” Biol Conserv 143:28–34. 

Travers, W, and R Straton. 1988. European Survey of Zoological Collections. Zoo Check 

contract for EEC (contract 6681 (87) 07. 

Travis, W, and R Straton. 1988. European Survey of Zoological Collections. Zoo Check 

contract for EEC (contract 6681 (87) 07. 

Tribe, A., and R. Booth. 2003. “Assessing the role of zoos in wildlife conservation.” Human 

Dimensions of Wildlife (8): 65-74. 

Milieu Ltd  
Brussels  

Evaluation Study to support the evaluation of the Zoos Directive 
Annexes to Final Report – August 2017/ 298 

 
 
 
UN. 2015. “Transforming our world: the 2030 Agenda for Sustainable Development. 
Resolution adopted by the General Assembly on 25 September 2015 [without 
reference to a Main Committee (A/70/L.1)] 70/1. .” Available at 
http://www.un.org/ga/search/view_doc.asp?s. 

UN. 2000. “United Nations Millennium Declaration. Resolution adopted by the General 

Assembly [without reference to a Main Committee (A/55/L.2)] 55/2.” Available at 
http://www.un.org/millennium/declaration/ares552e.pdf. Downloaded on 28 October 
2016. 

Unie českých a slovenských zoologických zahrad z.s. 2016. UCSZOO - Unie českých a 

slovenských zoologických zahrad z.s. http://www.zoo.cz/kontakty. 
Verband der Zoologischen Gärten VdZ . 2016. Association of Zoological Gardens. 

http://www.zoodirektoren.de/index.php?option=com_k2&view=item&layout=item&i
d=4843&Itemid=547. 

VetEffecT. 2015. EU Zoos Directive Good Practices Document. European Commission. 
Veterinary Services Cyprus. n.d. Legislations. Accessed November 22, 2016. 

http://www.moa.gov.cy/moa/vs/vs.nsf/All/EDD9A9B60DF4C5C0422576CC0039778
5/$file/3%20the%20protection%20and%20welfare%20of%20animals%20law%20of
%201994.pdf. 

Vlaanderen is toerisme. n.d. Attractiebarometer 2011-2015. Brussel: 

TOERISMEVLAANDEREN. 

Walpole, M., Almond, R., Besancon, C. et al. 2009. “Tracking progress toward the 2010 

biodiversity target and beyond. .” Science 325, 1503–1504. 

Way 2 Lithuania. 2016. Way 2 Lithuania. http://www.way2lithuania.com/en/travel-

lithuania/kaunas-zoo. 

WAZA. 2005. “Building a Future for Wildlife - The World Zoo and Aquarium Conservation 

Strategy.” Accessed 07 28, 2015. 
http://www.waza.org/files/webcontent/1.public_site/5.conservation/conservation_strat
egies/building_a_future_for_wildlife/wzacs-en.pdf. 

Wheater, R J. 1995. “World Zoo Conservation Strategy: a blueprint for zoo development.” 

Biodiversity Conservation (4): 44-52. 

Williams, S.E. & Hoffman, E.A. 2009. “Minimizing genetic adaptation in captive breeding 

programs: a review. .” Biological Conservation 142: 2388-2400. 

Zoo Prague. 2016. Zoo Praha . https://www.zoopraha.cz/en. 
zoo-infos.de. 2016. Die Zoo-Datenbank für Deutschland. http://www.zoo-infos.de/index.html. 
Zoonaute. 2016. “Fréquentation des Structures Zoologiques et Aquariums en France de 2010 

à 2015.” Zoonaute. 18 February. Accessed October 24, 2016. 
http://www.zoonaute.net/dossier/chiffres2010-2015.pdf. 

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ANNEX IVA – REFERENCE DATABASE 

Information source 

Weblink 

Level of 
Source 

Type of 
source 

s
s
e
n
e
v
i
t

c
e

f
f
E

y
c
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e
c

i

i
f
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e
c
n
e
r
e
h
o
C

l

e
u
a
V
d
e
d
d
A
-
U
E

Summary 

Zoos Directive 1999/22/EC 

Council Directive 338/97 on 
protection of wild fauna and 
flora  

Council Directive 79/409/EEC on 
conservation of wild birds 

Milieu Ltd  
Brussels  

http://e
ur-
lex.euro
pa.eu/L
exUri-
Serv/Lex
Uri-
Serv.do
?uri=OJ:
L:1999:0
94:0024:
0026:EN
:PDF  
http://e
ur-
lex.euro
pa.eu/l
egal-
con-
tent/EN
/TXT/PD
F/?uri=
CELEX:3
1997R03
38&fro
m=EN 
http://e
ur-
lex.euro

EU 

EU 

Legally 
binding 
docu-
ment 

Legally 
binding 
docu-
ment 

Y 

Y 

Y 

Y 

Y 

Basis for the study 

Y 

Background information 

EU 

Legally 
binding 
docu-

Y 

Background information 

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pa.eu/l
egal-
con-
tent/EN
/TXT/PD
F/?uri=
CELEX:3
1979L04
09&fro
m=EN 
http://e
ur-
lex.euro
pa.eu/l
egal-
con-
tent/EN
/TXT/PD
F/?uri=
CELEX:3
1992L00
43&fro
m=en 
http://e
ur-
lex.euro
pa.eu/l
egal-
con-
tent/EN
/ALL/?u
ri=CELE
X%3A32
005R173
9 
http://e
ur-
lex.euro
pa.eu/l
egal-

EU 

EU 

EU 

ment 

Legally 
binding 
docu-
ment 

Legally 
binding 
docu-
ment 

Legally 
binding 
docu-
ment 

Council Directive 92/43/EEC on 
conservation of natural habitats 
and wild fauna and flora 

Commission Regulation (EC) No 
1739/2005 laying down animal 
health requirements for the 
movement of circus animals 
between Member States 

Council Directive 92/65/EEC on 
Health requirements for the im-
port and trade of animals in the 
EU 

Y 

Background information 

Y 

Background information 

Y 

Background information 

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Council Directive 90/425/EEC on 
Veterinary and zootechnical 
checks of animals and products 
of animal origin for intra-
Community trade 

Balmford, A., Leader-Williams, 
N., Mace, G., Manica, A., Walter, 
O., West, C., Zimmerman, A., 
2008, “Message received? 
Quantifying the impact of infor-
mal conservation education on 
adults visiting UK zoos” in Zoos in 
the 21st Century: catalysts for 
conservation?, Cambridge Uni-
versity Press, Cambridge. p 120–
136. 

Horsman, P.V., 1988, Captive 
Polar Bears in UK and Ireland. 

con-
tent/EN
/TXT/?ur
i=URISER
V%3Al1
2012  
http://e
ur-
lex.euro
pa.eu/l
egal-
con-
tent/EN
/TXT/?ur
i=uriserv
:l12050 
http://w
ww2.zo
o.cam.
ac.uk/
mani-
ca/ms/
2007_Zo
o_educ
ation_b
ook_ch
apt-
er.pdf  
http://w
ww.zoo
check.c
om/wp-
con-
tent/upl
oads/20
15/06/C
ap-
tive_Pol
ar_Bear
s_in_UK_

EU 

Legally 
binding 
docu-
ment 

Y 

Background information 

National 

Scientific 
literature 

Y 

Information on effectiveness of awareness raising action of 
zoos. 

National 

Scientific 
literature 

Y 

Information on the state of play regarding the keeping of polar 
bears in UK and IE zoos before the adoption of the Zoos Di-
rective. 

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Brussels  

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Born Free, 2001, UK Zoos: Fit for 
Life  

BornFree. 2006, Zoo Health: An 
adaptation of Spanish zoos fol-
lowing the implementation of 
Act 31/2003. 
BornFree, 2007, Animal Ark or 
Sinking Ship? An Evaluation of 
conservation by UK zoos. 

and_Irel
and__P
aul_V_H
ors-
man__1
988.pdf  
http://w
ww.bor
nfree.or
g.uk/file
ad-
min/use
r_uploa
d/files/z
oo_che
ck/publi
cati-
ons/UK_
Zoos_Fit
_For_Lif
e.pdf  

http://w
ww.bor
nfree.or
g.uk/file
ad-
min/use
r_uploa
d/files/z
oo_che
ck/publi
cati-
ons/Info
zoos_Re
port_-
_pilot_st

National  Reports 
and stu-
dies 

Y 

Information on the state of play regarding the keeping of wild 
animals in UK zoos before the adoption of the Zoos Directive. 

National  Reports 
and stu-
dies 

National  Reports 
and stu-
dies 

Y 

Y 

Y 

Y 

Information on the transposition measures adopted by Spain 
according to the Zoos Directive. Investigation pointed at the 
shortcomings of the Spanish transposition and ultimately con-
tributed to the launch of Case C-340/09. 
Information on the effects of action of UK zoos on wider con-
servation of biodiversity. 

Y 

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National  Reports 
and stu-
dies 

udy__E
N_versio
n.pdf  
http://w
ww.bor
nfree.or
g.uk/file
ad-
min/use
r_uploa
d/files/z
oo_che
ck/publi
cati-
ons/Ani
mal_Ark
_or_sinki
ng_ship.
pdf 
http://w
ww.bor
nfree.or
g.uk/file
ad-
min/use
r_uploa
d/files/z
oo_che
ck/publi
cati-
ons/Info
zoos_Re
port_-
_zoos_in
_the_C
an-
aries_-
_EN_ver
sion.pdf  
http://w National  Reports 

National  Reports 
and stu-
dies 

InfoZoos, 2008, Zoo Health – The 
legal status of zoos in the Canary 
Islands  in accordance to Span-
ish Law 31/2003. 

InfoZoos, 2009, Investigation into 
the conditions in zoos in the 
Spanish Region of Valencia. 

EAZA, TAG reports 2013-14 

Milieu Ltd  
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Y 

Y 

Y 

Information on the transposition measures adopted by Spain 
(Canary Islands) according to the Zoos Directive. 

Y 

Information on the c transposition measures adopted by Spain 
(Canary Islands) according to the Zoos Directive. 

Y 

Y 

Y 

Y 

Information on conservation research and training pro-

Evaluation Study to support the evaluation of the Zoos Directive 
Annexes to Final Report – August 2017/ 304 

 
 
 
 
 
 
 
 
 
 
and stu-
dies 

grammes, 

EU 

Reports 
and stu-
dies 

Y 

Y 

Example of (EU funded) conservation programmes 

European Commission, LIFE and 
new partnerships for nature con-
servation, 2015 

ww.bor
nfree.or
g.uk/file
ad-
min/use
r_uploa
d/files/z
oo_che
ck/publi
ca-
tions/Inf
ozoos_R
eport_-
_Valenc
ia_zoos_
re-
port_20
09__EN_
ver-
sion.pdf  
http://e
c.europ
a.eu/en
viron-
ment/lif
e/publi
cati-
ons/life
publi-
cati-
ons/flip
pingbo
ok/life-
new-
partner-
shipsfor
natu-
tu-
re/HTML
/files/as

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Brussels  

Evaluation Study to support the evaluation of the Zoos Directive 
Annexes to Final Report – August 2017/ 305 

 
 
 
 
 
 
Convention on Biological Diver-
sity 

Convention on International 
Trade in Endangered Species of 
Wild Fauna and Flora (CITES) 

European Commission, 2015, EU 
Zoos Directive Good Practices 
Document 

European Commission, 2011, LIFE 
preventing species extinction: 
Safeguarding endangered flora 
and fauna through ex-situ con-
servation 

sets/bas
ic-
html/pa
ge-
1.html# 
https://
www.c
bd.int/c
onven-
tion/tex
t/ 
https://
www.cit
es.org/e
ng/disc
/text.ph
p 
http://e
c.europ
a.eu/en
viron-
ment/n
ature/p
df/EU_Z
oos_Dir
ec-
tive_Go
od_Pra
ctices.p
df 
http://e
c.europ
a.eu/en
viron-
ment/lif
e/publi
cati-
ons/life
publi-
cati-

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tional 

Interna-
tional 

EU 

Legally 
binding 
docu-
ment 

Legally 
binding 
docu-
ment 

Reports 
and stu-
dies 

Y 

Y 

Y 

Y 

Y 

Y 

Y 

Information on the current state of knowledge on good prac-
tices by zoos – in particular with regard to the implementation 
of measures pursuant to Article 3 of the Zoos Directive. 

EU 

Reports 
and stu-
dies 

Y 

Y 

Y 

Information on LIFE ‘ex-situ’ projects and the benefits of ‘ex-
situ’ conservation on the protection of biodiversity. 

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ons/lifef
ocus/d
ocu-
ments/r
eintro-
duc-
tion.pdf  
https://
www.re
searchg
ate.net/
publica
ca-
tion/261
781154_
Zoos_an
d_Capti
ve_Bree
ding_Re
sponse 
https://
www.a
cade-
mia.ed
u/19526
482/Des
igning_t
he_Ark_
Set-
ting_Pri
ori-
ties_for_
Cap-
tive_Bre
eding 
http://w
ww.waz
a.org/fil
es/web
con-

Balmford, A., Kroshko, J., Leader-
Williams, N., Mason, G., 2011. 
Zoos and captive breeding. 
Science 332:1149–1150. 

Balmford, A., Mace, G.M. & 
Leader-Williams, N., 1996. “De-
signing the ark: setting priorities 
for captive breeding”, 
in Conserv. Biol., vol. 10, pp. 719–
727. 

Barongi, R., Fisken, F. A., Parker, 
M., & Gusset, M. (eds), 2015, 
Committing to Conservation: The 
World Zoo and Aquarium Con-
servation Strategy, Gland: WAZA 

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Brussels  

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literature 

Y 

Y 

Y  Criticism of the possible role of zoos in the setting and contribu-

tion to global targets to avoid species extinction. 

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tional 

Scientific 
literature 

Y 

Y 

Y 

Information on the importance of prioritization of ex situ con-
servation measures in order to optimize the role of zoos in pre-
venting species extinction.  

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tional 

Scientific 
literature 

Y 

Information on the objectives of WAZA. 

Evaluation Study to support the evaluation of the Zoos Directive 
Annexes to Final Report – August 2017/ 307 

 
 
 
 
 
 
 
 
 
 
 
Executive Office, Switzerland.  

BBC, 1994, State of the Ark – 
Perspectives on the Role of Zoos. 

tent/1.p
ub-
lic_site/
5.conse
rva-
tion/co
nserva-
tion_stra
te-
gies/co
mmit-
ting_to_
conser-
va-
tion/WA
ZA%20C
onserva
va-
tion%20
Strate-
gy%202
015_Por
trait.pdf  
- 

Interna-
tional 

Scientific 
literature 

BornFree & WSPA, 1994,  The Zoo 
Inquiry. 

- 

Interna-
tional 

Scientific 
literature 

Y 

Y 

Y 

Y 

Y 

Interna-
tional 

Scientific 
literature 

Y 

Y 

Y 

Y 

BornFree. 2012, The EU Zoo In-
quiry 2011.  An implementation 
and enforcement of EC Directive 
1999/22, relating to the keeping 
of animals in zoos. Report fin-
dings and recommendations, 
Born Free Foundation, UK.  

http://e
ndcap.
eu/wp-
con-
tent/upl
oads/20
13/02/E
U-Zoo-
Inquiry-
Report-
Fin-

Information on the state of play regarding the quality of ani-
mal accommodations in zoos prior to the adoption of the Zoos 
Directive. 
Information on the state of play regarding the quality of ani-
mal accommodations in zoos prior to the adoption of the Zoos 
Directive. 
Frequency, practice and costs of zoos licensing and inspection 
and information (costs/benefits; contributions) on a) conserva-
tion research and training, b) public education and aware-
ness; c) accommodating animals under satisfactory condi-
tions; d) preventing escape and ecological threats and e) 
record keeping 

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Brussels  

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Interna-
tional 

Scientific 
literature 

Y 

Y 

Information on the existing gaps in the knowledge and training 
of MSCAs. 

Interna-
tional 

Scientific 
literature 

Y 

Y 

Y 

Role of zoos in the setting and contribution to global targets to 
avoid species extinction. 

BornFree, 2016, Identifying the 
Training Needs of Member State 
Competent Authorities. Survey to 
assess implementation of legis-
lation and need for training: wild 
animals kept in captivity, Born 
Free Foundation, UK. 
Bowkett A.E., 2009, “Recent 
Captive-Breeding Proposals and 
the Return of the Ark Concept to 
Global Species Conservation”, in 
Conservation Biology, vol.23, 
no.3, pp. 773-776. 

dings-
and-
Recom-
com-
menda-
tions.pd
f 
http://w
ww.bor
nfree.or
g.uk/eu
trade/p
ublica-
tion/ 
http://o
nlineli-
brary.wil
ey.com
/doi/10.
1111/j.1
523-
1739.20
08.0115
7.x/epd
f?r3_ref
erer=wo
l&tracki
ng_acti
on=pre
view_cli
ck&sho
w_chec
kout=1&
pur-
chase_r
efer-
rer=ww
w.googl
e.be&p
ur-

Milieu Ltd  
Brussels  

Evaluation Study to support the evaluation of the Zoos Directive 
Annexes to Final Report – August 2017/ 309 

 
 
 
 
 
 
 
 
chase_s
ite_licen
se=LICE
NSE_DE
NIED 
http://o
nlineli-
brary.wil
ey.com
/doi/10.
1111/ac
v.12116
/pdf 
https://
www.a
cadem-
ia.edu/
600576/
An_Eme
rging_R
ole_of_Z
oos_to_
Con-
serve_Bi
odiversi-
ty 
http://jo
ur-
nals.plo
s.org/pl
osone/
arti-
cle?id=
10.1371
/journal.
pone.00
80311  
http://o
nlineli-
brary.wil

Bowkett, A.E., 2014, “Ex situ con-
servation planning is more com-
plicated than prioritizing the 
keeping of threatened species in 
zoos”, in Animal Conservation, 
vol.17, no.2, pp.101-103.  

Conde, DA., Flesness, N., Col-
chero, F., Jones, OR., & Scheuer-
lein, A., 2011, “An emerging role 
of zoos to conserve biodiversity”’ 
in Science, vol.331, pp 1390–
1391. 

Conde, D.A., Colchero, F., Gus-
set, M., Pearce-Kelly, P., Byers, 
O., Flesness, N., Browne, R.K. & 
Jones, O.R., 2013, “Zoos through 
the lens of the IUCN Red List: a 
global metapopulation ap-
proach to support conservation 
breeding programs”, PLoS ONE. 

Dawson, J., Patel, F.,Griffiths, R.A. 
& Young, R.P., 2016, “Assessing 
the global zoo response to the 

Milieu Ltd  
Brussels  

Interna-
tional 

Scientific 
literature 

Y 

Information on whether threatened species held in zoos reflect 
the conservation impact.  

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tional 

Scientific 
literature 

Y 

Y 

Y 

Role of zoos in the setting and contribution to global targets to 
avoid species extinction. 

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tional 

Scientific 
literature 

Y 

Y 

Y 

Role of zoos in the setting and contribution to global targets to 
avoid species extinction. 

Interna-
tional 

Scientific 
literature 

Y 

Y 

Information on trends in global zoo amphibian holdings across 
species, zoo region, and species geographical region of origin 
from 1994 to 2014. 

Evaluation Study to support the evaluation of the Zoos Directive 
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Interna-
tional 

Scientific 
literature 

Y 

Y 

Information on the actions of EAZA zoos for 2013-2014. 

Interna-
tional 

Scientific 
literature 

Y 

Y 

Y 

Y 

Report on the implementation of the Zoos Directive. 

amphibian crisis through 20-year 
trends in captive collections”, in 
Conservation Biology, vol.30, 
no.1, pp. 82 -91. 

EAZA, 2015. Annual Report 2013-
2014. 

Eurogroup for Animals, 2006, 
Report on the implementation of 
the Zoos Directive 

ey.com
/doi/10.
1111/co
bi.12563
/abstra
ct 
http://w
ww.eaz
a.net/a
ssets/Up
loads/A
nnual-
re-
port/EA
ZA-
Annual-
Report-
2013-
14.pdf  
file:///C
:/Users/
afa/Do
wnload
s/Repor
t%20on
%20the
%20impl
ementa
ta-
tion%20
of%20th
e%20EU
%20zoo
%20dire
ctive%2
0(Eurogr
oup%20
-
%20EWL
A%2020

Milieu Ltd  
Brussels  

Evaluation Study to support the evaluation of the Zoos Directive 
Annexes to Final Report – August 2017/ 311 

 
 
 
 
 
 
 
Fa, J.E., Gusset, M., Flesness, N., 
& Conde, D.A., 2014, “Zoos have 
yet to unveil their full conserva-
tion potential”, in Animal Con-
servation, vol.17, no.2, pp.97–
100. 

Falk, J.H., Reinhard, E,, Vernon, 
C., Bronnenkant, K., Deans, N., 
Heimlich, J., 2007, Why zoos and 
aquariums matter: Assessing the 
impact of a visit, Association of 
Zoos and Aquariums, Silver 
Spring, MD.  

Gross, M., 2015, "Can zoos offer 
more than entertainment?" in 
Current Biology, 25, R391-R408, 
18 May 2015 

06).pdf  
http://o
nlineli-
brary.wil
ey.com
/doi/10.
1111/ac
v.12115
/full 
https://
www.re
searchg
ate.net/
publi-
cati-
on/2530
04933_
Why_Zo
os_Aqu
ari-
ums_M
at-
ter_Asse
ssing_th
e_Impa
ct_of_a
_Visit_to
_a_Zoo_
or_Aqu
arium 
http://w
ww.scie
ncedi-
rect.co
m/scien
ce/artic
le/pii/S0
9609822
1500538
2 

Interna-
tional 

Scientific 
literature 

Y 

Information on the potentially conflicting objectives of meet-
ing zoo visitors expectations and committing resources to bio-
diversity conservation. 

Interna-
tional 

Scientific 
literature 

Y 

Y 

Y 

Information on the benefits induced for visitors from a visit to 
the zoos. 

Interna-
tional 

Media 

Y 

Y 

Y 

Article questioning whether zoos and aquariums can adapt to 
a new role focused on conservation and education rather 
than just entertainment. 

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Brussels  

Evaluation Study to support the evaluation of the Zoos Directive 
Annexes to Final Report – August 2017/ 312 

 
 
 
 
 
 
 
 
 
 
 
http://w
ww.ncb
i.nlm.nih
.gov/pu
bmed/?
term=Th
e+glob
al+reac
h+of+zo
os+and
+aquari
ums+in+
visi-
tor+nu
mbers+
and+co
nserva-
tion+ex
pendi-
tures  
http://c
za.nic.in
/Gusset
%20et%
20al%20
2014.pd
f 
http://s
cience.
science
ence-
mag.or
g/conte
nt/330/
6010/15
03.full.p
df+html 
http://o
nlineli-
brary.wil

Gusset, M. & Dick, G., 2011, “The 
global reach of zoos and aquar-
iums in visitor numbers and con-
servation expenditures”, in Zoo 
Biol., vol.30, no.5, pp. 566–569. 

Gusset, M., Fa, J.E., Sutherland, 
W.J., & the Horizon Scanners for 
Zoos and Aquariums, 2014, “A 
horizon scan for species conser-
vation by zoos and aquariums.” 
in Zoo Biol, vol.33, no.5, pp. 375-
80.  
Hoffmann et al, 2010, “The Im-
pact of Conservation on the 
Status of the World’s Verte-
brates”, in Science, vol.330, 
no.6010, pp.1503-9. 

Hutchins, M., & Smith, B., 2003, 
“Characteristics of a world-class 
zoo or aquarium in the 21st cen-

Milieu Ltd  
Brussels  

Interna-
tional 

Scientific 
literature 

Y 

Y 

Y 

Y 

Information on worldwide zoo visitor numbers and conserva-
tion expenditure.  

Interna-
tional 

Scientific 
literature 

Y 

Y 

Horizon scan for zoos and aquariums to identify the 10 most 
important emerging issues for species conservation 

Interna-
tional 

Scientific 
literature 

Y 

Y 

Assessment of the status of the world’s vertebrates using data 
for 25,780 species categorized on the International Union for 
Conservation of Nature (IUCN) Red List. 

Interna-
tional 

Scientific 
literature 

Y 

Information on the ideal role and actions of zoos and aquari-
ums to optimize their impacts on biodiversity conservation. 

Evaluation Study to support the evaluation of the Zoos Directive 
Annexes to Final Report – August 2017/ 313 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
tury,” in International Zoo Year-
book, vol.38, pp.130-141. 

IUCN/SSC, 2014, Guidelines on 
the Use of Ex Situ Management 
for Species Conservation. Ver-
sion 2.0, IUCN Species Survival 
Commission, Switzerland.  

IUDZG/CBSG (IUCN/SSC), 1993, 
Executive Summary, The World 
Zoo Conservation Strategy; The 
Role of the Zoos and Aquaria of 
the World in Global Conserva-
tion, Chicago Zoological Socie-
ty, Illinois, U.S.A.  

ey.com
/doi/10.
1111/j.1
748-
1090.20
03.tb02
073.x/e
pdf 
http://w
ww.eaz
a.net/a
ssets/Up
loads/P
osition-
state-
ments/I
UCN-
Guide-
lines-on-
the-Use-
of-ex-
situ-
mana-
ge-
ment-
for-
species.
pdf 
https://
por-
tals.iucn
.org/libr
ary/sites
/library/
files/do
cu-
ments/1
993-
033_Ex_
Sum.pdf  

Interna-
tional 

Scientific 
literature 

Y 

Information on the good practices to optimise the use of “cap-
tive/ex situ” and “wild/in situ” measures as part of a coherent 
species conservation programme. 

Interna-
tional 

Scientific 
literature 

Y 

Y 

First World Zoo Conservation Strategy. 

Milieu Ltd  
Brussels  

Evaluation Study to support the evaluation of the Zoos Directive 
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Interna-
tional 
Interna-
tional 

Scientific 
literature 
Scientific 
literature 

Y 

Y 

Y 

Information on the key objectives of zoos and the prioritization 
between conservation, research, education and recreation. 
Information on the challenges faced by zoos in the setting and 
contributing to global targets to avoid species extinction. 

Y 

Interna-
tional 

Scientific 
literature 

Y 

Y 

Information on the challenges faced by zoos in managing 
breeding programmes in a scientific manner. 

Kear, J., 1990), Man and Wild-
fowl, T & A.D, Poyser, London. 
Lacy, R.C., 2013, “Achieving true 
sustainability of zoo popula-
tions”, in Zoo Biology vol.32, 
no.1, pp. 19–26. 

Lees, C.M., & Wilcken, J., 2009, 
“Sustaining the Ark: the chal-
lenges faced by zoos in main-
taining viable populations”, In-
ternational Zoo Yearbook, 
vol.43, pp. 6–18. 

- 

https://
www.re
searchg
ate.net/
publi-
cati-
on/2281
04856_A
chiev-
ing_True
_Sustain
abil-
ity_of_Z
oo_Pop
ulations 
http://o
nlineli-
brary.wil
ey.com
/doi/10.
1111/j.1
748-
1090.20
08.0006
6.x/epd
f?r3_ref
erer=wo
l&tracki
ng_acti
on=pre
view_cli
ck&sho
w_chec
kout=1&
pur-
chase_r
efer-
rer=ww

Milieu Ltd  
Brussels  

Evaluation Study to support the evaluation of the Zoos Directive 
Annexes to Final Report – August 2017/ 315 

 
 
 
 
 
 
 
 
 
 
 
 
w.googl
e.be&p
ur-
chase_s
ite_licen
se=LICE
NSE_DE
NIEDhtt
p://onli
neli-
brary.wil
ey.com
/doi/10.
1111/j.1
748-
1090.20
08.0006
6.x/epd
f?r3_ref
erer=wo
l&tracki
ng_acti
on=pre
view_cli
ck&sho
w_chec
kout=1&
pur-
chase_r
efer-
rer=ww
w.googl
e.be&p
ur-
chase_s
ite_licen
se=LICE
NSE_DE
NIED 
http://o

Martin, T.E., Lurbiecki, H., Joy, 

Milieu Ltd  
Brussels  

Interna-

Scientific 

Y 

Information on species held in zoos compared to those not 

Evaluation Study to support the evaluation of the Zoos Directive 
Annexes to Final Report – August 2017/ 316 

 
 
 
 
 
 
 
tional 

literature 

currently in captivity.  

Interna-
tional 

Scientific 
literature 

Y 

Y 

Y 

Information on zoo’s effectiveness in endangered species 
restoration, public education, and policy and operations. 

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tional 

Scientific 
literature 

Y 

Information on the good practices to optimise the use of “cap-
tive/ex situ” and “wild/in situ” measures as part of a coherent 
species conservation programme. 

Interna-
tional 

Scientific 
literature 

Y 

Y 

Y 

Large-scale impact evaluation survey to evaluate biodiversity 
literacy of zoo and aquarium visitors worldwide.  

J.B., & Mooers, A.O., 2014, 
“Mammal and bird species held 
in zoos are less endemic and 
less threatened than their close 
relatives not held in zoos”, Anim. 
Conserv., vol.17, no.2, pp. 89–96 

Mazur, N.A., & Clark, T.W., 2001, 
“Zoos and conservation: policy 
making and organizational chal-
lenges”, in Bulletin Series Yale 
School of Forestry and Environ-
mental Studies, vol.105, pp.185–
201. 

McGowan, P.J.K, Holzer-Taylor, 
K., & Leus, K., (in press), “IUCN 
guidelines for determining when 
and how ex situ management 
should be used in species con-
servation”, in Conservation Let-
ters.  

Moss, A., Jensen, E. & Gusset, M., 
2015, “Evaluating the contribu-
tion of zoos and aquariums to 
Aichi Biodiversity Target 1”, in 
Conserv Biol., vol.29, no.2, 
pp.537-44. 

nlineli-
bra-
ry.wiley.
com/do
i/10.111
1/acv.1
2069/ab
stract 
http://e
nviron-
ment.ya
le.edu/
publi-
cation-
se-
ries/doc
uments/
down-
loads/0-
9/105m
azur.pdf  
http://o
nlineli-
brary.wil
ey.com
/doi/10.
1111/co
nl.12285
/epdf 
http://w
ww.ncb
i.nlm.nih
.gov/pu
bmed/?
term=e
valuat-
ing+the
+contri
bu-
tion+of+

Milieu Ltd  
Brussels  

Evaluation Study to support the evaluation of the Zoos Directive 
Annexes to Final Report – August 2017/ 317 

 
 
 
 
 
 
 
 
 
 
 
Interna-
tional 

Reports 
and stu-
dies 

Y 

Information on the role of aquaria in the conservation of biodi-
versity 

Interna-
tional 

Reports 
and stud-
ies 

Y 

Information on the increasingly narrower distinction between 
“wild”, “captive”, “in situ” and “ex situ”. 

Penning, M., Reid, G. McG., Kol-
dewey, H., Dick, G., Andrews, B., 
Arai, K., Garratt, P., Gendron, S., 
Lange, J., Tanner, K., Tonge, S., 
Van den Sande, P., Warmolts, D. 
and Gibson, C. (Eds), 2009, Turn-
ing the Tide: A Global Aquarium 
Strategy for Conservation and 
Sustainability. World Association 
of Zoos and Aquariums, Bern, 
Switzerland.  

Pritchard, D.J., Fa, J.E., Oldfield, 
S. & Harrop, S.H., 2012, “Bring the 
captive closer to the wild: rede-
fining the role of ex situ conser-
vation”, in Oryx, vol.46, no.1, 
pp.18–23. 

zoos+an
d+aqua
riums+t
o+Aichi  
http://w
ww.waz
a.org/fil
es/web
con-
tent/1.p
ublic_sit
e/5.con
serva-
tion/co
nserva-
tion_stra
tegies/t
ur-
ning_th
e_tide/
Aqua-
rium%20
strate-
gy%20E
N.pdf  
http://jo
ur-
nals.ca
mbridg
e.org/a
ction/di
splayAb
Ab-
stract?fr
om-
Page=o
nline&ai
d=8499
086&fileI
d=S0030

Milieu Ltd  
Brussels  

Evaluation Study to support the evaluation of the Zoos Directive 
Annexes to Final Report – August 2017/ 318 

 
 
 
 
 
 
 
 
 
 
 
Interna-
tional 

Interna-
tional 

Reports 
and stu-
dies 

Reports 
and stu-
dies 

Y 

Information on the increasingly thinner distinction between 
“wild”, “captive”, “in situ” and “ex situ”. 

Y 

Y 

Y 

Y 

Information on the possibilities left to zoos by the Directive to 
avoid compliance with its core obligations. 

Interna-
tional 

Reports 
and stu-
dies 

Y 

Y 

Information on the difficulties faced by zoos on ensuring a 
significant role of zoos in species recovery. 

Redford, K.H., Jensen, D.B., Bre-
heny, J.J., 2012, “Integrating the 
captive and the wild”, in Sci-
ence, vol.338, pp.1157–1158. 
Rees, P.A., 2007, “The EC Zoos 
Directive: A Lost Opportunity to 
Implement the Convention on 
Biological Diversity”, in Interna-
tional Wildlife Law & Policy, vol. 
8, no.1, pp. 51-62. 

Snyder, N.F.R., Derrickson, S.R., 
Beissinger, S.R., Wiley, J.W., 
Smith, T.B., Toone, W.D., & Miller, 
B., 1996, “Limitations of Captive 
Breeding in Endangered Species 
Recovery”, in Society for Con-
servation Biology, vol.10, no.2, 
p.338–348. 

6053100
01766  

https://
www.re
searchg
ate.net/
publi-
cati-
on/2338
06251_I
ntegrat-
ing_the
_Captiv
e_and_t
he_Wild 
http://o
pensam
sam-
ple.info/
the-ec-
zoos-
di-
rective-
a-lost-
oppor-
tunity-
to-
imple-
ment-
the-
con-
vention-
on-
biologi-
cal-
diversity 

Milieu Ltd  
Brussels  

Evaluation Study to support the evaluation of the Zoos Directive 
Annexes to Final Report – August 2017/ 319 

 
 
 
 
 
 
 
 
 
 
 
 
Interna-
tional 

Reports 
and stu-
dies 

Y 

First study to propose the concept of zoo as an “ark of biodi-
versity” hence shifting the role of zoos from recreation to con-
servation. 

Interna-
tional 

Reports 
and stud-
ies 

Y 

Y 

Information on the quality of information provided to visitors at 
the zoos and its limited awareness raising and educational 
value. 

Soulé, M., Gilpin, M., Conway, 
W., & Foose, T., 1986, “The mil-
lennium ark: how long a voyage, 
how many staterooms. how 
many passengers?” in Zoo Biol-
ogy, vol.5, pp. 101–113. 

Therkelsen, A., & Lottrup, M., 
2015, “Being together at the zoo: 
zoo experiences among families 
with children”, in Leisure Studies, 
vol.34, no.3, pp. 354–37.  

https://
www.jst
or.org/st
able/23
86850?s
eq=1#p
age_sc
an_tab_
con-
tents  
http://o
nlineli-
brary.wil
ey.com
/doi/10.
1002/zo
o.14300
50205/e
pdf?r3_r
efer-
er=wol&
track-
ing_acti
on=pre
view_cli
ck&sho
w_chec
kout=1&
pur-
chase_r
efer-
rer=ww
w.googl
e.be&p
ur-
chase_s
ite_licen
se=LICE
NSE_DE
NIED 

Milieu Ltd  
Brussels  

Evaluation Study to support the evaluation of the Zoos Directive 
Annexes to Final Report – August 2017/ 320 

 
 
 
 
 
 
 
 
 
 
Interna-
tional 

Reports 
and stu-
dies 

Y 

Information on the state of play regarding the quality of ani-
mal accommodations in zoos prior to the adoption of the Zoos 
Directive. 

Interna-
tional 

Reports 
and stu-
dies 

Interna-
tional 

Reports 
and stu-
dies 

Y 

Y 

Information on the benefits induced for visitors from visiting 
zoos. 

Y 

Y 

Information on the role of zoos on wider wildlife conservation 
objectives. 

Interna-
tional 

Y 

Reports 
and stud-
ies 

Y 

Zoo Conservation Strategy 

Travers, W., & Straton, R., 1988,  
European Survey of Zoological 
Collections. 

Tribe, A., 2004, “Zoo tourism” in 
Wildlife Tourism impacts, man-
agement and planning, Ed. Hig-
ginbottom, K., Common Ground 
Publishing, pp. 35-56. 
Tribe, A., & Booth, R., 2006, “As-
sessing the role of zoos in wildlife 
conservation” in Human Dimen-
sions of Wildlife, vol.8, no.1, 
pp.65-74. 

WAZA, 2005, Building a Future for 
Wildlife - The World Zoo and 
Aquarium Conservation Strate-
gy, WAZA, Bern, Switzerland.  

http://id
rottsforu
m.org/l
eisure-
studies-
volume-
34-issue-
3-june-
2015/ 
- 

http://s
ustain.p
ata.org
/wp-
con-
tent/upl
oads/20
14/12/
Wildlife-
Tourism-
im-
pacts.p
df 
http://w
ww.tan
dfonline
.com/d
oi/abs/
10.1080
/108712
0039018
0163?jo
ur-
nalCod
e=uhdw
20 

Milieu Ltd  
Brussels  

Evaluation Study to support the evaluation of the Zoos Directive 
Annexes to Final Report – August 2017/ 321 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Interna-
tional 

Reports 
and stu-
dies 

Y 

Information on various conceptual approaches to integrated 
species conservation and several case studies of integrated 
species conservation - arguing that the ex situ and in situ con-
servation dichotomy is at an end.  

Interna-
tional 

Reports 
and stu-
dies 

Y 

Y 

Information on the role of zoos on wider wildlife conservation 
objectives. 

WAZA Magazine, 2013, Towards 
Integrated Species Conserva-
tion, WAZA, Gland, Switzerland, 
vol.13. 

West, C, Dickie L.A., 2007, “Is 
there a conservation role for 
zoos in a natural world under 
fire?”, in Zoos of the 21st century: 
catalysts for conservation? 
Cambridge University Press, 
Cambridge.  

http://w
ww.waz
a.org/fil
es/web
con-
tent/1.p
ub-
lic_site/
5.conse
rva-
tion/co
nserva-
tion_stra
te-
gies/bui
lding_a
_future_
for_wildl
ife/wza
cs-
en.pdf 
on 28 
July 
2015  
http://w
ww.waz
a.org/fil
es/web
con-
tent/1.p
ublic_sit
e/5.con
serva-
tion/int
egrated
_specie
s_conse
rva-
tion/WA
ZA%20M

Milieu Ltd  
Brussels  

Evaluation Study to support the evaluation of the Zoos Directive 
Annexes to Final Report – August 2017/ 322 

 
 
 
 
 
 
 
 
 
 
Wheater R.J., 1995, “World Zoo 
Conservation Strategy: a blue-
print for zoo development”, in 
Biodiver. Conserv., Vol.4, 
pp.544–52. 
Zoo Check Charitable Trust (now 
BornFree), 1993, Zoochotic Re-
port. 
Case C-302/03 (Commission v. 
Italy), 07/08/2004 

Case C-339/03 (Commission v. 
Germany), 20/09/2003 

Case C-340/09 (Commission v. 
Spain), 19/02/2011 

aga-
zine%20
14.pdf  

Book 

http://c
uria.eur
opa.eu/
ju-
ris/liste.js
f?langu
age=en
&num=
C-
302/03 
http://c
uria.eur
opa.eu/
ju-
ris/liste.js
f?langu
age=en
&num=
C-
339/03  
http://c
uria.eur
opa.eu/
ju-
ris/liste.js
f?langu
age=fr&
num=C-
340/09 

Interna-
tional 

Reports 
and stu-
dies 

Y 

Y 

Information on the role of zoos on wider wildlife conservation 
objectives. 

Interna-
tional 

EU 

Y 

Y 

Reports 
and stu-
dies 
Legally 
binding 
docu-
ment 

Y 

Information on the state of play before the adoption of the 
Zoos Directive. 

Y 

Y 

Judgment 

EU 

EU 

Legally 
binding 
docu-
ment 

Legally 
binding 
docu-
ment 

Y 

Y 

Y 

Judgment 

Y 

Y 

Y 

Judgment 

Milieu Ltd  
Brussels  

Evaluation Study to support the evaluation of the Zoos Directive 
Annexes to Final Report – August 2017/ 323 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
WAZA Magazine, 2011, Towards 
Sustainable Population Mana-
gement, (Vol. 12) 

 John Regan Associates, 2007, 
The EU and Europe’s Zoos 

EAZA, 2016, EAZA Conservation 
Database Snapshot – September 
2016 

http://w
ww.waz
a.org/fil
es/web
con-
tent/1.p
ublic_sit
e/6.mar
ke-
ting_an
d_medi
a/publi
ca-
tions/W
AZA%20
Maga-
zine12.p
df 
http://w
ww.john
rega-
nasso-
ciates.c
om/wp-
con-
tent/upl
oads/20
13/08/t
he_eu_
and_eu
ropes_z
oos.pdf  
http://w
ww.eaz
a.net/a
ssets/Up
loads/C
CC/Dat
abase-
Snap-

Interna-
tional 

Reports 
and stu-
dies 

Y 

Y 

Particularly, pag 26: Zoos Can Lead the Way with Ex Situ Con-
servation. The chapter investigates the role of zoos in protect-
ing threatened species. Data on share of threatened species 
in European zoos are reported (however, data is too aggre-
gated to be significant/useful). 

EU 

Reports 
and stu-
dies 

Y 

Y 

Y  An investigation into the synergy between the policies and 

philosophy of the European Union, and the practice and po-
tential of Europe’s progressive zoos, aquaria and allied institu-
tions.  

EU 

Y 

Reports 
and stu-
dies 

Examples of projects from the EAZA Conservation Database. 

Milieu Ltd  
Brussels  

Evaluation Study to support the evaluation of the Zoos Directive 
Annexes to Final Report – August 2017/ 324 

 
 
 
 
 
 
 
 
 
 
 
 
shot-
Ar-
chive-
new.pd
f 
http://w
ww.eaz
a.net/a
ssets/Up
loads/C
CC/Oct
ober-
2016-
Data-
base-
Snap-
shot-
Ar-
chive-
new.pd
f 
https://
ec.euro
pa.eu/f
ood/site
s/food/f
iles/ani
mals/do
cs/aw_
arch_p
p_eu_as
s_zoo_a
quar-
ia_en.p
df 
http://w
ww.eup
aw.eu/
docs/Fi
nal%20R

EAZA, 2016, EAZA Conservation 
Database Snapshot – October 
2016 

EAZA, 2011, EAZA Response to 
the Evaluation Report of the EU 
Policy on Animal Welfare 

GHK in association with ADAS 
UK, on behalf of DG SANCO, 
2010, Evaluation of the EU Policy 
on Animal Welfare and Possible 
Policy Options for the Future 

Milieu Ltd  
Brussels  

EU 

Y 

Reports 
and stu-
dies 

Examples of projects from the EAZA Conservation Database. 

EU 

Y 

Reports 
and stu-
dies 

Information on EAZA zoos including, for example, budget spent 
for research. 

EU 

Reports 
and stu-
dies 

Y 

Y 

Assessment of animal welfare EU legislation, including review of 
the measures for animal welfare in the Directive 1999/22/EC. 
Estimates on the number of wild animals kept in zoos in select-
ed EU MS. 

Evaluation Study to support the evaluation of the Zoos Directive 
Annexes to Final Report – August 2017/ 325 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
eport%2
0-
%20EUP
AW%20
Evalua-
tion.pdf  
https://
www.nc
bi.nlm.ni
h.gov/p
ub-
med/26
219401  
https://
www.nc
bi.nlm.ni
h.gov/p
ub-
med/25
736919  
http://li
nk.sprin
ger.co
m/articl
e/10.10
07/s105
31-012-
0256-8 
http://li
nk.sprin
ger.co
m/articl
e/10.10
07/s108
06-015-
9537-z 
book 

Dawson, J., Patel, F., Griffiths, 
R.A., Young, R.P., "Assessing the 
global zoo response to the am-
phibian crisis through 20-year 
trends in captive collections, in 
Conservation Biology 2016 (30)1, 
82-91 
Alroy J., "Limits to captive breed-
ing of mammals in zoos", in Con-
servation Biology, 2015 (29) 3, 
9526-31 

Gippoliti, S., "Ex-situ conserva-
tion programmes in European 
zoological gardens: can we 
afford to lose them" in Biodiversi-
ty Conservation", 2012 (21), 
1359-1364 

Keularts, J., "Captivity for Con-
servation? Zoos at a Crossroads", 
Agric Environ Ethics, 2015 (28), 
335-351 

Price, M.R., Fa,  J.E., "Reintroduc-
tions from zoos: a conservation 
guiding light or a shooting star?" 
in Catalysts for conservation: a 

Milieu Ltd  
Brussels  

Interna-
tional 

Scientific 
literature 

Y 

Y 

Contribution of captive breeding of amphibians to address 
decline of wild populations 

Interna-
tional 

Scientific 
literature 

Y 

Y 

Captive breeding of endangered mammals in zoos is im-
portant, yet ensuring meaningful contribution of ex-situ conser-
vation requries concerted effort 

EU 

Scientific 
literature 

Y  Highlights the conservation breeding potential of zoological 

gardens and aquaria in the European union, but it also recog-
nises the lack of a convincing scientific and legal framework 
that encourages ex situ activities for ‘exotic’ species. 

Interna-
tional 

Scientific 
literature 

Y 

Y 

Y 

Examines the changes in zoo's core tasks from "noah's ark" to 
integrated approach of biodiversity conservatino 

Interna-
tional 

Scientific 
literature 

Y 

Y 

Y 

Examines the potential and real contributions of zoos in biodi-
versity conservation through programmes of reintroduction of 
species in the wild 

Evaluation Study to support the evaluation of the Zoos Directive 
Annexes to Final Report – August 2017/ 326 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
direction for zoos in the 21st 
Century, London, United-
Kingdom, 2007, 155-177 
Marino, L., Lilienfeld, S.O., Mal-
amud, R., Nobis, N., Broglio, R., 
"Do zoos and aquariums pro-
mote attitude change in visitors? 
A critical evaluation of the 
American and aquarium study", 
in Society and Animals 2010 (18) 
2, 126-138 

Mennen, F., Beumer, C., Martens, 
P., "The Sustainable Zoo: Mediat-
ing the sustainability message 
through education in Gaia Zoo 
Kerkrade", ICIS Maastricht 
Univerisyt, 2016 

Luebke, J.F., Matiasek, J., "An 
exploratory study of zoo visitors' 
exhibit experiences and reac-
tions" in Zoo Biology, 2013 (32)4, 
407-16 

Moss, A., Jensen, E., Gusset, M., 

Milieu Ltd  
Brussels  

http://b
ooksan
djour-
nals.brill
online.c
om/con
tent/jou
rnals/10.
1163/15
6853010
x491980  
http://w
ww.icis.
unimaa
s.info/w
p-
con-
tent/upl
oads/20
10/06/M
ennen-
Beumer
-
Mar-
tens-
2015-
RE-
PORT.p
df 
https://
www.nc
bi.nlm.ni
h.gov/p
ub-
med/23
740472  
http://o

National 

Scientific 
literature 

Y 

Analysis the impacts of zoos and aquariums on visitors' behav-
iours and attitudes towards biodiversity conservation in the 
USA. 

EU 

Y 

Reports 
and stu-
dies 

Analysis the impacts of zoos and aquariums on visitors' educa-
tion on biodiversity (conservation) 

EU 

Scientific 
literature 

Y 

Y 

Analysis the impacts of zoos and aquariums on visitors' behav-
iours and attitudes towards biodiversity conservation 

Interna-

Scientific 

Y 

Y 

Study highlighting that the knowledge gained by zoo visitors 

Evaluation Study to support the evaluation of the Zoos Directive 
Annexes to Final Report – August 2017/ 327 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
nlineli-
brary.wil
ey.com
/doi/10.
1111/co
nl.12233
/pdf 
http://w
ww.waz
a.org/fil
es/web
con-
tent/1.p
ub-
lic_site/
5.conse
rva-
tion/un_
dec-
ade_bi
odiversi-
ty/WAZ
A%20Vis
itor%20S
ur-
vey%20
Re-
port.pdf  
http://o
pen-
sample.i
nfo/zoo
s-and-
aqua-
riums-
of-the-
world 
http://r
edlist-
arc.org/

"Probing the link between biodi-
versity-related knowledge and 
self-reported proconservation 
behavior in a Global Survey of 
Zoo Visitors", in Conservation 
Letter, 2016 

Moss, A., Jensen, E., Gusset, M., 
A Global Evaluation of Biodiver-
sity Literacy in Zoo and Aquari-
um Visitors, 2014 

Zoos and Aquariums of the 
World, Int. Zoo Yb, 2015 (49), 
226-386 

Browne, R.K, Wolfram, K., Garcia, 
G., Bagaturov, M.F., Pereboom, 
J.J.M., "Zoo-based amphibian 

Milieu Ltd  
Brussels  

tional 

literature 

during their visists has little impact on specific proenvironment 
behaviour they could take, let alone whether behaviour 
changes would actually take place. 

Interna-
tional 

Reports 
and stu-
dies 

Y 

Y 

Evaluation of zoo visitors knowledge of biodiversity 

Interna-
tional 

Scientific 
literature 

Y 

Y 

List of zoos 

Interna-
tional 

Scientific 
literature 

Y 

Y 

Good practices of research and conservation breeding pro-
grams on amphibians 

Evaluation Study to support the evaluation of the Zoos Directive 
Annexes to Final Report – August 2017/ 328 

 
 
 
 
 
 
 
 
 
 
 
 
research and conservation 
breeding programs" in Am-
phi.Reptile Conervsation, 2011 
(5) 3, 1-14 

Conway, W.G., "Buying time for 
wold animals with zoos", in Zoo 
Biol. 2011 (3), 1-8 

Zimmerman, A., "The role of zoos 
in contributing to in situ conser-
vation" in Kleiman, D.G., Thomp-
son, K.V., and Baer, C.K., Wild 
mammals in captivity - Principle 
& Techniques for Zoo Manage-
ment, 2010 (2nd ed.) 
Kierulff, M.C.M, Ruiz-Miranda, 
C.R., de Oliveira, P. P., Beck, B.B., 
Martins, A., Dietz, J.M., Rambaldi, 
D.M., Baker, A.J., "The Golden 
lion tamarin Leontopithecus 
rosalia: a conservation success 
story" in Int. Zoo Ub, 2012 (46), 
36-45 

Koldewey, H., Cliffe, A., Zim-
merman, B., "Breeding pro-
gramme priorities and man-
agement techniques for native 
and exotic freshwater fishes in 
Europe" in Int. Zoo Yb, 2013 (47), 
93-101 

Article-
PDFs/AR
C_5(3)_
01-
14_e28_
high_res
.pdf  
https://
www.nc
bi.nlm.ni
h.gov/p
ub-
med/20
938970  
Book 

http://o
nlineli-
bra-
ry.wiley.
com/do
i/10.111
1/j.1748-
1090.20
12.0017
0.x/abst
ract 
http://o
nlineli-
bra-
ry.wiley.
com/do
i/10.111
1/j.1748-
1090.20

Interna-
tional 

Scientific 
literature 

Y 

Y 

Importance of ex-situ conservation and criteria for prioritising 
species and programmes 

Interna-
tional 

Scientific 
literature 

Y 

Y 

On the role of zoos in contributing to in situ conservation 

Interna-
tional 

Scientific 
literature 

Y 

Y 

Example of successes of conservation programmes 

EU 

Scientific 
literature 

Y 

Y 

Example of successes of conservation programmes 

Milieu Ltd  
Brussels  

Evaluation Study to support the evaluation of the Zoos Directive 
Annexes to Final Report – August 2017/ 329 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Owen, A., Wilkinson, R., Sözer, R., 
"In situ conservation breeding 
and the role of zoological institu-
tions and private breeders in the 
recovery of highly endangered 
Indonesia passerine birds" in Int. 
Zoo Yb, 2014(48), 199-211 

Ziegler, T., "In situ and ex situ 
reptile projects of the Cologne 
Zoo: implications for research 
and conservation of South East 
Asia's herpetodiversity" in Int. 
Zoo Yb., 2015 (49), 8-21 

BE (Belgium)  
Law of 14 August 1986 on the 
protection and the well-being of 
animals (Loi du 14 aout 1986 
relative à la protection et au 
bien-être des animaux), 
14.08.1986, 01.01.1988, M.B. 
03.12.1986. 
Royal Order of 10 August 1998 
on the recognition of zoos (10 
Août 1998 - Arrêté royal relative 
à l’agrément des parc zo-
ologiques / 10 augustus 1998. – 
Koninklijk besluit betreffende de 
erkenning van dierentuinen), 
10.08.1998, 01.01.1999– 01 Janu-
ary 1999,  M.B. 13.11.1998. 
Ministerial Order of 3 May 1999 
on setting minimum criteria for 

Milieu Ltd  
Brussels  

Interna-
tional 

Scientific 
literature 

Y 

Y 

Example of successes of conservation programmes 

Interna-
tional 

Scientific 
literature 

Y 

Y 

Example of successes of conservation programmes 

12.0019
4.x/abst
ract 
http://o
nlineli-
bra-
ry.wiley.
com/do
i/10.111
1/izy.12
052/abs
tract 
http://o
nlineli-
bra-
ry.wiley.
com/do
i/10.111
1/izy.12
084/abs
tract 

Law 

National 

Regula-
tion 

National 

Legally 
binding 
docu-
ment 

Legally 
binding 
docu-
ment 

Y 

Y 

Y  National legislation on the well-being of animals. It mentions, 
among others, that the zoo keeper must do whatever it takes 
to ensure the animals’ well-being during performances and 
the zoo keeper must take all necessary measures to satisfy the 
animals’ needs. 

Y 

Y 

Y  National legislation on requirements to obtain recognition li-

cense for running a zoo. 

Regula-
tion 

National 

Legally 
binding 

Y 

Y 

Y  National legislation on requirements for keeping mammals in 

zoos. 

Evaluation Study to support the evaluation of the Zoos Directive 
Annexes to Final Report – August 2017/ 330 

 
 
 
 
 
 
 
 
 
  
  
  
  
  
  
  
  
  
 
 
 
 
 
 
keeping mammals in zoos 
(Arrêté ministériel fixant des 
norms minimales pour la deten-
tion de mammifères dans les 
parcs zoologiques /Ministerieel 
besluit tot vaststelling van mini-
mumnormen voor het houden 
van zoogdieren in dierentuinen), 
3.05.1999– - 19.08.1999, M.B. 
19.08.1999. 
Ministerial Order of 7 June 2000 
on setting minimum criteria for 
keeping birds in zoos (Arrêté 
ministériel fixant des norms min-
imals pour la detention des 
oiseaux dans les parcs zo-
ologiques / Ministerieel besluit 
tot vaststelling van mini-
mumnormen voor het ouden 
van vogels in dierentuinen), 
7.06.2000 – 5.09.2000, 5.09.2000. 
Ministerial Order of 23 June 2004 
on setting minimum criteria for 
keeping reptiles in zoos (23 Juin 
2004 – Arrêté ministériel fixant les 
norms minimales pour la deten-
tion des reptiles dans les parcs 
zoologiques / Miniosterieel 
besluit tot vaststelling vna mini-
mumnormen voor het houden 
van reptielen in dierentuinen), 
23.06.2004, 1.02.2005, 27.07.2004. 
Raad voor Dierenwelzijn, Werk-
groep: dolfijnen, Advies van de 
Raad voor Dierenwelzijn 
(10/12/2013). Betreffende het 
huisvesten van dolfijnen, Federal 
Public Service Public Health 
(Raad voor Dierenwelzijn. Werk-
groep: dolfijnen, 2013). 

Milieu Ltd  
Brussels  

docu-
ment 

Regula-
tion 

National 

Legally 
binding 
docu-
ment 

Y 

Y 

Y  National legislation on requirements for keeping birds in zoos. 

Regula-
tion 

National 

Legally 
binding 
docu-
ment 

Y 

Y 

Y  National legislation on requirements for keeping reptiles in 

zoos. 

National  Reports 
and stu-
dies 

Y 

Y  A working group of the federal government assessed the con-
cerns of keeping captivated dolphins and the need to renew 
legislation accordingly. No measure was taken by the gov-
ernment on the basis of that report. 

https://
www.ln
e.be/th
emas/di
eren-
welzijn/
advies-
dolfij-

Evaluation Study to support the evaluation of the Zoos Directive 
Annexes to Final Report – August 2017/ 331 

 
 
 
 
 
 
 
 
 
 
nen-
dolfina-
ria-
2013-
raad-
voor-
dieren-
welzijn.
pdf 
http://w
ww.bor
nfree.or
g.uk/upl
oads/m
edia/BE
LGIUM_
Zoo_Re
port_En
glish.pdf 

Born Free Foundation, The EU Zoo 
Inquiry 2011, An evaluation of 
the implementation and en-
forcement of the EC Directive 
1999/22, relating to the keeping 
of wild animlas in zoos, Belgium 

National  Reports 
and stu-
dies 

Y 

Y 

Investigation of the enforcement of Directive 1999/22/EC and 
the transposing Belgian laws in Belgian Zoos. Six zoos were 
assessed for conformity with the Directive and national trans-
posing legislation. The conclusions are as follows: 1) Belgian 
law has transposed Directive 1999/22/EC, although some gaps 
have been identified (such as the lack of reference to the 
conservation of biodiversity, details on zoo inspections and 
relocation of animals in case a zoos closes).  2) The Directive 
and the transposing legislation are ineffectively enforced. This 
could be due to the lack of expertise of the zoo inspectors and 
the fact that the zoo inspectors only react to complaints rather 
than proactive enforcing the legal requirements. 3) Some of 
the sample zoos encouraged contact between the public 
and the animals, even though this is prohibited by Belgian law. 
4) All investigated zoos do seem to have ‘conservation’ as a 
priority, as the animals they predominantly hold are not listed 
as ‘(European) threatened species’. Nor do the zoos cooper-
ate in breeding programmes. 5) The zoos tend to have limited 
educational value, as can be seen by the lack of information 
on the species exhibited and their natural habitats. 6) The living 
conditions for animals are unsustainable, since some enclo-
sures were too small for the animals’ spatial needs and birds of 
prey species were tethered by the leg. Furthermore, the enclo-
sures lack environmental enrichment. 

Born Free Foundation, The EU Zoo 
Inquiry 2011, An evaluation of 
the implementation and en-
forcement of EC Directive 
1999/22, relating to the keeping 
of animals in zoos. Report fin-
dings and recommendations 

http://e
ndcap.
eu/wp-
con-
tent/upl
oads/20
13/02/E

National  Reports 
and stu-
dies 

Y 

Y  Comparative analysis of the compliance of EU Member States 

with Directive 1999/22/EC (zoo and dolphinaria). 

Milieu Ltd  
Brussels  

Evaluation Study to support the evaluation of the Zoos Directive 
Annexes to Final Report – August 2017/ 332 

 
 
 
 
 
 
 
 
 
U-Zoo-
Inquiry-
Report-
Fin-
dings-
and-
Recom-
com-
menda-
tions.pd
f 
http://e
ndcap.
eu/wp-
con-
tent/upl
oads/20
15/08/D
olphinar
phinar-
ia_Repo
rt_en_fin
al.pdf  
http://w
ww.stan
daard.b
e/cnt/d
mf20150
417_016
34510  
http://w
ww.de
mor-
gen.be/
weten-
schap/
gezon-
de-
surplus-
giraf-

Whale and Dolphin Conserva-
tion, EU Zoo Inquiry, Dolphinaria, 
A review of the keeping of 
whales and dolphins in captivity 
in the European Union and EC 
Directive 1999/22, relating to the 
keeping of wild animals in zoos 

Planckendael slacht bedreigde 
antilope als voedsel voor roof-
dieren, De Standaard (17 April 
2015) 

and Gezonde surplusgiraf aan 
leeuw voederen? Nee: Zoo Ant-
werpen en Planckendael voeren 
"no kill-beleid" in, De Morgen (8 
April 2016) 

National  Reports 
and stu-
dies 

Y 

Y  Compliance of EU Member States with Directive 1999/22/EC 

regarding dolphinaria. 

National  Media 

Y 

National  Media 

Y 

Y 

Y 

Press reports that the zoo of Planckendael had a kill policy for 
redundant animals. Now ZOO Antwerpen and Plankendael 
have a ‘no kill-policy’. 

Press reports that the zoo of Planckendael had a kill policy for 
redundant animals. Now ZOO Antwerpen and Plankendael 
have a ‘no kill-policy’. 

Milieu Ltd  
Brussels  

Evaluation Study to support the evaluation of the Zoos Directive 
Annexes to Final Report – August 2017/ 333 

 
 
 
 
 
 
 
 
 
 
 
 
aan-
leeuw-
voede-
ren-
nee-
zoo-
antwer-
wer-
pen-en-
planc-
ken-
dael-
voeren-
no-kill-
beleid-
in-
b245ed
0f/ 
http://w
ww.zoo
antwer-
wer-
pen.be/
nl/nieu
ws/het-
beheer-
van-
dieren-
popula-
ties-zoo-
antwer-
wer-
pen-en-
planc-
kendael  
http://w
ww.gai
a.be/en
/news/f
ollow-

Het beheer van dierenpopulaties 
in ZOO Antwerpen en Plancken-
dael, Press release website ZOO 
Antwerpen (11 April 2016) 

Following constructive dialogue 
with GAIA, the Antwerp Zoo and 
Planckendael opt for the ethical 
management of “sur-
plus”animals, Press release GAIA 

Milieu Ltd  
Brussels  

National  Media 

Y 

Y 

Press reports that the zoo of Planckendael had a kill policy for 
redundant animals. Now ZOO Antwerpen and Plankendael 
have a ‘no kill-policy’. 

National  Media 

Y 

Y 

Press release from GAIA on the ‘no kill-policy’and a short de-
scription of the steps to be taken when dealing with a surplus 
animal. 

Evaluation Study to support the evaluation of the Zoos Directive 
Annexes to Final Report – August 2017/ 334 

 
 
 
 
 
 
 
 
 
(14 April 2016). 

Pouillard, V., 2008, Les zoos et la 
conservation des espèces – Le 
cas du zoo d’Anvers 

ing-
con-
struc-
tive-
dia-
logue-
gaia-
ant-
werp-
zoo-
and-
plancke
ndael-
opt-
ethical-
man-
age-
ment 
http://
mem-
en-
vi.ulb.a
c.be/M
emoires
_en_pdf
/MFE_07
_08/MFE
_Pouillar
d_07_08
.pdf  

National 

Scientific 
literature 

Y 

Y 

Study (final year dissertation) on the link between zoos and 
biodiversity conservation, looking in particular at the situation 
of the Zoo of Antwerpen (BE). 

BG (Bulgaria) 
Biodiversity Act (SG 
77/09.08.2002 Amended) 

Law 

National 

Regulation No.6 (SG 105 / 
2.12.2003, amended SG 44 
/12.07.2009) 

Regula-
tion 

National 

Y 

Y 

Y 

Y 

Legally 
binding 
docu-
ment 

Legally 
binding 
docu-
ment 

Adoption in national legislations of provisions on a) conserva-
tion research and training, b) public education and aware-
ness; c) accommodating animals under satisfactory condi-
tions; d) preventing escape and ecological threats and e) 
record keeping 
Regulation describing the minimum requirements and condi-
tions for keeping animals in zoos 

Milieu Ltd  
Brussels  

Evaluation Study to support the evaluation of the Zoos Directive 
Annexes to Final Report – August 2017/ 335 

 
 
 
 
 
 
  
  
  
  
  
  
  
  
  
 
 
 
 
 
 
Regulation No.1 (SG 
43/26.05.2006) 

Regula-
tion 

National 

National 

Legally 
binding 
docu-
ment 
Scientific 
literature 

Y 

Y 

Regulation issuing conditions for zoo licensing 

Y 

Y 

Scientific article which describes research conducted within 
the territory of the zoo in the city of Stara Zagora from 20 May 
2005 to 20 February 2015. In the spring of 2005, a wolf Gergana 
escaped from its cage. 

Mihaylov et. al. 2015 Cases of 
animal escapes from zoos. Inter-
national Journal in Physical & 
Applied Sciences  6: 40-45 

BornFree, 2011, The EU Zoo in-
quiry, Bulgaria  

Bornfree, 2012, Limitations in 
animal welfare Delivery PROB-
LEMS IN THE BULGARIAN ZOOS 

http://ij
mr.net.i
n/downl
oad.ph
p?filena
me=ac
MD1aT
CEVZIA
bu.pdf&
new=IJP
AS5Jun
e3124.p
df 
http://w
ww.bor
nfree.or
g.uk/zo
ore-
ports/b
ulgar-
ia/page
s/BFF_EZ
R_BULG
ARIA_FI
NAL__S_
.pdf  
http://w
ww.bor
nfree.or
g.uk/zo
ore-
ports/b
ulgar-
ia/page
s/BFF_EZ
R_BULG

National  Reports 
and stu-
dies 

Y 

Y  NGO report evaluating the implementation and enforcement 

of the Zoos Directive in 10 zoos in Bulgaria. A total of ten zoos 
were selected. This included: eight of the 16 municipally-
owned zoos, issued with a Conditional Licence; one dolphinar-
ium and an unlicensed small animal collection in a restaurant. 
It describes deficiencies in prevention of escape, conservation 
activites, education and research and animal welfare issues 

National  Reports 
and stu-
dies 

Y 

Y 

Information on the state of zoos in Bulgaria in 2012: 19 zoos in 
Bulgaria – 3 closed, 16 licensed under conditions; All zoos are 
owned and managed by the Municipal authorities; Facilities 
are too old and conditions are not up to the standards. The 
enclosures are not suitable for the biology and the ethology of 
the spices. Most of the habitats are not meeting the require-
ments of the Ordinances. 

Milieu Ltd  
Brussels  

Evaluation Study to support the evaluation of the Zoos Directive 
Annexes to Final Report – August 2017/ 336 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
CY (Cyprus) 
Regulation 81/2002: the Animal 
Protection and Welfare Act 
(Keeping of Wild Animals in 
Zoos) (Οι περί Προστασίας και 
Ευημερίας των Ζώων (Διατήρηση 
Άγριων Ζώων σε Ζωολογικούς 
Κήπους) Kανονισμοί του 2002) 
The EU Zoo Inquiry 2011: Country 
Report Cyprus  

ARIA_FI
NAL__S_
.pdf  

Regula-
tion 

http://w
ww.bor
nfree.or
g.uk/zo
ore-
ports/ire
land/ 

Data-
base 

Data-
base 

EU 

EU 

Infringement case 2004/2164 
(Commission v. Cyprus), 
12/07/2004 
Infringement case 2009/2285 
(Commission v. Cyprus), 
23/09/2009 
CZ (Czech Republic) 
Zákon č. 162/2003 Sb., o pod-
mínkách provozování zoo-
logických zahrad a o změně 
některých zákonů (zákon o zoo-
logických zahradách), (Act on 
Zoological Gardens) No. 
162/2003  

National 

Legally 
binding 
docu-
ment 

Y 

Y 

Adoption in national legislations of provisions on a) conserva-
tion research and training, b) public education and aware-
ness; c) accommodating animals under satisfactory condi-
tions; d) preventing escape and ecological threats and e) 
record keeping 

National  Reports 
and stu-
dies 

Y 

Y 

Findings from zoo visits and country visits on licensing, legal 
follow-up and housing conditions of the animals . Cypriot zoos 
were assessed to evaluate the effectiveness and level of im-
plementation and enforcement of the Zoos Directive 
1999/22/EC Information was collected about a number of key 
aspects of each zoo’s operation including: participation in 
conservation activities; public education; enclosure quality; 
public safety; and the welfare of the animals. These parame-
ters were evaluated against the legal requirements of Di-
rective 1999/22/EC and the Cypriot Animal Protection and 
Welfare (Keeping Wild Animals in Zoos) Regulation 81/2002. 
Infringement against Cyprus regarding the illegal functioning 
of the Limassol Zoo (bad application of the Zoos Directive) 

Case law 

Y 

Y 

Y 

Case law 

Y 

Y 

Y 

Infringement against Cyprus regarding the illegal functioning 
of the Limassol Zoo (bad application of the Zoos Directive) 

National 

Legally 
binding 
docu-
ment 

Y 

Y 

Y  Adoption in national legislations of provisions on a) conserva-

tion research and training, b) public education and aware-
ness; c) accommodating animals under satisfactory condi-
tions; d) preventing escape and ecological threats and e) 
record keeping 

http://w
ww.mzp
.cz/ww
w/platn
alegisla-
tiva.nsf/
5F0999A
1F25C7
4E7C12
56E7600
3E400F/

Milieu Ltd  
Brussels  

Evaluation Study to support the evaluation of the Zoos Directive 
Annexes to Final Report – August 2017/ 337 

 
 
 
  
  
  
  
  
  
  
  
  
 
 
 
 
 
 
 
 
 
 
  
  
  
  
  
  
  
  
  
 
 
UCSZOO, Annual Report 2015 

Martina Chalupova. 2014. Dy-
namic Modelling of ZOO Man-
agement: from Challenge to 
Opportunity. ECMLG Zagreb 

Eurogroup for Animals, 2006, 
Report on the implementation of 
the EU zoo Directive  

$file/Z%
20162_2
003.pdf  
http://w
ww.zoo.
cz/medi
a/files/v
yrocni-
zprava-
ucszoo-
za-r.-
2015.pd
f 
https://
www.re
searchg
ate.net/
publica
ca-
tion/273
125985_
Dyna-
mic_Mo
del-
ling_of_
ZOO_M
anage-
ge-
ment_fr
om_Ch
al-
lenge_t
o_Opp
ortunity 
https://
www.rs
pca.org
.uk/Ima
geLoca
ca-

National  Reports 
and stu-
dies 

Y 

Y 

Y 

Annual report containing collection updated, member infor-
mation, economic data, visitor numbers, and activities  

National 

Scientific 
literature 

Y 

Y 

Y 

Article focusing on managerial aspects of zoological gardens 
(ZOOs), using the data from ZOO Jihlava, middle sized ZOO in 
terms of the Czech ZOO market. ZOOs in the Czech Republic 
have undergone considerable quantitative and qualitative 
changes in the last two decades. Still, their management is 
frequently far from optimal, which may result in weak strate-
gies, undeveloped standardized processes or ambiguous per-
formance indicators. 

EU 

Reports 
and stu-
dies 

Y 

Y 

Report containing information on the implementation of the 
Zoos Directive in several European countries including Czech 
Republic. It refers to legislation, competent authorities, zoos 
and licenses, and use of guidelines. 

Milieu Ltd  
Brussels  

Evaluation Study to support the evaluation of the Zoos Directive 
Annexes to Final Report – August 2017/ 338 

 
 
 
 
 
 
 
 
 
 
tor/Loc
ateAs-
As-
set?ass
et=doc
ument&
as-
setId=12
3271139
9501&m
ode=pr
d 

https://
www.g
esetze-
im-
inter-
net.de/
bnatsch
g_2009/
BJNR25
4210009
.html  
https://
www.g
esetze-
im-
inter-
net.de/
bnatsch
g_2009/
BJNR25
4210009
.html  
http://w
ww.bor
nfree.or
g.uk/zo
ore-

DE (Germany) 
Federal Nature Conservation Act 
(BNatSchG)  

Animal Protection Act 
(18/05/2006) (BGBl. I S. 1206, 
1313), amended by Act of 9 
December 2010 (BGBl. I S. 1206, 
1313) (‘TierSchG’) 

The EU Zoo Inquiry – Country 
Report Germany 

National 

Legally 
binding 
docu-
ment 

Y 

Y 

Adoption in national legislations of provisions on a) conserva-
tion research and training, b) public education and aware-
ness; c) accommodating animals under satisfactory condi-
tions; d) preventing escape and ecological threats and e) 
record keeping 

National 

Legally 
binding 
docu-
ment 

Y 

Y 

Act containing provisions on animal welfare  

National  Reports 
and stu-
dies 

Y 

Y 

Study assessing 25 zoos selected from the 600 zoological col-
lections thought to exist in Germany. Information was collect-
ed about a number of key aspects of each zoo´s engagement 
including: participation in conservation activity, public educa-
tion, public safety, enclosure quality and the welfare of the 

Milieu Ltd  
Brussels  

Evaluation Study to support the evaluation of the Zoos Directive 
Annexes to Final Report – August 2017/ 339 

 
 
 
  
  
  
  
  
  
  
  
  
 
 
 
 
 
 
 
 
 
ports/G
er-
many-
En/ 
http://w
ww.bm
el.de/D
E/Tier/Ti
erschutz
/Tiersch
utzgu-
tach-
ten/_tex
te/Guta
chten-
Dos-
sier.html 

http://w
ww.bm
el.de/D
E/Tier/Ti
erschutz
/Tiersch
utzgu-
tach-
ten/_tex
te/Haltu
ngSaeu
ge-
tiere.ht
ml  
http://w
ww.deu
tsche-
tier-

Guidelines published by the 
Federal Ministry of Food, Agricul-
ture and Consumer Protection 
(BMELV). Tierschutz 

Guidelines published by the 
Federal Ministry of Food, Agricul-
ture and Consumer Protection 
(BMELV). Haus -und Zootiere.  

BEMMANN, I. et al. (2002): Re-
cherchen zum Wiederansied-
lungsvorhaben des Steinkauzes 
(Athene noctua SCOPOLI 1769) 

Milieu Ltd  
Brussels  

National  Policy 
docu-
ment 

Y 

Y 

National  Policy 
docu-
ment 

Y 

Y 

animals. These parameters were compared with the legal 
requirements of the European Directive 1999/22/EC, the Ger-
man Federal Nature Conservation Act and the German Pro-
tection of Animals Act.  
Horses: “Leitlinien zur Beurteilung von Pferdehaltungen unter 
Tierschutzgesichtspunkten” (09/06/2009). Game animals in 
enclosures: “Leitlinien für eine tierschutzgerechte Haltung von 
Wild in Gehegen” (26/10/2005). Freshwater fish: “Gutachten 
über die Anforderungen an die Haltung von Zierfischen, die 
mindestens eingehalten werden sollen” (30/12/1998). Reptiles: 
“Gutachten der Sachverständigengruppe über die Mindestan-
forderungen an die Haltung von Reptilien” (10/01/1997). Ostri-
ches (accept kiwis): “Gutachten über Mindestanforderungen 
an die Haltung von -Straußenvögeln, außer  Kiwis" (10/09/1996). 
Small birds: “Gutachten der Sachverständigengruppe über die 
tierschutzgerechte Haltung von Vögeln” (10/07/1996). Mam-
mals: “Gutachten über die Mindestanforderungen an die Hal-
tung von Säugetieren” (10/06/1996). Birds of prey and owls: 
“Gutachten über die tierschutzgerechte Haltung von Greifvö-
geln und Eulen” (10/01/1995). Parrots: “Gutachten der Sach-
verständigengruppe über die Mindestanforderungen an die 
Haltung vonPapageien” (10/01/1995). 
Gutachten über die Mindestanforderungen an die Haltung 
von Säugetieren 

National 

Scientific 
literature 

Y 

Y 

Resettlement project for german screech owl supported by 
DTG members Animal Park Olderdissen Bielefeld, Tierpark Bis-
chofswerda, Tiergarten Eisenberg, Tiergarten Halberstadt, Tier-
park Hirschfeld, Opel Zoo Kronberg, Tierpark Petersberg, Tier-

Evaluation Study to support the evaluation of the Zoos Directive 
Annexes to Final Report – August 2017/ 340 

 
 
 
 
 
 
 
 
 
 
 
 
im nordöstlichen Harzvorland, 
Landkreis Quedlinburg.  

ECJ, Commission v. Germany, 
Judgment of the Court (Fourth 
Chamber) on Case C-339-03, 
14.10.2004. 

parkge-
sell-
schaft.d
e/down
loads/c
atego-
ry/43-
stein-
kauz?d
own-
load=13
7:recher
chen-
zum-
wieder-
ansied-
lungs-
vorha-
ben-
stein-
kauz-
2002  
http://c
uria.eur
opa.eu/
ju-
ris/docu
ment/d
ocu-
ment.jsf;
jses-
sionid=9
ea7d2d
c30d5f9
28b5e4f
b504415
b8a886
7d61724
817.e34
Kax-

park Riesa, Tierpark Hexentanzplatz Thale, Heimatnaturgarten 
Weißenfels and White water animal park. 

EU 

Case law 

Y 

Y 

On June 2002 the Commission issued a letter of formal notice 
to the German Government regarding its transposition of the 
Directive. A main act was already in place (ie BNatSchG) 
transposing Articles 3(4), 3(5) and 4. The other articles had to 
be transposed by the different Landers. Only three (out of 16) 
landers had done so. In October 2002 the Commission issued a 
Reasoned Opinion. Two other landers transposed the legisla-
tion. In August 2003 the Commission referred the case to the 
ECJ. In the course of the procedure additional eight landers 
transposed the Directive. On 14 October 2004 the Court ruled 
in Case C-339/03 that Germany had failed to transpose the 
Directive (Commission v. Germany, 2004). 

Milieu Ltd  
Brussels  

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Annexes to Final Report – August 2017/ 341 

 
 
 
 
 
 
iLc3qM
b40Rch
0SaxyKa
x50?text
=&doci
d=4922
0&page
In-
dex=0&
doclan
g=DE&
mode=l
st&dir=&
occ=firs
t&part=
1&cid=1
519262  
http://w
ww.abc
.net.au/
news/20
16-09-
30/lion-
mot-
shegetsi
-shot-
dead-
at-
ger-
man-
zoo-
after-
es-
cape/7
891472?
pfmre-
dir=sm 
https://
www.th
eguard-

Lion escape from Leipzig Zoo 
(2016) 

Zoos in court battle over Knut the 
polar bear 

National  Media 

Y 

Y 

Media article on German zookeepers who shot a lion after two 
animals escaped from their enclosure. 

National  Media 

Y 

Y 

Media article on two German zoos who fought over rights to 
bear who has earned millions in revenue and merchandising 

Milieu Ltd  
Brussels  

Evaluation Study to support the evaluation of the Zoos Directive 
Annexes to Final Report – August 2017/ 342 

 
 
 
 
 
 
 
 
 
National 

Legally 
binding 
docu-
ment 

Y 

Y 

Adoption in national legislations of provisions on a) conserva-
tion research and training, b) public education and aware-
ness; c) accommodating animals under satisfactory condi-
tions; d) preventing escape and ecological threats and e) 
record keeping 

National  Reports 
and stu-
dies 

Y 

Y 

Legislation and implementation  

DK (Denmark) 
Zoo Order (Bekendtgørelse om 
zoologiske haver; Order no. 
1023; 1/1/2003 (Retsinformation 
DK, sd), followed by  Zoos Order 
1397 on zoos 02/12/2015   

Report on implementation of EU 
Zoo Directive EWLA 2006 

ian.com
/environ
ment/2
009/ma
y/19/ge
rman-
zoos-
fight-
over-
knut 

https://
www.re
tsinfor-
mation.
dk/Form
s/R0710.
aspx?id
=175918 
file:///C
:/Users/
Gebrui-
ker/Dro
pbox/1
62_DG%
20ENV%
20Zoos
%20Dire
ctive/0
Docu-
menta-
tion/Im
ple-
menta-
tionEU-
zooDi-
rec-
tive_Eur
ogroup
_2006.p

Milieu Ltd  
Brussels  

Evaluation Study to support the evaluation of the Zoos Directive 
Annexes to Final Report – August 2017/ 343 

 
 
 
  
  
  
  
  
  
  
  
  
 
 
 
 
 
 
df 

https://
www.b
oe.es/b
us-
car/act.
php?id
=BOE-A-
2003-
19800&
p=2003
1028&tn
=1 
https://
www.b
oe.es/b
us-
car/act.
php?id
=BOE-A-
2007-
21490&
p=2015
0922&tn
=1 
https://
www.b
oe.es/b
us-
car/act.
php?id
=BOE-A-
2006-
20847&
p=2006
1130&tn
=1 
https://
www.b

ES (Spain) 
Law 31/2003 

Law 42/2007  

Royal Decree 1333/2006 

Royal Decree 479/2004 

Milieu Ltd  
Brussels  

National 

Legally 
binding 
docu-
ment 

Y 

Y 

Y 

Y 

Y  Adoption in national legislations of provisions on a) conserva-

tion research and training, b) public education and aware-
ness; c) accommodating animals under satisfactory condi-
tions; d) preventing escape and ecological threats and e) 
record keeping 

National 

Legally 
binding 
docu-
ment 

Y 

Y 

Y 

Y 

Y 

This law establishes the legal framework for the preservation, 
sustainable use, improvement and restoration of the natural 
heritage and biodiversity. It creates the Spanish Inventory and 
Strategic Plan of Natural Heritage and Biodiversity. The Inven-
tory includes sections on wild species, endangered species 
and zoos.  

National 

Legally 
binding 
docu-
ment 

Y 

Y 

Y 

Y 

Y 

This Royal Decree regulates the destination that should be 
given to seized specimens of endangered wild fauna and flora 
as part of the Convention on International Trade in Endan-
gered Species of Wild Fauna and Flora (CITES). Among other 
measures, it determines the treatment that should be given to 
species in rescue centres (i.e. centres where seized species are 
taken to). 

National 

Legally 
binding 

Y 

Y 

Y 

Y 

Y 

This Royal Decree was adopted after the Law 31/2003 estab-
lishing and regulating the general register of livestock farms. 

Evaluation Study to support the evaluation of the Zoos Directive 
Annexes to Final Report – August 2017/ 344 

 
 
 
  
  
  
  
  
  
  
  
  
docu-
ment 

This register includes the zoos regulated under Law 31/2003. 

National 

Legally 
binding 
docu-
ment 

Y 

Y 

Y 

Y 

Y 

This Decree is prior to the Directive and regulates the authori-
sation and registration of zoological centres, establishments to 
practice horse riding, centres for the enhancement and care 
of companion animals and other similar centres. The proce-
dures for authorisation and licensing of zoos follow the rules 
under this act. 

National  Policy 
docu-
ment 

Y 

Y 

Y 

Y 

Y 

National  Reports 
and stu-
dies 

Y 

Y 

Y 

Y 

Y 

The aim of the guide is to explain the objectives of the recently 
adopted law 31/2003 and the measures to be taken in zoos to 
ensure its implementation. The document summarizes the rele-
vant legislation, presents and discusses the concept of zoo, 
describes the measures to be taken to achieve the objectives. 
The measures described in the guide include species conser-
vation programs and actions including species breeding in 
captivity, measures ensuring the animal welfare including the 
safety of their accommodation, planning conservation pro-
grams and education and public awareness measures, human 
resources requirements and the control and inspection of zoos. 
This Annual Report provides information on the state of preser-
vation of wild species of fauna, including endangered species 
among others. Last report: 2013.  

Decree 1119/1975 

Ministry of Environment, 2010. 
The zoo, a new ally of biodiversi-
ty. Guide to the implementation 
of law 31/2003 on the conserva-
tion of wildlife in zoos (2nd Edi-
tion) (El parque zoológico, un 
nuevo aliado de la biodiver-
sidad. Guía para la aplicación 
de la ley 31/2003 de conserva-
ción de la fauna silvestre en los 
parques zoológicos (2° edición)) 
Annual Report of the MAGRAMA 
on Natural Heritage and Biodi-
versity (Part 3b) 

oe.es/di
ario_bo
e/txt.ph
p?id=B
OE-A-
2015-
710 
https://
www.b
oe.es/di
ario_bo
e/txt.ph
p?id=B
OE-A-
1975-
11042  

http://w
ww.ma
gra-
ma.gob
.es/es/b
iodiver-
sidad/t
emas/in
ventari-
os-
nacion
ales/inv
entario-

Milieu Ltd  
Brussels  

Evaluation Study to support the evaluation of the Zoos Directive 
Annexes to Final Report – August 2017/ 345 

 
 
 
      
es-
panol-
patri-
monio-
natural-
bio-
div/Infor
me_201
3_IEPNB.
aspx  
http://w
ww.junt
ade-
andalu-
lu-
cia.es/e
xport/dr
upaljda
/pc-
nucle-
os-
zoo-
logicos-
2016.pd
f 

https://
www.re
searchg
ate.net/
publi-
cati-
on/5123
3707_D
o_natur
alistic_e
nclosur

Junta de Andalucía, 2016, An-
dalusian Plan on Animal Health 
Controls and Inspections 

Model form to be used when 
carrying out zoos inspections, 
Comunidad Autónoma de Gali-
cia.  
Fàbregas, M.C., Garcés-Narrro, 
C., Guillén-Salazar, G., 2012, Do 
naturalistic enclosures provide 
suitable environments for zoo 
animals?, Zoo Biology 31(3), pp. 
362-73 

National  Policy 
docu-
ment 

Y 

Y 

Y 

Y 

This document sets the procedures and indicators to carry out 
inspections in zoos in Andalucía.  

National  Policy 
docu-
ment 

Zoo inspection form 

National 

Scientific 
literature 

Y 

Y 

Y 

Y 

Y  Analysis of naturalistic and non-naturalistic enclosures in 63 
Spanish zoological parks to assess the suitability of the envi-
ronment provided. 

Milieu Ltd  
Brussels  

Evaluation Study to support the evaluation of the Zoos Directive 
Annexes to Final Report – August 2017/ 346 

 
 
 
 
    
 
 
 
 
 
es_provi
de_suit
able_en
viron-
ments_f
or_zoo_
animals 
https://
www.re
searchg
ate.net/
publi-
cati-
on/5103
9274_Un
ravel-
ing_the
_Compl
exi-
ty_of_th
e_Zoo_
Com-
muni-
ty_Ident
ify-
ing_the
_Variabl
es_Relat
ed_to_
Conser-
va-
tion_Per
for-
mance_
in_Zoolo
gi-
cal_Par
ks 
https://
www.re

Fàbregas, M.C., Garcés-Narrro, 
C., Guillén-Salazar, G., 2012, 
Unravelling the complexity of the 
zoo community: identifying the 
variables related to conservation 
performance in zoological 
parks, Zoo Biology 31, pp. 55-70 

Fàbregas, M.C., Garcés-Narrro, 
C., Guillén-Salazar, G., 2010, The 

Milieu Ltd  
Brussels  

National 

Scientific 
literature 

Y 

Y 

Y 

Y 

Y  Assessment of the conservation performance of 60 Spanish 

zoos in accordance with the requirements set in Directive 
1999/22/EC. 

National 

Scientific 
literature 

Y 

Y 

Y 

Y 

Y 

Evaluation of the risk of potential animal escape at zoological 
parks by assessing the security of animal enclosures in 63 Span-

Evaluation Study to support the evaluation of the Zoos Directive 
Annexes to Final Report – August 2017/ 347 

 
 
 
ish zoological parks. 

National  Reports 
and stu-
dies 

National  Reports 
and stu-
dies 

Y 

Y 

Y 

Y 

This website gathers the reports drafted in the framework of 
project Infozoos regarding different zoos in different Autono-
mous Communities based on the field visits carried out. 

Information on the transposition measures adopted by Spain 
according to the Zoos Directive. Investigation pointed at the 
shortcomings of the Spanish transposition and ultimately con-
tributed to the launch of Case C-340/09. 

risk of zoological parks as po-
tential pathways for the intro-
duction of non-indigenous spe-
cies, Biological Invasions 12(10), 
pp. 3627-3636 

Infozoos, Reports of zoos in dif-
ferent Spanish Autonomous 
Communities (Valencia, Castilla-
La-Mancha, Asturias, Galicia, 
Catalonia, Madrid) (2009-2015) 
BornFree, 2006, Zoo Health: An 
adaptation of Spanish zoos fol-
lowing the implementation of 
Act 31/2003 

searchg
ate.net/
publi-
cati-
on/2251
65010_T
he_risk_
of_zool
ogi-
cal_par
ks_as_p
oten-
tial_pat
hways_f
or_the_i
ntroduc
duc-
tion_of_
non-
indige-
nous_sp
ecies 
http://w
ww.info
zoos.org
/proyec
to.php  
http://w
ww.bor
nfree.or
g.uk/file
ad-
min/use
r_uploa
d/files/z
oo_che
ck/publi
cati-
ons/Info
zoos_Re

Milieu Ltd  
Brussels  

Evaluation Study to support the evaluation of the Zoos Directive 
Annexes to Final Report – August 2017/ 348 

 
 
 
 
 
 
 
 
 
National  Reports 
and stu-
dies 

Y 

Y 

Information on the transposition measures adopted by Spain 
(Canary Islands) according to the Zoos Directive. 

National  Reports 
and stu-
dies 

Y 

Y 

Information on the transposition measures adopted by Spain 
(Canary Islands) according to the Zoos Directive. 

InfoZoos, 2008, Zoo Health – The 
legal status of zoos in the Canary 
Islands in accordance to Span-
ish Law 31/2003 

InfoZoos, 2009, Investigation into 
the conditions in zoos in the 
Spanish Region of Valencia 

port_-
_pilot_st
udy__E
N_versio
n.pdf  
http://w
ww.bor
nfree.or
g.uk/file
ad-
min/use
r_uploa
d/files/z
oo_che
ck/publi
cati-
ons/Info
zoos_Re
port_-
_zoos_in
_the_C
an-
aries_-
_EN_ver
sion.pdf  
http://w
ww.bor
nfree.or
g.uk/file
ad-
min/use
r_uploa
d/files/z
oo_che
ck/publi
cati-
ons/Info
zoos_Re
port_-
_Valenc

Milieu Ltd  
Brussels  

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Annexes to Final Report – August 2017/ 349 

 
 
 
 
 
 
 
 
 
ia_zoos_
re-
port_20
09__EN_
ver-
sion.pdf  

EAZA, TAG reports 2013-14 

EU 

Reports 
and stu-
dies 

Y 

Y 

Y 

Y 

Information on conservation research and training pro-
grammes. 

http://w
ww.aiza
.org.es/
pdf/pu
blicacio
cio-
nes/gui
a_aplic
acion_l
ey_31_2
007.pdf  
http://w
ww.ma
gra-
ma.gob
.es/es/b
iodiver-
sidad/p
ublica-
ciones/
pbl_estr
ategia_
mundi-
al_zoos_
acuari-
os_06_t
cm7-
20337.p
df 
http://w
ww.vid

AIZA, 2007, ‘The zoological gar-
den, a new ally for biodiversity’ 
(El parque zoológico un nuevo 
aliado de la biodiversidad) 

World Association of Zoos and 
Aquariums, 2005, ‘Building a 
future for the Wild Fauna’ 

Igualdad Animal, 2011, ‘Lives in 
captivity’ (Vidas enjauladas) 

Milieu Ltd  
Brussels  

National  Reports 
and stu-
dies 

Y 

Y 

Y 

Y 

Y  Guide for the implementation of Law 31/2003 transposing Di-

rective 1999/2002. 

Interna-
tional 

Reports 
and stu-
dies 

Y 

Y 

Y 

Y 

Y  World Strategy for the preservation of wild species in zoos and 

aquariums. 

National  Reports 
and stu-

Y 

Y 

Y 

Y 

Study on the field visits to 8 zoos in Spain (Madrid, Catalonia, 
Valencia and Andalucía. 226 animal enclosures were visited, 

Evaluation Study to support the evaluation of the Zoos Directive 
Annexes to Final Report – August 2017/ 350 

 
 
 
 
 
 
dies 

examining the situation of 271 specimens covering 155 terres-
trial animal species. 

asen-
jaula-
das.org
/resume
n_infor
me_zoo
s_2011.
pdf 

EU 

Case law 

Y 

Y 

Y 

Judgment 

Case C-340/09 (Commission v. 
Spain), 19/02/2011 
FR (France) 
Order of 25 March 2004 

Regula-
tion 

National 

Y 

Legally 
binding 
docu-
ment 

Order of 10 August 2004  

Regula-
tion 

National 

Y 

Legally 
binding 
docu-
ment 

National  Media 

Y 

2012, Les parcs zoologiques et 
les aquariums, Ministère de 
l’Environnement, de l’Energie et 
de la Mer (2 July 2012) 

http://w
ww.dev
eloppe-
pe-
ment-
du-
rable.g
ouv.fr/P

This is the main French regulation transposing Directive 
1999/22/EC (amended in 2009). This Ministerial Order contains 
rules applying to: the scope of the zoos to which the order 
applies (Art 1); the physical organisation of the zoos (type of 
buildings containing animals, height of enclosures, etc.) (Art 2); 
the zoo staff and their working conditions (Art 3 to 5); the pre-
vention of accidents (Art 6 to 9); the well-being of animals 
(conditions satisfying the biological and conservation require-
ments of species, etc.) (Art 10 to 26); the public presentation of 
animals to visitors (Art 27 to 40); the sanitary prevention of ill-
nesses amongst animals (Art 41 to 52); the participation in ani-
mal conservation activities (Art 53 to 56); the promotion of 
public education in relation to biodiversity (Art 57 to 63); the 
prevention of ecological risks (Art 64 to 68). 
Zoos are considered establishments practicing the breeding of 
non-domestic animals. As a result, Order of 10 August 2004 
applies to zoos. It contains various rules relevant to the appli-
cation of Directive 1999/22/EC: conditions to obtain a licence 
(Art 1 to 5); identification and tagging of animals (Art 6 to 11); 
conditions for the practice of hunting by bird of prey (Art 12 to 
15). 
Web page of the French Environment Ministry providing infor-
mation on the licensing of zoos. Zoos must have an authoriza-
tion to open (autorisation d’ouverture) and a competence 
certificate (certificat de capacité). In each French depart-
ment, such licensing is overseen by the regional veterinary 
services (direction départementale de la protection des popu-
lations), under the authority of the Prefect. 

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arcs-
zoolo-
giques-
et-
aqua-
riums.ht
ml  
http://w
ww.dev
eloppe-
pe-
ment-
du-
rable.g
ouv.fr/S
uivi-et-
con-
trole-
des.htm
l  

http://w
ww.lad
ocu-
menta-
tionfran
fran-
caise.fr/
var/stor
age/ra
pports-
pu-
blics/10
4000588
.pdf  
http://w
ww.lad
ocu-
menta-
tionfran

2012, Le suivi et le contrôle des 
établissements, Ministère de 
l’Environnement, de l’Energie et 
de la Mer (2 July 2012) 

Maillot, E. and others, 2010, Rap-
port: Conditions d’accueil des 
animaux d’espèces non domes-
tiques saisis ou recueillis – Faune 
sauvage exotique, Ministère de 
l’Alimentation, de l’Agriculture et 
de la Pêche et Ministère de 
l’Ecologie, de l’Energie, du Dé-
veloppement Durable et de la 
Mer, La Documentation Fran-
çaise, Paris 

Fouché, A., 2009, Rapport 
d’information au premier Ministre 
relatif aux enjeux liés à 
l’évolution des parcs de loisirs en 
France, Premier Ministre, La Do-

Milieu Ltd  
Brussels  

National  Media 

Y 

National  Reports 
and stu-
dies 

Y 

Y 

Web page of the French Environment Ministry providing infor-
mation on administrative inspection of zoos. This inspection 
aims to control: the respect of licences, animal well-being, and 
the absence of risk to the security of persons ; the lawful origin 
of animals and the identification of species for which tagging 
is compulsory; the movement of animals; changes which took 
place and should have been communicated to the adminis-
trative authority, important changes that require a new li-
cence; the need for administrative and criminal penalties ac-
cording to the Environmental Code. Such inspection is done 
by regional veterinary services (directions départementales de 
la protection des populations), in coordination with the na-
tional office of hunting and wildlife (Office national de la 
chasse et de la faune sauvage). 
This governmental report provides information on the law ap-
plying to seized or collected non-domestic animal species. It 
contains some information on the role zoos can play in shelter-
ing these animals.  

National  Reports 
and stu-
dies 

Y 

Y 

This governmental report assesses the challenges arising from 
the evolution of entertainment parks, including zoos. The au-
thor points out a number of deficiencies of the French legal 
law applying to zoos. He argues that French rules neglect to 
take into account the different roles zoos play (eg biodiversity 

Evaluation Study to support the evaluation of the Zoos Directive 
Annexes to Final Report – August 2017/ 352 

 
 
 
 
 
 
 
 
 
 
 
 
 
fran-
caise.fr/
var/stor
age/ra
pports-
pu-
blics/09
4000267
.pdf  
http://w
ww.calv
ados.go
uv.fr/IM
G/pdf/
CdC_et
_AO_Et
abl-
_presen
ta-
tion_au
_public.
pdf 
http://d
ocu-
ments.ir
evues.in
ist.fr/bits
tream/h
an-
dle/204
2/56531
/AVF_16
7_4_349
.pdf?se
quence
=1&isAll
owed=y   
http://d
ocu-
ments.ir

cumentation Française, Paris 

2008, Circulaire MEEDDAT 
DNP/CFF 2008/03 (11 April 2008) 

Laidebeure, S. and Lecu, A., 
2014, ‘Evolution du Concept de 
Parc Zoologique de Paris de 
1934 à 2014 – Evolution of the 
Concept of Paris Zoo from 1934 
to 2014’, in Bull. Acad. Vét. 
France, Tome 167, No 4, pp. 349-
354 

Lecu, A. and Petit, T., 2012, ‘Ca-
dres Règlementaires de 
l’Exercice Vétérinaire en Parc 

Milieu Ltd  
Brussels  

conservation) or that zoos contribute to a general interest 
mission (p. 29-30). The author calls for the creation of observa-
tories fully dedicated to the activities of zoos (p. 43) and for the 
adoption of a national protocol of collaboration between zoos 
and regional environmental agencies to facilitate the funding 
of zoos (p. 65). 

National  Policy 
docu-
ment 

Y 

Example of guidance on how to apply for a competence 
certificate in Calvados 

National 

Scientific 
literature 

Y 

Y 

This paper describes the evolution of the Paris zoo regarding 
various aspects of the organization and the operation of the 
zoo, such as taxonomic diversity of species, animal welfare, 
and participation in conservation and research programmes.  

National 

Scientific 
literature 

Y 

Y 

Y 

This paper describes the various international, European and 
national regulations applying to veterinarian practice in 
French zoos. The author underlines the complexity of European 

Evaluation Study to support the evaluation of the Zoos Directive 
Annexes to Final Report – August 2017/ 353 

 
 
 
 
 
 
 
 
 
 
 
 
Zoologique - Regulatory Frame-
work of Veterinary Practice in 
Zoos’, in Bull. Acad. Vét. France, 
Tome 165, No 2, pp. 163-167 

Bourgeois, A. and Lecu, A., 2012, 
‘Travailler en Parc Zoologique: 
Dangers Physiques et Zoono-
tiques, Moyen de Prévention - 
Working in a Zoo: Physical and 
Zoonotic Hazards, Preventive 
Measures’, in Bull. Acad. Vét. 
France, Tome 165, No 2, pp. 155-
161 

Petit, T., 2008, ‘L’Activité Vétéri-
naire dans les Parcs Zoologiques 
de France - Veterinary Practice 
in Zoos in France’, in Bull. Acad. 
Vét. France, Tome 161, No 2, pp. 
139-144. 

evues.in
ist.fr/bits
tream/h
an-
dle/204
2/48204
/AVF_20
12_2_16
3.pdf?s
equenc
e=1&isA
llowed=
y  
http://d
ocu-
ments.ir
evues.in
ist.fr/bits
tream/h
an-
dle/204
2/48203
/AVF_20
12_2_15
5.pdf?s
equenc
e=1&isA
llowed=
y 
http://d
ocu-
ments.ir
evues.in
ist.fr/bits
tream/h
an-
dle/204
2/47936
/AVF_20
08_2_13

National 

Scientific 
literature 

Y 

Y 

National 

Scientific 
literature 

Y 

regulation, especially in relation to veterinary’s healthcare 
duties. The paper also describes the interactions and/or link-
ages between Directive 1999/22/EC and other EU regulations 
and/or Directives. 

This paper describes hazards for veterinarians and animal 
keepers working with zoo animals. The staff is exposed to a risk 
of injury, either directly due to the animals or indirectly due to 
the equipment used for their care. The broad range of species 
gathered in the same place, and daily contacts between the 
staff and the animals also constitute a zoonotic risk. The paper 
underlines that European and international safety norms tend 
to create a level playing field amongst zoos. Preventive 
measures may involve health and security measures, staff 
training, and communication with all the actors of animal and 
human health. 

This paper describes the work of veterinarians in zoos in France. 
It compares the rules laid down by both Directive 1999/22/EC 
and French law in relation to veterinarian practice in zoos. In 
France zoos started recruiting veterinarians relatively recently. 
Directive 1999/22/EC has played an important role in increas-
ing the role of both veterinarians working in zoos and veterinar-
ians in charge of inspecting zoos. In practice, the work of zoo 
veterinarians is not limited to medical activities and they may 
act successively as clinicians, pathologists, nutritionists, breed-
ers, architects, etc. Although this paper is not critical, readers 
can, nonetheless, question whether the workload of veterinar-

Milieu Ltd  
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Evaluation Study to support the evaluation of the Zoos Directive 
Annexes to Final Report – August 2017/ 354 

 
 
 
 
 
 
 
 
 
 
Code Animal, 2013, Rapport 
d’Enquête Octobre 2013 Zoo de 
l’Orangerie, Strasbourg (Bas-
Rhin) 

Born Free, 2010, Enquête de 2011 
sur les Zoos de l’Union Euro-
péenne : Une Evaluation de la 
Mise en Application et du Res-
pect de la Directive CE 1999/22 
Relative à la Détention 
d’Animaux Sauvages dans un 
Environnement Zoologique 
FRANCE, ENDCAP 

9.pdf?s
equenc
e=1&isA
llowed=
y 
http://w
ww.zoo-
de-
france.
com/sit
es/defa
ult/files/
doc_a_t
el/rapp
ort_stras
bourg.p
df 
http://w
ww.bor
nfree.or
g.uk/zo
ore-
ports/Fr
ancefr/
pages/
BFF_EZR
_FRANC
E_FINALf
r.pdf  

National  Reports 
and stu-
dies 

Y 

National  Reports 
and stu-
dies 

Y 

Y 

Y 

Born Free, 2010, Enquête de 2011  http://e

EU 

Reports 

Y 

Y 

Y 

ians is a hurdle to the proper implementation of the objectives 
of Directive 1999/22/EC. 

Investigation led by the animal welfare NGO Code Animal 
assessing the respect by the Strasbourg Zoo of various provi-
sions under Order of 25 March 2004, Directive 1999/22/EC, 
French Rural Code and French Environmental Code. The re-
port concludes that the Strasbourg Zoo does not respect the 
rules related to the biological and conservation requirements 
of animals, and to security.  

Investigation on the application of Directive 1999/22/EC in 
French zoos. A sample of 25 zoos was inspected and evaluat-
ed against the legal requirements of Directive 1999/22/EC and 
French transposition measures. Analysis was undertaken on a 
number of key aspects of their operation including: participa-
tion in conservation activities, the acquisition of animals, public 
education, public safety and animal welfare. Investigators 
found that, although France transposed the Directive into 
French law, 13% of the sample did not conform to the rules of 
the French transposition measures. The following shortcomings 
were found: Lack of territorial uniformity in the application of 
licensing measures (power belonging to the local authority 
“préfet”); Living standards of animals were below the stand-
ards set up by Directive 1999/22/EC in 36% of the sample. The 
biological and conservation requirements of individual species 
were not respected; Lack of adequate measures to prevent 
the escape of animals, threatening the security of local spe-
cies and of visitors; Contribution to the conservation of biodi-
versity was actually weak; The educational value of zoos was 
limited (64% of the sample appears to have an educational 
programme; at the same time, more than half of the sample 
offered wild animal shows).  
Investigation on the application of Directive 1999/22/EC in 18 

Milieu Ltd  
Brussels  

Evaluation Study to support the evaluation of the Zoos Directive 
Annexes to Final Report – August 2017/ 355 

 
 
 
 
 
 
 
 
 
 
 
ndcap.
eu/eu-
dolphi-
naria/ 

sur les Zoos de l’Union Euro-
péenne. Les Delphinariums : Une 
Evaluation de la Détention de 
Baleines et de Dauphins en 
Union européenne et de la Di-
rective 1999/22/CE, Relative à la 
Détention d’Animaux Sauvages 
dans un Environnement Zoolo-
gique, ENDCAP 

and stu-
dies 

Tribunal Administratif de Limo-
ges, 11 February 2016, M. A…, n° 
1300852 

CAA Nancy, 22 January 2015, 
Société coopérative de produc-
tion à responsabilité limitée « 
Parc Zoo d’Amnéville »  

National  Case law 

Y 

National  Case law 

Y 

http://li
mo-
ges.trib
unal-
admi-
nistra-
tif.fr/co
ntent/d
ownlo-
ad/6668
0/60660
8/versio
n/1/file/
1300852
.anon_c
ompl%5
B1%5D.
pdf 

https://
www.le
gi-
france.
gouv.fr/
affichJu
fichJu-
riAd-

dolphinaria of EU Member States (including France). Analysis 
was undertaken on a number of key aspects of their operation 
including: participation in conservation activities, the acquisi-
tion of animals, public education, public safety and animal 
welfare. These parameters were evaluated against the legal 
requirements of EC Directive 1999/22, EU Council Regulation 
338/97 and other relevant EU legislation. The report concluded 
that EU dolphinaria do not comply with the key objectives of 
the EC Zoos Directive (insignificant contribution to biodiversity 
conservation; live cetaceans importations in spite of prohibi-
tion under EU CITES Regulation; poor public education; signifi-
cant risk of disease and injury; etc.). 
Ruling (Administrative Court. This case was related to a private 
owner of non-domestic animals, not a zoo. However, this ruling 
is relevant for zoos too. In this case, the owner of two emus had 
seen his request to keep these animals rejected by the Prefect 
on the grounds that the plaintiff did not hold, contrary to Arti-
cle 1 of the Order of 10 August 2004, the competence certifi-
cate requested to keep non-domestic animals pursuant to 
Article L413-2 of the Environmental Code. The plaintiff chal-
lenged the applicability of Order of 10 August 2004, notably on 
the grounds that he had had emus since 2003. The Limoges 
Administrative Court rejected the plaintiff’s argument. It held 
that, pursuant to Order of 10 August 2004,  the possibility to 
keep emus was subject to Articles L413-2 and L413-3 of the 
Environmental Code and, as a result, to the detention of a 
competence certificate. More importantly, the Court held that 
the fact that the owner had the animals before the entry into 
force of Order of 10 August 2004 did not preclude the applica-
tion of this Order. Furthermore, the Order could not provide for 
a different set of rules applicable to persons owning non-
domestic animals before its entry into force. 
Ruling (Appeal Administrative Court). In this case, the Adminis-
trative Appeal Court of Nancy found that the Amnéville Zoo 
was liable to pay the preventive archaeology tax for buildings 
constructed to house orangutans. The Court held that these 
buildings were not farming premises since the main activity of 
the zoo is to show wild animals to the public. The construction 
of buildings to house animals, even though they are critically 
endangered and belong to a conservation programme for 

Milieu Ltd  
Brussels  

Evaluation Study to support the evaluation of the Zoos Directive 
Annexes to Final Report – August 2017/ 356 

 
 
 
 
 
 
 
 
 
 
 
min.do?
oldAc-
tion=rec
hJuriAd-
riAd-
min&idT
exte=C
ETATEXT
0000301
71758&f
astRe-
qId=745
813752
&fastPo
s=1  
http://w
ww.con
seil-
etat.fr/c
on-
tent/do
wnload
/38228/
332174/
ver-
sion/3/fil
e/LJA-
37-
web.pd
f 
https://
www.le
gi-
france.
gouv.fr/
affichJu
fichJu-
riJu-
di.do?id
Texte=J

2015, ‘Régime fiscal d’un abri 
pour orangs-outans’, La Lettre de 
La Justice Administrative, No 37 

Cass (crim), 4 October 2011, 
n°11-80198 

species in danger of extinction, cannot have a farming pur-
pose and be exempted from tax. 

National  Case law 

Y 

Summary of case CAA Nancy, 22 January 2015, Société coo-
pérative de production à responsabilité limitée « Parc Zoo 
d’Amnéville » 

National  Case law 

Y 

Ruling (Court of Cassation – Criminal Chamber). This case was 
related to a circus, not a zoo. However, this ruling is relevant for 
zoos too. The owner of a circus had the competence certifi-
cate required by Art L413-2 of the Environmental Code. How-
ever, he was not on the premises of the circus on the day of 
the inspection and was found criminally liable for his absence 
by the Appeal Court of Grenoble on the basis of Art L415-3 of 
the Environmental Code. However, the Court of Cassation 
struck down the appeal judgement. It held that Art L 415-3 did 
not require the owner of the certificate to be on the premises. 

Milieu Ltd  
Brussels  

Evaluation Study to support the evaluation of the Zoos Directive 
Annexes to Final Report – August 2017/ 357 

 
 
 
 
 
 
 
 
 
 
 
Scientific 
literature 

National 

National  Media 

URI-
TEXT000
0247879
23 
http://w
ww.cair
n.info/r
evue-
revue-
juri-
dique-
de-
lenvi-
ronne-
ment-
2012-4-
page-
730.htm  
http://w
ww.afd
pz.org/i
ndex.ph
p?optio
n=com_
con-
tent&vi
ew=arti
cle&id=
79&Item
id=114 
http://w
ww.zoo-
amne-
ville.co
m/lePar
c/cons
erva-
tion.ph
p 
http://w National  Reports 

National  Media 

Jaworski, V., 2012, ‘Espèces pro-
tégées’, in Revue juridique de 
l’environnement, Vol 37, No 4, 
pp. 730-731 

AFdPZ, 2016, Commission Con-
servation 

Zoo d’Amnéville, 2016, Nos pro-
grammes de conservation  

Zoos de France, 2015, Zoo de 

Milieu Ltd  
Brussels  

Y 

Y 

Y 

Y 

Summary of criminal case Cass (crim), 4 October 2011, n°11-
80198 

Information on the conservation measures of AFdPZ. For in-
stance, in 2016, AFdPZ funded 16 programmes of in situ con-
servation for an amount of 63,000 EUR.  

Webpage of the Amnéville Zoo on their conservation activities. 
Over the last 5 years, the Zoo spent 2 million euros on conser-
vation activities in various developing countries. 

Following Code Animal’s criminal complaint against the Stras-

Evaluation Study to support the evaluation of the Zoos Directive 
Annexes to Final Report – August 2017/ 358 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
ww.zoo-
de-
france.
com/co
ntent/z
oo-de-
l%E2%80
%99ora
ngerie-
publi-
cation-
du-
rapport-
d%E2%8
0%99en
qu%C3
%AAte-
de-
code-
animal 
http://w
ww.rue
89strasb
ourg.co
m/une-
en-
quete-
sur-le-
zoo-de-
loran-
gerie-
pour-
rait-
aboutir-
a-sa-
ferme-
ture-
27637  
http://w
ww.cod

l’Orangerie: Publication du Rap-
port d’Enquête de Code Animal 
(10 February 2015) 

Marty, M., 2013, ‘Une enquête 
sur le zoo de l’Orangerie pourrait 
aboutir à sa fermeture’, Rue 89 
Strasbourg (8 January 2013) 

Code Animal, 2013, Zoo de 
Strasbourg: Une Structure Ar-

Milieu Ltd  
Brussels  

and stu-
dies 

bourg Zoo, the Instance Court (Tribunal d’Instance) of Stras-
bourg opened an investigation. As of February 2015, it appears 
that the Public Prosecutor was still investigating the facts of the 
complaint 

National  Media 

Y 

This journal articles describes the conflict between the Stras-
bourg Zoo on one hand, and animal welfare NGOs and Green 
local politicians. Parties argue about whether the Strasbourg 
Zoo respects Directive 199/22/EC. The city of Strasbourg was 
asked to intervene in this conflict. 

National  Reports 
and stu-

Y 

The French NGO Code Animal brought a criminal complaint 
against the Strasbourg Zoo for violation of Order of 25 March 

Evaluation Study to support the evaluation of the Zoos Directive 
Annexes to Final Report – August 2017/ 359 

 
 
 
 
 
 
 
 
 
 
 
dies 

2004 and Directive 1999/22/EC, and other provisions of the 
Rural Code and the Criminal Code. 

National  Media 

Y 

This journal article describes the response of the local authori-
ties, in particular the Direction Départementale de la Protec-
tion des Populations (DDPP), to the petition launched against 
the Fréjus Zoo after cases of poor treatment of animals had 
been raised.  

chaïque en Echec (31 October 
2013) 

‘Zoo de Fréjus : les services de 
l’Etat demandent des mesures 
d’amélioration’, Nice-Matin (10 
September 2014) 

e-
ani-
mal.co
m/wp-
con-
tent/upl
oads/20
15/09/c
p_endc
ap_ok.p
df 
http://a
rchives.
nicema
ma-
tin.com
/dernier
e-
mi-
nute/zo
o-de-
frejus-
les-
ser-
vices-
de-
l%E2%80
%99etat
-
deman-
man-
dent-
des-
me-
sures-
d%E2%8
0%99a
meliora-
tion.189
8211.ht

Milieu Ltd  
Brussels  

Evaluation Study to support the evaluation of the Zoos Directive 
Annexes to Final Report – August 2017/ 360 

 
 
 
 
 
 
 
‘Éléphants assoiffés, loup blessé, 
ara déplumé... J'ai visité le zoo 
de Fréjus, une horreur’, L’Obs Le 
Plus (22 August 2014) 

Garric, A., 2012, ‘Les zoos fran-
çais protègent-ils assez les ani-
maux ?’, Le Monde (5 May 2012) 

ml 
http://le
plus.nou
ve-
lobs.co
m/contr
ibu-
tion/123
3741-
ele-
phants-
as-
soiffes-
loup-
blesse-
ara-
deplum
e-j-ai-
visite-le-
zoo-de-
frejus-
une-
hor-
reur.htm
l 
http://w
ww.lem
onde.fr/
pla-
nete/art
icle/201
2/05/05
/les-
zoos-
fran-
cais-
prote-
gent-ils-
assez-
les-

National  Media 

Y 

This blog article criticizes the treatment of animals and the lack 
of measures respecting the biological needs of animals in the 
Fréjus Zoo. 

National  Media 

Y 

This journal article questions whether French zoos respect their 
obligations under Directive 1999/22/EC following the publica-
tion of a Born Free’s report on the implementation of the Di-
rective in various EU Member States. The French NGO Code 
Animal criticizes the French law applying to zoos for being not 
precise enough. “They do not provide the minimal norms for all 
species; as a result each zoo interprets its general missions as it 
wishes”. The article describes three main issues: inadequate 
measures to ensure animal well-being; lack of conservation 
measures by zoos; and insufficient public education. 

Milieu Ltd  
Brussels  

Evaluation Study to support the evaluation of the Zoos Directive 
Annexes to Final Report – August 2017/ 361 

 
 
 
 
 
 
 
 
 
 
 
ani-
maux_1
693904_
3244.ht
ml#SPwi
Dmdl4Zi
p36pX.9
9 

https://
www.n
pws.ie/s
ites/def
ault/files
/public
ations/p
df/ISMZ
P 
2016.pd
f 
https://
www.n
pws.ie/li
cences/
educa-
tion-
and-
sci-
ence/z
oo-
licences  
https://
www.n
pws.ie/li
cences/

IE (Ireland) 
European Communities (Licens-
ing and Inspection of Zoos) Reg-
ulations 2003, S.I. No. 440/2003 of 
19/09/2003 

Irish Standards of Modern Zoo 
Practice  

Irish Zoo Licence Guidance 
Notes: GN01 Zoo Licencing Use-
ful Information  

Irish Zoo Licence Guidance 
Notes: GN02 Zoo Licencing Pro-
cess 

National 

Legally 
binding 
docu-
ment 

National  Policy 
docu-
ment 

Y 

Y 

Y 

Y 

Y 

Adoption in national legislation of provisions on a) conserva-
tion research and training, b) public education and aware-
ness; c) accommodating animals under satisfactory condi-
tions; d) preventing escape and ecological threats and e) 
record keeping 
Specification of modern standards of zoo practice, including a 
range of forms  

National  Policy 
docu-
ment 

Y 

Y 

Y 

Specification of modern standards of zoo practice, including a 
range of forms  

National  Policy 
docu-
ment 

Y 

Y 

Y 

Specification of modern standards of zoo practice, including a 
range of forms  

Milieu Ltd  
Brussels  

Evaluation Study to support the evaluation of the Zoos Directive 
Annexes to Final Report – August 2017/ 362 

 
 
 
  
  
  
  
  
  
  
  
  
 
 
 
 
 
 
 
 
 
 
Irish Zoo Licence Guidance 
Notes: GN03 Exemption Criteria 
and Application  

The EU Zoo Inquiry 2011: Country 
Report Ireland  

educa-
tion-
and-
sci-
ence/z
oo-
licences  
https://
www.n
pws.ie/li
cences/
educa-
tion-
and-
sci-
ence/z
oo-
licences  
http://w
ww.bor
nfree.or
g.uk/zo
ore-
ports/ire
land/ 

National  Reports 
and stu-
dies 

Y 

June 2002 Letter of formal notice 

EU 

Case law 

Y 

National  Policy 
docu-
ment 

Y 

Y 

Y 

Specification of modern standards of zoo practice, including a 
range of forms  

Y  Of the 27 identified zoological collections in the Republic of 
Ireland, eight zoos were assessed as part of a pan-European 
project to evaluate the effectiveness and degree of imple-
mentation and enforcement of European Council Directive 
1999/22/EC. The Born Free report checked eight zoos in Ireland 
(6 licensed and 2 ‘unlicensed’) in 2009. She concluded, 
amongst other issues, that Irish zoos appear to demonstrate a 
limited commitment to the conservation of biodiversity and, in 
particular, Threatened species, and that requirements of the 
EC Directive 1999/22 has been accurately transposed into 
R440/2003, there are inconsistencies in its application. 
June 2002: a Letter of formal notice was sent to Ireland con-
cerning the non-transposition of the Directive into national law. 
This was followed by a Reasoned Opinion in October 2002, 
which in turn was followed by Saisine in June 2003. Ireland 
responded in September 2003 with European Communities 
(Licensing and Inspection of Zoos) Regulations 2003, S.I. No. 
440/2003. The case was then withdrawn. 

Y 

IT (Italy) 
Legislative Decree 21 March 
2005 n. 73 (Official Gazette n. 
100, 02/05/2005): ‘Attuazione 

Milieu Ltd  
Brussels  

http://w
ww.ca
me-

National 

Legally 
binding 
docu-

Y 

Y 

Adoption in national legislations of provisions on a) conserva-
tion research and training, b) public education and aware-
ness; c) accommodating animals under satisfactory condi-

Evaluation Study to support the evaluation of the Zoos Directive 
Annexes to Final Report – August 2017/ 363 

 
 
 
 
 
 
 
 
 
 
 
 
  
  
  
  
  
  
  
  
  
 
 
 
della direttiva 1999/22/CE relati-
va alla custodia degli animali 
selvatici nei giardini zoologici’. 

Decreto del Ministero 
dell’Ambiente 18 gennaio 2006. 
Modifica all’allegato 4 del de-
creto legislativo 21 marzo 2005, 
n. 73, recante attuazione della 
direttiva 1999/22/CE relativa alla 
custodia degli animali selvatici 
nei giardini zoologici. Gazzetta 
Ufficiale n. 26 del 1° febbraio 
2006 
Decreto Legislativo 4 aprile 2006 
n. 192 (2006). Disposizioni corret-
tive del decreto legislativo 21 
marzo 2005, n. 73, recante at-
tuazione della direttiva 
1999/22/CE relativa alla custo-
dia degli animali selvatici nei 
giardini zoologici. Gazzetta Uffi-
ciale n. 121 del 26 maggio 2006.  
Legge n. 101 del 6 giugno 2008 
(pubblicata nella Gazzetta Uffi-
ciale n. 132 del 7 giugno 2008), 
“Conversione in legge, con mo-
dificazioni, del decreto-legge 8 
aprile 2008, n. 59, recante dispo-
sizioni urgenti per l'attuazione di 
obblighi comunitari e l'esecuzio-
ne di sentenze della Corte di 
giustizia delle Comunità euro-
pee". 
Gippoliti, S., Kitchener, C., 2007, 
‘The Italian Zoological Gardens 
and their Role in Mammal Sys-
tematic Studies, Conservation 

ra.it/par
lam/leg
gi/dele
ghe/050
73dl.ht
m 
http://g
az-
zette.co
mune.je
si.an.it/2
006/26/
9.htm  

http://g
az-
zette.co
mune.je
si.an.it/2
006/121
/1.htm 

http://w
ww.ca
me-
ra.it/par
lam/leg
gi/0810
1l.htm  

http://w
ww.itali
an-
journal-

ment 

tions; d) preventing escape and ecological threats and e) 
record keeping. 

National 

Legally 
binding 
docu-
ment 

Modifying the annex 4 of the Italian legislative decree n. 
73/2005 by removing the time limit of 180 days that were nec-
essary to submit the application for obtaining the license re-
quired for the opening of new zoos. 

National 

Legally 
binding 
docu-
ment 

Modifying the definition of zoos in the Italian legislative decree 
n. 73/2005 which implements the Directive 1999/22/CE. Modify-
ing provisions about the license in the Italian legislative decree 
n. 73/2005 which implements the Directive 1999/22/CE. 

National 

Legally 
binding 
docu-
ment 

Y 

Y 

Y 

Y 

Y 

Law enacted since the previous modifications of the legislative 
decree n. 73/2005 (Ministerial Decree of 18 January 2006 and 
Legislative Decree 192/2006) were interpreted by the Europe-
an Commission as a breach of the Directive 1999/22/CE. Due 
to this situation the European Commission issued an infringe-
ment procedure against the Italian republic (2007/2179). To 
comply with the requests of the European Commission this law 
re-establishes the original definition of zoo as it was written in 
the first version of art. 2, legislative decree n. 73/ 2005 

National 

Scientific 
literature 

Y 

A stronger collaboration between zoos, museums and universi-
ties is needed to maximise the scientific and conservation val-
ue of Italian mammal collections. 

Milieu Ltd  
Brussels  

Evaluation Study to support the evaluation of the Zoos Directive 
Annexes to Final Report – August 2017/ 364 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Biology and Museum Collec-
tions’, in Hystrix It. J. Mamm. 
(n.s.), vol. 18 n. ), pp. 173-184 

Rizzelli, D., Carratù, A., Montella, 
F, Nobili, C , Gaetano, F, 2013, ‘A 
thousand ways to educate peo-
ple: the case of the ‘grassmen’ 
workshop at Zoomarine Italy’, in 
IZE Journal vol. 49 

Born Free Foundation, 2011, ‘The 
EU Zoo Inquiry, An evaluation of 
the implementation and en-
forcement of the EC Directive 
1999/22, relating to the keeping 
of wild animals in zoos – ITALY’ 

of-
mam-
malo-
gy.it/arti
cle/vie
w/4401/
4337  
http://iz
ea.net/
/wp-
con-
tent/upl
oads/20
15/03/A
-
thou-
sand-
ways-
to-
edu-
cate-
peo-
ple_-
the-
case-of-
the-
grass-
men-
work-
shop-at-
Zoo-
marine-
Italy.pdf  
http://w
ww.bor
nfree.or
g.uk/zo
ore-
ports/It
aly-

National 

Scientific 
literature 

Y 

The grassmen workshop is a powerful tool to educate people 
about wild species and conservation activities in the zoos. 

National  Reports 
and stu-
dies 

Y 

Y 

Y 

Y  Many of the requirements applicable to zoos in Italy are more 
stringent than those required by the Directive. Findings indi-
cated that the Italian zoo law was not being effectively im-
plemented and enforced, with significant numbers of zoos 
remaining unlicensed and unregulated, yet operational. Find-
ings concluded that few zoo inspections have taken place, 
the majority of zoos remain uninspected and many have yet 

Milieu Ltd  
Brussels  

Evaluation Study to support the evaluation of the Zoos Directive 
Annexes to Final Report – August 2017/ 365 

 
 
 
 
 
 
 
 
to request an operational licence. Whilst some individual zoos 
were performing better than others, overall findings indicate 
that zoos in Italy were failing to comply with their legal obliga-
tions of LD73/2005. This does not meet the fundamental objec-
tive of Article 4 of the Directive. Overall zoos appeared to be 
making an insignificant contribution to the conservation either 
globally or in Europe of species threatened with extinction. 
Species information was not available to the public for almost 
one third of the exhibited species holdings across the 25 zoos 
analysed in the report. The majority of the animal demonstra-
tions observed showed the animals performing unnatural be-
haviours. Some zoos were not taking appropriate measures to 
prevent the escape of non-indigenous animals into the natural 
environment. 
The system of licenses in Italy is not properly working as it does 
not respect the time limits established by EU Directive. The 
Italian minister of Environment (competent authority for zoos in 
Italy) is often vague or unclear is answering request for clarifi-
cation asked by the stakeholders. Overall, the document ar-
gues that the EU Zoo Directive is not rightly applied in Italy. 

National 

Scientific 
literature 

Y 

Y 

Y 

EU 

Case law 

Y 

Y 

Y 

The Italian Republic failed to adopt the laws, regulations and 
administrative provisions necessary to implement Directive 
1999/22, and was ordered to pay the costs of the trials.  

Masutti, N., 2009, ‘10 anni di 
buio, valutazione del benessere 
animale nelle strutture di deten-
zione presenti in Italia’, LAV dos-
sier, pp. 1 – 22 

Case C-302/03 (Commission v. 
Italy), 07/08/2004 

it/page
s/BFF_EZ
R_ITALY
_FINAL_
24-04-
12_SML.
pdf 

https://i
ssuu.co
m/lavo
nlus6/d
ocs/zoo
_-
_dieci_
an-
ni_di_bu
io 
http://c
uria.eur
opa.eu/
ju-
ris/docu
ment/d
ocu-
ment.jsf
?text=&
do-
cid=492
83&pag
eIn-
dex=0&
doclan
g=EN&

Milieu Ltd  
Brussels  

Evaluation Study to support the evaluation of the Zoos Directive 
Annexes to Final Report – August 2017/ 366 

 
 
 
 
 
 
 
National  Case law 

Y 

Y 

Y 

National  Case law 

Y 

Y 

mode=l
st&dir=&
occ=firs
t&part=
1&cid=1
394853  
http://w
ww.cort
ecos-
tituzion
ale.it/a
ction-
Scheda
Pronun-
cia.do?
an-
no=200
8&num
ero=220 

http://w
ww.cort
ecos-
tituzion
ale.it/a
ction-
Scheda
Pronun-
cia.do?
an-
no=200
8&num
ero=387 

The Valle d’Aosta Region - which is an autonomous region with 
special statute and powers - was also implementing the Di-
rective 1999/22 with a regional act: The regional act n. 
34/2006. The issue at stake was to verify whether the Valle 
d’Aosta, being a special region, had a competence to also 
implement a European piece of legislation. According to the 
Italian government, the Valle d’Aosta Region, despite the 
special powers recognised by the Italian constitution, had no 
competences to implement a European directive whose gen-
eral aim is the protection of the environment. The latter being 
in fact a state competence, and not a regional one. In the 
end, the constitutional judge did not decide on the matter, 
since the Italian government failed to specify which division of 
powers between state and regions were breached by the 
regional act of Valle d’Aosta.  
In Italy the Directive 1999/22 has been transposed and imple-
mented by the Italian legislative decree 21 march n. 73/2005. 
The province of Bolzano - which is an autonomous province 
with special statute and powers - was also implementing the 
Directive 1999/22 with a provincial act: the provincial act n. 
10/2007. According to the Italian government, some articles of 
the act issued by the province of Bolzano were not in line were 
the provisions of the Italian legislative decree n.73/2005, and 
consequently with the Directive.  The issue at stake was to 
verify whether the province of Bolzano, being a special region, 
had a competence to legislate in matters such as environment 
and zoos. According to the constitutional judge, the State is 
the only territorial entity which has competence to legislate in 
matter of environment and zoos, therefore the articles of the 
provincial at n. 20/2007 not in line with the Italian legislative 
decree 73/2005 were declared invalid.  

https://
www.e-

National 

Legally 
binding 

Y 

Y 

The Order stipulates licensing and inspection of zoos, referring 
to a) conservation research and training, b) public education 

Evaluation Study to support the evaluation of the Zoos Directive 
Annexes to Final Report – August 2017/ 367 

Case 220/2008 – Italian Gov-
ernment (representing the Italian 
State) vs Valle d’Aosta Region 

Case 387/2008 - Italian Govern-
ment (representing the Italian 
State) vs Provincia di Bolzano 

LT (Lithuania) 
Order No. 298, 04/06/02 
[amended in 25/09/02 and 

Milieu Ltd  
Brussels  

 
 
 
 
 
 
 
 
  
  
  
  
  
  
  
  
  
 
 
 
and awareness; c) accommodating animals under satisfactory 
conditions; d) preventing escape and ecological threats and 
e) record keeping.  

Y 

Y 

The standards for the keeping of wild animals in zoos are in-
cluded in this law, including guidelines for housing. 

Y 

Y 

The Order prescribes how to take wild animals from the wild to 
form zoological collections and on registration of zoological 
collections. 

25/03/03](Licensing and inspec-
tions of zoos) (Wild Fauna Rules) 

Order No. 346, 27/06/02 (Keep-
ing Wild Animals in Zoos) 

Order No. 250/224, 16/05/02 
(Taking of Wild Animals from the 
Wild to Form Zoological Collec-
tions and on Registration of Zoo-
logical Collections) 

docu-
ment 

Legally 
binding 
docu-
ment 

Legally 
binding 
docu-
ment 

National 

National 

tar.lt/po
rtal/lt/le
galAct/
TAR.A6F
660FEBB
B1 
https://
www.e-
tar.lt/po
rtal/lt/le
galAct/
TAR.F31
219F5A
CFC 
https://
www.g
oogle.nl
/url?sa=
t&rct=j&
q=&esrc
=s&sour
ce=we
b&cd=1
&cad=rj
a&uact
=8&ved
=0ahUK
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t2trQAh
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oKHQXj
CW8QF
ggdMA
A&url=h
ttp%3A
%2F%2F
www.lm
zd.lt%2F
files%2F
upload-

Milieu Ltd  
Brussels  

Evaluation Study to support the evaluation of the Zoos Directive 
Annexes to Final Report – August 2017/ 368 

 
 
 
 
 
 
 
 
 
BornFree, 2011, EU Zoo Inquiry 
Report, Lithuania 

Eurogroup, 2006, Report on the 
implementation of the EU Zoo 
Directive 

load-
ed%2Ft
aisykles-
2011.pd
f&usg=
AFQjCN
F5hEjJV
0pMDq
cGTKWi
zzu5Q6E
UUA  
http://w
ww.bor
nfree.or
g.uk/zo
ore-
ports/Lit
huania-
en/pag
es/EU_Z
OO_IN
QUIRY_L
ITHUA-
NIA_EN
G.pdf 
https://
www.rs
pca.org
.uk/Ima
geLoca
ca-
tor/Loc
ateAs-
As-
set?ass
et=doc
ument&
as-
setId=12
3271139

National  Reports 
and stu-
dies 

Y 

Y 

The investigation evaluated five zoos in Lithuania, two munici-
pally-owned, Lietuvos Zoologijos Sodas (‘Lithuanian Zoo’) and 
the Lithuanian Sea Museum, and three; Grūto Park, the Natu-
ralist Centre Mini Zoo (‘Mini Zoo’) and Lithuania’s Young Natu-
ralists’ Centre, are privately owned. 

EU 

Reports 
and stu-
dies 

Y 

Y 

The report contains information about the implementation of 
the Zoos Directive in several European countries including Lith-
uania. It refers to legislation, competent authorities, zoos and 
licenses, and use of guidelines. 

Milieu Ltd  
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NL (Netherlands) 
Animal Act 

Evaluation of Animal Act  

Artis, 2015, Annual Report 2015 

9501&m
ode=pr
d 

http://w
et-
ten.ove
rheid.nl/
BWBR00
30250/2
015-02-
01 
https://
www.rijk
sover-
heid.nl/
docu-
men-
ten/rap
por-
ten/200
9/04/01
/evalua
tie-van-
het-
dieren-
tuinen-
besluit-
eindrap
drap-
port 
http://w
ww.artis
.nl/nl/fo
oter/ov
er-
natura-
artis-
magis-
tra/jaar

National 

Legally 
binding 
docu-
ment 

Y 

Y 

Adoption in national legislations of provisions on a) conserva-
tion research and training, b) public education and aware-
ness; c) accommodating animals under satisfactory condi-
tions; d) preventing escape and ecological threats and e) 
record keeping 

National  Reports 
and stu-
dies 

Y 

Y 

Y 

Evaluation study, concerning the adoption of Zoos Directive, 
assessing issues with derogation, delay in licensing, and costs 
involved. 

National  Reports 
and stu-
dies 

Description of activities of the zoo in 2015, and the collection 
of animals  

Milieu Ltd  
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Evaluation Study to support the evaluation of the Zoos Directive 
Annexes to Final Report – August 2017/ 370 

 
 
 
  
  
  
  
  
  
  
  
  
 
 
 
 
 
 
 
 
 
 
ABN-AMRO, 2014, Sectorupdate 
– Leisure: Voor dierentuinen valt 
een wereld te winnen 

PL (Poland) 
Nature Protection Act on Envi-
ronmental Protection, Pursuant to 
Article 69(1) points 1-5 

Regulation of the Minister of the 
Environment of 16 April 2003 on 
the detailed conditions for the 
breeding and husbandry of re-
spective groups of species in 
zoological gardens 
(Rozporządzenie Ministra 
Środowiska z dnia 16 kwietnia 
2003 r. w sprawie szcze-
gółowych warunków dla chowu 
i hodowli poszczególnych grup 
zwierząt w ogrodach zoo-
logicznych) (RZ04/2003) 
Regulation of the Minister of the 
Environment of 20 December 

Milieu Ltd  
Brussels  

National  Reports 
and stu-
dies 

Y 

Y 

Short study with general data on the zoo sector, with visitors 
numbers 

National 

National 

Legally 
binding 
docu-
ment 

Legally 
binding 
docu-
ment 

Y 

Y 

Y 

Y 

This is the main Polish legislation transposing Directive 
1999/22/EC. Article 69(1) points 1-5 includes provisions on: a) 
conservation research and training; b) public education and 
awareness; c) accommodating animals under satisfactory 
conditions; d) preventing escape and ecological threats; and 
e) record keeping 
The regulation provides detailed conditions for the breeding 
and husbandry of different species in zoological gardens. 

versla-
gen/ 
https://i
nsights.
ab-
namro.
nl/2014/
07/diere
ntuinen-
ge-
baat-
bij-
innova-
tie-
aan-
bod-en-
prijszet-
ting/ 

Legisla-
tion 

http://isi
p.sejm.
gov.pl/
De-
tailsServl
et?id=W
DU2003
0990916  

http://is
ap.sejm

National 

Legally 
binding 

Y 

Y 

The regulation provides detailed conditions for the husbandry 
and keeping of different species in zoological gardens. 

Evaluation Study to support the evaluation of the Zoos Directive 
Annexes to Final Report – August 2017/ 371 

 
 
 
 
 
 
  
  
  
  
  
  
  
  
  
 
 
 
 
 
 
 
 
 
docu-
ment 

EU 

Reports 
and stu-
dies 

Y 

Y 

Y 

The report is a publication about welfare of animals in Zoos 
and EU legal standard. Is discusses the role of zoos, the EU legis-
lative framework and policies, national regulations. summarises 
the Born Free Polandcountry report, and the functioning of the 
British zoo licensing system. 

National 

Scientific 
literature 

Y 

The paper describes the welfare of bears in captivity in Poland, 
which became a big issue of concern when a case of a bear 
being ill-treated became a high-profile case in the media . It 
describes that major welfare problems were identified. 

EU 

Scientific 
literature 

Y 

The paper describes legal standards on animal welfare across 
the EU. 

2004 on the conditions for the 
husbandry and keeping of re-
spective groups of species in 
zoological gardens 
(Rozporządzenie Ministra 
Środowiska z dnia 20 grudnia 
2004 r. w sprawie warunków 
hodowli i utrzymywania 
poszczególnych grup gatunków 
zwierząt w ogrodzie zoo-
logicznym) (RZ12/2004) 
The Welfare of Animals in Zoos 
and EU Legal Standards; Warsaw 
2014 

Maślak R., et al., 2015, ‘The Wel-
fare of Bears in Zoos: A Case 
Study of Poland’ in Journal of 
Applied Animal Welfare Sci-
ence, vol 19, 2016 
Gardockam T. et al., 2014, The 
Welfare of Animals in Zoos and 
EU Legal Standards 

.gov.pl/
De-
tailsServl
et?id=W
DU2005
0050032  

https://
www.a
cadem-
ia.edu/
3009273
8/The_
Wel-
fare_of_
Ani-
mals_in_
Zoos_an
d_EU_Le
gal_Sta
ndards 

https://
www.a
cadem-
ia.edu/
3009273
8/The_
Wel-
fare_of_
Ani-
mals_in_

Milieu Ltd  
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Zoos_an
d_EU_Le
gal_Sta
ndards  
http://w
ww.bor
nfree.or
g.uk/zo
ore-
ports/P
oland-
en/pag
es/BFF_
EZR_PO
LAND_FI
NAL_SM
L_09-11-
11.pdf  
http://w
ww.pols
kie-
zoo.info
/ 

Regula-
tion 

BornFree, Endcap, 2011, An 
evaluation of the implementa-
tion and enforcement of the EC 
Directive 1999/22, relating to the 
keeping of wild animals in Zoos, 
Poland  

Basta!, 2014, Polish NGO  

PT (Portugal) 
Decree-Law No. 59/2003 (Diaro 
da republica I serie-A No. 77), 
rectified by Decree-Law 
104/2012 

National  Reports 
and stu-
dies 

Y 

Y 

Information on how did 8 Zoos in Poland implemented the EC 
Directive 1999/22. The report describes shortcomings of the 
Polish licensing and inspection system, and animal welfare 
problems identified in zoos visited. 

National  Media 

Y 

Y 

BASTA! has prepared a video illustrating bad housing condi-
tions and welfare problems of animals in Polish zoos. In 2013 
and 2014 activists led by Szczecin Initiative for Animal Welfare 
BASTA!, visited over 20 zoos in Poland. 

National 

Legally 
binding 
docu-
ment 

Y 

Y 

The Decree-law 104/2012  amends Decree-Law No 59/2003 of 
1 April, corrected by the Declaration of Rectification no. 7-D / 
2003, of May 31, which transposed the Zoos Directive 1999/22 
/EC, with regard to: A) Of Decree-Law no. 92/2010, of July 26, 
which Principles and rules to simplify the free movement of 
access and exercise of service activities carried out In national 
territory, which transposed into the legal order Directive 
2006/123 / EC of the European Parliament and of the Parlia-
ment and of the Council of 12 December on In the internal 
market; and B) Law No. 9/2009, of March 4, which transposed 
to Directive 2005/36 / EC of the European Parliament and of 
the European Parliament and of the Council of 7 September 
On the recognition of professional qualifications, and Directive 
2006/123 / EC of the European Parliament and of the Council 
of 12 December, which adapts certain Directive on the free 
movement of persons, in particular accession of Bulgaria and 

Milieu Ltd  
Brussels  

Evaluation Study to support the evaluation of the Zoos Directive 
Annexes to Final Report – August 2017/ 373 

 
 
 
 
 
 
 
 
 
  
  
  
  
  
  
  
  
  
 
 
 
National 

Scientific 
literature 

Y 

Romania. 

Y  A technique for ex-situ breeding of endangered fish species in 

controlled conditions is presented, illustrating contribution of 
Portuguese zoos to conservation of biodiversity.  

National 

Scientific 
literature 

Y 

Y  A technique for ex-situ breeding of endangered fish species 

cyprinids (Carla Sousa-Santos, 2013) in controlled conditions is 
presented, illustrating contribution of Portuguese zoos to con-
servation of biodiversity 

National  Reports 
and stu-
dies 

National  Reports 
and stu-
dies 

Y 

Y 

Y 

Extensive study on the implementation of the Zoos Directive in 
Portugal by assessing 10 of Portugal zoos. Findings address in 
particular legal issues and animal welfare problems.  

Y 

Information on some of the Zoological Gardens and History of 
Zoos in Portugal. 

An Efficient Technique for the 
Captive Breeding of an Endan-
gered Freshwater Fish Salaria 
fluviatilis (Pisces: Blenniidae), 
with a Description of Its Ontoge-
ny; J World aquaculture society 
2010: 41 (49-56) 

Ex situ reproduction of Portu-
guese endangered cyprinids in 
the context of their conservation, 
Sousa-Santos, C., Gil, F. & Alma-
da, V.C. Ichthyol Res (2014) 61: 
193 

BornFree, Endcap 2011, An eval-
uation of the implementation 
and enforcement of the EC Di-
rective 1999/22, relating to the 
keeping of wild animals in Zoos, 
Portugal 

Paterok O, Livet J, 2007, Zoologi-
cal collections in Portugal (Part1, 
International Zoo News, Vol 54, 
No.7, 2007, pp 388-402 

http://o
nlineli-
brary.wil
ey.com
/doi/10.
1111/j.1
749-
7345.20
09.0033
2.x/abst
ract 
http://li
nk.sprin
ger.co
m/articl
e/10.10
07/s102
28-013-
0383-6 
http://w
ww.bor
nfree.or
g.uk/zo
ore-
ports/P
ortugal-
en/  
http://w
ww.rhin
ore-
source-
cen-
ter.com
/pdf_file
s/119/11
9971727
9.pdf  

Conservation projects aquario 
Vasco de Gama ( PROJECTO DE 

National  Reports 
and stu-

Y 

Y 

The document illustrates how Vasco da Gama Aquarium will 
assist in the reproduction of endemic fish at greater risk, provid-

Milieu Ltd  
Brussels  

Evaluation Study to support the evaluation of the Zoos Directive 
Annexes to Final Report – August 2017/ 374 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
CONSERVAÇÃO EX-SITU DE OR-
GANISMOS FLUVIAIS)(our survey) 

Scientific conservation pro-
gramme Jardim Zoo (Programas 
de Conservacao)(our study) 
Education programmes at Esta-
ção Litoral da Aguda (our study) 

dies 

National  Reports 
and stu-
dies 

National  Reports 
and stu-
dies 

Y 

Y 

ing facilities and technical personnel and providing infor-
mation, illustrating the contribution of this Acquarium to con-
servation of biodiversity. 
The document illustrates conservation programmes underta-
ken at Jardim Zoo 

The document illustrates education programmes undertaken 
at Estação Litoral da Aguda 

Y 

Y 

Milieu Ltd  
Brussels  

Evaluation Study to support the evaluation of the Zoos Directive 
Annexes to Final Report – August 2017/ 375 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
ANNEX V – GLOSSARY 

Biodiversity or biological diversity: The diversity of life in all its forms—the diversity of species, of 
genetic variations within one species, and of ecosystems (CBD, CEPA Toolkit Glossaries). 

Conservation: Means a series of measures required to maintain or restore the natural habitats and the 
populations of species of wild fauna and flora at a favourable status. (Habitats Directive, 2007 version)  

Conservation of biodiversity: The management of human interactions with genes, species and eco-
systems so as to provide the maximum benefit to the present generation while maintaining their poten-
tial to meet the needs and aspirations of future generations; encompasses elements of saving, studying 
and using biodiversity. (CBD) 

Environmental  Enrichment:  The  husbandry  provision  of  species-specific  opportunities  within  an 
animal’s environment to enable it to express a diversity of desirable and natural behaviours. (Hosey et 
al. 2009) 

Ex-situ conservation: The conservation of species outside their natural habitats. / The conservation of 
components of biological diversity outside their natural habitats. (CBD) 

Education:  Organised  and  sustained  communication  designed  to  bring  about  learning.  Learning  is 
taken as any change in behaviour, information, knowledge, understanding, attitudes, skills, or capabili-
ties which can be retained and cannot be ascribed to physical growth or to the development of inherit-
ed behaviour patterns. (UNESCO, OECD, 2001)  

EEP: The EEP is the most intensive type of population management for a species kept in zoos part of 
the European Association of Zoos and Aquaria (EAZA). Each EEP has a coordinator (someone with a 
special interest in and knowledge of the species concerned, who is working in an EAZA zoo or aquar-
ium). He or she is assisted by a Species Committee. The coordinator has many tasks to fulfil, such as 
collecting information on the status of all the animals of the species for which he or she is responsible 
kept in EAZA zoos and aquariums, producing a studbook, carrying out demographic and genetic anal-
yses, and producing a plan for the future management of the species. Together with the Species Com-
mittee, recommendations are made each year on which animals should breed or not breed, which indi-
vidual animals should go from one zoo to another, and so on. (EAZA website) 

ESB: The ESB is less intensive than the EEP programme. The studbook keeper who is responsible for 
a certain ESB collects all the data on births, deaths, transfers, etc., from all the EAZA zoos and aquar-
iums  that  keep  the  species  in  question.  These  data  are  entered  in  special  computer  software  pro-
grammes,  which  allow  the  studbook  keeper  to  carry  out  analyses  of  the  population  of  that  species. 
EAZA zoos may ask the studbook keepers for recommendations on breeding or transfers. By collect-
ing  and  analysing  all  the  relevant  information  on  the  species,  the  studbook  keeper  can  judge  if  it  is 
doing well in EAZA zoos and aquariums, or if maybe a more rigid management is needed to maintain 
a healthy population over the long term. In that case, the studbook keeper may propose that the species 
be managed as an EEP programme. (EAZA website) 

Fauna: Animals of any particular region or time. (General definition) 

In-situ conservation: The conservation of species in their natural surroundings. / The conservation of 
ecosystems and natural habitats and the maintenance and recovery of viable populations of species in 
their natural surroundings and, in the case of domesticated or cultivated species, in the surroundings 
where they have developed their distinctive properties. (CBD) 

Invasive  alien  species:  an  alien  species  whose  introduction  or  spread  has  been  found  to  threaten  or 
adversely  impact  upon  biodiversity  and  related  ecosystem  services.  (Regulation  1143/2014  on  inva-
sive alien species) 

International  Species  Information  System  (ISIS):  Network  collecting  and  sharing  knowledge  on 
animals and their environments. (ISIS website) 

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International Union for Conservation of Nature (IUCN): IUCN is a membership Union composed 
of government and civil society organisations.  IUCN works across a range of themes related to con-
servation, environmental and ecological issues. (IUNC website) 

One-off costs/investments: Costs faced by actors targeted by regulation since they have to adjust and 
adapt to the changes legal rule. All these costs are not likely to be borne by the targeted stakeholder on 
a regular basis in the future: to the contrary, they occur only once, after the entry into force of the new 
regulation. ("Assessing the Costs and Benefits of Regulation", CEPS – Economisti Associati Study for 
the European Commission) 

Pest and vermin: Are intended as vectors or reservoirs of disease that can adversely affect zoo ani-
mals (“EU Zoos Directive, Good  Practices Document”,  VetEffecT study for the European  Commis-
sion) 

Public awareness: brings the issues relating to biodiversity to the attention of key groups who have 
the power to influence outcomes. Awareness is an agenda setting and marketing exercise helping peo-
ple to know what and why this is an important issue, the aspirations for the targets, and what is and 
can be done to achieve these. (CBD CEPA Toolkit Glossaries) 

Record keeping system: System supporting the collection of animal records. Under the scope of the 
Zoos Directive, animal records serve two well-defined functions: i) they are a source of information 
for  competent  authorities  during  inspection  and  authorization,  and;  ii)  they  are  essential  for  a  zoo 
when planning and executing conservation, education and veterinary care programmes. (adapted from 
“EU Zoos Directive, Good Practices Document”, VetEffecT study for the European Commission) 

Recurrent costs: Those types of substantive compliance costs that are sustained by the targeted stake-
holders on a regular basis as a result of the existence of a legal rule that imposes specific periodic be-
haviours. ("Assessing the Costs and Benefits of Regulation", CEPS – Economisti Associati Study for 
the European Commission) 

Species:  Often  defined  as  a  group  of  related  organisms,  or  a  set  of  animals  or  plants  in  which  the 
members have similar characteristics to each other and can breed with each other. (General definition) 

Training: Intended as the process of learning the skills needed for a particular job or activity. (General 
definition) 

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ANNEX VI – TARGETED SURVEYS REPORT 

1 

INTRODUCTION 

In line with the Better Regulation Guidelines on Stakeholder Consultation, this report aims at summa-
rizing  the  methodology  and  results  of  the  targeted  surveys  of  stakeholders  undertaken  as  one  of  the 
consultation activities for the study to support the evaluation of the Zoos Directive. 

Within the consultation strategy developed for this study, the targeted surveys were part of the overall 
consultation strategy consisting of: 

  Targeted surveys addressed to competent authorities (CAs), zoos federations, non-governmental 
organisations  (NGOs)  and  zoo  operators  from  the  14  selected  Member  States  (17  August  –  28 
November 2016); 

  Open public consultation (15 September – 8 December 2016); 
 

In-depth  interviews  with  CAs,  zoos  federations,  NGOs  and  zoo  operators  from  the  14  selected 
Member States (18 October – 12 December 2016).  

This targeted consultation comprised, first, the questionnaire-based online surveys targeted to specific 
stakeholder  groups,  and  secondly  follow-up  interviews  to  complement  the  information  collected 
through the targeted surveys, and make sure that the points raised by stakeholders were fully under-
stood (see Interviews Report published on the REFIT website467). 

The  targeted  online  questionnaires  aimed  at  collecting  detailed,  quantitative  and  qualitative,  infor-
mation to support the answers to the evaluation questions. The questionnaires focused on the collec-
tion of detailed information and data, especially on the implementation of the Directive (the conserva-
tions measures undertaken by the zoos and actions taken by the CAs and enforcement authorities), and 
the costs and benefits brought by the Directive. 

The questionnaires were discussed during a Steering Group Meeting on 5 July 2016 and revised ac-
cording to the members' comments.  

The following sections present information on: 

  The stakeholders targeted and mapped; and the reach out strategy; 
  The questionnaires; 
 
  The publication and use of answers. 

Information on respondents; 

467 http://ec.europa.eu/environment/nature/legislation/refitzoosdirective/index_en.htm  

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2 

TARGETED STAKEHOLDERS 

The  questionnaires  targeted  all  stakeholder  categories  in  the  14  selected  Member  States  and  at  EU 
level: 

1.  Member States Competent Authorities (MSCAs); 
2.  NGOs, zoos federations, and experts at national and EU level468; 
3.  Zoo operators. 

Stakeholders to be contacted for the survey were identified via different methods:  

  Zoos: mainly through desk research by the national experts drafting the country fiches; 
  MSCAs, NGOs, Federations and Scientific experts: through desk research, but also with input 

from EU level stakeholders (EAZA and BornFree469) and from the Commission.  

The tables presented in Annex I list all contacted stakeholders for each stakeholder group. In total, the 
study team contacted: 19 MSCAs; 53 NGOs, federations and experts; 19 EU and international stake-
holders; and 514 zoos. 

468 The questionnaire targeting these stakeholders is hereinafter referred to as ‘high level questionnaire’.  
469 An initial list of relevant stakeholders identified through desk research was communicated to the two organisations for completion.  

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3 

TARGETED QUESTIONNAIRES AND OUTREACH 

Questionnaires 
The  questionnaires  were  structured  around  the  evaluation  questions,  sub-questions  according  to  the 
evaluation framework. The links between questions and evaluation criteria were guided and then illus-
trated in the correspondence matrix in order to: 

 

 

 

guarantee the added value of each question of the surveys to the evaluation;  
facilitate the comparison of results and; 
ensure the usability of collected data. 

A major focus was placed on those evaluation questions for which the information is likely to be par-
ticularly  scarce  (such  as  state  of  play,  effectiveness,  efficiency  and  EU  added  value).  The  question-
naire for the targeted survey included closed questions, to facilitate comparability and quantification, 
and open questions for explanations and qualitative information. The questionnaires were also tailored 
to each different types of respondents, e.g., while MSCAs were asked to provide information on the 
transposing legislation, zoos were asked questions in relation to their activities, in order to measure the 
level of implementation of the Article 3 conservation measures.   

We used the online service of EU survey. The three different questionnaires are available on the RE-
FIT website470. 

Dissemination 
Stakeholders  were  informed  about  the  scope  and  indicative  timeline  of  all  consultation  activities  in-
cluding public consultation end of June 2016, 6 weeks before the first targeted questionnaire was sent. 

Upon approval by the Commission, the survey was launched on 11 August 2016, through emails with 
an introduction to the survey, a guidance document on the functioning of the survey system and spe-
cific  links  to  the  relevant  surveys  depending  on  the  stakeholders’  type  (MSCAs,  zoo  operators  or 
NGOs and zoos federations).  

In order to reach a large panel of zoos operators, the questionnaire addressed to zoos was translated in 
the national languages of the 14 selected Member States. Moreover, federations and NGOs were en-
couraged to disseminate the invitation to participate to the surveys to all their members and other in-
terested stakeholders.  

A follow up through emails and phone was carried out, especially with: 

 

 

non-EAZA zoos to ensure a more balanced representation of zoos members and not members of 
the association (see below); and all zoos in countries where the response rate was particularly low 
(e.g. France and Spain) 
the stakeholders selected for the interviews, in order to encourage the completion of the survey 
before the interview.  

Considering the limited availability of stakeholders during the summer period and the slow response 
rate  of  institutional  stakeholders  such  MSCAs,  the  initial  deadline  of  the  survey  (i.e.  12 September 
2016)  was  extended  several  times  between  September  and  November.  The  questionnaires  were  un-
published for zoos and federations/NGOs/experts on 14 November, and for MSCAs on 28 November 
upon submission of the last missing contribution from national authorities.  

470 http://ec.europa.eu/environment/nature/legislation/refitzoosdirective/index_en.htm  

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4  RESPONDENTS 

The CAs of the 14 selected Member States responded to the survey. Obtaining answers from some of 
the authorities required close follow-up and, in some cases, involvement of the European Commission. 

Table 43: Overview of MSCAs responding to the questionnaire 

Member 
States 

BE 

BG 

CY 

CZ 

DK 

FR 

IT 

LT 

DE 

IE 

NL 

PL 

PT 

ES 

Stakeholder type 

Competent authori-
ties 
Competent authori-
ties 
Competent authori-
ties 
Competent authori-
ties 
Competent authori-
ties 
Competent authori-
ties 
Competent authori-
ties 
Competent authori-
ties 
Competent authori-
ties 
Competent authori-
ties 
Competent authori-
ties 
Competent authori-
ties 
Competent authori-
ties 
Competent authori-
ties 

Source: Our survey  

Animal Welfare - Walloon region and Flanders 

Organisation 

Ministry of Environment and Water; National Nature Protection 
Service Directorate 
Ministry of Agriculture, Natural Resources and Environment, Animal 
Health & Welfare Division 
Ministry of the Environment  

Ministry of Environment and Food; Danish Veterinary and Food 
Administration 
Ministry of Environment, Energy and Sea; Sub- Directorate for the 
Protection and promotion of species and their environment 
Ministry of Environment, Land and Sea Protection 

Ministry of Environment of the Republic of Lithuania 

Federal Ministry of Environment, Nature Protection and Nuclear 
Safety, Protection of Species, Dept. NI3 
National Parks and Wildlife Service, Department of Arts, Heritage & 
the Gaeltacht 
Ministry of Economic Affairs, Directie Dierlijke Agroketens en Die-
renwelzijn 
Ministry of Environmental Protection   

Ministry of Agriculture, General Directorate for Food and Veterinary 
services 
Ministry of Agriculture 

Regarding  the  survey  addressed  to  zoos  federations  and  NGOs,  27  stakeholders  replied,  divided  as 
illustrated in the table below. 

Table 44: Overview of types of respondents to the high-level questionnaire 

Level 

Federations 

NGOs 

Con-
tact-
ed 

Re-
spond-
ing 

Response 
rate (%) 

EU 
International 
National 
Source: Our survey  

4 
3 
15 

2 
1 
10 

50% 
33% 
67% 

Con-
tact-
ed 

3 
1 
35 

Re-
spond-
ing 

3 
0 
10 

Response 
rate (%) 

100% 
0% 
29% 

Authorities and ex-
perts471 

Con
tact
ed 
5 
3 
2 

Re-
spond-
ing 

0 
0 
1 

Re-
sponse 
rate (%) 
0% 
0% 
50% 

At national level, zoos federations and NGOs were from the following countries: 

471 CBD and CITES Secretariats were considered as “Authorities” and are counted in this table under the “Authorities and experts” category. 

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Table 45: Geographical distribution of federations and NGOs responding to the questionnaire 

BE 

CY 

DE 

DK 

ES 

FR 

IT 

NL 

PT 

Federations 
NGOs 
Source: Our survey  

- 
1 

- 
1 

2 
2 

1 
- 

1 
2 

1 
1 

- 
1 

2 
- 

1 
- 

Organisations  active  in  the  field  of  biodiversity  conservation  (IUCN,  CITES,  CBD)  were  non-
responsive to repeated invitations to contribute to the study. 

Regarding the involvement of zoos, in order to maximise the outreach, we contacted a large number of 
zoo operators (i.e. 514 zoos which represent around 25%472 of the total registered or recognised zoos 
in the 14 Member States) based on the information gathered during the inception phase (desk research 
and lists from CAs473). We achieved the  original goal of reaching a response rate between 15% and 
20% of all contacted zoos. 70 zoos from the 14 Member States selected as case studies have replied to 
the survey. 12 additional zoos responded only by direct emails474. The total response rate was therefore 
16%. 
In terms of representativeness of the responses, most of the zoos that have replied are part of EAZA, 
or  other  national  federations.  EAZA  zoos  are  overrepresented  among  the  respondents  to  the  survey 
(EAZA zoos represent nearly 20% of the total number of licensed zoos475 in the 14 selected Member 
States, and 52% of the respondents). The difficulties relating to representativeness are detailed in Sec-
tion 3.5.1.2 below. 

However, the survey captured the point of view of also covering zoos affiliated to national federations 
as well as zoos with no membership (6 indicated no membership, and 11 did not answer the question). 
Similarly,  the  replies  represent  zoos  of  different  sizes,  especially  small  establishments  (between  10 
and 49 employees), and include a number of very small zoos, with less than 10 employees (Figure 6). 
The presence in the sample of small zoos is particularly important, since one of the objectives of the 
evaluation  is  assessing  whether  small  zoos  might  face  more  difficulties  in  complying  with  the  re-
quirements  of  the  Zoos  Directive.  To  this  purpose,  the  questionnaire  was  translated  in  the  national 
languages of the 14 Member States in the scope of the analysis and this strategy resulted successful in 
increasing the outreach of the survey and enhancing the participation of smaller operators. 

Finally,  the  respondents  to  the  survey  represent  both  private  and  public  establishments,  and  entities 
with mixed ownership.  

The charts below present the main features of the sample of zoos that replied to our survey.  

Figure 43: Distribution of the zoos having replied the survey by membership,number of employees and type of entity 
(in absolute numbers) 

Membership 

Number of employees 

37 

40

30

20

10

0

16 

11 

6 

EAZA

Other
Federation

No answer

NO
Federation

40

30

20

10

0

30 

21 

10 

10-49

50-249

Less than 10

472 Please note that, given the lack of precise information on the number of zoos in each Member State, this number represents an approxima-
tion.  
473 MSCAs were asked to provide information and contact details of the zoos, possibly recorded to the purposes of the licensing system. In 
parallel, the mapping was conducted through desk research, and with input of other stakeholders.  
474 Those zoos did not reply through the survey but highlighted their interest or lack of interest on the Directive by emails. 
475 As reported by MSCAs in our survey: 195 EAZA members of 1006 zoos 

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Type of Entity 

30

25

20

15

10

5

0

6 

1 

Charity /
foundation

Mix Private /
Charity

9 

Other

24 

19 

8 

3 

Private – 
operating a 
single zoo 

Private – 
operating 
several zoos 

Public – run by 
local authority 

Public – run by 
national 
authority 

Source: Our survey  

The  geographical  distribution  of  responding  zoos  is  illustrated  below  (together  with  the  number  of 
zoos contacted, and the related response rate). 

Table 46 Geographical representation of zoos responding to the survey 

Countries 

BE 

BG  CY 

CZ 

DE 

DK 

ES 

FR 

IE 

IT 

LT 

NL 

PL 

PT 

Nb of contacted zoos 

Nb of responding zoos 

29 

7 

7 

2 

6 

1 

19 

82 

26 

20 

100 

17 

67 

6 

17 

0 

7 

10 

4 

4 

8 

1 

30 

21 

22 

2 

1 

8 

Response rate (%) 

24%  29%  17%  35%  21%  0%  35%  10%  23%  6%  12%  7%  5%  36% 

Source: Our survey  

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5  USE OF ANSWERS 

In line with the Better Regulation Guidelines on Stakeholder Consultation, respondents to the surveys 
were provided with three options regarding the publication of their answers, i.e. whether they replies: 

  Can be published, including your name or that of your organisation (I consent to publication of all 
information  in  my  contribution  and  I  declare  that  none  of  it  is  under  copyright  restrictions  that 
prevent publication) 

  Can be published in an anonymous way (I consent to publication of all information in my contri-
bution except my name/the name of my organisation, and I declare that none of it is under copy-
right restrictions that prevent publication) 

  Cannot  be  published  but  only  used  for  statistical  and  analytical  purposes,  in  the  context  of  the 

present study. 

The answers of respondents who have not required total anonymity were published by the European 
Commission through the webpage dedicated to the evaluation. 

The answers provided by the surveys were integrated in the analysis of the evaluation criteria accord-
ing to the evaluation framework (see main Study Report). 

CONTACTED STAKEHOLDERS 

Table 47: Competent authorities 

MS 
BE 

Organisation 

Animal Welfare - Brussels region 

BE 

Animal Welfare - Walloon region 

MS 
IT 

LT 

BE 

Animal Welfare Services  - Flemish region  

DE 

BG  Ministry of Environment and Water; Na-
tional Nature Protection Service Direc-
torate 

IE 

Organisation 

Ministry of Environment, Land and Sea Pro-
tection 
Ministry of Environment of The Republic of 
Lithuania 
Federal Ministry of Environment, Nature Pro-
tection and Nuclear Safety, Protection of 
Species, Dpt NI3 
National Parks and Wildlife Service, Depart-
ment of Arts, Heritage & the Gaeltacht 

CY  Ministry of Agriculture, Natural Resources 

NL  Ministry of Economic Affairs, Directie Dierlijke 

Agroketens en Dierenwelzijn 

Ministry of Environmental Protection   
Główny Inspektorat Weterynarii 

Ministry of Agriculture, General Directorate for 
Food and Veterinary services 
Ministry of Agriculture 

and Environment, Animal Health & Welfare 
Division 

CZ  Ministry of the Environment  
DK  Ministry of Environment and Food; Danish 
Veterinary and Food Administration 

DK  Ministry of Environment and Food 

FR  Ministry of Environment, Energy and Sea; 

Sub- Directorate for the Protection and 
promotion of species and their environ-
ment 

FR  Ministry of Environment, Energy and Sea; 

Sub- Directorate for the Protection and 
promotion of species and their environ-
ment, Flora and Fauna Dpt 

PL 
PL 

PT 

ES 

Table 48: NGOs and zoos federations 

N
b 

Member 
States 

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Organisation 

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Member 
States 

N
b 
1  BE 
2  BE 
3  BE 
4  BE 
5  BE 

6  BG 
7  BG 
8  CY 
9  CY 
10  CZ 

11  CZ 
12  CZ 
13  DK 

14  FR 
15  FR 

16  FR 
17  FR 

18  FR 

19  FR 
IT 
20 

IT 
21 
IT 
22 
IT 
23 
24 
IT 
25  LT 
26  LT 
27  LT 
28  DE 

29  DE 

30  DE 

31  DE 

32  DE 
33  DE 
34  DE 
35 
36 
37 
38 
39 
40 

IE 
IE 
IE 
IE 
IE 
IE 

41 

IE 

42  NL 

43  NL 

Stakeholder type 

Organisation 

NGO 
NGO 
NGO 
NGO 
Zoos organisa-
tion 
NGO 
NGO 
NGO 
NGO 
Zoos organisa-
tion 
NGO 
NGO 
Zoos organisa-
tion 
NGO 
NGO 

NGO 
Zoos organisa-
tion 
Zoos organisa-
tion 
NGO 
Zoos organisa-
tion 
NGO 
NGO 
NGO 
NGO 
NGO 
NGO 
NGO 
Zoos organisa-
tion 
Zoos organisa-
tion 
Zoos organisa-
tion 
Keeper Organi-
sation 
NGO 
NGO 
NGO 
NGO 
NGO 
NGO 
NGO 
NGO 
Zoos organisa-
tion 
Keeper organisa-
tion 
Zoos organisa-
tion 
NGO 

GAIA 
Dauphin libre 
Natuurpunt 
Natagora 
Zoovaria 

Four Paws 
Green Balkans 
Animal Party Cyprus  
ARC Cyprus 
Union of Czech and Slovak Zoological Gardens 

Nadace na ochranu zvířat 
Svoboda zvířat (Freedom For Animals)  
Danish Association of Zoological Gardens and Aquaria 

Societe Nationale de Protection de la Nature 
Noé (biodiversity protection, conservation, animal protec-
tion) 
Code Animal 
Association Francaise  des Parcs Zoologiques (AfdPZ) 

Union des Conservateurs d' Aquarium (UCA) 

One Voice 
Italian Union of Zoos & Aquaria 

Born Free Italia - Nata Libera Italia 
Lega Italiana dei diritti dell'animale 
Animalista Italiani 
Lega Anti Vivisezione 
Lithuanian Society for the Protection Animals(LiSPA) 
PIFAS 
Lithuania Animal Rights Protection 
Verband der Zoologischen Gärten (VdZ) e.V. 

Deutschen Tierpark-Gesellschaft (DTG) 

German Zoo Educators Association VZP 

Berufsverband der Zootierpfleger (BdZ) – Union of Zookeepers 

BMT 
Animal Public e.V. 
Whale Dolphin Conservation 
International Otter Survival Fund 
Wildlife Rehabilitation Ireland 
Irish Society for Prevention of Cruelty to Animals 
Veterinary Ireland 
CAPS 
British and Irish Association of Zoos and Aquariums (BIAZA)- Ms 
Kirsten Pullen 
Association of British and Irish Wild Animal Keepers (ABWAK) 

Nederlandse Dierentuin Vereniging 

Stichting Aap  

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N
b 
44  NL 
45  NL 
46  PL 

47  PT 

48  ES 

49  ES 
50  ES 

51  ES 
52  ES 

53  ES 

Member 
States 

Stakeholder type 

Organisation 

NGO 
NGO 
Zoos organisa-
tion 
Zoos organisa-
tion 
Zoos organisa-
tion 
NGO 
NGO 

University 
Zoos organisa-
tion 
NGO 

Dolphinmotion 
Natuur en Recht- Mr.E. Philippi-Gho  
Board of Directors of Polish Zoos and Aquariums  

APZA (Associação Portuguesa de Zoos e Aquária)  

Iberian Association of Zoos and Aquaria 

Info zoos 
La Asociación Nacional para la Defensa de los Animales 
ANDA, Mr Alberto Diaz Michelana 
Universidad Autónoma de Barcelona 
La Asociacion Iberica de Cuidadores de Animales Salvajes 
(AICAS) – Iberian Zookeepers Association 
FAADA Asociación por los animales- Mrs Carla Mirambell, 
Director 

Table 49: EU and international stakeholders 

Type of stakeholder 

Name 

Nb 
1 
2 

Level of activity 
International  
International 

International 
International 
International 
EU 
EU 
EU 
EU 
EU 

EU 
EU 
EU 
EU 
EU 
EU 

3 
4 
5 
6 
7 
8 
9 
10 

11 
12 
13 
14 
15 
16 

17 
18 
19 

Organisation 
Authority  

Organisation 
Organisation 
Authority 
NGO 
NGO 
Organisation 
Organisation 
Organisation 

NGO 
Experts/Academia 
Experts/Academia 
Experts/Academia 
Experts/Academia 
Organisation 

International 
EU 
EU 

Experts/Academia 
Experts/Academia 
Experts/Academia 

World Association of Zoos and Aquariums (WAZA) 
Secretariat on the Convention of Biological Diversity 
(CBD) 
International Union for Conservation of Nature (IUCN) 
International Fund for Animal Welfare (IFAW) 
CITES Secretariat 
FourPaws 
BornFree Foundation (including EDNCAP) 
European Association of Zoos and Aquaria (EAZA) 
European Association for Aquatic Mammals (EAAM) 
European Association of Zoo and Wildlife Veterinari-
ans (EAZWV) 
Eurogroup for Animals 
Dalia Conde  
Vincent Nijman 
Paul A. Rees 
Sjaak Kaandorp;  
Federation of Veterinarians of Europe, Section EASVO 
- European Association of State Veterinary Officers 
Prof Fa 
Philip McGowan  
Susannah Thorpe, Jackie Chappell, University of Bir-
mingham 

Table 50: Number of contacted zoos per Member State 

BE  BG  CY  CZ 
19 
29 

7 

6 

DE  DK 
26 
82 

ES 
20 

FR 
100 

IE 
17 

IT 
67 

LT 
8 

NL 
30 

PL 
21 

PT 
22 

Member State 
Nb of contacted 
zoos 

Table 51: Zoos  

Aquarium de Bruxelles 

NV Plopsaland S.A. 

Boudewijn Seapark 

Nb  MS 

1 

2 

3 

BE 

BE 

BE 

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Organisation 

EAZA / non EAZA 

non EAZA 

non EAZA 

non EAZA 

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5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

29 

30 

31 

32 

33 

34 

35 

36 

BE 

BE 

BE 

BE 

BE 

BE 

Serpentarium 

National Sealife Blankenberge 

N.V. Bellewaerde Park S.A. 

Recreatiedomein "De Brielmeersen" 

Familiepark Harry Malter 

Domein Eendenkooi 

BE  Olmense Zoo 

BE 

BE 

BE 

BE 

BE 

BE 

BE 

BE 

Zoo Antwerpen 

Dierenpark Planckendael 

Provinciedomein Huizingen 

Aquatopia 

Noordzeeaquarium 

De Zonnegloed 

NAVIGO - Nationaal Visserijmuseum 

Parc "Les Onays" 

BE  Musée d'Histoire Naturelle 

BE 

BE 

BE 

BE 

BE 

BE 

BE 

BE 

BE 

La grange à papillons 

Aquarium - Museum de l'Université de Liège 

Parc animaler de Bouillon "La Crête des cerfs" 

Réserve d'Animaux sauvages de Han-sur-Lesse 

Parc animaler de La Ried 

Parc Mont Mosan 

Pairi Daiza 

Parc à Gibier de Saint-Hubert 

Tierpark 

BE  Massembre 

BG  Varna Zoo 

BG 

Stara Zagora Zoo 

BG  Haskovo Zoo 

BG 

Sofia Zoo 

BG 

Lovech Zoo 

BG 

Blagoevgrad Zoo 

BG 

Plovdiv Zoo 

37  CY 

Zoo Limassol 

38  CY 

Pafos Zoo 

39  CY  Animal Park Achna Village 

40  CY  Ocean Aquarium 

41  CY  Camel Park 

42  CY 

Pafos Aquarium 

43  CZ 

Liberec Zoo 

44  CZ  Dvur Kralove 

non EAZA 

non EAZA 

EAZA 

non EAZA 

non EAZA 

non EAZA 

non EAZA 

EAZA 

EAZA 

non EAZA 

non EAZA 

non EAZA 

non EAZA 

non EAZA 

non EAZA 

EAZA 

non EAZA 

non EAZA 

non EAZA 

EAZA 

non EAZA 

non EAZA 

EAZA 

non EAZA 

non EAZA 

non EAZA 

non EAZA 

non EAZA 

non EAZA 

non EAZA 

non EAZA 

non EAZA 

non EAZA 

non EAZA 

non EAZA 

non EAZA 

non EAZA 

non EAZA 

non EAZA 

EAZA 

EAZA (temporary) 

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45  CZ  Ohrada Zoo 

46  CZ 

Pilsen Zoo 

47  CZ  Decin Zoo 

48  CZ  Chleby Zoo 

49  CZ 

Brno Zoo 

50  CZ 

Zlin Zoo 

51  CZ  Olomouc Zoo 

52  CZ  Ostrava Zoo 

53  CZ 

Vyskov Zoo 

54  CZ 

Hodonin Zoo 

55  CZ 

Sea World  

56  CZ  Obri akvarium 

57  CZ 

Usti Zoo 

58  CZ 

Jihlava Zoo 

59  CZ  Chomutov ZooPark 

60  CZ  Crocodile zoo 

61  CZ 

Zoologicka zahrada Praha 

62 

63 

64 

65 

66 

67 

68 

69 

70 

71 

72 

73 

74 

75 

76 

77 

78 

79 

80 

81 

82 

83 

84 

85 

DK 

Ree Park - Ebeltoft safari 

DK 

Hansenberg Organia 

DK 

Skærup Zoo 

DK  Nordsøen Oceanarium 

DK 

Krokodille Zoo 

DK 

Fjord & Bælt 

DK  NaturBornholm 

DK  Den Blå Planet 

DK 

Blåvand Zoo 

DK 

Knuthenborg Park og Safari 

DK  Danmarks Fugle Zoo 

DK  Munkholm Zoo 

DK  Guldborgsund Zoo 

DK 

Terrariet Vissenbjerg 

DK  Aalborg Zoologiske Have 

DK  Nordsjællands Fuglepark 

DK  Odsherreds Zoo Dyrepark 

DK 

Randers Regnskov 

DK 

Skandinavisk Dyrepark 

DK  Copenhagen Zoo 

DK 

Skolehjemmet Orøstrand 

DK  Givskud Zoo Zootopia 

DK 

Jyllands Park Zoo 

DK 

Jesperhus Blomsterpark ApS 

EAZA 

EAZA 

EAZA 

non EAZA 

EAZA 

EAZA 

EAZA 

EAZA 

non EAZA 

EAZA 

non EAZA 

non EAZA 

EAZA 

EAZA 

EAZA 

non EAZA 

EAZA 

EAZA 

non EAZA 

non EAZA 

EAZA 

non EAZA 

non EAZA 

non EAZA 

EAZA 

non EAZA 

EAZA 

non EAZA 

non EAZA 

non EAZA 

non EAZA 

EAZA 

non EAZA 

non EAZA 

EAZA 

non EAZA 

EAZA 

non EAZA 

EAZA 

non EAZA 

EAZA 

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86 

87 

88 

89 

90 

91 

92 

93 

94 

95 

96 

97 

98 

99 

DK 

Kattegatcentret 

DK  Odense Zoo 

FR 

FR 

FR 

FR 

FR 

FR 

FR 

FR 

FR 

FR 

FR 

FR 

Cigoland 

Centre de réintroduction des Cigognes et des Loutres 

Parc zoologique et botanique de Mulhouse 

Le Paradis des papillons 

Aquarium du Perigord noir 

Réserve Zoologique de Calviac 

Zoo d' Asson 

Parc' Ours 

Reptilarium de Labenne 

Parc animalier d' Auvergne 

Le Pal 

La valleé des daims 

100 

FR 

Parc de l'Auxois 

101 

FR 

Parc naturel de Boutissaint 

102 

FR 

Touroparc Zoo 

103 

FR  Oceanopolis 

104 

FR 

Parc ornithologique de Bretagne 

105 

FR 

Zoo de Pont-Scorff 

106 

FR 

Le ZooParc de Beauval 

107 

FR 

Reserve de la Haute-Touche 

108 

FR  Grand Aquarium de Touraine 

109 

FR 

La Ferme aux oiseaux exotiques 

110 

FR 

Espace faune de la foret d'Orient 

111 

FR 

A Cupulatta - La cité des tortues 

112 

FR 

La Citadelle de Besançon 

113 

FR 

Le parc Polaire 

114 

FR 

La Ménagerie, Zoo du Jardin des Plantes 

115 

FR 

Parc des Félins 

116 

FR 

Zoo de Vincennes 

117 

FR 

Aquarium de Paris 

118 

FR 

Sea Life Paris - Val d'Europe 

119 

FR 

Zoo de Montpellier - Parc Darwin 

120 

FR 

Les Loups du Gévaudan 

121 

FR 

Réserve africaine de Sigean 

122 

FR 

Seaquarium 

123 

FR 

Zoo du Reynou 

124 

FR 

La Cité des Insectes 

125 

FR 

Parc animalier des Monts du Guéret 

EAZA 

EAZA 

non EAZA 

non EAZA 

EAZA 

non EAZA 

non EAZA 

EAZA 

non EAZA 

non EAZA 

non EAZA 

EAZA 

EAZA 

non EAZA 

non EAZA 

non EAZA 

EAZA 

EAZA 

non EAZA 

EAZA 

EAZA 

EAZA 

non EAZA 

non EAZA 

non EAZA 

non EAZA 

non EAZA 

EAZA 

non EAZA 

non EAZA 

EAZA 

non EAZA 

EAZA 

non EAZA 

EAZA 

non EAZA 

EAZA 

non EAZA 

non EAZA 

126 

FR 

Zoo d'Amnéville 

EAZA (temporary) 

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FR 

Parc animalier de Sainte-Croix 

128 

FR 

Zoo African Safari 

129 

FR 

La Forêt des singes 

130 

FR 

Zoo des trois vallées 

131 

FR 

Animaparc 

132 

FR 

La ferme aux bisons 

133 

FR 

Parc animalier des Pyrénées 

134 

FR 

Ecoparc du Rocher des Aigles 

135 

FR 

Parc Zoologique de Lille 

136 

FR 

Parc animalier des Cytises      

137 

FR 

Insectarium du musée d'histoire naturelle de Lille 

138 

FR 

Biotropica 

139 

FR 

Parc de Clères                               

140 

FR 

Zoo de Champrépus 

141 

FR 

Zoo de Jurques 

142 

FR 

Bioparc de Doué la Fontaine     

143 

FR 

Zoo de la Flèche 

144 

FR 

Planète Sauvage 

145 

FR 

Le Refuge de l'Arche 

146 

FR 

Spaycific Zoo 

147 

FR  Ocearium du Croisic 

148 

FR 

Parc Zoologique d'Amiens métropole 

149 

FR 

Parc des Grands Félins 

150 

FR 

La Vallée des Singes 

151 

FR 

Zoo de la Palmyre 

152 

FR 

Zoodyssée 

153 

FR 

Aquarium de la Rochelle 

154 

FR 

La Marais aux oiseaux 

155 

FR 

La Colline enchantée 

156 

FR 

Alpha, le Parc des loups du Mercantour 

157 

FR 

Zoo de la Barben 

158 

FR 

Parc Zoologique de Fréjus 

159 

FR 

Parc animalier domestique du Verdon 

160 

FR 

Parc Phoenix 

161 

FR 

La Réserve biologique des monts d' Azur 

162 

FR 

Corbi Parc 

163 

FR 

Espace Marineland 

164 

FR 

Jardin Zoologique Tropical 

165 

FR 

Jardin Zoologique de Lyon 

166 

FR 

Safari de Peaugres 

167 

FR 

Parc animalier du château de Bouthéon 

EAZA 

EAZA 

non EAZA 

non EAZA 

non EAZA 

non EAZA 

EAZA 

non EAZA 

EAZA 

non EAZA 

non EAZA 

non EAZA 

EAZA 

EAZA 

EAZA 

EAZA 

EAZA 

non EAZA 

non EAZA 

non EAZA 

non EAZA 

EAZA  

EAZA 

EAZA 

EAZA 

EAZA (temporary) 

non EAZA 

non EAZA 

non EAZA 

non EAZA 

EAZA 

non EAZA 

non EAZA 

non EAZA 

non EAZA 

non EAZA 

EAZA 

non EAZA 

EAZA 

EAZA 

non EAZA 

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168 

FR 

Parc de Courzieu 

169 

FR 

Le Domaine des Fauves 

170 

FR 

Espace Zoologique de Saint-Martin-la-Plaine 

171 

FR 

Zoo d' Upie (Jardin aux Oiseaux) 

172 

FR 

Aquarium de Lyon 

173 

FR 

Parc des Oiseaux 

174 

FR 

La Ferme aux crocodiles 

175 

FR 

Zoo de Guadeloupe 

176 

FR 

Les Jardins de la Mer 

177 

FR 

Zoo du Bois d'Attilly 

178 

FR 

Alligator Bay 

179 

FR 

Le Bois des Aigles 

180 

FR 

Zoo de la Boissière du Doré 

181 

FR 

Zoo des Sables d'Olonne 

182 

FR 

Le grand parc du Puy du fou 

183 

FR 

La Ferme Souchinet 

184 

FR 

Zoo de Guyane 

185 

FR 

Zoo de l'Orangerie de Strasbourg 

186 

FR 

Parc animalier de la Bédouère 

187 

FR 

L'Arche féline  

188 

189 

190 

191 

192 

193 

194 

195 

196 

197 

198 

199 

200 

201 

202 

203 

204 

205 

206 

207 

208 

IT 

IT 

IT 

IT 

IT 

IT 

IT 

IT 

IT 

IT 

IT 

IT 

IT 

IT 

IT 

IT 

IT 

IT 

IT 

IT 

IT 

Zoomarine 

Parco Zoo Punta Verde 

Le Cornelle Parco Faunistico 

Giardino Zoologico di Pistoia 

Acquario di Genova 

Parco Zoo di Falconara 

Parco Faunistico La Torbiera 

Parco Natura Viva 

Parco Faunsitico Cappelier 

Casa delle Farfalle di Bordano 

Le Dune Del Delta 

Bioparco di Roma 

Parco Faunistico Valcorba 

Butterfly ARC s.r.l 

Case delle Farfalle & Co (Atlatide) 

Casa delle farfelle Monteserra (giardino Zoologico) 

Bioparco di Sicilia 

Safari Park - Pombia 

Zoom Torino (Baitelandia) 

Le Navi - Acquario di Cattolica 

Sea Life di Jesolo 

non EAZA 

non EAZA 

EAZA 

non EAZA 

non EAZA 

non EAZA 

EAZA 

non EAZA 

non EAZA 

non EAZA 

non EAZA 

non EAZA 

EAZA 

EAZA 

non EAZA 

non EAZA 

EAZA 

non EAZA 

non EAZA 

non EAZA 

EAZA 

EAZA 

EAZA 

EAZA 

EAZA 

EAZA 

EAZA 

EAZA 

non EAZA 

non EAZA 

non EAZA 

EAZA 

non EAZA 

non EAZA 

non EAZA 

non EAZA 

non EAZA 

non EAZA 

EAZA 

non EAZA 

non EAZA 

Milieu Ltd  
Brussels  

Evaluation Study to support the evaluation of the Zoos Directive 
Annexes to Final Report – August 2017/ 391 

 
 
 
209 

210 

211 

212 

213 

214 

215 

216 

217 

218 

219 

220 

221 

222 

223 

224 

225 

226 

227 

228 

229 

230 

231 

232 

233 

234 

235 

236 

237 

238 

239 

240 

241 

242 

243 

244 

245 

246 

247 

248 

249 

IT 

IT 

IT 

IT 

IT 

IT 

IT 

IT 

IT 

IT 

IT 

IT 

IT 

IT 

IT 

IT 

IT 

IT 

IT 

IT 

IT 

IT 

IT 

IT 

IT 

IT 

IT 

IT 

IT 

IT 

IT 

IT 

IT 

IT 

IT 

IT 

IT 

IT 

IT 

IT 

IT 

Parco Oltremare 

Tropicarium Park (Aquarium Reptilarium) 

Acquario di Livorno 

1 Parco Zoo della Fauna Europea - Poppi 

Parco Safari Delle Langhe - Murazzano 

Zoo Safari di Fasano 

Zoo D'Abruzzo di Bellucci Mario enrico (Embell Riva) 

Oasi degli animali 

Parco delle star "Daniel Berquiny" 

Gallorose 

Giardino Zoologico di Napoli 

Zoo delle Maitine 

Acquario dell'elba 

Zoo Acquario di Imola (see row 276) 

L'Acquario Mediterraneo 

Acquario Cala Gonone 

Parco di Villa Pallavicino 

Acquario di Alghero 

Zooproject / Rettilario di Perugia 

Parco Nazionale d'Abruzzo, Lazio e Molise 

Parco Faunistico Spormaggiore 

Civico Acquario Marino & Vivarium 

Acquario E Civica Stazione Idrobiologica Milano 

Oasi di Sant' Alessio 

Citta della domenica 

Acquario Stazione Zoologixa Anton Dohrn Napoli 

Safari Ravenna 

Parco Faunistica Cappeller 

Gardaland Sea Life Acquarium 

Bioparco Faunistico d'Abruzzo 

Parc Animalier d'introd 

Parco degli Angeli 

Parco Faunistico al Bosco 

Parco La Rupe 

Zoosafaria Fasonalandia 

Parco Faunistico del Monte Amiata 

Parco Naturale di Cavriglia 

Minitalia Leolandia Park 

Acquario Comunale Laguna di Ortobello 

Acquario Mediterraneo del Comune di monte Argentario 

Parco Faunistico Varcorba 

non EAZA 

non EAZA 

non EAZA 

non EAZA 

non EAZA 

non EAZA 

non EAZA 

non EAZA 

non EAZA 

non EAZA 

non EAZA 

non EAZA 

non EAZA 

non EAZA 

non EAZA 

non EAZA 

non EAZA 

non EAZA 

non EAZA 

non EAZA 

non EAZA 

non EAZA 

non EAZA 

non EAZA 

non EAZA 

non EAZA 

non EAZA 

non EAZA 

non EAZA 

non EAZA 

non EAZA 

non EAZA 

non EAZA 

non EAZA 

non EAZA 

non EAZA 

non EAZA 

non EAZA 

non EAZA 

non EAZA 

non EAZA 

Milieu Ltd  
Brussels  

Evaluation Study to support the evaluation of the Zoos Directive 
Annexes to Final Report – August 2017/ 392 

 
 
 
250 

251 

252 

253 

254 

IT 

IT 

IT 

IT 

IT 

Parco Natura La Selvotta 

Parco del Sole 

Parco d'orlearns 

Tiger Experience 

Zoo Acquario di Imola 

255 

LT 

Kaunas Zoo;  Lithuanian zoological garden  

256 

LT 

Mini Zoo; Klaipėda zoo 

257 

LT 

Live Tropical Butterfly Exhibition 

258 

LT 

Grutas Park 

259 

LT 

LITHUANIAN SEA MUSEUM 

260 

LT 

Zoopark 

261 

LT 

Mapeta zoo 

262 

LT 

Lithuanian Center of Young Naturalists 

263  DE  Munchener Tierpark Hellabrunn 

264  DE 

Zoologischer Garten Schwerin 

265  DE 

Zoologischer Garten Rostock 

266  DE 

Zoo Stralsund 

267  DE 

Tiergarten Neustrelitz 

268  DE 

Tierpark Burg Stargard 

269  DE 

Tierpark Grimmen 

270  DE 

Tierpark Wismar 

271  DE 

Heimattierpark Hansestadt Greifswald 

272  DE 

Tierpark Ueckermünde 

273  DE 

Tierpark Wolgast 

274  DE 

Tierpark Sassnitz 

275  DE  Müritzeum 

276  DE  Ozeaneum Stralsund 

277  DE  Deutsches Meeresmuseum 

278  DE  Natur- und Umweltpark Güstrow 

279  DE 

Vogelpark Marlow 

280  DE 

BÄRENWALD Müritz 

281  DE 

Vogel- und Freizeitpark „Nebeltal“ 

282  DE 

Karls Markt 

283  DE 

Schmetterlingspark Klütz 

284  DE 

Elefantenhof Platschow 

285  DE 

Erlebnis- und Tigerpark Dassow 

286  DE  Wildlife Usedom  

287  DE 

Hausdtierpark Lelkendorf 

288  DE 

Tropenhaus Bansin 

289  DE 

Tierpark Hellabrunn München 

290  DE 

Zoologischer Garten Augsburg 

non EAZA 

non EAZA 

non EAZA 

non EAZA 

non EAZA 

non EAZA 

non EAZA 

non EAZA 

non EAZA 

non EAZA 

non EAZA 

non EAZA 

non EAZA 

EAZA 

EAZA 

EAZA 

non EAZA 

non EAZA 

non EAZA 

non EAZA 

non EAZA 

non EAZA 

non EAZA 

non EAZA 

non EAZA 

non EAZA 

non EAZA 

non EAZA 

non EAZA 

EAZA 

non EAZA 

non EAZA 

non EAZA 

non EAZA 

non EAZA 

non EAZA 

non EAZA 

non EAZA 

non EAZA 

EAZA 

EAZA 

Milieu Ltd  
Brussels  

Evaluation Study to support the evaluation of the Zoos Directive 
Annexes to Final Report – August 2017/ 393 

 
 
 
291  DE 

Tiergarten Nürnberg 

292  DE 

Zoologisch-Botanischer Garten Wilhelma Stuttgart 

293  DE 

Zoologischer Garten Karlsruhe 

294  DE 

Heidelberg Zoo 

295  DE 

Saarbrücken Zoo 

296  DE  Neunkirchen Zoo 

297  DE 

Frankfurt/Main Zoo 

298  DE 

Kölner Zoo 

299  DE  Wuppertal Zoo 

300  DE 

Krefeld Zoo 

301  DE  Duisburg 

302  DE 

Zoom Erlebniswelt Gelsenkirchen 

303  DE  Dortmund Zoo 

304  DE  Allwetterzoo Münster 

305  DE  Osnabrück Zoo 

306  DE 

Erlebnis-Zoo Hannover 

307  DE 

Schwerin Zoo 

308  DE 

Tierpark Friedrichsfelde Berlin 

309  DE  Dresden Zoo 

310  DE  Naturerlebnispark Kirchheim Kirchheim 

311  DE  Wildpark Frankenberg 

312  DE 

Erlebniswald Trappenkamp Daldorf 

313  DE  Wild- und Freizeitpark Klotten bei Cochem 

314  DE  Wildpark Klaushof Bad Kissingen 

315  DE 

Tiergehege Zeulenroda 

316  DE  Wildpark Neuhaus Holzminden 

317  DE  Wildpark Johannismühle Baruth-Klasdorf 

318  DE 

Schwarzwaldpark Löffingen 

319  DE  Wildpark Bilsteintal Warstein 

320  DE 

Zoo Safaripark Schloss Holte-Stukenbrock 

321  DE 

Serengeti-Park Hodenhagen 

322  DE 

Krefeld Zoo 

323  DE  Aquadom Bad Wiessee 

EAZA 

EAZA 

EAZA 

EAZA 

EAZA 

EAZA 

EAZA 

EAZA 

EAZA 

EAZA 

EAZA 

EAZA 

EAZA 

EAZA 

EAZA 

EAZA 

EAZA 

EAZA 

EAZA 

non EAZA 

non EAZA 

non EAZA 

non EAZA 

non EAZA 

non EAZA 

non EAZA 

non EAZA 

non EAZA 

non EAZA 

non EAZA 

non EAZA 

EAZA 

non EAZA 

324  DE  Aquarium und Schmetterlingshaus  im Botanischen Garten Tübingen 

non EAZA 

325  DE  Ostsee-Info-Center Eckernförde 

326  DE  Gruson-Gewächshäuser 

327  DE 

Sea Life Speyer 

328  DE  Naturkundemuseum Potsdam 

329  DE  Meereszentrum Burg auf Fehmarn 

330  DE  Meeresaquarium Oberwiesenthal 

331  DE  Aquarium Wilhelmshaven 

non EAZA 

non EAZA 

non EAZA 

non EAZA 

non EAZA 

non EAZA 

non EAZA 

Milieu Ltd  
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Evaluation Study to support the evaluation of the Zoos Directive 
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332  DE  Neuwied Zoo 

333  DE  Aachen Zoo 

334  DE  NaturZoo Rheine 

335  DE 

Tierpark Chemnitz 

336  DE  Aschersleben Zoo 

337  DE 

Zoo in der Wingst 

338  DE  Gettorf Zoo 

339  DE  Arche Noah Zoo Braunschweig 

340  DE 

Landau in der Pfalz Zoo 

341  DE 

Zoo Vivarium Darmstadt 

342  DE  Opel-Zoo Kronberg 

343  DE  Weltvogelpark Walsrode 

344  DE  Naturschutz-Tierpark Görlitz 

345 

346 

347 

348 

349 

350 

351 

352 

353 

354 

355 

356 

357 

358 

359 

360 

361 

IE 

IE 

IE 

IE 

IE 

IE 

IE 

IE 

IE 

IE 

IE 

IE 

IE 

IE 

IE 

IE 

IE 

Burren Birds of Prey Centre 

Galway Atlantaquaria 

Dromoland Falconry 

Eagles Flying 

Stonehall Visitor Farm, Adare, Co. Limerick 

Tropical World 

Dingle Ocean World 

Tayto Park, Ashbourne, Co. Meath 

Ardmore Manor 

National Sealife Centre, Bray, Co. Wicklow 

Ardmore Open Farm 

Woodlands Falconry/Bird of Prey Centre 

Dublin Zoo 

National Reptile Zoo 

Fota Wildlife Park 

Coolwood Wildlife Park 

Secret Valley Adventure Farm 

362  NL 

Apenheul Primate Park 

363  NL 

AQUAZOO FRIESLAND 

364  NL 

Vogelpark Avifauna 

365  NL 

Royal Burgers' Zoo 

366  NL 

DierenPark Amersfoort 

367  NL  Wildlands 

368  NL 

Dierenrijk 

369  NL 

Dolfinarium Harderwijk 

370  NL  GaiaZOO 

371  NL  Ouwehands Zoo 

372  NL 

Safaripark Beekse Bergen 

EAZA 

EAZA 

EAZA 

EAZA 

non EAZA 

non EAZA 

non EAZA 

non EAZA 

EAZA 

EAZA 

EAZA 

EAZA 

EAZA 

non EAZA 

non EAZA 

non EAZA 

non EAZA 

non EAZA 

non EAZA 

non EAZA 

non EAZA 

non EAZA 

non EAZA 

non EAZA 

non EAZA 

EAZA 

non EAZA 

EAZA 

non EAZA 

non EAZA 

EAZA 

EAZA 

EAZA 

EAZA 

EAZA 

EAZA 

EAZA 

EAZA 

EAZA 

EAZA 

EAZA 

Milieu Ltd  
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Evaluation Study to support the evaluation of the Zoos Directive 
Annexes to Final Report – August 2017/ 395 

 
 
 
373  NL 

Zoo Parc Overloon 

374  NL 

SEA LIFE Scheveningen 

375  NL 

Dierenpark Zie Zoo 

376  NL 

Vlinderparadijs Papiliorama 

377  NL 

Vogelrevalidatiecentrum Zundert 

378  NL 

DoeZoo 

379  NL 

Aquariumvereniging De Discus 

380  NL 

Vogelpark Ruinen 

381  NL 

Berkenhof's Tropical Zoo 

382  NL 

Zoo Veldhoven 

383  NL 

Dierenpark van Blanckendaell 

384  NL 

De Orchideeen Hoeve 

385  NL 

Vogelbush Eureka 

386  NL 

Reptielen- en Amfibieënhuis De Aarde 

387  NL 

Artis royal Zoo 

388  NL 

Diergaarde Blijdorp 

389  NL 

Ecomare 

390  NL 

Reptielenzoo Iguana 

391  NL  Mondo Verde 

392  PL 

Bydgoszczy Zoological Garden 

393  PL 

The Silesian Zoological Garden 

394  PL  Municipal Zoological Garden of Sea Cost Gdansk 

395  PL  Gdynia Aquarium National Marine Fisheries Research Institute 

396  PL 

Prof.Benedykt Dybowski Wildlife Park 

397  PL 

Local Park and Zoological Garden - Foundation 

398  PL 

Łódź Municipal Zoological Garden 

399  PL  Opole Zoological Garden 

400  PL 

Plock Municipal Zoological Garden 

401  PL 

Poznan zoo 

402  PL 

Zoo Safari Świerkocin Ltd 

403  PL 

Torun Zoobotanical Garden 

404  PL  Wroclaw zoo Ltd 

405  PL 

Stefan Miler Zoological Garden Zamosc 

406  PL 

Zoo Farma 

407  PL 

Akcent Zoo 

408  PL  Gdynia Aquarium 

409  PL 

Canpol Zoo 

410  PL 

Zoo Charlotta 

411  PL  Warsaw Zoo 

412  PL 

 Ogród Zoologiczny w Lubinie 

413  PT 

Zoo Santo Inacio 

EAZA 

non EAZA 

non EAZA 

non EAZA 

non EAZA 

non EAZA 

non EAZA 

non EAZA 

non EAZA 

non EAZA 

non EAZA 

non EAZA 

non EAZA 

non EAZA 

EAZA 

EAZA 

non EAZA 

non EAZA 

non EAZA 

non EAZA 

non EAZA 

EAZA 

non EAZA 

non EAZA 

EAZA 

EAZA 

EAZA 

EAZA 

EAZA 

non EAZA 

EAZA 

EAZA 

EAZA 

non EAZA 

non EAZA 

non EAZA 

non EAZA 

non EAZA 

EAZA 

EAZA 

EAZA 

Milieu Ltd  
Brussels  

Evaluation Study to support the evaluation of the Zoos Directive 
Annexes to Final Report – August 2017/ 396 

 
 
 
414  PT 

Zoo Lourosa 

415  PT  Oceanario de Lisboa 

416  PT 

Jardim Zoologico de Lisboa 

417  PT 

Aquario Vasco da Gama 

418  PT 

Parque Zoológico de Lagos 

419  PT 

ZooMarine 

420  PT 

ESTAÇÃO LITORAL DA AGUDA 

421  PT 

ZOO DA MAIA 

422  PT 

PARQUE BIOLÓGICO DE GAIA 

423  PT 

AQUAMUSEU DO RIO MINHO 

424  PT  MERLIN ENTERTAINMENTS SEA LIFE PORTO UNI 

425  PT 

EUROPARADISE - PARQUE ZOOLÓGICO , LDA 

426  PT 

PARQUE DOS MONGES 

427  PT 

BADOCA , ACTIVIDADES TURISTICAS , LDA 

428  PT  MONTE SELVAGEM - RESERVA ANIMAL , LDA 

429  PT 

FLUVIARIO DE MORA 

430  PT 

KRAZY WORLD 

431  PT 

PARQUE ZOOLÓGICO DE GOUVEIA 

432  PT 

PARQUE BIOLOGICO DA SERRA DA LOUSA 

433  PT 

PARQUE BIOLOGICO DA SERRA DAS MEADAS 

434  PT 

PARQUE BIOLÓGICO DE VINHAIS 

435  ES 

Aquarium Roquetas de Mar 

436  ES 

Canada de los Pájaros 

437  ES 

Crocrodile Park 

438  ES 

Lobo Park 

439  ES  Mariposario de Benalmádena 

440  ES 

Reserva Natural del Castillo de las Guardas 

441  ES  Oasys: un mundo lleno de color 

442  ES 

Selwo Aventura 

443  ES 

Selwo Marina  

444  ES 

Zoo de Castellar 

445  ES 

Zoo de Sevilla (Mundo Park - fundacion Juan Luis Malpartida) 

446  ES 

Aquarium de Almunécar 

447  ES 

Parque Ornitológico Loro Sexi 

448  ES 

Parque de la Naturaleza Pena Escrita 

449  ES 

Parque Zoológico Jardín Botánico Alberto Durán 

450  ES 

Zoobotanico de Jerez 

451  ES 

La Cuniacha. Parque Faunísitico de los Pirineos 

452  ES 

Acuario de Zaragoza 

453  ES 

Acuario de Gijon 

454  ES 

Rincon de las Aves 

EAZA 

EAZA 

EAZA 

EAZA 

EAZA 

EAZA 

non EAZA 

non EAZA 

non EAZA 

non EAZA 

non EAZA 

non EAZA 

non EAZA 

non EAZA 

non EAZA 

non EAZA 

non EAZA 

non EAZA 

non EAZA 

non EAZA 

non EAZA 

non EAZA 

non EAZA 

non EAZA 

non EAZA 

non EAZA 

non EAZA 

non EAZA 

EAZA 

EAZA 

non EAZA 

non EAZA 

non EAZA 

non EAZA 

non EAZA 

non EAZA 

non EAZA 

non EAZA 

non EAZA 

non EAZA 

non EAZA 

Milieu Ltd  
Brussels  

Evaluation Study to support the evaluation of the Zoos Directive 
Annexes to Final Report – August 2017/ 397 

 
 
 
455  ES 

Cercado Osero de Santo Adriano 

456  ES 

La Grandera-Faunastur 

457  ES 

Aquarium Cap Blanc 

458  ES 

Lloc de Menorca 

459  ES  Marineland de Menorca 

460  ES 

Natura Parc 

461  ES 

Palma Aquarium 

462  ES 

Aquàrium del Centre de Visitants del PN de Cabrera 

463  ES 

Aquarium de Costa Teguise Lanzarote S.L. 

464  ES 

Jungle Park Las Aguilas 

465  ES 

La Lajita Oasis Park 

466  ES  Mariposario del Dragó 

467  ES  Maroparque 

468  ES  Monkey Park 

469  ES  Oceanarium Explorer 

470  ES 

Palmitos Park 

471  ES 

Rancho Texas Lanzarote Park 

472  ES 

Zoo de Santillana del Mar 

473  ES 

Parque de la naturaleza Cabárceno 

474  ES  Museo de la Fauna Salavaje 

475  ES 

El Coto Escolar 

476  ES 

Safari Show Park 

477  ES 

Centre d'apropament a la natura (CAN) 

478  ES 

Centre de recuperació de primats (Fundació mona) 

479  ES 

Cim d'àligues 

480  ES  Món Natura Pirineus (Planes de Son) 

481  ES 

Butterfly Park 

482  ES 

L'aquarium de Barcelona 

483  ES 

Parc animal dels Pirineus "Les Bernedes 

484  ES 

Parc zoològic de Barcelona 

485  ES  Mercelle Natureza 

486  ES 

Aquarium Finisterrae - Casa de los peces 

487  ES 

Centro de Naturaleza Cañada Real 

488  ES 

Faunia 

489  ES 

Zoo de Madrid 

490  ES 

Sendaviva Parque de la Naturaleza de Navarra 

491  ES 

Refugio de Fauna y Flora Basondo 

492  ES 

Centro de Acogida de Fauna Karpín. Karpín Abentura 

493  ES  Getxo Aquarium 

494  ES 

Rioja Natura 

495  ES 

Jardín del Papagayo 

non EAZA 

non EAZA 

non EAZA 

non EAZA 

EAZA 

non EAZA 

non EAZA 

non EAZA 

non EAZA 

non EAZA 

non EAZA 

non EAZA 

non EAZA 

non EAZA 

non EAZA 

non EAZA 

non EAZA 

EAZA (Since 1997) 

EAZA 

non EAZA 

non EAZA 

non EAZA 

non EAZA 

non EAZA 

non EAZA 

non EAZA 

non EAZA 

non EAZA 

non EAZA 

EAZA 

non EAZA 

non EAZA 

non EAZA 

EAZA 

non EAZA 

non EAZA 

non EAZA 

non EAZA 

non EAZA 

non EAZA 

non EAZA 

Milieu Ltd  
Brussels  

Evaluation Study to support the evaluation of the Zoos Directive 
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496  ES 

L'Oceanografic 

497  ES 

Safari Aitana 

498  ES 

Terra Natura Zoo  Benidrom 

499  ES 

Terra Natura Murcia 

500  ES 

Loro parque 

501  ES 

Zoo de Fuengirola 

502  ES 

Parque del Oeste 

503  ES 

Parque Zoologico de Córdova 

504  ES 

Parque Zoologico Prudencio Navarro Pallarés 

505  ES 

EL Bosque 

506  ES 

Safari-zoo Services S.L 

507  ES 

Centro de interpretación avifauna 

508  ES  Org. Autónomo municipal Parque das Ciencias. Vigozoo 

509  ES 

Safari Madrid 

510  ES 

Zoo Aquarium de Madrid 

511  ES 

Bioparc 

512  ES  Mundomar 

513  ES 

Rio Safari 

514  ES 

Zoobotanico de Jerez 

EAZA 

non EAZA 

EAZA 

EAZA (temporary) 

EAZA 

EAZA 

non EAZA 

non EAZA 

non EAZA 

Non EAZA  

non EAZA 

Non EAZA 

non EAZA 

non EAZA 

EAZA 

EAZA 

non EAZA 

non EAZA 

EAZA 

Milieu Ltd  
Brussels  

Evaluation Study to support the evaluation of the Zoos Directive 
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ANNEXES VIA TO VIC – TARGETED SURVEYS QUESTIONNAIRES 

Targeted survey as part of the REFIT evaluation of the Zoos 
Directive 

Fields marked with * are mandatory. 

Targeted consultation as part of the REFIT evaluation of the Zoos 

Directive 

Questionnaire addressed to zoos 

The European Commission is not responsible for the content of questionnaires created using the 

EUSurvey service - it remains the sole responsibility of the form creator and manager. The use of 

EUSurvey service does not imply a recommendation or endorsement, by the European Commission, 

of the views expressed within them. 

The evaluation is part of the European Commission's Regulatory Fitness and Performance Pro-

gramme (REFIT). This programme involves a comprehensive, evidence-based assessment of 

whether the current regulatory framework is proportionate and fit for purpose, and delivering as ex-

pected. 

Objectives of the evaluation 

Milieu Ltd  
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Evaluation Study to support the evaluation of the Zoos Directive 
Annexes to Final Report – August 2017/ 400 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
The evaluation examines the relevance, effectiveness, efficiency, coherence and EU added value of 

the EU Directive 1999/22/EC relating to keeping of wild animals in zoos (hereinafte r 'the Zoos Di-

rective'). It will evaluate what has worked well or poorly, and will compare actual performance to 

initial expectations. It looks to see if the rules set out in the Directive are simple, clear and do not 

cause unnecessary costs. 

The results will be used by the Commission to inform future decisions relating to the protection of 

wild animals and the enhancement of EU biodiversity, to which ex-situ conservation and zoos con-

tribute. The evaluation in itself does not consider possible future changes to the legislation. 

This survey is part of a broader range of consultation activities. Further information on the evalua-

tion and the different activities it involves can be consulted on the Commission’s eval uation web-

site. 

The aim of this consultation is to gather the views and opinions of interested stakeholders on the cur-

rent EU legislation on zoos and its implementation to date. Your responses will be used to help as-

sess the current situation and ensure that the most accurate and comprehensive evidence is taken into 

account. It is therefore important that you complete this questionnaire as fully as possible. 

The evaluation will look in particular at the implementation and functioning of the EU rules on the 

regulation of zoos with regards to: (1) the protection of wild animals; (2) the conservation of bio-

diversity by strengthening the role of zoos. 

Milieu Ltd  
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Evaluation Study to support the evaluation of the Zoos Directive 
Annexes to Final Report – August 2017/ 401 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
The Zoos Directive, was adopted with the objective to promote wild animal species protection and 

conservation by strengthening the role of zoos in the conservation of biodiversity. The Directive in-

tended to achieve these objectives by the adoption of measures by Member States for the licensing 

and inspection of zoos in order to ensure that zoos respect conservation and protection measures, in-

cluding appropriate accommodation of the animals. 

The Directive requires Member States to establish a licencing and inspection system in order to 

ensure that zoos implement the following Article 3 conservation measures: 

Participate in one or more of the following: i) research and training through which con-

servation objectives may be achieved, ii) exchange of information relating to species con-

servation, iii) captive breeding, iv) repopulation, or v) reintroduction of species into the 

wild; 

Promote public education and awareness in relation to the conservation of biodiversity, partic-

ularly by providing information about the species exhibited and their natural habitats; 

Accommodate animals under conditions which aim to satisfy the biological and conservation 

requirements of the individual species and maintaining a high standard of animal husbandry; 

Prevent the escape of animals in order to avoid threats to indigenous species and intrusion 

of outside pest and vermin; 

Keep appropriate records of the zoo’s collection. 

Guidance 

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The questionnaire for this targeted online survey has been prepared in order to gather evi-

dence-based information for the evaluation. 

Please answer questions based on direct experience. As far as possible, please provide evidence to 

substantiate your replies in the open text fields. For many questions it is also possible to upload sup-

porting documents. Where possible, quantitative evidence should be provided. Where this is not pos-

sible, estimates and qualitative evidence would be welcome. 

You can skip questions that you do not feel comfortable responding to. However, replies to ques-

tions marked with an asterisk are compulsory. 

To facilitate understanding of the questions, the survey is available in 13 languages. Given possible 

delays in translating comments submitted in some languages, contributions in English for the open 

text fields are welcome, as they will help to process the survey more swiftly. 

This questionnaire is being sent out to zoo operators in 14 selected Member States (Belgium, 

Bulgaria, Cyprus, Czech Republic, Denmark, Estonia, France, Germany, Italy, Ireland, Nether-

lands, Poland, Portugal, Spain). 

NB: Several different questionnaires for different stakeholder groups have been estab-

lished, namely: 

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National competent authorities (e.g. ministries or regional/local authorities re-

sponsible for implementing and enforcing the Zoos Directive) 

EU-level and national-level federations and associations of zoos (e.g. zoos federations) and 

non-governmental associations (NGOs in the field of biodiversity conservation or animal 

welfare)), as well as academics and other experts in the area 

Zoo operators 

In addition, a public consultation for the broader public will run on the Commission’s website ‘Your 

Voice in Europe’ between September and December 2016. 

The different surveys have been distributed via different distribution channels. If you feel you have 

not received the right questionnaire, or have any queries please contact zoos.dire ctive@milieu.be. If 

you are aware of additional specific documents that should be taken into account in the evidence 

gathering process, please submit them through the evaluation website. 

The present questionnaire is structured as follows: 

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Part I investigates the implementation of conservation measures by Zoos, in line with Article 

3 of the Zoos Directive 

Part II gathers information and opinions in relation to the results achieved with the Zoos Di-

rective, in order to assess its effectiveness, efficiency, relevance, coherence and added value 

Part III gives stakeholders the possibility to add concluding remarks 

You may pause at any time and continue later. Once you have submitted your answers, you can 

download a copy of your completed responses. 

We kindly ask you to fill in the questionnaire within 4 weeks of receipt. 

Use of the results 

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1 
* 

Please note that according to the Commission's Better Regulation Guidelines, stakeholder's 
contributions will be published on the dedicated evaluation website. 

Regardless of the option chosen below, your contribution may be subject to a request for ac-
cess to documents under Regulation 1049/2001 on public access to European Parliament, 
Council and Commission documents. In such cases, the request will be assessed against the 
conditions set out in the Regulation and in accordance with applicable data protection rules. 

According to relevant data protection rules, please indicate whether your reply: 

   Can be published, including your name or that of your organisation (I consent to publi-
cation of all information in my contribution and I declare that none of it is under copy-
right restrictions that prevent publication) 

   Can be published in an anonymous way (I consent to publication of all information in my 
contribution except my name/the name of my organisation, and I declare that none of it is 
under copyright restrictions that prevent publication) 

   Cannot be published but only used for statistical and analytical purposes, in the context 

of the present study 

Background Information 

2 
* 

Please indicate here the language that you will use in your replies. 

   Bulgarian 
Czech 
   Danish 
Dutch 
English 

   Estonian 
French  Ger-
man  Greek 
Italian 
   Polish 
   Portuguese 

Spanish 

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*  3  Name of the zoo 

* 4  Contact name 

* 5  Email address 

* 6  Telephone number 

* 7  Member State 
     Belgium 

Bulgaria 

Cyprus 

   Czech Republic 

   Denmark 

   Estonia 

France 

Germany 

Italy 

   Ireland 

   Netherlands 

Poland 

   Portugal 

Spain 

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8  Type of business entity 

* 

     Private – operating a single zoo 
Private  –  operating  several  zoos 
Public  –  run  by  national  authority 
Public  –  run  by  regional  authority 
Public – run by local authority 

   Charity / foundation 
  Mix Public/Private 

Mix Public / Charity 
Mix Private / Charity 
Other 

9  If 'Other', please specify: 

* 

250 character(s) maximum 

* 10  Number of emploees 
   250 employees or more 
   Between 50-249 employees 
   Between 10-49 employees 

Less than 10 employees 
Don't know 

* 11  Please indicate the zoo's visitor number per year. 

   < 200,000 
   200,000 - 750,000 
   > 750,000 
   Don't know 

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12 Type of Zoo 

* 

   Zoo 
   Zoo with aquarium included 
  Aquarium 
   Animal park (zoo in which wild animals are housed and displayed in large open spaces 

designed to resemble their native habitats) 

   Safari park (enclosed park in which wild animals are kept uncaged in the open and can be 

viewed by the public from cars, etc.) 

   Other 

13  If 'Other', please specify 

* 

250 character(s) maximum 

14   Does the zoo have a license issued by the national authority to keep and 

* 

display wild animals? 

   Yes 
No 
   Applied, but licence pending 

15   Does the zoo have an exemption from licensing? 

* 

   Yes 
No 

16    Who is the authority responsible for issuing the zoo's licence? Please 

* 

specify the name of the organisation. 

250 character(s) maximum 

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17    Who is the authority responsible for granting the exemption? Please 

* 

specify the name of the organisation. 

250 character(s) maximum 

18    Is the zoo a member of a zoos association / representative body? If yes, 

please specify which one. 

250 character(s) maximum 

19    Is the zoo member of other organisations (biodiversity conservation, ex-
situ management, tourism, visitor attraction, business assoication etc.) If 
yes, please specify which ones. 

250 character(s) maximum 

20   Are any members of the zoo's staff member of Specialist Groups of 

IUCN’s Species Survival Commission? If yes, please specify which ones. 

500 character(s) maximum 

21 

How many species of animals and how many individual animals are kept in the zoo? 

Number 

Species 

Individual animals 

22 

Can you provide the source (report link, ISIS record, publication reference,..)? 

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23  If relevant, please also upload documents here. 

24 

Please specify the percentage of species you keep that are on global/European/national red lists. 

% of species 

Global red list 

European red list 

National red list 

Part I - Implementation of conservation measures 

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Under Article 3 of the EU Directive (Council Directive 1999/22/EC of 29 March 1999 relating to the 

keeping of wild animals in zoos) Member States (MS) are required to implement conservation 

measures to strengthen the role of zoos in the conservation of biodiversity. 

The conservation measures that EU zoos must implement under Article 3 of the Directive in order to 

obtain a licence are: 

Participation in one or more of the following: research and training through which conserva-

tion objectives may be achieved, exchange of information relating to species conservation 

skills, captive breeding, repopulation, or reintroduction of species into the wild; 

Promotion of public education and awareness in relation to the conservation of biodiversity, 

particularly by providing information about the species exhibited and their natural habitats; 

Accommodate animals under conditions which aim to satisfy the biological and conservation 

requirements of the individual species and maintaining a high standard of animal husbandry; 

Preventing the escape of animals in order to avoid threats to indigenous species and intrusion 

of outside pests and vermin; 

Keeping appropriate records of the zoo's collection 

Research, training and exchange of information 

25 

Throughout the implementation period of the Zoos Directive (2003-2016), has your zoo participated in 
research projects designed to benefit conservation? 

   Yes 
No 

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26  If your answer is “yes”, please provide the following information: 

From 

0 to 10 

From 

10 to 

25 

From 

25 to 

50 

More 

than 

50 

Don't 

know 

Number of research pro-

jects in which the zoo 

took part 

Number of publications 

issued (General interest 

publications, scientific 

publications, Guidance 

documents) 

27 

Could you provide a list of the main topics addressed in these research projects? If possible, 
substantiate your answer by providing the relevant documents or the list of projects or publi-
cations with full reference, or provide the URL here. 

850 character(s) maximum 

28  If relevant, please upload documents here. 

29 

Does the zoo offer trainings in conservation skills for professionals? 

   Yes 
No 

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30 

If your answer is “yes”, please specify the target groups of the trainings: 

Please select one or more answers 
   Own employees 
   Employees of other zoos 
  Students 
   Veterinarians 

Biologists 

   Volunteers 
   Other professionals 

31 

Please specify "other professionals" 

250 character(s) maximum 

32   Does the zoo take part in information sharing activities? 

   Yes 
No 

33 

If your answer is yes, please specify: 

   Exchange information with other zoos 
   Attendance at meetings with other regional or national stakeholders (e.g. zoos federa-

tions, national authorities) 

   Attendance of meetings with other international stakeholders (e.g., IUCN, EAZA) 

Use the International Species Information System (ISIS) 

   Other (please specify below) 

34 

If 'Other', please specify. 

500 character(s) maximum 

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35 

Please provide a short description of the information sharing activities carried out. 

850 character(s) maximum 

Captive breeding, repopulation or reintroduction of species into the wild 

36 

Do you have a written conservation strategy/plan? 

   Yes 
No 

37 

If possible, please provide the document, reference or URL. 

38  Please upload your document(s) here. 

39 

Please indicate the overall number of EEP (European Endangered Species Programme) or ESB (European 
Stud Books) captive breeding programmes the zoo takes part in or coordinates. 

Taking part 

Coordinating 

EEP 

ESB 

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40 

Please indicate the number and kind of other conservation programmes/projects the zoo 

participates in: 

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1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

Milieu Ltd  
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Name of the programme/project 

In-situ (conservation of species in their natural 

Ex-situ (conservation of species outside their 

Local/regional/national (please enter one of the 

EU/international (please enter one of the two 

In-situ or ex-situ conservation project within the 

habitats) (Yes/No) 

natural habitats) (Yes/No) 

three options) 

options) 

frame of Birds- and Habitats Directive (Yes/No) 

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41 

Please indicate if a species was downlisted in any red list (i.e. moved to a lower threat cate-
gory) or taken off any red list because of conservation programmes your zoo participated 
in? Please provide a short description. 

850 character(s) maximum 

42 

Please  indicate  the  number  of  individual  animals  bred  in  your  zoo  that  were  rein-
troduced into the wild over the last 15 years? Which species and which conservation 
programmes were involved? 

850 character(s) maximum 

43   If possible, please provide the documents, references or URLs. 

44 

Please upload your document(s) here. 

Promoting public education and awareness in relation to the conservation of bio-

diversity 

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45 

Does the zoo have a written education strategy (i.e., for non-specialists)? 

   Yes 
No 

46 

If your answer is “yes”, please provide the document, reference or URL or shortly de-
scribe the areas addressed, the target groups and kind of activities. 

850 character(s) maximum 

Please upload your document(s) here. 

47 

48 

Does the zoo carry out any of the following activities? 

Please select one or more answers 
   Animal shows 
Animal handling 
Keeper talks 

   Guided tours 
   Illustrated species talks 
  Interactive displays 
   Zoo maps 
   Species information boards 
   Literature provided at the entrance 

Other (please specify below) 

   None of the above 

49 

If 'Other', please specify. 

250 character(s) maximum 

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50 

If possible, please substantiate your answers by providing relevant documents or exam-
ples, e.g. annual report, press release, references, URLs. 

51  Please upload your document(s) here. 

52 

Which groups are targeted by these activities? 

Please select one or more answers 

   Schools 
   Wider public 
   Other (please specify below) 

53 

If 'Other', please specify. 

250 character(s) maximum 

Animal accommodation and husbandry 

54 

Are there minimum standards on animal accomodation for each species, issued by national authorities, 
zoos organisations or other bodies which the zoo applies? 

   Yes 
No 
   Not Applicable (if you are not aware of standards existing in your country) 

Don't know 

55 

If your answer is “yes”, please specify. 

500 character(s) maximum 

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56 

If your answer is “no”, please indicate on what you base the design of your enclo-
sures? 

850 character(s) maximum 

57 

Can you please provide the number (and percentage on total) of enclosures with environmental enrich-
ment measures? Please provide examples of these measures. If possible, please also provide the refer-
ences or sources. 

850 character(s) maximum 

58  If relevant, please also upload documents here. 

59 

Are animal keepers at the zoo required to have a national (if existing in your country)/international quali-
fication on animal care? 

   Yes 
No 
   Don't know 

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60 

Can you please indicate whether the zoo has the following capabilities? 

Yes 

No 

Written health care programmes (preventive and/or curative) 

Written nutrition programme 

In house qualified veterinarian with experience and 

knowledge of wild animals 

Contact with external qualified veterinarian with experience 

and knowledge of wild animals 

Hygiene plans for cleaning and change of food/water 

Protocols for capture/handling/transport of animals 

Other (please specify below) 

61 

If 'Other', please specify. 

250 character(s) maximum 

Prevention of escapes and intrusion 

62 

Can you please provide the number of escapes from the zoo posing threats to indigenous species that oc-
curred in the last 15 years (if any)? Which species were concerned? 

850 character(s) maximum 

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63 

Does the zoo have a formal plan/protocol to prevent animal escape and prevent intrusion of outside pests 
and vermin? 

Please select one or more answers 

   Yes, for escape of animals 
   Yes, for intrusion of outside pests and vermin 

No 

64 

If possible, please provide the plan/protocol. 

Record keeping 

65 

Does the zoo have a record keeping system of the zoo's collection? 

   Yes 
No 

66 

If your answer is “yes”, please specify the options that apply: 

Please select one or more answers 

   Paper-based system 
   Electronic or computer based system 
   Standardised data format is used and compliant with other institutions 

Individual record (per animal) 

   Group record (per species or groups within a species) 

Mainly individual records with few group records 

   Complete collection covered 
   Use of Zoological Information Management System (ZIMS ) 
   Records are used also for permits, information exchange, and transport certifi-

cates 

   Animal identification systems in line with national/international trade regulations (e.g. 

Council Regulation 338/97, and Commission Regulation 865/2006 ) 

   Information to be included is determined by the zoo 
   Information to be included is determined by the competent authority 

Other (please specify below) 

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67 

If 'Other', please specify. 

250 character(s) maximum 

Part II - Assessment of the Zoos Directive 

Effectiveness 

Assessing the effectiveness of the Zoos Directive means analysing the extent to which its objectives 

have been met, and identifying any significant factors that may have contributed to or inhibited 

progress towards meeting those objectives. 

68 

In your opinion, to what extent did the Directive contribute to achieving the following objectives? 

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Did not 

Slightly 

Strongly 

Fully con-

No 

contribute 

contributed 

contributed 

tributed 

opinion 

Protecting 

threatened 

wild species 

Reinforcing 

the role of 

zoos in 

preserving 

biodiversity 

Make peo-

ple aware 

of the val-

ues of bio-

diversity 

and the 

steps they 

can take to 

conserve 

and use it 

sustainably 

(as laid 

down in 

Aichi Target 

1 of the 

Convention 

of Biologic 

Diversity). 

Other 

(please 

specify 

below) 

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69 

If 'Other', please specify. 

500 character(s) maximum 

70 

If possible, please justify your replies with evidence. 

850 character(s) maximum 

71 

In your opinion, has the role of zoos in the conservation of biodiversity been strengthened over the last 
15 years? Can this be attributed to the Zoos Directive? 

   Yes, and it can be fully attributed to the Directive 

Yes, and it can be partly attributed to the Directive 
Yes, but it cannot be attributed to the Directive 
   No strengthened role has been observed 

No opinion 

72 

Please specify the reasons for your reply. 

850 character(s) maximum 

73 

Have you observed any other positive or negative changes as a consequence of the Directive? 

Please select one or more answers 

   Positive 
Negative 
   Don't know 

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74 

Please provide examples of positive changes that can be attributed to the Directive. 

500 character(s) maximum 

75 

Please provide examples of negative changes that can be attributed to the Directive. 

500 character(s) maximum 

76 

Concerning the licensing and inspection system established by the enforcement authorities, to what ex-
tent do you agree with the following statements? 

Totally 

Somewhat 

Somewhat 

Totally 

disagree 

disagree 

agree 

agree 

Don't 

know 

An appropriate li-

censing and inspec-

tion system is es-

tablished in my 

country 

Inspectorate has 

sufficient (financial 

and human) re-

sources to ensure 

the enforcement of 

the Directive’s re-

quirements 

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Inspectors have 

sufficient 

knowledge/training 

to ensure the en-

forcement of the 

Directive’s re-

quirements 

Every zoo is 

licensed 

Licenses contain 

conditions to en-

force Article 3 

requirements 

Zoos compliance is 

monitored regularly 

Inspections are 

carried out before 

granting/refusing a 

license 

Inspections are 

carried out before 

extending a license 

Inspections are 

carried out before 

significantly 

amending a license 

If a zoo does not 

meet licensing 

conditions, it is 

closed and/or has 

to comply with 

specific require-

ments 

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Penalties are im-

posed if breaches 

are detected are ef-

fective, proportion-

ate and dissuasive 

Other (please 

specify below) 

77 

If 'Other', please specify. 

250 character(s) maximum 

78 

If possible, please justify your replies with evidence. 

850 character(s) maximum 

79 

In your view, which main factors have contributed to or stood in the way of achieving the Zoos Di-
rective's objectives? 

850 character(s) maximum 

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Efficiency 

The central question asked here is whether the costs involved in the implementation of the Di-

rective are reasonable and in proportion to the benefits achieved. Both 'costs' and 'benefits' can be 

monetary and/or non-monetary. 

The implementation of the Directive and the related licensing system could have prompted one-off 

investments and triggered recurrent costs, in order to ensure the compliance of the zoo with the re-

quirements introduced. 

Important: For all questions below, only additional costs, directly due to the Zoos Directive, should 

be considered. Business-as-usual costs (costs from activities that would be incurred even in the ab-

sence of the legislation) should not be considered. To this purpose, we also ask you to identify the 

share of the costs/resources dedicated to the implementation of the Zoos Directive. 

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80 
Did you undertake the following investments? What share of these investments was made to obtain and keep the licence? 

As far as possible, please provide an estimate of the total investments undertaken (in 

€). If the investments were done fully or partly because of the Directive, indicate the share 

that can be attributed to the Directive (%). 

If the same investments would have been done also in absence of the Directive, please 

indicate 0%. 

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Total amount of the investments (€) 

Approximate share that can be attributed to the Directive (%). Please indicate 0% if 

the same investments would have been done also in absence of the Directive. 

Investments for: 

Renovation of the enclosures 

Provision of information on exhibited animals 

Improvement of standard of animal husbandry and of the enclosures 

Systems to prevent escape of animals and/or intrusion of outside pests and 

vermin 

Record keeping/animal identification systems 

Other (please specify below) 

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81 

If applicable, please specify 'Other'. 

250 character(s) maximum 

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82 
Have you observed increased recurrent costs in your zoo? What share of these costs is due to licencing requirements? 

As far as possible, please provide an estimate of the following annual costs in € and the share 

which can be attributed to obtaining/keeping a licence required by the Zoos Directive. If the 

investments were done fully or partly because of the Directive, indicate the share that can be 

attributed to the Directive (%). 

Recurrent costs: Estimate of annual costs (€) 

Share that can be attributed to the Directive (%). Please indicate 0% if the 

same investments would have been done also in absence of the Directive. 

Research and conservation projects 

Training activities 

Information exchange activities 

Education and awareness raising activities 

Information on exhibited animals 

Animal accommodation and high standard of animal husbandry 

Preventing escape of animals 

Preventing intrusion of outside pests and vermin 

Record keeping/animal identification systems 

Other (please specify below) 

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83  If applicable, please specify 'Other'. 

250 character(s) maximum 

84 

Did your zoo hire new staff in order to obtain a licence? 

   Yes 
No 
   Don't know 

85 

If “yes”, please indicate how many people and their responsibilities. 

500 character(s) maximum 

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86 

Do the procedures for licensing and inspection trigger administrative costs? 

As far as possible, please provide an estimate of the following information, as costs in € ded-

icated to the licensing and inspection procedure. Also possible penalties for non-compliance 

with licensing requirements are included. If your zoo was subject to a licensing system also 

before the implementation of the Zoo Directive, please estimate the increase occurred because 

of the system introduced by the national authority in order to implement the Zoo Directive. 

Costs for non-compliance with licensing requirements (penalties) ( Annual estimate in €) 

Charge paid to obtain the license (€) 

Zoo personnel involved in license applications: man days needed to prepare the application to obtain the license 

Zoo personnel involved in inspections by the MS Competent authorities: man days per one single inspection (preparatory work for the 

inspection, send documents to authorities, fill-in pre-inspection questionnaires, taking part in the visit of the MS Competent authorities, 

providing answer to the inspection report) 

Other (please specify below) 

Estimate 

Where licensing existed in your country before the Directive, estimate of the increase due to the implementation of the Zoo Directive (%). If 

licencing did not exist, the increase is 100% 

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87  If applicable, please specify 'Other'. 

250 character(s) maximum 

88 

Have there been delays in licensing that caused additional costs (e.g. investments in enclosure renova-
tion, foregone ticket sales, lower visitor numbers, etc.? 

   Yes 
No 
   Don't know 

89 

If your answer is “yes”, please provide a short description, and provide supporting evi-
dence to substantiate your statement (court judgments, complaint to the authorities). 

500 character(s) maximum 

90  If relevant, please also upload documents here. 

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91 

In your experience, does the Directive imply disproportionate costs? Please indicate which costs you 
deem as disproportionate and the reasons for that. 

Yes 

No 

Don't know 

Investments in order to ensure compliance with 

the licensing requirements 

Recurrent costs triggered by the licensing 

requirements in your zoo 

Administrative costs, in relation to the 

procedures for licensing and inspection 

Other (please specify below) 

92 

If 'Other', please specify. 

250 character(s) maximum 

93 

If possible, please justify your replies with evidence. 

850 character(s) maximum 

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94 

Was it difficult for your zoo to comply with and finance Article 3 requirements in order to obtain a li-
cense? 

   Very difficult 
   Moderatley difficult 
  Slightly diffucult 
   Not difficult at all 
  Don't know 

95 

Please provide examples from your experience. 

850 character(s) maximum 

96 

Do you know any good practices in terms of cost-effective implementation of the Zoos Directive? If yes, 
please provide examples. 

850 character(s) maximum 

97 

In your opinion, how significant are the benefits associated with the Directives? For each of the items 
below, please indicate to what extent benefits have been delivered. 

No 

Minor 

Moderate 

Major 

No 

benefits 

benefits 

benefits 

benefits 

opinion 

Benefits for overall 

biodiversity con-

servation 

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Benefits for pro-

tecting species 

from extinction 

Benefits for ex-situ 

conservation efforts 

Benefits for public 

education and better 

knowledge on biodi-

versity 

Benefits for positive 

changes of behav-

iour towards biodi-

versity protection 

Benefits for higher 

engagement of the 

public/stakeholders 

in biodiversity pro-

tection and other 

nature protection 

activities 

Benefits for ac-

commodation of 

animals and 

standard of animal 

husbandry 

Benefits for the local 

economy (e.g. new 

jobs in the zoo and 

related recreational 

activities, increased 

tourism, research 

and innovation on 

conservation issues) 

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Benefits for zoos as 

economic operators 

because of an EU 

wide legal framework 

(similar conditions 

among zoo operators 

in different EU MS) 

Benefits for zoos as 

economic operators 

as Zoos Directive 

triggers higher visitor 

numbers 

Benefits for society 

(e.g. health, culture, 

recreation) 

Other (please specify 

below) 

98 

If 'Other', please specify. 

250 character(s) maximum 

99 

Please provide examples for items where you see clear benefits and also the reasons why you 
don't see benefits for other items. Could you provide quantitative or monetary evidence for 
any of the benefits? 

850 character(s) maximum 

Coherence 

Evaluating the coherence of the Directive means assessing if the legislation is consistent with 

other legislation as well as with other related EU policies. 

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100 

Have you experienced problems (e.g. duplication of work) while applying requirements from other EU or 
international policies or legislation in addition to the zoos licensing requirements? 

Please select one or more answers 

   EU policies and legislation 
   International policies and agreements 

Don’t know 

101 

Please provide examples (e.g. regulations on animal health requirements, regula-
tions on trade, regulations on nature protection). 

850 character(s) maximum 

Relevance 

Relevance concerns the extent to which the objectives of the Zoos Directive are consistent with the 

needs of EU biodiversity conservation. It relates to whether the objectives of the legislation are still 

necessary and appropriate and whether the objectives and requirements set out in the Directive are 

still valid. 

102 

In your opinion, are the following needs that justified the adoption of the Directive still important? 

Yes 

No 

No opinion 

Protect species threatened by extinction 

Regulate ex-situ conservation 

Public awareness of biodiversity 

conservation issues 

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103 

Please justify your replies. 

850 character(s) maximum 

104 

In your opinion, is the Directive adapted to technical and scientific progress in the field of biodiversity 
conservation, especially ex-situ conservation and its links to in-situ conservation? 

Not at 

To some 

To a large 

No 

all 

extent 

extent 

opinion 

In the field of biodiversity 

conservation in general 

In relation to strengthening 

links between in-situ and 

ex-situ conservation 

Other (please specify below) 

105 

If 'Other', please specify. 

250 character(s) maximum 

106 

Please justify your replies. 

850 character(s) maximum 

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EU added value 

EU Added Value is defined as the additional value resulting from EU legislation compared to what 

would have been achieved by Member States acting in isolation.EU added value questions ask 

whether EU action was needed and is still needed. 

107 

In your zoo, were the measures listed below already in place before the adoption of the Directive? 

Yes 

No 

Don’t 

know 

Participation in research and training from which 

conservation objectives may be achieved, ex-

change of information relating to species conser-

vation skills and, where appropriate, captive breed-

ing, repopulation, or reintroduction of species into 

the wild 

Promotion of public education and awareness in 

relation to the conservation of biodiversity, par-

ticularly by providing information about the spe-

cies exhibited and their natural habitats 

Accommodating the animals under conditions that 

aim to satisfy the biological requirements of the 

species by providing specific enrichment to the 

enclosures, as well as maintaining high standards 

of animal husbandry and veterinary preventive and 

curative care 

Preventing the escape of the animals and avoid 

intrusion of outside pests and vermin 

Keep appropriate records of the zoo's collection 

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108 
In your zoo, to what extent has the Zoos Directive contributed to implementing new conservation 
measures or improving the existing ones? 

Did not 

Somewhat 

Fully con-

contribute 

contributed 

tributed 

Don't 

know 

Participation in research 

and training from which 

conservation objectives 

may be achieved, ex-

change of information 

relating to species con-

servation skills and, 

where appropriate, cap-

tive breeding, repopula-

tion, or reintroduction of 

species into the wild 

Promotion of public ed-

ucation and awareness 

in relation to the con-

servation of biodiversi-

ty, particularly by 

providing information 

about the species ex-

hibited and their natural 

habitats 

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Accommodating the ani-

mals under conditions 

that aim to satisfy the 

biological  requirements 

of the species by provid-

ing specific enrichment to 

the enclosures, as well 

as maintaining high 

standards of animal hus-

bandry and veterinary 

preventive and curative 

care 

Preventing the escape of 

the animals and the in-

trusion of outside pests 

and vermin. 

Keep appropriate records 

of the zoo's collection 

109 

Do you think an EU legislative act is necessary to ensure that zoos implement Article 3 measures? 

   Yes 
No 
   No opinion 

110 

Please justify your reply. 

850 character(s) maximum 

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111 

Could the same objectives be partly or entirely achieved with the relevant existing international conven-
tions, programmes or other instruments? 

Such instruments include the Convention on biological Diversity (CBD) with the Aichi Tar-
gets; the Birds Directive (Council Directive 79/409/EEC) and Habitats Directive (Council 
directive 92/43/EEC); the Convention on International Trade in endangered Species of Wild 
Flora and Fauna (CITES) and Council regulation No 338/97 on the protection of species and 
wild fauna and flora by regulating trade; Regulation 1143/2014 on invasive alien species; 
National species action plans in EU Member States; European code of conduct on zoological 
gardens and aquaria and invasive alien species (Council of Europe, Invasive alien Specialist 
Group, EAZA); European Endangered Species Programmes (EEP); IUCN technical guide-
lines for the management of ex-situ populations for conservation; WAZA World Zoo and 
Aquarium Conservation Strategy. 

   Yes, partly 
  Yes, fully 
  No 
   Don’t know 

112 

Please comment on your reply. 

850 character(s) maximum 

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113 

In your opinion would the Zoos Directive's objectives of protecting wild fauna and conserving biodiver-
sity have been better achieved with additional EU rules on the following matters? 

Yes 

No 

No 

opinion 

Monitoring and reporting obligations to the 

EU 

Coherent minimum standards for animal 

accommodation for all species kept in zoos 

EU-wide strategic approach for species 

conservation in zoos 

Focusing on conservation efforts in zoos 

on species of transnational importance 

Other (please specify below) 

114 

If 'Other', please specify. 

250 character(s) maximum 

115  Please justify your replies. 

850 character(s) maximum 

Part III - Concluding remarks 

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116 

What works well and what does not in the current legislation on the keeping of wild animals 
in zoos? Do you have specific recommendations for improvements? Please substantiate your 
reply. 

1000 character(s) maximum 

Thank you for your participation! 

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Targeted survey as part of the REFIT evaluation of the Zoos Directive, addressed to Mem-
ber State Competent Authorities 

Fields marked with * are mandatory. 

Disclaimer 

The European Commission is not responsible for the content of questionnaires created using the EUSurvey service - it 

remains the sole responsibility of the form creator and manager. The use of EUSurvey service does not imply a rec-

ommendation or endorsement, by the European Commission, of the views expressed within them. 

About this consultation 

The evaluation is part of the European Commission's Regulatory Fitness and Performance Pro-

gramme (REFIT). This programme involves a comprehensive, evidence-based assessment of 

whether the current regulatory framework is proportionate and fit for purpose, and delivering as ex-

pected. 

Objectives of the evaluation 

The evaluation examines the relevance, effectiveness, efficiency, coherence and EU added value of 

the EU Directive 1999/22/EC relating to keeping of wild animals in zoos (hereinafte r 'the Zoos Di-

rective'). It will evaluate what has worked well or poorly, and will compare actual performance to in-

itial expectations. It looks to see if the rules set out in the Directive are simple, clear and do not 

cause unnecessary costs. 

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The results will be used by the Commission to inform future decisions relating to the protection of 

wild animals and the enhancement of EU biodiversity, to which ex-situ conservation and zoos con-

tribute. The evaluation in itself does not consider possible future changes to the legislation. 

This survey is part of a broader range of consultation activities. Further information on the evalua-

tion and the different activities it involves can be consulted on the Commission’s eval uation web-

site. 

The aim of this consultation is to gather the views and opinions of interested stakeholders on the cur-

rent EU legislation on zoos and its implementation to date. Your responses will be used to help as-

sess the current situation and ensure that the most accurate and comprehensive evidence is taken into 

account. It is therefore important that you complete this questionnaire as fully as possible. 

The evaluation will look in particular at the implementation and functioning of the EU rules on the 

regulation of zoos with regards to: (1) the protection of wild animals; (2) the conservation of bio-

diversity by strengthening the role of zoos. 

The Zoos Directive, was adopted with the objective to promote wild animal species protection and 

conservation by strengthening the role of zoos in the conservation of biodiversity. The Directive in-

tended to achieve these objectives by the adoption of measures by Member States for the licensing 

and inspection of zoos in order to ensure that zoos respect conservation and protection measures, in-

cluding appropriate accommodation of the animals. 

The Directive requires Member States to establish a licencing and inspection system in order to 

ensure that zoos implement the following Article 3 conservation measures: 

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Participate in one or more of the following: i) research and training through which con-

servation objectives may be achieved, ii) exchange of information relating to species con-

servation, iii) captive breeding, iv) repopulation, or v) reintroduction of species into the 

wild; 

Promote public education and awareness in relation to the conservation of biodiversity, partic-

ularly by providing information about the species exhibited and their natural habitats; 

Accommodate animals under conditions which aim to satisfy the biological and conservation 

requirements of the individual species and maintaining a high standard of animal husbandry; 

Prevent the escape of animals in order to avoid threats to indigenous species and intrusion 

of outside pest and vermin; 

Keep appropriate records of the zoo’s collection. 

Guidance 

The questionnaire for this targeted online survey has been prepared in order to gather evi-

dence-based information for the evaluation. 

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Please answer questions based on direct experience. As far as possible, please provide evidence to 

substantiate your replies in the open text fields. For many questions it is also possible to upload sup-

porting documents. Where possible, quantitative evidence should be provided. Where this is not pos-

sible, estimates and qualitative evidence would be welcome. 

You can skip questions that you do not feel comfortable responding to. However, replies to ques-

tions marked with an asterisk are compulsory. 

This questionnaire is being sent out to Competent Authorities in 14 selected Member States (Bel-

gium, Bulgaria, Cyprus, Czech Republic, Denmark, France, Germany, Italy, Ireland, Lithuania, 

Netherlands, Poland, Portugal, Spain). 

NB: Several different questionnaires for different stakeholder groups have been estab-

lished, namely: 

National competent authorities (e.g. ministries or regional/local authorities re-

sponsible for implementing and enforcing the Zoos Directive) 

EU-level and national-level federations and associations of zoos (e.g. zoos federations) and 

non-governmental associations (NGOs in the field of biodiversity conservation or animal 

welfare)), as well as academics and other experts in the area 

            Zoo operators 

In addition, a public consultation for the broader public will run on the Commission’s website ‘Your 

Voice in Europe’ between September and December 2016. 

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The different surveys have been distributed via different distribution channels. If you feel you have 

not received the right questionnaire, or have any queries please contact zoos.dire ctive@milieu.be. If 

you are aware of additional specific documents that should be taken into account in the evidence 

gathering process, please submit them through the evaluation website. 

The present questionnaire is structured as follows: 

Part I investigates the the transposition of the Directive in your Member State. 

Part II concerns the implementation of conservation measures including licensing and en-

forcement activities. 

Part III gathers information and opinions in relation to the results achieved with the Zoos 

Directive, in order to assess its effectiveness, efficiency, relevance, coherence and added 

value. 

Part IV gives you the possibility to add concluding remarks. 

You may pause at any time and continue later. Once you have submitted your answers, you can 

download a copy of your completed responses. 

We kindly ask you to fill in the questionnaire within 4 weeks of receipt. 

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Use of the results 

1 
* 

Please note that according to the Commission's Better Regulation Guidelines, stakeholder's 
contributions will be published on the dedicated evaluation website. 

Regardless of the option chosen below, your contribution may be subject to a request for ac-
cess to documents under Regulation 1049/2001 on public access to European Parliament, 
Council and Commission documents. In such cases, the request will be assessed against the 
conditions set out in the Regulation and in accordance with applicable data protection rules. 

According to relevant data protection rules, please indicate whether your reply: 

   Can be published, including your name or that of your organisation (I consent to publi-
cation of all information in my contribution and I declare that none of it is under copy-
right restrictions that prevent publication) 

   Can be published in an anonymous way (I consent to publication of all information in my 
contribution except my name/the name of my organisation, and I declare that none of it is 
under copyright restrictions that prevent publication) 

   Cannot be published but only used for statistical and analytical purposes, in the context 

of the present study 

Information on the respondent 

*  2 Complete name of the organisation or expert 

* 3  Name and position of the respondent 

* 4  Email address 

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* 5  Telephone number 

* 6  Member State 
     Belgium 
Bulgaria 
Cyprus 
   Czech Republic 
  Denmark 
   France 

Germany 
Italy 

   Ireland 
Lithuania 
   Netherlands 

Poland 

   Portugal 
Spain 

Part I - Transposition of the Directive in your Member State 

*   7 Please provide the full name of the act(s) transposing the Directive 1999/22/EC, and the link to the web-

site where the legislation can be found. 

* 8 Which is (are) the designated competent authority (ies) in your Member State with 

overall responsibility for implementing the Directive? 

850 character(s) maximum 

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9. Has the deadline for transposition of the Directive into national law been met (original deadline was 9 
April 2002)? 

   Yes 
No 

10. If not, what was the reason for this and when has it been finally transposed? 

500 character(s) maximum 

11.  Are the objectives of the Zoos Directive (to protect wild animals and conserve biodiversity, strengthen the 

role of zoos in conservation of biodiversity) reflected correctly in national law? 

   Yes 
No 
   Don't know 

12. If not, where do you see discrepancies? 

500 character(s) maximum 

Article 2 of the Directive reads as follows: “[…], ‘zoos’ mean all permanent establishments 

where animals of wild species are kept for exhibition to the public for 7 or more days a year, 

with the exception of circuses, pet shops and establishments which Member States exempt from 

the requirements of the Directive on the grounds that they do not exhibit a significant number of 

animals or species to the public and the exemption will not jeopardise the objectives of the Di-

rective.” 

13.  Does national law provide for a definition of ‘zoos’? 

   Yes 
No 

14. If yes, please quote (in English) the text of the definition. 

850 character(s) maximum 

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15  Does national law provide for a definition of ‘animal of wild species’? 

   Yes 
No 

16 

If yes, please quote (in English) the text of the definition. 

850 character(s) maximum 

17  Does national law include exemptions according to Article 2? 

   Yes 
No 

18 

If yes, in which cases and how is a "significant number of animals" defined? 

500 character(s) maximum 

19 Are there minimum standards set by law, for animal accommodation/enclosure size? 

   Yes 
No 

20 

If your answer was “yes”, please provide reference and a short description. 

850 character(s) maximum 

21  If yes, are the standards set by law species-specific? 

   Yes 
No 

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22  If your answer was “yes”, please provide reference and a short description. 

500 character(s) maximum 

23 Are there any provisions in national law that go beyond those of the Zoos Directive? 

   Yes 
No 
   Don't know 

24 

If yes, please state which ones. 

500 character(s) maximum 

Part II – Implementation of the Directive in your Member State 

The initial deadline for transposition provided in the Directive is 9 April 2002. The implementa-

tion period corresponds to the time between the transposition of the Directive and today. The 

original deadline to have all zoos licenced by the competent authority was 29 March 2003 (four 

years after the entry into force of the Directive). 

Licensing in your Member State 

25  Which institution(s) or competent authority(ies) grant licenses to zoos? 

850 character(s) maximum 

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26 Are other (non-governmental) bodies/advisors involved? If so, please specify who they are 

and the role they play. 

850 character(s) maximum 

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27. Please provide the following numbers for your country, for the implementation period 
“New zoos” cover any zoo established later than four years after the entry into force of the Directive. If you 

cannot provide some of the answers, please state 'N/a' in the table. 

Number 

Number of zoos licenced within four years after the entry into 

force of the Directive 

Number of zoos licenced later than four years after the entry 

into force of the Directive (excluding new zoos) 

Number of new zoos licenced later than four years after the 

entry into force of the Directive 

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28. Please provide the following numbers for your country 

'Zoo' is understood within the meaning of the Directive. 

If you cannot provide some of the answers, please state 'N/a' in the table. 

2010 

2015 

Number of zoos to date (licensed and not 

licensed) 

Number of licensed zoos to date 

Number of zoos with a license application 

pending to date 

Number of zoos exempted from licensing 

to Article 2 

Number of zoos for which a license was 

refused (conditions not met) 

Number of zoos for which a license was 

initially refused (conditions not met) but 

granted later on after improvements have 

been made 

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29. If the first year of reference of the data you provided is different than 2010, please specify 
here. 

250 character(s) maximum 

30 If the last year of reference of the data you provided is different than 2015, please specify here. 

250 character(s) maximum 

31 

Please provide the reference to the source, or the URL where this data can be found, here: 

32  You  can  also  upload  relevant  documents  here.  If  a  document  is  too  big  to  be  up-

loaded, please send it to the address: zoos.directive@milieu.be 

33. What is the duration of validity of a license? If different types of licenses are provided, please indicate 
the types and differences in duration. 

850 character(s) maximum 

34 What is the cost of a license for an applicant? If costs vary, please indicate the costs for different types 
of licences. 

850 character(s) maximum 

Enforcement activities in your Member State 

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Organisation of enforcement authorities 

35  Which institution(s) or competent authority(ies) inspect the zoos? 

850 character(s) maximum 

36 If more institutions/authorities at local and/or regional level are identified, please describe also 
how their work is coordinated. Please also indicate if the authorities are supported by adviso-
ry bodies or external experts. 

850 character(s) maximum 

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37  What is the enforcement authority(ies) capacity for inspections? 

If you cannot provide some of the answers, please state 'N/a' in the table. 

Number 

Full time (equivalent) staff dedicated to zoos inspections 

Duration of one inspection procedure including reviewing 

documents, inspection form, inspection visit, report 

Number of zoos to be covered by one inspector (per year) 

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38 Please add any other information related to the enforcement authority(ies) capacity for in-

spections. 

850 character(s) maximum 

39 What other responsibilities does a zoo inspector have (e.g. general animal welfare, food safety, epidem-
ics control etc.)? 

850 character(s) maximum 

40 Are there specific criteria (in terms of educational background/expertise) to be met by inspectors ap-
pointed for zoos inspections? 

   Yes 
No 
   Don't know 

41 

If your answer was “yes”, please specify. 

500 character(s) maximum 

42  Are there training/training programmes for zoo inspectors? 

   Yes 
No 
   Don't know 

43 

If your answer was “yes”, please specify the content and frequency of training 

500 character(s) maximum 

Inspection regime and licensing procedure 

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44  What aspects are taken into account when carrying out inspections? 

850 character(s) maximum 

45. Is there a structured inspection form and a set of inspection criteria? 

   Yes 
No 
   Don't know 

46. If  your  answer  was  “yes”,  please  describe  it  below  and/or  upload  a  template  of  the 

form/criteria. 

850 character(s) maximum 

47  Please upload your document. If a document is too big to be uploaded, please send it to the 

address: zoos.directive@milieu.be 

48.  Does an inspection include pre- and post-inspection meetings with zoo staff? 

   Yes 
No 
   Don't know 

49.  Is relevant documentation requested in advance? 

   Yes 
No 
   Don't know 

50.  Is an inspection report prepared? 

   Yes 
No 
   Don't know 

51.  Is inspection work sub-contracted to other associations/entities? 

   Yes 
No 
   Don't know 

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52.  If  your  answer  was  “yes”,  please  specify  the  type  and  organisation  of  such  sub-

contracts, including their monitoring. 

500 character(s) maximum 

53.  Is there a central zoo database with results/documents of licencing/inspection procedures? 

   Yes 
No 
   Don't know 

54.  If so, can this database be accessed by all local and regional authorities dealing with the Zoos Directive? 

   Yes 
No 

55.  Are inspections carried out before: 

Granting/refusing a license 

Extending a license 

Significantly amending a license 

Yes 

No 

56. Are inspections carried out after a licence is granted? 

   Yes 
No 

57. If your answer was “yes”, how often do they take place (e.g. once per year)? 

500 aracter(s) maximum 

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58.  Could you provide an estimate of total number of inspections carried out for the following purposes since 

the entry into force of the Directive? 

If you cannot provide some of the answers, please state 'N/a' in the table. 

Number of inspections 

Granting/refusing a license 

Extending a license 

Significantly amending a license 

59.  According to national law implementing the EU Zoos Directive, are zoos required to carry out any of these 

activities in order to obtain the license? 

Yes 

No 

Don't 

know 

Research and/or training and/or exchange of 

information on species conservation 

Captive breeding, repopulation, reintroduction of 

species into the wild 

Public education and awareness raising in relation to 

conservation of biodiversity 

Providing information about exhibited species 

Accommodating animals under conditions which aim 

to satisfy the biological and conservation require-

ments of the individual species 

Maintain high standard of animal husbandry with 

programmes of preventive and curative veterinary 

care and nutrition 

Preventing the escape of animals in order to avoid 

ecological threats to indigenous species/preventing 

intrusion of outside pests and vermin 

Keeping of up to date records of zoos collection 

Other 

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60. If 'other', please specify: 

250 aracter(s) maximum 

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Criteria/indicators applied to assess whether the activity is properly carried out 

61.  Which criteria are applied for the assessment of these activities? 

Please provide the assessment criteria for the activities zoos are required to carry out, according to your answers to 

the previous question. 

Research and/or training and/or exchange of information on species conservation 

Captive breeding, repopulation, reintroduction of species into the wild 

Public education and awareness raising in relation to conservation of biodiversity 

Providing information about exhibited species 

Accommodating animals under conditions which aim to satisfy the biological and conservation 

requirements of the individual species 

Maintain high standard of animal husbandry with programmes of preventive and curative 

veterinary care and nutrition 

Preventing the escape of animals in order to avoid ecological threats to indigenous 

species/preventing intrusion of outside pests and vermin 

Keeping of up to date records of zoos collection 

Other (please specify in the table) 

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62.  Are there monetary penalties foreseen in case zoos do not comply with the Directive? 

   Yes 
No 

63. If your answer was “yes”, please indicate the range of monetary penalties applied to dif-

ferent breaches of the national legislation. 

500 character(s) maximum 

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64  With reference to information on breaches to national legislation, please pro-

vide the following data: 

If you cannot provide some of the answers, please state 'N/a' in the 
table. 

Number of regular inspections (as per Art.4(3) of 

Number of detected breaches after license was 

Number of zoos subject to penalties, due to 

Number of zoos completely closed because of 

Number of zoos partially closed because of 

the Directive) or average per year 

granted 

non-compliance with the Directive 

non-compliance 

non-compliance 

1998 

1999 

2000 

2001 

2002 

2003 

2004 

2005 

2006 

2007 

2008 

2009 

2010 

2011 

2012 

2013 

2014 

2015 

2016 

Total 

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65. Based on data collected during inspections, which are the most common reasons for breaches of Article 3 

provisions? 

High 

Medium 

Low 

Don't 

know 

Research and/or training and/or ex-

change of information on species 

conservation and/or captive breeding, 

repopulation, reintroduction of species 

into the wild 

Public education and awareness 

raising in relation to conservation of 

biodiversity, particularly by providing 

information about exhibited species 

and their habitats 

Accommodating animals under condi-

tions which aim to satisfy the biologi-

cal and conservation requirements of 

the individual species 

Maintain high standard of animal 

husbandry with programmes of 

preventive and curative veterinary 

care and nutrition 

Preventing the escape of animals in 

order to avoid ecological threats to 

indigenous species/preventing intru-

sion of outside pests and vermin 

Keeping of up to date records of zoos 

collection 

Other 

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66. If 'other', please specify 
250 aracter(s) maximum 

67. In  case  of  closure,  does  a  national  action  plan  or  other  arrangements  in  place  for  the  relocation  and  ac-

commodation of animals? 

   Yes 
No 
   Don't know 

68. If your answer was “yes”, please specify. For instance, are there sanctuaries and/or does a 

network of national/international contacts exist for animal placement? 

500 character(s) maximum 

69. Are you aware of escapes of wild animals from zoos over the implementation period? 

   Yes 
No 
   Don't know 

70 

If yes, please indicate the overall number of escapes as well as the species and the zoo con-
cerned. 

250 character(s) maximum 

71  Did you notice a reduction in these cases over the years? 

   Yes 
No 
   Don't know 

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72 

Please provide the reference to the source, or the URL where this data can be found, here: 

73 You can also upload documents here. If a document is too big to be uploaded, please send it to 

the address: zoos.directive@milieu.be 

Part III - Assessment of the Zoos Directive 

Effectiveness 

Assessing the effectiveness of the Zoos Directive means analysing the extent to which its objectives 

have been met, and identifying any significant factors that may have contributed to or inhibited 

progress towards meeting those objectives. 

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74 
In your opinion, to what extent did the Directive contribute to achieving the following objectives? 

Did not 

Slightly 

Strongly 

Fully con-

No 

contribute 

contributed 

contributed 

tributed 

opinion 

Protecting 

threatened 

wild species 

Reinforcing 

the role of 

zoos in 

preserving 

biodiversity 

Make peo-

ple aware 

of the val-

ues of bio-

diversity 

and the 

steps they 

can take to 

conserve 

and use it 

sustainably 

(as laid 

down in 

Aichi Target 

1 of the 

Convention 

of Biologic 

Diversity). 

Other 

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75 

If 'Other', please specify. 

250 character(s) maximum 

76 

If possible, please justify your replies with evidence. 

850 character(s) maximum 

77 

In your opinion, has the role of zoos in the conservation of biodiversity been strengthened over the last 
15 years? Can this be attributed to the Zoos Directive? 

   Yes, and it can be fully attributed to the Directive 

Yes, and it can be partly attributed to the Directive 
Yes, but it cannot be attributed to the Directive 
   No strengthened role has been observed 

No opinion 

78 

Please specify the reasons for your reply. 

850 character(s) maximum 

79 

Have you observed any other positive or negative changes as a consequence of the Directive? 

Please select one or more answers 

   Positive 
Negative 
   No changes 
  Don't know 

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80 

Please provide examples of positive changes that can be attributed to the Directive. 

500 character(s) maximum 

81 

Please provide examples of negative changes that can be attributed to the Directive. 

500 character(s) maximum 

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82 
Concerning the licensing and inspection system, to what extent do you agree with the following state-
ments? 

Totally 

Somewhat 

Somewhat 

Totally 

disagree 

disagree 

agree 

agree 

Don't 

know 

The monitoring and 

reporting system in 

your Member State 

is well suited to en-

sure compliance 

with the Article 3 

requirements 

Inspectors have 

sufficient 

knowledge/training 

to ensure the en-

forcement of the 

Directive’s re-

quirements 

Inspectorate has 

sufficient (financial 

and human) re-

sources to ensure 

the enforcement of 

the Directive’s re-

quirement 

Penalties available 

are effective, pro-

portionate and 

dissuasive 

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83 

If possible, please justify your replies with evidence. 

850 character(s) maximum 

84 Can you describe any action taken in the last years in order to improve the licensing and inspection sys-
tem (e.g. periodic trainings of inspectors, establishment of advisory bodies, development of centralised 
system of record keeping on inspections, etc.)? Or any other good practices in relation to inspections and 
licensing? 

850 character(s) maximum 

85 Are you aware of any other factors (e.g. actions by national authorities or other stakeholders, external 
factors) which contributed to or affected negatively the effective implementation of the Directive’s re-
quirements? 

850 character(s) maximum 

Efficiency 

The central question asked here is whether the costs involved in the implementation of the Di-

rective are reasonable and in proportion to the benefits achieved. Both 'costs' and 'benefits' can 

be monetary and/or non-monetary. 

Important: For all questions below, only additional costs, directly due to the Zoos Directive, 

should be considered. Business-as-usual costs (costs from administrative activities that would 

be occurred even in the absence of the legislation) should not be considered. 

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86. Have you observed increased costs triggered by the Directive in your administration in relation to: 

Yes 

No 

Don't 

know 

Treating license applications 

Preparing the inspection necessary for granting of 

the license 

Desk based inspections (e.g. analysis of records) 

On-site inspections 

Follow-up of inspections 

Training of inspectorate staff 

Monitoring the compliance of the legislation, 

providing information to the EC, exchanging 

information with other authorities 

Other 

87.  If 'other', please specify: 

250 character(s) maximum 

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88.  Can you estimate the following costs? 

If you cannot provide some of the answers, please state 'N/a' in the table. 

Estimate on an annual basis 

Costs incurred by authorities for closure of zoos 

Costs caused by invasive alien species that escaped from zoos   

Other 

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89.  If relevant, please specify 'other': 

250 aracter(s) maximum 

90.  If you could not provide specific estimate in the previous question, please provide an order of  magnitude 

of the costs incurred. 

Please provide an estimation of the magnitude of costs per year, in euros. 

100s 

1,000s 

10,000s 

100,000s 

1,000,000s 

Don't 

know 

Costs in-

curred by 

authorities 

for closure 

of zoos 

Costs 

caused by 

invasive al-

ien species 

that es-

caped from 

zoos 

Other 

91. If 'other', please specify: 

250 character(s) maximum 

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92 

In your experience, does the Directive imply disproportionate costs for the competent authorities? Please 
indicate which costs you deem as disproportionate and the reasons for that. 

Yes 

No 

Don't know 

Costs of licensing and inspections 

Costs relating to the closure of zoos 

Monitoring compliance 

Providing information to the EC 

Exchanging information with other authorities 

Other 

93 

If 'Other', please specify. 

250 character(s) maximum 

94 

Please justify your replies with evidence. 

850 character(s) maximum 

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95  In your opinion, how significant are the benefits associated with the Directives? For each of the 
items below, please indicate to what extent, in your opinions, direct and indirect benefits have been de-
livered. 

No 

Minor 

Moderate 

Major 

benefit 

benefits 

benefits 

benefits 

Don't 

know 

Benefits for overall 

biodiversity con-

servation 

Benefits for protecting 

species from extinction 

Benefits for ex-situ 

conservation efforts 

Benefits for public 

education and better 

knowledge on biodi-

versity 

Benefits for positive 

changes of behaviour 

towards biodiversity 

protection 

Benefits for higher 

engagement of the 

public/stakeholders in 

biodiversity protection 

and other nature pro-

tection activities 

Benefits for accom-

modation of animals 

and standard of ani-

mal husbandry 

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Benefits for the local 

economy (e.g. new 

jobs in the zoo and 

related recreational 

activities, increased 

tourism, research and 

innovation on conser-

vation issues) 

Benefits for zoos as 

economic operators 

because of an EU wide 

legal framework (crea-

tion of a level playing 

field among zoo opera-

tors in different EU 

MS) 

Benefits for zoos as 

economic operators as 

Zoos Directive triggers 

higher visitor numbers 

Benefits for society 

(e.g. health, culture, 

recreation) 

Other 

96  If 'other', please specify: 

250 character(s) maximum 

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97 

Please provide examples for items where you see clear benefits and also the reasons why you 
don't see benefits for other items. Could you provide quantitative or monetary evidence for 
any of the benefits? 

850 character(s) maximum 

98 Do you think it is more difficult for small zoo establishments (< 10-50 employees) to comply with and 
finance Article 3 requirements in order to obtain a license? 

   Yes 
No 
   Don't know 

99 

Please provide examples from your experience. 

850 character(s) maximum 

100 

Do you know any good practices in terms of cost-effective implementation of the Zoos Directive? If yes, 
please provide examples. 

850 character(s) maximum 

Coherence 

Evaluating the coherence of the Directive means assessing if the legislation is consistent with 

other legislation as well as with other related EU policies. 

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101 Is the Zoos Directive consistent with and mutually supportive of the following legal interventions or 
do you see significant gaps, overlaps or inconsistencies? 

Consistent 

and/or 

Mutually 

supportive 

Gaps 

Overlaps 

Inconsistencies 

Don't 

know 

Convention on 

biological Di-

versity (CBD 

)/Aichi targets 

Birds Directive, 

1979 (Council 

Directive 

79/409/EEC) 

and Habitats 

Directive, 1992 

(Council di-

rective 

92/43/EEC) 

Convention on 

International 

Trade in endan-

gered Species 

of Wild Flora 

and Fauna 

(CITES), 

embraced by 

Council Regula-

tion No 338/97 

on the protec-

tion of species 

and wild fauna 

and flora by 

regulating trade 

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Regulation 

1143/2014 on 

invasive alien 

species 

Commission 

regulation No 

1739/2005 of 21 

October 2005 

laying down an-

imal health re-

quirements for 

the movement of 

circus animals 

between Mem-

ber States 

Council Di-

rective 

92/65/EEC 0f 13 

July 1992 laying 

down animal 

health require-

ments govern-

ing trade in and 

imports into the 

Community of 

animals, semen, 

ova and embry-

os not subject to 

animal health 

requirements 

laid down in 

specific rules re-

ferred to in an-

nex A (I) to Di-

rective 

90/425/EEC 

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Council Di-

rective 

90/425/EEC of 

26 June 1990 

concerning vet-

erinary and zoo 

technical checks 

applicable in in-

tra-Community 

trade in certain 

live animals and 

products with a 

view to the 

completion of 

the internal 

market 

National species 

action plans in 

EU Member 

States 

National animal 

welfare acts 

Other 

102  If 'other', please specify 

250 character(s) maximum 

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103 

If you identified gaps, overlaps or inconsistencies, how do they impact the achievement of 
the Zoos Directive's objectives and the achievement of the objectives of the other legal in-
terventions? Do gaps, overlaps or inconsistencies result in additional administrative bur-
den? What would be your suggestion to resolve these inconsistencies? 

850 character(s) maximum 

104 Is the Zoos Directive consistent with and mutually supportive of the following non-legal instru-
ments or do you see significant gaps, overlaps or inconsistencies? 

Consistent 

and/or 

Mutually 

supportive 

Gaps 

Overlaps 

Inconsistencies 

Don't 

know 

European 

code of con-

duct on zoo-

logical gar-

dens and 

aquaria and 

invasive alien 

species 

(Council of 

Europe, Inva-

sive alien 

Specialist 

Group, EAZA) 

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IUCN 

technical 

guidelines for 

the man-

agement of 

ex-situ popu-

lations for 

conservation 

WAZA World 

Zoo and 

Aquarium 

Conservation 

Strategies 

European En-

dangered 

Species Pro-

grammes ( 

EEP) 

Other 

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105  If 'other', please specify: 

250 character(s) maximum 

106 

If you identified gaps, overlaps or inconsistencies, how do they impact the achievement of 
the Zoos Directive's objectives and the achievement of the objectives of the other legal inter-
ventions? Do gaps, overlaps or inconsistencies result in additional administrative burden? 
What would be your suggestion to resolve these inconsistencies? 

850 character(s) maximum 

Relevance 

Relevance concerns the extent to which the objectives of the Zoos Directive are consistent with the 

needs of EU biodiversity conservation. It relates to whether the objectives of the legislation are still 

necessary and appropriate and whether the objectives and requirements set out in the Directive are 

still valid. 

107 

In your opinion, are the following needs that justified the adoption of the Directive still important? 

Yes 

No 

No opinion 

Protect species threatened by extinction 

Regulate ex-situ conservation 

Public awareness of biodiversity 

conservation issues 

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108 

Please justify your replies. 

850 character(s) maximum 

109 

In your opinion, is the Directive adapted to technical and scientific progress in the field of biodiversity 
conservation, especially ex-situ conservation and its links to in-situ conservation? 

Not at 

To some 

To a large 

No 

all 

extent 

extent 

opinion 

In the field of biodiversity 

conservation in general 

In relation to strengthening 

links between in-situ and 

ex-situ conservation 

Other 

110 

If 'Other', please specify. 

250 character(s) maximum 

111 

Please justify your replies. 

850 character(s) maximum 

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EU added value 

EU Added Value is defined as the additional value resulting from EU legislation compared to what 

would have been achieved by Member States acting in isolation.EU added value questions ask 

whether EU action was needed and is still needed. 

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112 
Were the following conservation measures applying to zoos already in place in the national legislation 
before the adoption of the Directive? 

Yes 

No 

Don’t 

know 

Defining biodiversity conservation as the purpose of 

ex-situ conservation 

Research and/or training and/or exchange of in-

formation on species conservation, captive 

breeding, repopulation, reintroduction of species 

into the wild 

Public education and awareness raising in relation 

to conservation of biodiversity 

Providing information about exhibited species 

Accommodating animals under conditions which 

aim to satisfy the biological and conservation 

requirements of the individual species 

Maintain high standard of animal husbandry with 

programmes of preventive and curative veterinary 

care and nutrition 

Preventing the escape of animals in order to avoid 

ecological threats to indigenous species/preventing 

intrusion of outside pests and vermin 

Keeping of up to date records of zoos collection 

Other measures you are aware of 

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113  Please specify 'other measures': 

250 character(s) maximum 

114. Do you think that the EU intervention has contributed to make zoos adopt or implement the Article 
3 conservation measures more efficiently or more quickly as compared to national law or non-legal ini-
tiatives? 

   Yes 
No 
   Don't know 

115. Please justify your reply. 

850 character(s) maximum 

116 

Do you think an EU legislative act is necessary to ensure that zoos implement Article 3 measures? 

   Yes 
No 
   No opinion 

117 

Please justify your reply. 

850 character(s) maximum 

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118 

In your opinion, could the same objectives be partly or entirely achieved with the relevant existing inter-
national conventions, programmes or other instruments? 

Such instruments include the Convention on biological Diversity (CBD) with the Aichi Tar-
gets; the Birds Directive (Council Directive 79/409/EEC) and Habitats Directive (Council 
directive 92/43/EEC); the Convention on International Trade in endangered Species of Wild 
Flora and Fauna (CITES) and Council regulation No 338/97 on the protection of species and 
wild fauna and flora by regulating trade; Regulation 1143/2014 on invasive alien species; 
National species action plans in EU Member States; European code of conduct on zoological 
gardens and aquaria and invasive alien species (Council of Europe, Invasive alien Specialist 
Group, EAZA); European Endangered Species Programmes (EEP); IUCN technical guide-
lines for the management of ex-situ populations for conservation; WAZA World Zoo and 
Aquarium Conservation Strategy. 

   Yes, partly 
  Yes, fully 
  No 
   Don’t know 

119 

Please justify your reply. 

850 aracter(s) maximum 

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120. In your opinion would the Zoos Directive's objectives of protecting wild fauna and conserving biodi-
versity have been better achieved with additional EU rules on the following matters? 

Yes 

No 

No 

opinion 

Monitoring and reporting obligations to the 

EU 

Coherent minimum standards for animal 

accommodation for all species kept in zoos 

EU-wide strategic approach for species 

conservation in zoos 

Focusing on conservation efforts in zoos 

on species of transnational importance 

Other 

121.If 'Other', please specify. 

250 character(s) maximum 

122  Please justify your replies. 

850 character(s) maximum 

Part IV - Concluding remarks 

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123 

Which aspects, if any, of the Zoos Directive do you see as successful? Why? 

1000 racter(s) maximum 

124. Which aspects, if any, of the Zoos Directive do you see as failures? Why? 

1000 racter(s) maximum 

125. Do you have specific recommendations for improvements? 

1000 character(s) maximum 

* 126  May we contact you for further input to the study? 

   Yes 
No 

Thank you for your participation! 

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Targeted survey as part of the REFIT evaluation of the Zoos Directive, ad-
dressed to NGOs, zoos federations and experts 

Fields marked with * are mandatory. 

Disclaimer 

The European Commission is not responsible for the content of questionnaires created using the EUSurvey service - it 

remains the sole responsibility of the form creator and manager. The use of EUSurvey service does not imply a rec-

ommendation or endorsement, by the European Commission, of the views expressed within them. 

About this consultation 

The evaluation is part of the European Commission's Regulatory Fitness and Performance Pro-

gramme (REFIT). This programme involves a comprehensive, evidence-based assessment of 

whether the current regulatory framework is proportionate and fit for purpose, and delivering as ex-

pected. 

Objectives of the evaluation 

The evaluation examines the relevance, effectiveness, efficiency, coherence and EU added value of 

the EU Directive 1999/22/EC relating to keeping of wild animals in zoos (hereinafte r 'the Zoos Di-

rective'). It will evaluate what has worked well or poorly, and will compare actual performance to in-

itial expectations. It looks to see if the rules set out in the Directive are simple, clear and do not 

cause unnecessary costs. 

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The results will be used by the Commission to inform future decisions relating to the protection of 

wild animals and the enhancement of EU biodiversity, to which ex-situ conservation and zoos con-

tribute. The evaluation in itself does not consider possible future changes to the legislation. 

This survey is part of a broader range of consultation activities. Further information on the evalua-

tion and the different activities it involves can be consulted on the Commission’s eval uation web-

site. 

The aim of this consultation is to gather the views and opinions of interested stakeholders on the cur-

rent EU legislation on zoos and its implementation to date. Your responses will be used to help as-

sess the current situation and ensure that the most accurate and comprehensive evidence is taken into 

account. It is therefore important that you complete this questionnaire as fully as possible. 

The evaluation will look in particular at the implementation and functioning of the EU rules on the 

regulation of zoos with regards to: (1) the protection of wild animals; (2) the conservation of bio-

diversity by strengthening the role of zoos. 

The Zoos Directive, was adopted with the objective to promote wild animal species protection and 

conservation by strengthening the role of zoos in the conservation of biodiversity. The Directive in-

tended to achieve these objectives by the adoption of measures by Member States for the licensing 

and inspection of zoos in order to ensure that zoos respect conservation and protection measures, in-

cluding appropriate accommodation of the animals. 

The Directive requires Member States to establish a licencing and inspection system in order to 

ensure that zoos implement the following Article 3 conservation measures: 

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Participate in one or more of the following: i) research and training through which con-

servation objectives may be achieved, ii) exchange of information relating to species con-

servation, iii) captive breeding, iv) repopulation, or v) reintroduction of species into the 

wild; 

Promote public education and awareness in relation to the conservation of biodiversity, partic-

ularly by providing information about the species exhibited and their natural habitats; 

Accommodate animals under conditions which aim to satisfy the biological and conservation 

requirements of the individual species and maintaining a high standard of animal husbandry; 

Prevent the escape of animals in order to avoid threats to indigenous species and intrusion 

of outside pest and vermin; 

Keep appropriate records of the zoo’s collection. 

Guidance 

The questionnaire for this targeted online survey has been prepared in order to gather evi-

dence-based information for the evaluation. 

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Please answer questions based on direct experience. As far as possible, please provide evidence to 

substantiate your replies in the open text fields. For many questions it is also possible to upload sup-

porting documents. Where possible, quantitative evidence should be provided. Where this is not pos-

sible, estimates and qualitative evidence would be welcome. 

You can skip questions that you do not feel comfortable responding to. However, replies to ques-

tions marked with an asterisk are compulsory. 

To facilitate understanding of the questions, the survey is available in 13 languages. Given possible 

delays in translating comments submitted in some languages, contributions in English for the open 

text fields are welcome, as they will help to process the survey more swiftly. 

This questionnaire is being sent out to EU-level and national-level federations and associations 

of zoos in 14 selected Member States (Belgium, Bulgaria, Cyprus, Czech Republic, Denmark, 

France, Germany, Italy, Ireland, Lithuania, Netherlands, Poland, Portugal, Spain), as well as to 

NGOs and experts. 

NB: Several different questionnaires for different stakeholder groups have been estab-

lished, namely: 

National competent authorities (e.g. ministries or regional/local authorities re-

sponsible for implementing and enforcing the Zoos Directive) 

EU-level and national-level federations and associations of zoos (e.g. zoos federations) and 

non-governmental associations (NGOs in the field of biodiversity conservation or animal 

welfare)), as well as academics and other experts in the area 

            Zoo operators 

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In addition, a public consultation for the broader public will run on the Commission’s website ‘Your 

Voice in Europe’ between September and December 2016. 

The different surveys have been distributed via different distribution channels. If you feel you have 

not received the right questionnaire, or have any queries please contact zoos.dire ctive@milieu.be. If 

you are aware of additional specific documents that should be taken into account in the evidence 

gathering process, please submit them through the evaluation website. 

The present questionnaire is structured as follows: 

Part I investigates the implementation of the Directive 

Part II gathers information and opinions in relation to the results achieved with the Zoos Di-

rective, in order to assess its effectiveness, efficiency, relevance, coherence and added value. 

Part III gives stakeholders the possibility to add concluding remarks 

You may pause at any time and continue later. Once you have submitted your answers, you can 

download a copy of your completed responses. 

We kindly ask you to fill in the questionnaire within 4 weeks of receipt. 

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Use of the results 

1 
* 

Please note that according to the Commission's Better Regulation Guidelines, stakeholder's 
contributions will be published on the dedicated evaluation website. 

Regardless of the option chosen below, your contribution may be subject to a request for ac-
cess to documents under Regulation 1049/2001 on public access to European Parliament, 
Council and Commission documents. In such cases, the request will be assessed against the 
conditions set out in the Regulation and in accordance with applicable data protection rules. 

According to relevant data protection rules, please indicate whether your reply: 

   Can be published, including your name or that of your organisation (I consent to publi-
cation of all information in my contribution and I declare that none of it is under copy-
right restrictions that prevent publication) 

   Can be published in an anonymous way (I consent to publication of all information in my 
contribution except my name/the name of my organisation, and I declare that none of it is 
under copyright restrictions that prevent publication) 

   Cannot be published but only used for statistical and analytical purposes, in the context 

of the present study 

Information on the respondent 

* 2. Complete name of the organisation or expert 

* 3  Name and position of the respondent 

* 4  Email address 

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* 5  Telephone number 

6 
* 
What type of stakeholder do you represent? 

   Federation of zoos and/or aquaria 

Trade union 
   NGO 
   Scientific expert, academic, researcher 

Other 

7 
* 

If 'Other', please specify: 

250 character(s) maximum 

*  8  Do you operate mainly at international, EU or national level? 

You may choose one or more answers 
   International level 
  EU level 
   National level 

* 9  If you operate at national level, in which Member State are you based? 

     Belgium 
Bulgaria 
Cyprus 
   Czech Republic 
  Denmark 
   France 

Germany 
Italy 

   Ireland 
Lithuania 
   Netherlands 
Poland 
   Portugal 
Spain 

Other 

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* 10  If other, please specify: 

* 11  Which of the following best describes your main field of activity? 

   Environment, nature 
   Biodiversity in-situ conservation (conservation of species in their natural envi-

ronment) 

   Biodiversity – ex-situ conservation (conservation of species outside their natural envi-

ronment) 

   Animal welfare 
  Education 
   Recreation 

Tourism 
   Other 

* 12  If 'other', please specify: 

* 13  Are you registered in the EU Transparency Register? 

In the interests of transparency, organisations, networks, platforms or self-employed individuals engaged 
in activities aimed at influencing the EU decision making process have been invited to provide the public 
with relevant information about themselves, by registering in Transparency Register and subscribing to 
its Code of Conduct. 
Please note: If the organisation is not registered, the submission is published separately from the regis-
tered organisations. During the analysis of replies to a consultation, contributions from respondents who 
choose not to register will be treated as individual contributions (unless the contributors are recognised as 
representative stakeholders through Treaty provisions, European Social Dialogue, Art. 154-155 TFEU). 

If your organisation is not registered, you have the opportunity to register now. 

   Yes 
No 

14  If yes, please provide your EU Transparency Register ID number. 

Part I - Implementation of the Directive 

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Licensing 

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15 If you have the following data at the EU level, please provide the following numbers at EU level for 2015. If the data you have refers to another year, please specify in the next 
question. 
If you are an international/EU stakeholder- if you have information for all or some EU Member States, please 

provide the information in a separate document. 

'Zoo' is to be understood within the meaning of the Directive. 

Number 

Number of zoos to date (licensed and not licensed) 

Number of licensed zoos to date 

Number of zoos with a license application pending 

Number of zoos exempted from licensing according to Article 2 of the 

Directive(e.g. zoos that do not exhibit a significant number of animals or 

species to the public) 

Number of zoos for which a license was refused (conditions not met) 

Number of zoos closed over the implementation period, due to 

non-compliance with the requirements 

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16 

If the year of reference of the data you provided is different than 2015, please specify here. 

250 character(s) maximum 

17 

Please provide the reference to the source, or the URL where this data can be found, here: 

18  You can also upload documents here. If a document is too big to be uploaded, please send it to 

the address: zoos.directive@milieu.be 

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19. If you have the following data for your Member State, please provide the following numbers for your country, for 2015. If the data you have refers to another year, please specify 
in the next question. 
'Zoo' is to be understood within the meaning of the Directive. 

Number 

Number of zoos to date (licensed and not licensed) 

Number of licensed zoos to date 

Number of zoos with a license application pending 

Number of zoos exempted from licensing according to Article 2 of the 

Directive(e.g. zoos that do not exhibit a significant number of animals or 

species to the public) 

Number of zoos for which a license was refused (conditions not met) 

Number of zoos closed over the implementation period, due to 

non-compliance with the requirements 

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20 

If the year of reference of the data you provided is different than 2015, please specify here. 

250 character(s) maximum 

21 

Please provide the reference to the source, or the URL where this data can be found, here: 

22  You can also upload documents here. If a document is too big to be uploaded, please send it to 

the address: zoos.directive@milieu.be 

Enforcement activities 

23.  In case of closure, are you aware of national plan(s) or other arrangements for the relocation and accommo-

dation of zoos? 

   Yes 
No 
   Don't know 

24 

If you are an international or EU stakeholder, please specify the countries/region you refer to. 

250 character(s) maximum 

25 If your answer was “yes”, please specify. For instance, are there sanctuaries and/or does a 

network of national/international contacts exist for animal placement? 

500 character(s) maximum 

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26 Are you aware of escapes of wild animals from zoos over the implementation period? 

   Yes 
No 
   Don't know 

27 

If yes, please indicate number of escapes observed, per year where applicable, and the geo-
graphical coverage 

250 character(s) maximum 

28  Did you notice a reduction in these cases over the years? 

   Yes 
No 
   Don't know 

29 

Please provide the reference to the source, or the URL where this data can be found, here: 

30 You can also upload documents here. If a document is too big to be uploaded, please send it to 

the address: zoos.directive@milieu.be 

Part II - Assessment of the Zoos Directive 

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Under Article 3 of the EU Directive (Council Directive 1999/22/EC of 29 March 1999 relat-

ing to the keeping of wild animals in zoos.) Member States (MS) are required to implement 

conservation measures to strengthen the role of zoos in the conservation of biodiversity. The 

conservation measures that EU zoos must implement under Article 3 of the Directive in order 

to obtain a licence are: 

Participation in one or more of the following: research and training through which 

conservation objectives may be achieved, exchange of information relating to spe-

cies conservation skills, captive breeding, repopulation, or reintroduction of species 

into the wild; 

Promotion of public education and awareness in relation to the conservation of bio-

diversity, particularly by providing information about the species exhibited and their 

natural habitats; 

Accommodating the animals under conditions that aim to satisfy the biological re-

quirements of the species by providing specific enrichment to the enclosures, as well 

as maintaining high standards of animal husbandry and veterinary preventive and cu-

rative care; 

Preventing the escape of the animals in order to avoid threats to indigenous 

species and intrusion of outside pests and vermin; 

Keeping appropriate records of the zoo's collection 

Effectiveness 

Assessing the effectiveness of the Zoos Directive means analysing the extent to which its objec-

tives have been met, and identifying any significant factors that may have contributed to or in-

hibited progress towards meeting those objectives. 

31 

In your opinion, to what extent did the Directive contribute to achieving the following objectives? 

Did not 

Slightly 

Strongly 

Fully con-

No 

contribute 

contributed 

contributed 

tributed 

opinion 

Protecting 

threatened 

wild species 

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Reinforcing 

the role of 

zoos in 

preserving 

biodiversity 

Make peo-

ple aware 

of the val-

ues of bio-

diversity 

and the 

steps they 

can take to 

conserve 

and use it 

sustainably 

(as laid 

down in 

Aichi Target 

1 of the 

Convention 

of Biologic 

Diversity). 

Other 

(please 

specify 

below) 

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32 

If 'Other', please specify. 

250 character(s) maximum 

33 

If possible, please justify your replies with evidence. 

850 character(s) maximum 

34 

In your opinion, has the role of zoos in the conservation of biodiversity been strengthened over the last 
15 years? Can this be attributed to the Zoos Directive? 

   Yes, and it can be fully attributed to the Directive 

Yes, and it can be partly attributed to the Directive 
Yes, but it cannot be attributed to the Directive 
   No strengthened role has been observed 

No opinion 

35 

Please specify the reasons for your reply, with reference or evidence if possible. 

850 character(s) maximum 

36 

Have you observed any other positive or negative changes as a consequence of the Directive? 

Please select one or more answers 

   Positive 
Negative 
   No changes 
  Don't know 

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37 

Please provide examples of positive changes that can be attributed to the Directive. 

500 character(s) maximum 

38 

Please provide examples of negative changes that can be attributed to the Directive. 

500 character(s) maximum 

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39 
Concerning the licensing and inspection system, to what extent do you agree with the following state-
ments? 

Totally 

Somewhat 

Somewhat 

Totally 

No 

disagree 

disagree 

agree 

agree 

opinion 

Appropriate li-

censing and in-

spection sys-

tem(s) is(are) 

established 

Inspectors have 

sufficient 

knowledge/training 

to ensure the en-

forcement of the 

Directive’s re-

quirement 

Inspectorate has 

sufficient (financial 

and human) re-

sources to ensure 

the enforcement of 

the Directive’s re-

quirement 

Penalties applied if 

breaches are de-

tected are effec-

tive, proportionate 

and dissuasive 

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40 

If possible, please justify your replies with evidence. 

850 character(s) maximum 

41 If you are a national stakeholder, to what extent do you agree with the following statements? Please 
answer with reference to your Member State. 
Please answer with reference to your Member State only. 

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Totally 

Somewhat 

Somewhat 

Totally 

No 

disagree 

disagree 

agree 

agree 

opinion 

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Every zoo is 

licensed 

Licenses contain 

conditions to en-

force Article 3 

requirements 

Zoos compliance 

is monitored 

regularly 

Inspections are 

carried out before 

granting/refusing 

a license 

Inspections are 

carried out before 

extending a li-

cense 

Inspections are 

carried out before 

significantly 

amending a li-

cense 

If a zoo does not 

meet licensing 

conditions, it is 

closed and/or has 

to comply with 

appropriate re-

quirements im-

posed within an 

appropriate time 

period 

Other 

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42 

If 'Other', please specify. 

250 character(s) maximum 

43 

If possible, please justify your replies with evidence. 

850 character(s) maximum 

44 

In your view, which main factors have contributed to or stood in the way of achieving the Zoos Di-
rective's objectives? 

850 character(s) maximum 

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45 In your opinion, which main factors have contributed to or negatively affected the effective implementation 
of the Directive’s requirements? 

Has contribut-

ed to the effec-

tive implemen-

tation 

Has 

Had 

negatively 

no 

affected 

effect 

No 

opinion 

Transposition/implementation/enforcement 

by Member State(s) 

Enforcement by the Commission 

Level of clarity of the Directive’s provisions 

Coordination at different levels (EU, 

national, regional, local) 

Dedicated funding and resources 

Stakeholders’ involvement 

Public awareness and support 

Level of scientific knowledge about 

species and ex-situ conservation 

Integration of the Zoos Directive in other 

policies 

Other 

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46  If 'other', please specify. 

250 character(s) maximum 

47 

Please provide examples of factors that have 
contributed or negatively affected the effec-
tive implementation. 

850 character(s) maximum 

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Efficiency 

The central question asked here is whether the costs involved in the implementation of the Di-

rective are reasonable and in proportion to the benefits achieved. Both 'costs' and 'benefits' can be 

monetary and/or non-monetary. 

The implementation of the Directive and the related licensing system could have prompted one-off 

investments and triggered recurrent costs, in order to ensure the compliance of the zoo with the 

requirements introduced. 

Important: For all questions below, only additional costs, directly due to the Zoos Directive, should 

be considered. Business-as-usual costs (costs from activities that would be incurred even in the ab-

sence of the legislation) should not be considered. To this purpose, we also ask you to identify the 

share of the costs/resources dedicated to the implementation of the Zoos Directive. 

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48  Did the Zoo Directive imply an increase of costs for zoos and Member States? 

Following the enter into force of the Directive, zoos might have incurred new or high-

er costs in relation to the elements such as: 

Investments and/or recurrent costs to implement the national requirements to obtain or 

keep the licence (i.e. to implement the conservation measures related to Article 3); 

Administrative burdens (administrative costs to meet information obligations that are 

caused solely by the legislation and doesn't include business-as-usual administrative 

costs), arising from licensing and inspection procedures (i.e. labour costs for writing 

the license application, preparing the inspection necessary for granting of the license, 

send documents to authorities, fill 

pre-inspection questionnaires, etc.); 

Charges, e.g. license fees. 

Similarly, Member State authorities might incur administrative burdens that include but 

are not restricted to the following: labour costs for treating license applications, monitoring 

of compliance, exchange of information. Member States’ enforcement costs relate to com-

pliance monitoring, e.g., preparing the inspection necessary for granting of the license, 

evaluate pre-inspection questionnaires, onsite inspections, writing inspection report or 

costs for training of inspectorate staff. 

No significant 

costs 

Slightly 

increased 

costs 

High increase 

of costs 

Don't 

know 

Costs for zoos 

Costs for MS 

authorities 

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49 

Please provide a source or reference of evidence. 

50  If  relevant,  you  can  also  upload  documents  here.  If  a  document  is  too  big  to  be  up-

loaded, please send it to the address: zoos.directive@milieu.be 

51.  In your opinion, does the Directive imply disproportionate costs for the zoos and/or competent authorities? 

   Yes, for zoos 
   Yes, for MS competent authorities 

No 

   Don’t know 

52 

Please justify your reply. 

850 character(s) maximum 

53 

Do you know any good practices in terms of cost-effective implementation of the Zoos Directive? If yes, 
please provide examples. 

850 character(s) maximum 

54  Do you think it is more difficult for small zoo establishments (< 10-50 employees per year) to comply 
with and finance Article 3 requirements in order to obtain a license? 

   Yes 
No 
   Don't know 

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55 

Please provide examples 

850 character(s) maximum 

56 

In your opinion, how significant are the benefits associated with the Directives? For each of the items 
below, please indicate to what extent benefits have been delivered. 

No 

Minor 

Moderate 

Major 

No 

benefits 

benefits 

benefits 

benefits 

opinion 

Benefits for overall 

biodiversity con-

servation 

Benefits for pro-

tecting species 

from extinction 

Benefits for ex-situ 

conservation efforts 

Benefits for public 

education and better 

knowledge on biodi-

versity 

Benefits for positive 

changes of behav-

iour towards biodi-

versity protection 

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Benefits for higher 

engagement of the 

public/stakeholders 

in biodiversity pro-

tection and other 

nature protection 

activities 

Benefits for ac-

commodation of 

animals and 

standard of animal 

husbandry 

Benefits for the local 

economy (e.g. new 

jobs in the zoo and 

related recreational 

activities, increased 

tourism, research 

and innovation on 

conservation issues) 

Benefits for zoos as 

economic operators 

because of an EU 

wide legal framework 

(similar conditions 

among zoo operators 

in different EU MS) 

Benefits for zoos as 

economic operators 

as Zoos Directive 

triggers higher visitor 

numbers 

Benefits for society 

(e.g. health, culture, 

recreation) 

Other (please specify 

below) 

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57 

If 'Other', please specify. 

250 character(s) maximum 

58 

Please provide examples for items where you see clear benefits and also the reasons why you 
don't see benefits for other items. Could you provide quantitative or monetary evidence for 
any of the benefits? 

850 character(s) maximum 

Coherence 

Evaluating the coherence of the Directive means assessing if the legislation is consistent with 

other legislation as well as with other related EU policies. 

59 Is the Zoos Directive consistent with and mutually supportive of the following legal interventions or do 
you see significant gaps, overlaps or inconsistencies? 

Consistent 

and/or 

Mutually 

supportive 

Gaps 

Overlaps 

Inconsistencies 

Don’t 

know 

Convention on 

biological Di-

versity (CBD 

)/Aichi targets 

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Birds Directive, 

1979 (Council Di-

rective 

79/409/EEC) and 

Habitats Di-

rective, 1992 

(Council directive 

92/43/EEC) 

Convention on 

International 

Trade in endan-

gered Species 

of Wild Flora 

and Fauna 

(CITES), 

embraced by 

Council Regula-

tion No 338/97 

on the protec-

tion of species 

and wild fauna 

and flora by 

regulating trade 

Regulation 

1143/2014 on 

invasive alien 

species 

Commission 

regulation No 

1739/2005 of 21 

October 2005 

laying down an-

imal health re-

quirements for 

the movement of 

circus animals 

between Mem-

ber States 

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Council Directive 

92/65/EEC 0f 13 

July 1992 laying 

down animal 

health require-

ments governing 

trade in and im-

ports into the 

Community of 

animals, semen, 

ova and embryos 

not subject to an-

imal health re-

quirements laid 

down in specific 

rules referred to 

in annex A (I) to 

Directive 

90/425/EEC 

Council Directive 

90/425/EEC of 

26 June 1990 

concerning vet-

erinary and zoo 

technical checks 

applicable in in-

tra-Community 

trade in certain 

live animals and 

products with a 

view to the com-

pletion of the in-

ternal market 

National species 

action plans in 

EU Member 

States 

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National animal 

welfare acts 

Other 

60  If 'other', please specify. 

250 character(s) maximum 

61 If you identified gaps, overlaps or inconsistencies, how do they impact the achievement of 
the Zoos Directive's objectives and the achievement of the objectives of the other legal in-
terventions? Do gaps, overlaps or inconsistencies result in additional administrative bur-
den? What would be your suggestion to resolve these inconsistencies? 

850 character(s) maximum 

62 Is the Zoos Directive consistent with and mutually supportive of the following non-legal instru-
ments or do you see significant gaps, overlaps or inconsistencies? 

Consistent 

and/or 

Mutually 

supportive 

Gaps 

Overlaps 

Inconsistencies 

Don’t 

know 

European code 

of conduct on 

zoological gar-

dens and 

aquaria and in-

vasive alien 

species 

(Council of Eu-

rope, Invasive 

alien Specialist 

Group, EAZA) 

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IUCN technical 

guidelines for 

the manage-

ment of ex-situ 

populations for 

conservation 

WAZA World 

Zoo and 

Aquarium 

Conservation 

Strategies 

European En-

dangered 

Species Pro-

grammes ( 

EEP) 

Other 

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63  If 'other', please specify. 

250 character(s) maximum 

64 If you identified gaps, overlaps or inconsistencies, how do they impact the achievement of the 
Zoos Directive's objectives and the achievement of the objectives of the other legal interven-
tions? Do gaps, overlaps or inconsistencies result in additional administrative burden? What 
would be your suggestion to resolve these inconsistencies? 

850 character(s) maximum 

Relevance 

Relevance concerns the extent to which the objectives of the Zoos Directive are consistent with the 

needs of EU biodiversity conservation. It relates to whether the objectives of the legislation are still 

necessary and appropriate and whether the objectives and requirements set out in the Directive are 

still valid. 

65 

In your opinion, are the following needs that justified the adoption of the Directive still important? 

Yes 

No 

No opinion 

Protect species threatened by extinction 

Regulate ex-situ conservation 

Public awareness of biodiversity 

conservation issues 

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66 

Please justify your reply. 

850 character(s) maximum 

67 

In your opinion, is the Directive adapted to technical and scientific progress in the field of biodiversity 
conservation, especially ex-situ conservation and its links to in-situ conservation? 

Not at 

To some 

To a large 

No 

all 

extent 

extent 

opinion 

In the field of biodiversity 

conservation in general 

In relation to strengthening 

links between in-situ and 

ex-situ conservation 

Other (please specify below) 

68 

If 'Other', please specify. 

250 character(s) maximum 

69 

Please justify your reply. 

850 character(s) maximum 

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EU added value 

EU Added Value is defined as the additional value resulting from EU legislation compared to what 

would have been achieved by Member States acting in isolation.EU added value questions ask 

whether EU action was needed and is still needed. 

70 If you are a national stakeholder, were the following conservation measures already in place in the na-
tional legislation before the adoption of the Directive? 

Yes 

No 

Don't 

know 

Defining biodiversity conservation as the purpose of 

ex-situ conservation 

Research and/or training and/or exchange of infor-

mation on species conservation, captive breeding, 

repopulation, reintroduction of species into the wild 

Public education and awareness raising in relation to 

conservation of biodiversity 

Providing information about exhibited species 

Accommodating animals under conditions which aim 

to satisfy the biological and conservation require-

ments of the individual species 

Maintain high standard of animal husbandry with 

programmes of preventive and curative veterinary 

care and nutrition 

Preventing the escape of animals in order to avoid 

ecological threats to indigenous species/preventing 

intrusion of outside pests and vermin 

Keeping of up to date records of zoos collection 

Other measures you are aware of 

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71  Please specify 'other measures'. 

250 character(s) maximum 

72. If you are an EU/international stakeholder, are you aware of specific rules that were in place before 
the introduction of the Directive in one or several Member States? 

   Yes 
No 

73.  Please comment on your reply. 

850 character(s) maximum 

74.  Do  you  think that the EU  intervention has contributed  to adopt or implement the Article 3  conservation 

measures more efficiently or more quickly as compared to national law or non-legal initiatives? 

   Yes 
No 
   Don't know 

75.  Please comment on your reply. 

850 character(s) maximum 

76 

Do you think an EU legislative act is necessary to ensure that zoos implement Article 3 measures? 

   Yes 
No 
   No opinion 

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77 

Please justify your reply. 

850 character(s) maximum 

78 

In your opinion, could the same objectives be partly or entirely achieved with the relevant existing inter-
national conventions, programmes or other instruments? 

Such instruments include the Convention on biological Diversity (CBD) with the Aichi Tar-
gets; the Birds Directive (Council Directive 79/409/EEC) and Habitats Directive (Council di-
rective 92/43/EEC); the Convention on International Trade in endangered Species of Wild 
Flora and Fauna (CITES) and Council regulation No 338/97 on the protection of species and 
wild fauna and flora by regulating trade; Regulation 1143/2014 on invasive alien species; Na-
tional species action plans in EU Member States; European code of conduct on zoological 
gardens and aquaria and invasive alien species (Council of Europe, Invasive alien Specialist 
Group, EAZA); European Endangered Species Programmes (EEP); IUCN technical guide-
lines for the management of ex-situ populations for conservation; WAZA World Zoo and 
Aquarium Conservation Strategy. 

   Yes, partly 
  Yes, fully 
  No 
   Don’t know 

79 

Please comment on your reply. 

850 character(s) maximum 

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80. In your opinion would the Zoos Directive's objectives of protecting wild fauna and conserving biodi-
versity have been better achieved with additional EU rules on the following matters? 

Yes 

No 

No 

opinion 

Monitoring and reporting obligations to the 

EU 

Coherent minimum standards for animal 

accommodation for all species kept in zoos 

EU-wide strategic approach for species 

conservation in zoos 

Focusing on conservation efforts in zoos 

on species of transnational importance 

Other (please specify below) 

81.  If 'Other', please specify. 

250 character(s) maximum 

82  Please justify your replies. 

850 character(s) maximum 

Part III - Concluding remarks 

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83 
What works well and what does not in the current legislation on the keeping of wild animals in 
zoos? Do you have specific recommendations for improvements? Please substantiate your reply. 

1000 character(s) maximum 

* 84  May we contact you for further input to the study? 
  Yes  
  No 

Thank you for your participation! 

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ANNEX VII – INTERVIEWS REPORT 

1 

INTRODUCTION 

In line with the Better Regulation Guidelines on Stakeholder Consultation, this report aims at summa-
rizing the methodology and results of the stakeholders’ interviews undertaken as one of the consulta-
tion activities of the study to support the evaluation of the Zoos Directive. 

Within the consultation strategy applied to this study, the interviews were designed as part of the tar-
geted consultation of stakeholders. This targeted consultation comprised, first, the questionnaire-based 
online  surveys  targeted  to  specific  stakeholder  groups  (see  Targeted  Surveys  Report),  and  secondly 
follow-up interviews to complement the information collected through the targeted surveys, and make 
sure that the points raised by stakeholders were fully understood. 

The interviews were organised between 18th October 2016 and 1st March 2017 with: 

  National stakeholders: within each of the 14 Member States, depending on the number of rele-
vant stakeholders acting at national level, at least two and up to four interviews were held. The 
interviews at national level at least included one interview with the competent authority. The re-
maining ones were carried out with a different type of stakeholder preferably the main national 
zoo  federation,  an  NGO  involved  in  biodiversity  conservation,  ex-situ  conservation  or  animal 
welfare, or a zoo.  

  EU and international stakeholders: besides the stakeholders within the 14 Member States, the 
data collection team performed eight additional interviews with stakeholders from the EU and in-
ternational  level:  the European Association  of Zoos and Acquaria (EAZA),  the European  Com-
mission, the European Association for Aquatic Mammals (EAAM), Eurogroup for Animals and 
Born Free (Daniel Turner; Will Travers) and experts in biodiversity conservation. 

2  STAKEHOLDERS INTERVIEWED 

In  total,  44  stakeholders  were  interviewed:  13  MSCAs,  8  zoo  federations,  6  NGOs,  9  zoo  operators 
and 9 EU and international stakeholders. This is higher than the target initially provided in the consul-
tation strategy476. Table 8 provides the overview of the 44 stakeholders interviewed.  

Table 52: Overview of interviewed stakeholders 

Nb  Country  

1 

2 

3 

4 

5 

6 

7 

BE 

BE 

BE 

BG 

BG 

CY 

CY 

Stakeholder 
type 
MSCAs 

NGO 

Zoos 

NGO 

Zoos 

MSCAs 

NGO 

Organisation 

Walloon and Flemish Public Service for Animal Welfare 

GAIA 

BE Zoo (anonymity requested) 

Four Paws 

Sofia Zoo 

Veterinary Services 

ARC Cyprus 

476 A 14total of minimum 28 and maximum 42 interviews at national level, plus up to eight interviews at EU/international level. 

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8 

9 

10 

11 

12 

CY 

CZ 

DE 

DE 

DE 

13 

DK 

14 

DK 

15 

ES 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

29 

30 

31 

32 

33 

34 

35 

36 

37 

ES 

ES 

ES 

FR 

FR 

FR 

IE 

IE 

IE 

IT 

IT 

IT 

IT 

LT 

LT 

NL 

PL 

PL 

PT 

PT 

PT 

EU 

38 

EU 

39 

EU 

40 

EU 

41 

EU 

Milieu Ltd  
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Zoos 

MSCAs 

MSCAs 

MSCAs 

Zoos  federa-
tions 
MSCAs 

Zoos  federa-
tions 
MSCAs 

Zoos 

NGO 

Zoos  federa-
tions 
NGO 

Zoos 

MSCAs 

MSCAs 

Zoos  federa-
tions 
Zoos 

MSCAs 

Zoos  federa-
tions 
Zoos 

NGO 

MSCAs 

Zoos 

MSCAs 

Zoos 

Zoos  federa-
tions 
Zoos 

Zoos  federa-
tions 
MSCAs 

EU  and 
ternational 
EU  and 
ternational 
EU  and 
ternational 
EU  and 
ternational 
EU  and 
ternational 

in-

in-

in-

in-

in-

Pafos Zoo 

Ministry of the Environment of the Czech Republic  

Regional department for Health and Food Safety; Regional Insti-
tute for Animal Health, Bavaria 
Federal Ministry for the Environment, Nature Conservation 

Verband der Zoologischen Gärten – VdZ 

Ministry  of  Environment  and  Food;  Danish  Veterinary  and  Food 
Administration 
Danish Association of Zoos and Aquaria - DAZA 

Ministry  of  Agriculture,  Food  and  Environment,  General  direc-
torate  for  environmental  quality  and  evaluation,  General  sub-
directorate for natural environment,  
Zoobotanico Jerez 

Infozoos 

Asociación Ibérica de Zoos y Acuarios - AIZA 

Code Animal 

FR Zoo (anonymity requested) 

Ministry of Environment 

Ministry of Environment 

British and Irish Association of Zoos and Aquariums - BIAZA 

Fota 

Ministry  of  Environment,  Land  and  Sea  Protection;  Nature  and 
Sea Protection Directorate; CITES Management Authority 
Italian zoos federation 

IT zoo 

Animalisti Italiani 

Ministry of Environment; Nature Protection Department, Biodiver-
sity Division;  
Lithuanian Zoological Gardens 

Ministry of Economic Affairs 

Wroclaw Zoo 

Board of Directors of Polish Zoological Gardens and Aquaria 

Jardim zoologico e de aclimaçao em Portugal 

Associacao Portuguesa de Zoos e Aquaria - APZA 

Division of Animal Welfare - DGAV-DSPA 

Eurogroup for Animals 

EAZA 

BornFree (Daniel Turner; Will Travers) 

EAAM 

European Commission, DG Environment, Unit D.2 (Biodiversity) 

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42 

EU 

43 

EU 

44 

EU 

in-

EU  and 
ternational 
EU  and 
ternational 
EU  and 
ternational 

in-

in-

IUCN SSC Commission expert/Vice-Director of Copenhagen Zoo 

Expert in biodiversity conservation  

Expert in biodiversity conservation 

Source: Interviews in the context of this study  

Non-responsive stakeholders 
 

Some stakeholders were difficult to reach: CAs in Bulgaria, Cyprus, the Czech Republic, Poland 
and Lithuania were particularly slow in replying or non-responsive:  

  Bulgaria submitted the answer to the questionnaire very late in the process and declined an inter-

view. The Polish CAs also declined the interview.  

  The Dutch Federation of Zoos (NDV) wanted to seek information from their network for the in-
terview. Because this did not succeed, the federation refused to be interviewed and limited their 
response to the online questionnaire.  

  Most international stakeholders contacted declined an interview (WAZA, CITES Secretariat and 

CBD Secretariat).  

An expert of the SSC Commission of IUCN was interviewed, but no formal contribution of IUCN as 
an organisation was provided. 

3 

INTERVIEW QUESTIONS 

The interviews questions ensured a full coverage of the evaluation questions and tailored the questions 
to the different types of stakeholder groups identified. The links between the evaluation questions and 
interview questions were added to the evaluation framework. A semi-flexible approach was adopted to 
make  sure  that:  on  the  one  hand,  each  interview  takes  into  account  the  specific  context  and  issues 
raised by the stakeholder in the targeted survey; on the other hand, that the same topics are covered in 
all interviews and information remains comparable to a certain degree. 

The interview questions were drafted in collaboration with the European Commission. The interview 
questions,  as  well  as  the  targeted  stakeholders  and  the  general  approach,  were  discussed  during  a 
Steering Group Meeting on 6th October 2016. The minutes of the meeting are presented in Annex I to 
this report. 

Interview guidelines 
The project management team developed interview guidelines for the preparation and execution of the 
interviews.  The  guidance  document  was  subject  to  approval  by  DG  ENV,  and  afterwards  circulated 
among  the  study  team.  The  guidance  document  included  information  on:  the  purpose  of  the  inter-
views; the targeted stakeholders; instructions for contacting stakeholders,  preparing  (and tailoring  as 
needed)  the  questions  and  conducting  the  interviews;  the  interview  questions.  As  illustrated  in  the 
tables below, for each question, we provided:  

  The questions that were asked to the interviewees; 
  The type of stakeholders that are targeted for each question; 
 

background  information  based  on  the  early  findings  from  October  2016  for  the  interviewer  to 
understand the context of certain questions as needed;  
the links to the questions of the targeted questionnaires. To prepare the interviews, the interviewer 
was asked to check the answers provided by the interviewee to these specific questions. 

 

  The respondents that provided answers to those questions. 

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Some  interviews  were  carried  out  as  a  second  round  to  complement  specific  points  of  the 
study on which data was found to be particularly scarce. The table below provides an over-
view of those second round of interviews and the specific aspects that they covered.  

Table 53: Supplementary interviews 

Purpose of the interview 
Gain additional insight regarding: 
-  the  context  leading  to the  adoption  of the  Zoos 
Directive; 
- the situation in the EU countries prior to its imple-
mentation (baseline). 

Interaction of the Directive with the IAS Regulation 

Interviewee 
BornFree (Will Travers)  
Expert  in  biodiversity  conservation  (Stanley  John-
son)  
Expert 
Sundseth - Ecosystems ltd)  
IUCN  SSC  Commission  expert/Vice-Director  of 
Copenhagen Zoo (Bengt Holst) 
European  Commission,  DG  Environment,  Unit  D.2 
(Biodiversity) 

in  biodiversity  conservation 

(Kerstin 

Such interviews were based on a more flexible approach and did not follow exactly the same 
structure as the others. Hence they might not appear as systematically in the tables below.  

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Table 54: Effectiveness 

Question 

Target 

Background information 

Question 1. 
What  progress  have 
Member  States  made  over  time  to-
wards achieving the objectives set out 
in  the  Directive  and  the  related  trans-
posed  national legislations  (to  protect 
wild fauna and to conserve biodiversi-
ty/to strengthen the role of zoos in the 
conservation  of  biodiversity)?  Could 
you provide evidence?  

Zoos  feder-
ation 
MSCA 
NGO 

Question 2. 
 What  has  worked 
well and what hasn’t in the implemen-
tation  of  the  Directive  and  why? 
Which  factors  contributed  or  stood  in 
the  way  of  achieving  the  Directive 
objectives? 

Zoos  feder-
ation 
MSCA 
NGO 

A  majority  of  zoos  considered  that  the  Directive 
contributed  (to a  more  or less significant  extent)  to 
the  protection  of  species  and  the  preservation  of 
biodiversity.  A  vast  majority  of  zoos  also  estimated 
that the role they have played on biodiversity con-
servation  has  been  strengthened  over  the  past  15 
years and that this could be at least partly attribut-
ed  to  the  Directive.  Different  profiles  of  zoos  (con-
servation  oriented  zoos  vs  more  entertainment  ori-
ented zoos, small vs big zoos, conservation-oriented 
vs  entertainment-oriented,  public  vs  private  zoos) 
might  show  different  patterns  in  the  evolution  of 
their activities towards conservation. 

Several  factors  were  mentioned  in  the  question-
naires  that  influenced  the  achievement  of  the  Di-
rective’s goals positively or negatively. 
Examples  of  positive  factors:  Membership  in  zoos 
association, small zoos forming conservation clusters 
to  build  capacity  for  bigger  conservation  pro-
grammes, zoos’ financial contributions to in situ con-
servation,  cross-border  cooperation  of  zoos  and 
national  authorities,  minimum  standards  for  animal 
husbandry in national legislation, national legislation 
going  beyond  Article  3(1)  of  the  Directive,  involve-
ment of advisory boards/committees or zoos associ-

targeted 

Link  with 
online questionnaire 
: 
Zoos  questionnaire 
questions  25-42;  107-
113 
MSCAs  questionnaire  : 
questions 112-126 

: 

Zoos  questionnaire 
questions 76, 116 
MSCAs  questionnaire  : 
questions  35-71 ;  82-
85 ; 123-126 
NGOs&Federation 
questionnaire :  ques-
tions 39-41 ; 83-84 

Interview respondents 

federations :  EAZA, 
Zoos 
EAAM,  Verband  der  Zoo-
logischen  Gärten 
(VdZ), 
DAZA477,  AIZA478,  BIAZA479, 
APZA480,  UIZA481. 
MSCAs :  BE,  DE  (central), 
ES, FR, IT, NL. 
NGOs: 
Euro-
BornFree, 
group for Animals, GAIA482, 
Four Paws Bulgaria, Animal 
Rescue  Centre  (ARC)  Cy-
Infozoos483,  Code 
prus, 
Animal,  Animalisti 
Italia-
ni484. 
federations :  EAZA, 
Zoos 
EAAM,  VdZ,  DAZA,  AIZA, 
BIAZA, APZA,  UIZA. 
MSCAs :  BE,  CZ,  DE  (re-
gional),  DE  (central),  DK, 
ES,  FR, IE, IT, NL, PT. 
NGOs: 
Eu-
rogroup for Animals, GAIA, 
Four Paws Bulgaria, Animal 
Rescue  Centre  (ARC)  Cy-
prus,  Infozoos,  Code  Ani-
mal, Animalisti Italiani. 

BornFree, 

477 DK zoos federation. 
478 ES zoos federation. 
479 British and Irish zoos federation. 
480 Portuguese zoos federation. 
481 IT zoos federation. 
482 BE animal welfare NGO. 
483 ES NGO. 
484 IT NGO. 

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ations in the inspection procedure. 
Examples  of  negative  factors:  lack  of  enforcement 
by  authorities  due  to  resource  constraints,  lack  of 
knowledge  in  competent  authorities,  tendency  to 
keep  non-compliant  zoos  open  as  closure  is  cum-
bersome, lack of support from more entertainment-
oriented  zoos,  vagueness  of  Directive’s  require-
ments  (especially  Article  3(1)  either-or-option),  lack 
of  monitoring  and  reporting  system,  lack  of  refer-
ence in the Directive to growing importance of zoos 
for in situ conservation 
See  background  under  question  2.  For  instance,  in 
terms  of  contribution,  literature  suggests  that,  be-
sides  actively  taking  part 
in  conservation  pro-
grammes,  some  zoos  also  invest  part  of  their  funds 
in  conservation  projects  (both  in  situ  and  ex  situ). 
Actions  triggered  by  EAZA  membership  and  coop-
eration  programmes  between  MSCAs  are  exam-
ples. 

Zoos  questionnaire 
: 
questions  25-32 ;  36-
42 ; 107-113 
MSCAs  questionnaire  : 
questions 112-126 

Question 3. 
Are  you  aware  of 
specific actions by stakeholders which 
contributed  or  impeded  the  require-
ments  of  the  Directive?  Any  good  or 
bad practice examples? 

Zoos  feder-
ation 
MSCA 
NGO 

Question 4. 
How  have  the  con-
servation  related  activities  (research 
programmes,  public  awareness  rais-
ing, 
zoos 
changed  with  the  adoption  of  the 
Directive? 

accommodation) 

of 

See background under question 1.  

Overall answers 

Zoos  feder-
ation 
MSCA 
NGO 

Question 5. 
Beyond the objectives 
of  biodiversity  conservation  and  pro-
tection  of  wild  fauna,  have  you  ob-
served other significant changes, posi-
tive  or  negative,  resulting  from  the 

Zoos  feder-
ation 
MSCA 
NGO 

See  background  under  question  2.  For  instance, 
harmonisation of standards across EU zoos. 

: 

Zoos  questionnaire 
question 73 
MSCAs  questionnaire  : 
question 79 
NGO& 

federations 

Zoos 
federations :  EAZA, 
EAAM,  VdZ,  DAZA,  AIZA, 
BIAZA, APZA,  UIZA. 
MSCAs :  BE,  DE  (regional), 
DE  (central),  ES,  FR,  IE,  IT, 
NL, PT. 
NGOs: 
Euro-
BornFree, 
group  for  Animals,  GAIA, 
Four Paws Bulgaria, Animal 
Rescue  Centre  (ARC)  Cy-
prus,  Infozoos,  Code  Ani-
mal, Animalisti Italiani. 
federations :  EAZA, 
Zoos 
EAAM,  VdZ,  DAZA,  AIZA, 
BIAZA, APZA,  UIZA. 
MSCAs :  BE,  DE  (regional), 
DE  (central),  DK,  ES,  FR,  IE, 
IT, NL, PT. 
NGOs: 
Eu-
rogroup for Animals, GAIA, 
Four Paws Bulgaria, Animal 
Rescue  Centre  (ARC)  Cy-
prus,  Infozoos,  Code  Ani-
mal, Animalisti Italiani. 
Zoos 
federations :  EAZA, 
EAAM,  VdZ,  DAZA,  AIZA, 
BIAZA, APZA. 
MSCAs :  BE,  DE  (central), 
DK, FR, IE, IT, NL, PT. 

BornFree, 

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adoption  and  implementation  of  the 
Directive? 

questionnaire :  ques-
tion 41. 

Question 6. 
Has the formulation of 
the  Directive  (e.g.  definition  of  ‘zoos’, 
conservation measures listed in Article 
3,  either-or-option  of  Article  3  (1)) 
been problematic in your experience? 
law  formulate  more 
Does  national 
specific  or  more  stringent 
require-
ments?  If  so,  does  this  efficiently  ad-
dress these shortcomings? 

Zoos  feder-
ation 
MSCA 
NGO 

Evidence  received  so  far  from  competent  authori-
ties’  replies  indicates  that  there  are  different  ap-
proaches  to  transpose,  implement  and  enforce  the 
Directive  which  could  result  in  different  levels  of  ef-
fectiveness.  There  seems  to  be  a  huge  difference 
across Member States in enforcement capacity and 
therefore in the number of non-licenced zoos. 

: 

Zoos  questionnaire 
question 116 
MSCAs  questionnaire  : 
questions 7-24  
NGOs&Federation 
questionnaire :  ques-
tions 45-47 

the 

Question 7. 
licensing 
Does 
system in your country work  properly? 
Can you explain why – or why not? In 
particular,  do  the  authorities  have 
sufficient  capacity,  knowledge  and 
resources? 

Zoos  feder-
ation 
MSCA 
NGO 

See background under question 2. The proportion of 
unlicensed zoos varies significantly from a country to 
another.  In  some  countries  the  licensing  procedures 
is semi-automatical – without inspections necessarily 
carried out before the issuance of a licence. 

MSCAs  questionnaire  : 
questions 25-71. 
NGOs  & 
federations 
questionnaire  :  ques-
tions 31-45. 

How  did  the 

Question 8. 
imple-
mentation  and  enforcement  of  the 
Directive  by  Member  States  compe-
tent  authorities  evolve  in  your  Mem-
ber State over the time? 

Zoos  feder-
ation 
MSCA 
NGO 

A  few  replies  to  the  questionnaires  indicate  that  a 
major  part  of  the  inspection  system  refers  to  tech-
nical  issues  like  animal  health,  conditions  under 
which animals are kept, enclosure size, animal regis-
tration system, CITES issues, etc.). 

MSCAs  questionnaire  : 
questions 25-71. 
NGOs  & 
federations 
questionnaire  :  ques-
tions 31-45. 

BornFree, 

BornFree, 

NGOs: 
Eu-
rogroup for Animals, GAIA, 
Four Paws Bulgaria, Animal 
Rescue  Centre  (ARC)  Cy-
prus,  Infozoos,  Code  Ani-
mal. 
Zoos 
federations :  EAZA, 
EAAM,  VdZ,  DAZA,  AIZA, 
BIAZA,  UIZA. 
MSCAs :  BE,  DE  (regional), 
DE  (central),  DK,  ES,  FR,  IE, 
IT, NL, PT. 
NGOs: 
Eu-
rogroup for Animals, GAIA, 
Four Paws Bulgaria, Animal 
Rescue  Centre  (ARC)  Cy-
prus,  Infozoos,  Code  Ani-
mal, Animalisti Italiani. 
Zoos 
federations :VdZ, 
DAZA,  AIZA,  BIAZA,  APZA,  
UIZA. 
Zoos 
federations :  VdZ, 
DAZA,  AIZA,  BIAZA,  APZA,  
UIZA. 
MSCAs :  BE,  CZ,  DE  (regio-
nal),  DE  (central),  DK,  ES, 
FR, IT, NL, PT. 
NGOs: 
Euro-
BornFree, 
group  for  Animals,  GAIA, 
Four Paws Bulgaria, Animal 
Rescue  Centre  (ARC)  Cy-
prus,  Infozoos,  Code  Ani-
mal, Animalisti Italiani. 
Zoos 
federations :  EAZA, 
EAAM,  VdZ,  DAZA,  AIZA, 
BIAZA, APZA,  UIZA. 
MSCAs :  BE,  DE  (regional), 
DE  (central),  DK,  ES,  FR,  IT, 
NL, PT. 
NGOs: 

BornFree, 

Euro-

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Question 9. 
How  are  closures  of 
zoos  handled  at  national 
in 
practice?  Do  you  have  specific  ex-
amples  of  actions  taken  for  the  dis-
posal/relocation of animals?  

level 

Zoos  feder-
ation 
MSCA 
NGO 

There  seems  to  be  a  tendency  to  keep  non-
compliant  zoos  open  as  disposal/relocation  of  ani-
mals in case of closure is very cumbersome. It seems 
as closure is only used as a means to put pressure on 
zoos  to  comply  (e.g.  reducing  number  of  species, 
renovating enclosures) or stop their business. 

MSCA  questionnaire: 
questions 67-68 

Question 10. 
Is  the  EU  Zoos  Di-
rective  Good  Practices  Document 
used  by  competent  authorities  to 
enhance  their  understanding  of  the 
Directive?  

MSCA 

The  lack  of  knowledge  was  mentioned  many  times 
across  all  stakeholders,  even  by  MSCAs  themselves. 
It would be helpful to elaborate further on this prob-
lem. So far no MSCA mentioned the use of the Good 
Practices  Document.  The  fact  that  the  Good  Prac-
tices  Document  exist  only  in  English  was  highlighted 
by stakeholders as impeding its use across the EU. 

- 

Table 55: Efficiency 

group  for  Animals,  GAIA, 
Four Paws Bulgaria, Animal 
Rescue  Centre  (ARC)  Cy-
prus,  Infozoos,  Code  Ani-
mal. 
federations :  EAZA, 
Zoos 
EAAM,  VdZ,  DAZA,  AIZA, 
BIAZA, APZA,  UIZA. 
MSCAs :  BE,  DE  (regional), 
DE  (central),    FR,  ES,  IE,  IT, 
NL, PT. 
NGOs: 
Eu-
rogroup for Animals, GAIA, 
Four Paws Bulgaria, Animal 
Rescue  Centre  (ARC)  Cy-
prus,  Infozoos,  Code  Ani-
mal, Animalisti Italiani. 
MSCAs :  BE,  CZ,  DE  (re-
gional),  DE  (central),  DK, 
ES, FR, IE, IT, NL, PT. 

BornFree, 

Question 

Target 

Background information 

Link  with  targeted  online 
questionnaire 

Interview respondents 

Zoos  feder-
ation 
Zoo 

Compliance costs for zoos: one-off investments and recurrent costs due to the Directive 
Question 11. 
In  order  to  ensure 
compliance  with  the  Zoo  Directive, 
did  zoos  incur  additional  one-off 
costs 
that 
(i.e.  excluding  costs 
would  have  occurred  also  in  the 
absence  of 
legislation),  such  as 
hiring  of  personnel,  or  investments 
for  the  renovation  of  enclosures, 
provisions of information, etc.? If so, 
which  are  the  most  relevant  addi-

The implementation of the Directive and the relat-
ed  licensing  system  could  have  prompted  one-off 
investments  (e.g.  building  new  enclosure)  and 
triggered  recurrent  costs  (e.g.  training  activities, 
information  exchange,  record  keeping,  etc.),  in 
order to ensure the compliance of the zoo with the 
requirements  introduced  by  the  Directive.  Also, 
additional  staff  could  have  been  hired  to  address 
the  needs  created  by  the 
require-
ments.NB:  For  all  questions  below,  only  additional 

licensing 

Zoos  questionnaire  :  ques-
tions 80-97 
MSCAs  questionnaire 
questions 86-100 
NGOs&  federations  ques-
tionnaire : 48-56 

: 

Zoos 
federations :  EAZA, 
VdZ,  DAZA,  AIZA,  BIAZA, 
APZA,  UIZA. 
Zoos :  BE  Zoo,  Sofia  Zoo, 
Pafos  Zoo,  Zoobotanico 
Jerez,  FR  Zoo,  Fota,  Italian 
Zoo, Lithuanian Zoological 
Gardens,  Wroclaw  Zoo, 
Jardim  zoologico  e  de 
aclimaçao em Portugal. 

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tional  costs?  Could  you  provide 
quantitative  evidence/figures  or  at 
least the magnitude of costs, based 
on specific examples?  

Zoos  feder-
ation 
Zoo 

Question 12. 
zoos  experi-
Did 
ence  an increase of recurrent costs 
(e.g.  costs  for  training,  information 
exchange,  awareness  raising,  etc.) 
that  would  have  not  been  borne  in 
absence of the Zoos Directive? If so, 
which  are  the  most  relevant  addi-
tional  costs?  Could  you  provide 
quantitative  evidence/figures  or  at 
least the magnitude of costs, based 
on specific examples? 
Administrative burden (and enforcement costs) 
Question 13. 
[For  zoos,  zoos  fed-
erations]  To  what  extent  did  the 
Zoos  Directive  imply  additional  ad-
ministrative  costs  related  to  licenc-
ing  and 
inspection  procedures? 
Could  you  provide  information  on 
the  procedures  carried  out  by  zoos 
that  trigger  additional  costs  and  on 
the  magnitude  of  these  costs?    Are 
you  aware  of  missing  revenues  due 
to  delays  in  the  licensing  proce-
dure?  
 [For MSCAs] To what extent did the 
Directive  imply  additional  costs  for 
the  MSCA  (costs  related  to  the  li-
system, 
censing  and 

inspection 

Zoos  feder-
ation 
Zoo 
MSCA 

costs, directly due to the Zoos Directive, should be 
considered.  Business-as-usual  costs  (costs  from  ac-
tivities that would be incurred even in the absence 
of the legislation) should not be considered. 
During  the  interview,  it  is  important  to:  understand 
whether  new  costs  (which  would  have  not  been 
occurred  without 
the  Directive)  were  borne; 
among  the  new  costs,  understand  which  are  the 
most  significant;  collect  information  on  the  magni-
tude  of  the  costs  (in  monetary  terms  if  estimates 
exist  or,  for  example  number  of  investments  done, 
number of new people hired, etc.).  

See background information for question 11. 

Licensing  often  can  be  cumbersome  and  time-
consuming for zoos (especially small structures). In 
some  isolated  cases,  issues  in  terms  of  excessively 
long licencing procedures have been raised. 
In particular, please consider the following: 
Regarding zoos: 
a) The purpose of the questions addressed to zoos 
is  to  walk  through  the  steps  needed  to  ob-
tain/renew  the  licence  (e.g.  applying  for  the  li-
cence; prepare the documents requested by the 
authority  before  the  inspection;  presence  during 
the  inspection;  providing  additional  documents 
after the inspection, etc.) and, for each step, col-
lect  information  on:  time  or  “man  days”  needed 
to  carry  out 
frequency  per 
the  activity, 
year/across  years  (which  depends  on  the  fre-

Zoos  questionnaire  :  ques-
tions 80-97 
MSCAs  questionnaire 
questions 86-100 
NGOs& 
federa-
tions questionnaire : 48-56 

: 

Zoos  questionnaire  :  ques-
tions 80-97 
MSCAs  questionnaire 
questions 86-100 
NGOs& 
federa-
tions questionnaire : 48-56 

: 

Zoos 
federations:  EAZA, 
VdZ,  DAZA,  AIZA,  BIAZA, 
APZA,  UIZA. 
Zoos:  BE  Zoo,  Sofia  Zoo, 
Pafos  Zoo,  Zoobotanico 
Jerez,  FR  Zoo,  Fota,  Italian 
Zoo, Lithuanian Zoological 
Gardens,  Wroclaw  Zoo, 
Jardim  zoologico  e  de 
aclimaçao em Portugal. 

Zoo, 

Zoos 
federations :  EAZA, 
VdZ,  DAZA,  AIZA,  BIAZA, 
APZA,  UIZA. 
Zoos :  BE  Zoo,  Sofia  Zoo, 
Pafos  Zoo,  FR  Zoo,  Fota, 
Lithuanian 
Italian 
Zoological 
Gardens, 
Wroclaw  Zoo,  Jardim  zoo-
logico  e  de  aclimaçao 
em Portugal. 
MSCAs :  BE,  DE  (regional), 
DE (central), DK, ES, FR, IE, 
IT, NL, PT. 

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monitoring  of  the  compliance  with 
the  legislation,  closure  of  zoos  and 
relocation  of  animals,  etc.)?  Which 
are  the  most  relevant  additional 
costs?  Could  you  provide 
infor-
mation  on  the  procedures  that  trig-
ger  additional  costs?  Could  you 
please  detail  the  steps  of  the  pro-
cedures  (including  number  of  man 
days needed and frequency)?  

quency of controls). As for the questions above, it 
is  important  to  understand  if  similar  licencing  and 
inspections  activities  were  carried  out  also  before 
the entering into force of the Directive (based on 
national  legislation)  and,  if  so,  to  what  extent  the 
Directive  implied  increased  costs  and  why  (i.e. 
what changed). 
b)  Costs  due  to  delays  should  be  based  on  esti-
mates  provided  by  the  Zoo,  or  quantified  in 
months/days  during  which  the  zoo  was  closed 
because of the delays in obtaining the licence.  
For MSCAs: 
b) Costs related to licencing and inspection: like in 
point  a)  above,  the  objective  is  to  walk  through 
the  procedure  (from  the  point  of  view  of  the  au-
thority  performing  the  control),  and  collect  infor-
mation  on  the  steps  and  man  days  needed  in 
each step. At national level, aggregated estimate 
can  be  asked  about  the  costs  on  the  licencing 
and  inspection  system  (taken  into  account  that 
these estimate can include the cost for inspectors 
carrying  out  also  other  duties).  If  similar  licencing 
and  inspections  procedures  existed  before  the 
Directive, the extent to which costs are higher and 
why (i.e. what changed) should be discussed.  
c)  Other  costs  can  be  occurred  by  the  authority 
for  the  regular  monitoring  of  the  compliance  or, 
for example, for the exchange of information with-
in  the  administration.  The  objective  of  the  inter-
view should be to understand which are the activ-
ities  that  generate  significant  costs,  and  if  man 
days  dedicated  to  these  activities  on  an  annual 
basis  can  be  quantified  (as  above,  it  should  be 
taken into account that personnel is likely to carry 
out  also  other  activities,  not  strictly  related  to  the 
Zoo Directive, and costs cannot be isolated). 
d)  Regarding  the  other  costs  mentioned  (closure 
of zoos and costs due to escapes of invasive alien 
species), overall estimates  should be obtained by 
the  authority  (if  relevant  and  available),  along 

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Benefits 
Question 14.  What are the bene-
fits brought about by the Directive? 
Could  you  provide  quantitative 
least  the 
evidence/figures  or  at 
magnitudes for particular benefits?  

Zoos  feder-
ation 
Zoo 
MSCA 

with a description of the cases encountered. 

In  the  questionnaires,  statements  pointed  to  clear 
benefits  of  Directive  for  biodiversity  conservation. 
However, it’s difficult to quantify them. Examples of 
quantitative evidence were an increase in number 
of EAZA  members,  an  increase  of EAZAs European 
Endangered  Species  programmes  between  2000-
2015,  an  increase  in  number  of  zoos  taking  part  in 
the conservation database Species 360. 
There  was  ambiguous  evidence  regarding  the 
economic benefits. 

Zoos  questionnaire  :  ques-
tions 80-97 
MSCAs  questionnaire 
questions 86-100 
NGOs& 
federa-
tions questionnaire : 48-56 

: 

Question 15.  Could 
you  give 
examples  of  economic  benefits  for 
zoos or socio-economic benefits for 
citizens  (e.g.  increased  visitor  num-
ber  as  Zoos  Directive 
improved 
quality  of  zoos,  creation  of  jobs, 
better  recreation  opportunities  for 
citizens)? Could you provide quanti-
tative  evidence/figures  or  at  least 
the magnitudes for particular bene-
fits? 
Proportionality of costs 
Question 16.  Could  you  provide 
evidence 
relation 
between costs and benefits brought 
about  by  the  Directive?  Are  the 
costs  proportionate  or  dispropor-
tionate  compared  to  the  benefits 
and why? 

regarding 

the 

Zoos  feder-
ation 
Zoo 

See background information for question 14. 

Zoos  questionnaire  :  ques-
tions 80-97 
MSCAs  questionnaire 
questions 86-100 
NGOs& 
federa-
tions questionnaire : 48-56 

: 

Zoos  feder-
ation 
Zoo 
MSCA 

The  majority  of  responding  zoos  feel  that,  even  if 
they encountered additional costs caused by the 
Directive, they were proportionate to the benefits. 
Similarly, many MSCAs indicated that the Directive 
triggered 
increased  costs,  which  nevertheless 
were  not  regarded  as  disproportionate,  as  they 
use  existing  structures  in  veterinary  authorities  to 
licence/inspect  zoos.  However,  in  some  isolated 
cases, issues in terms of excessively long licencing 
procedures have been raised. 

Zoos  questionnaire  :  ques-
tion 91 - 93. 
MSCAs  questionnaire 
questions 92 - 94. 
NGOs& 
federa-
tions questionnaire : 51 -53. 

: 

Zoos 
federations :  EAZA, 
EAAM,  VdZ,  DAZA,  AIZA, 
BIAZA, APZA,  UIZA. 
Zoos :  BE  Zoo,  Sofia  Zoo, 
Pafos  Zoo,  Zoobotanico 
Italian  Zoo, 
Jerez,  Fota, 
Lithuanian 
Zoological 
Gardens,  Wroclaw  Zoo, 
Jardim  zoologico  e  de 
aclimaçao em Portugal. 
MSCAs :  BE,  DE  (regional), 
DE  (central),  DK,  FR,  IE,  IT, 
NL, PT. 
Zoos 
federations :  EAZA, 
EAAM,  VdZ,  DAZA,  AIZA, 
BIAZA, APZA,  UIZA. 
Zoos :  Pafos  Zoo,  Zoobo-
tanico  Jerez,  Fota,  Lithua-
nian  Zoological  Gardens, 
Wroclaw  Zoo,  Jardim  zoo-
logico  e  de  aclimaçao 
em Portugal. 

federations :  EAZA, 
Zoos 
EAAM,  VdZ,  DAZA,  AIZA, 
BIAZA, APZA,  UIZA. 
Zoos :  BE  Zoo,  Sofia  Zoo, 
Pafos  Zoo,  Zoobotanico 
Jerez,  FR  Zoo,  Fota,  Parco 
Faunistico,  Le  Cornelle, 
Lithuanian 
Zoological 
Gardens,  Wroclaw  Zoo, 
Jardim  zoologico  e  de 
aclimaçao em Portugal. 
MSCAs :  BE,  DE  (regional), 
DE  (central),  DK,  FR,  IE,  IT, 

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Zoos  feder-
ation 
Zoo 

- 

- 

Funding 
Question 17.  Are  availability  and 
access  to  funding  a  constraint  or 
support?  Does  the  Zoo  Directive 
facilitate  or  enhance  chances  for 
zoos in applying for funding for bio-
diversity  or  conservation  activities? 
Which  kind  of  funding  programmes 
at national, EU or international level 
are  mostly  frequently  used  by  zoos 
for conservation projects?  

Table 56: Relevance 

Question 

Target 

Background information 

Question 18. 
Is  the  Zoo  Directive  in 
line  with  the  evolution  of  the  EU  and 
global  objectives  and  targets  con-
cerning  conservation  of  biodiversity? 
Which  are  the  most  important  needs 
in  this  field  and  how  are  they  ad-
dressed by the Directive? 

Zoos  feder-
ation 
MSCA 
NGO 

There  was  broad  agreement  that  the  needs 
that  triggered  the  implementation  of  the  Zoos 
Directive  still  exist.  Nevertheless,  contradictory 
views were expressed about the adaptation of 
the  Directive  to  scientific  and  technical  pro-
gress.  

Question 19. 
How  well  adapted  is 
the  Zoos  Directive  to  technical  and 
scientific progress in the field of biodi-
versity  conservation,  and  relation  to 
in-situ and ex-situ conservation? 

Zoos  feder-
ation 
MSCA 
NGO 

See background information for question 18. 

targeted  online 

Link  with 
questionnaire 
Zoos questionnaire : question 
102-104. 
MSCAs  questionnaire  :  ques-
tions 109-111. 
NGOs  &  federations  ques-
tionnaire: questions 65-67. 

Zoos questionnaire : question 
102-104. 
MSCAs  questionnaire  :  ques-
tions 109-111. 
NGOs  &  federations  ques-
tionnaire: questions 65-67. 

NL, PT. 

Zoos 
federations :  EAZA, 
EAAM,  VdZ,  DAZA,  BIAZA, 
APZA,  UIZA. 
Zoos :  BE  Zoo,  Sofia  Zoo, 
Zoobotanico 
FR 
Italian  Zoo, 
Zoo,  Fota, 
Lithuanian 
Zoological 
Gardens,  Wroclaw  Zoo, 
Jardim  zoologico  e  de 
aclimaçao em Portugal. 

Jerez, 

Interview respondents 

BornFree, 

Zoos  federations :  EAZA, 
EAAM, 
BIAZA, 
AIZA, 
APZA,  UIZA. 
MSCAs : BE, IE, IT, NL. 
Eu-
NGOs: 
rogroup 
for  Animals, 
GAIA,  Animal  Rescue 
Centre 
(ARC)  Cyprus, 
Infozoos. 
Zoos  federations :  EAZA, 
EAAM,  VdZ,  AIZA,  BIAZA, 
APZA. 
MSCAs :  BE,  DE  (central), 
ES, IT, NL, PT. 
NGOs:  BornFree,  Euro-
group  for  Animals,  GAIA, 
Four  Paws  Bulgaria,  Ani-
mal 
Rescue  Centre 
(ARC)  Cyprus,  Infozoos, 
Code Animal. 

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Have 

Question 20. 
you  ob-
served any inconsistencies or over-
laps  between  the  requirements  of 
the  Zoos  Directive  and  those  of 
international  policies 
other  EU/ 
and 
legislation  on  biodiversity 
conservation and animal welfare?  
 
In  particular,  do  you  think 
there  are inconsistencies with 
the IAS Regulation? 

  Do  you  think  that  there  are 
in  addi-
resulting 
overlaps, 
tional  administrative  burden? 
In particular, do you consider 
there  are  overlaps  between 
the  Zoos  Directive  and  Di-
rective  92/65/EEC  on  animal 
health  requirements485  or  the 
national  transposing  legisla-
tion, in particular legally bind-
ing  standards  for  accommo-
dation,  e.g.  different  inspec-
tion procedures?  

Question 21. 
[For  MSCAs]  Have 
you  experienced  any  positive 
interfaces  and  synergies  between 
the  Zoos  Directive  and  other  EU/ 
international  policies  and  legisla-
tion  on  biodiversity  conservation 
and  animal  welfare?  Can  the 
implementation  of  the  Zoos  Di-
rective 
the  objectives 
pursued  by  these  policies  and 

support 

Table 57: Coherence 

Question 

Target 

Background information 

Link  with  targeted  online 
questionnaire 
Zoos  questionnaire  :  ques-
tions 100-101. 
MSCAs  questionnaire 
questions 101-106. 
NGOs  &  federations  ques-
tionnaire: questions 59-62. 

: 

Interview repondents 

Zoos 
federations :  EAZA, 
EAAM,  VdZ,  DAZA,  AIZA, 
BIAZA, APZA,  UIZA. 
MSCAs :  BE,  DE  (regional), 
DE  (central),  ES,  IE,  IT,  NL, 
PT. 

Zoos  feder-
ation 
MSCA 

Issues  in  relation  to  the  IAS  Regulation  have  been 
raised. On one hand, some stakeholders noted that 
zoos can no longer keep species (except captured 
ones)  that  are  listed  in  the  IAS  Regulation.  This  im-
pedes  the  creation  of  educational  programmes 
tailored  to  the  problem  of  Invasive  Alien  Species, 
while  also  impacting  the  biodiversity  of  zoo  collec-
tions.  On  the  other  hand,  zoos  may  play  a  role  in 
the management of listed species.  
Concerning  potential  overlaps  between  the  Zoos 
Directive  and  other  legislation,  replies  from  zoo  op-
erators pointed to problems, such as duplication of 
work,  they  have  experienced  when  applying  the 
Directive. 

Zoos  feder-
ation 
MSCA 

In  relation  to  synergies,  examples  may  include 
conservation programmes or programmes for rein-
troducing  species  covered  by  the  Habitats  Di-
rective undertaken by zoos or of zoos taking part in 
in  situ  conservation  measures  of  species  covered 
by  the  Habitats  or  Birds  Directive,  or  educational 
programmes  undertaken  by  zoos,  addressing 
Natura 2000. 
There was no question on the economic level play-
ing  field,  which  was  subgrouped  under  Efficiency-

Zoos  questionnaire  :  ques-
tions 100-101. 
MSCAs  questionnaire 
questions 101-106. 
NGOs  &  federations  ques-
tionnaire: questions 59-62. 

: 

Zoos 
federations :  EAZA, 
EAAM,  VdZ,  AIZA,  BIAZA, 
APZA,  UIZA. 
MSCAs :  BE,  DE  (central), 
DK, ES, FR, IE, IT, NL. 

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benefits. Opinions regarding the level playing field 
were mixed. 

Zoos  feder-
ation 
MSCA 

There was no question on the economic level play-
ing  field,  which  was  subgrouped  under  Efficiency-
benefits. Opinions regarding the level playing field 
were mixed. 

Zoos  questionnaire  :  ques-
tions 100-101. 
MSCAs  questionnaire 
questions 101-106. 
NGOs  &  federations  ques-
tionnaire: questions 59-62. 

: 

Zoos 
federations :  EAZA, 
EAAM,  AIZA,  BIAZA,  APZA,  
UIZA. 
MSCAs :  BE,  DE  (central), 
DK, IE. 

legislation,  and  reciprocally?  For 
example,  are  you  aware  of  any 
conservation  programmes  or  pro-
grammes for reintroducing species 
covered  by  the  Habitats  Directive 
undertaken  by  zoos  or  of  zoos 
taking  part  in  in  situ  conservation 
measures  of  species  covered  by 
the Habitats or Birds Directive? Are 
you  aware  of  educational  pro-
grammes  undertaken  by  zoos, 
addressing  Natura  2000?  Are  you 
aware  of  any  other  such  instanc-
es?   
[For Zoo federations, zoos] Are you 
aware of any positive or negative 
effects  of  the  Zoos  Directive  on 
the  EU  internal  market  and  the 
creation  of  an  economic  level 
playing field for zoos as economic 
operators?  Could  you  provide 
evidence for these effects? 
Question 22.  Are  you  aware  of 
any  significant  discrepancies  and 
differences  in  the  implementation 
of 
the  Zoos  Directive  among 
Member  States,  e.g.  concerning 
costs,  benefits,  level  of  penalties, 
which could be an obstacle to the 
creation  of  a  level  –playing  field 
for zoo operators across the EU? 

Table 58: EU Added Value 

Question 

Target 

Background information 

Question 23. 
 What  was  the  situa-
tion regarding the contribution of zoos 
to  biodiversity  conservation  in  your 
country/in  the  EU  at  the  moment  of 

Zoos  feder-
ation 
MSCA 
NGO 

The  wide  majority  of  responding  stakeholders 
sees  benefits  from  the  existence  of  the  Zoos 
Directive on the conservation of biodiversity. 

targeted  online 

Link  with 
questionnaire 
Zoos  questionnaire  :  ques-
tions 107-108 
MSCAs questionnaire : 
Questions 7-23 ; 112-122  

Interview respondents 

Zoos 
federations :  EAZA, 
EAAM, DAZA, BIAZA, APZA,  
UIZA. 
MSCAs : BE, IE, IT, NL, PT. 

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the  adoption  of  the  Zoos  Directive 
and to what extent is the current situa-
tion due to the Directive? 

 

Question 24.  Do  you  deem  a  Zoos 
Directive necessary to make sure that 
zoos contribute to the conservation of 
biodiversity?  Please  specify  the  rea-
sons  why  or  why  not.  What  would  be 
the  likely  situation  without  the  Zoos 
Directive being in place? 

Zoos  feder-
ation 
MSCA 
NGO 

The  majority  of  stakeholders  (MSCA,  NGOs, 
federations  and  zoos)  believes  that  EU  inter-
vention is (still) needed to make zoos adopt or 
implement Article 3 measures. 

NGOs  &  federations  ques-
tionnaire: questions 70-75 ; 56 

Zoos  questionnaire  :  ques-
tions 109-110. 
MSCAs  questionnaire  :  ques-
tions 116-117. 
NGOs  &  federations  ques-
tionnaire: questions 74-77, 56. 

Question 25.  Could  the  same  ob-
jectives  have  been  achieved  under 
national/international  conventions  or 
programmes? If not,  which aspects of 
the Directive would not be covered? 

Zoos  feder-
ation 
MSCA 
NGO 

Most  respondents  to  the  questionnaires  con-
sider that the objectives of the Directive could 
not  be  fully  achieved  under  existing  interna-
tional  conventions  or  programmes,  either 
because they are not sufficiently enforceable 
or  because  they  do  not  cover  the  whole 
scope of the Directive. 

Zoos  questionnaire  :  ques-
tions 111-112. 
MSCAs  questionnaire  :  ques-
tions 118-119. 
NGOs  &  federations  ques-
tionnaire: 78-79 

BornFree, 

NGOs: 
Euro-
BornFree, 
group  for  Animals,  GAIA, 
Four Paws Bulgaria, Animal 
Rescue  Centre  (ARC)  Cy-
prus,  Infozoos,    Animalisti 
Italiani. 
Zoos 
federations :  EAZA, 
EAAM,  VdZ,  DAZA,  AIZA, 
BIAZA, APZA,  UIZA. 
MSCAs :  BE,  DE  (regional), 
DE  (central),  DK,  FR,  IE,  IT, 
NL, PT. 
NGOs: 
Eu-
rogroup for Animals, GAIA, 
Four Paws Bulgaria, Animal 
Rescue  Centre  (ARC)  Cy-
prus,  Infozoos,  Code  Ani-
mal, Animalisti Italiani. 
Zoos 
federations :  EAZA, 
EAAM,  VdZ,  AIZA,  BIAZA, 
APZA,  UIZA. 
MSCAs :  BE,  DE  (regional), 
DE  (central),  DK,  ES,  IE,  IT, 
PT. 
NGOs: 
Eu-
rogroup for Animals, GAIA, 
Four Paws Bulgaria, Animal 
Rescue  Centre  (ARC)  Cy-
prus,  Infozoos,  Code  Ani-
mal, Animalisti Italiani. 

BornFree, 

Table 59: Overall assessment – concluding question 

Question 

Target 

Background information 

Question 26. 
 What  works  well and 
what  does  not  in  the  current  legisla-
tion on the keeping of wild animals in 
zoos?  Do  you  have  specific  recom-
mendations for improvements? 

Zoos  feder-
ation 
MSCA 
NGO 

Many  stakeholders  think  the  goal  of  the  Di-
rective  could  be  better  achieved  if  monitor-
ing and reporting mechanisms to the EU had 
been  in  place.  Other  stakeholders  support 
the  introduction  of  species  specific  require-

Link with targeted online ques-
tionnaire 
- 

Interview respondents 

Zoos 
federations :  EAZA, 
EAAM,  DAZA,  AIZA,  BIAZA, 
APZA,  UIZA. 
MSCAs :  BE,  CZ,  DE  (re-
gional),  DE  (central),  DK, 

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ments on the accommodation of animals. 

BornFree, 

ES, IE, IT, PT. 
Eu-
NGOs: 
rogroup for Animals, GAIA, 
Four Paws Bulgaria, Animal 
Rescue  Centre  (ARC)  Cy-
prus,  Infozoos,  Code  Ani-
mal, Animalisti Italiani. 

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In addition to this guidance document, the interviewers received: 

  The questionnaire of the online surveys completed by the interviewees; 
  All answers from the other stakeholders from the relevant Member State; 
  An excel matrix (“general transcript”) to report the information gathered during the interviews; 
  The list of questions to send to the interviewee ahead of the interview.  Four different lists were 

prepared, one for each stakeholder type486. 

Performing the interviews  
To help ensure effective and efficient interviews, interviewers were in charge of sending the list ques-
tions to the interviewee in advance so that they are aware of the topics to be discussed. 

We  have  validated  the  results  of  the  interviews  by  cross-checking  information,  such  as  asking  the 
same question to different stakeholders, and verifying statements by evidence as far as possible (legis-
lation, publications, etc.).  

Finally, we have ensured to the possible extent that our team can perform interviews in the national 
languages of the selected Member States if interviews in English were not possible. 

4  USE OF ANSWERS AND KEY POINTS 

Transcripts of interviews were requested for each interview. Once drafted, the transcripts were submit-
ted for approval and additional input to the interviewee. Transcripts were fed into a general transcript 
in an Excel document (in English) in order to allow the study team to compare and collect the relevant 
information for answering the evaluation questions. The transcript of interviews is  an internal docu-
ment used and produced exclusively by the study team and will not be published. Key points raised by 
interviewed MSCAs, zoo federations and NGOs are however summarized below in an aggregate man-
ner. This provides an overview of the most substantial points made by stakeholders during the inter-
views.  The  questions  asked  to  zoos  focused  on  the  costs  incurred  for  the  implementation  of  the  Di-
rective and are hence not reproduced among the key points listed below. Similarly, the supplementary 
interviews listed in Table 53 and covering specific topics are not included in the sections below. 

The answers provided by the interviews were integrated in the analysis of the evaluation criteria ac-
cording to the evaluation framework and the links highlighted in the tables above.  

4.1  MEMBER STATE COMPETENT AUTHORITIES 

The 13 interviewed MSCAs underlined the following key points. 

The implementation of the zoos directive is more focused on animal welfare than biodiversity con-
servation. The Zoo directive has strengthened the efforts made by zoos to improve and satisfy the bio-
logical and requirements of the individual species. MSCAs reported that only large zoos or specialized 
institutions  can  provide  contributions  to  wider  biodiversity  conservation,  these  are  not  the  focus  of 
smaller zoos which lack resources for such activities. Although MSCAs underlined that the wording of 
Article 3, first indent allows zoos to opt only for “exchange of information” as a means to comply with 
the EU requirements, none suggested that all those options should become compulsory. 

MSCAs  encouraged  greater  harmonisation  of  standards  to  strengthen  cross-border  collaboration 
(exchange of information and animals), including on the definition of zoos (as well as on “significant 

486 MSCAs, Federations and NGOs, Zoos, EU stakeholders. 

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number of animals or species” and criteria for exemption). 
It was reported by interviewed MSCAs that the Zoos Directive should put more emphasis on the im-
portance of skilled staff and veterinary care, both within zoos (for zoo operators and zoo keepers) 
and within the competent authorities. MSCAs often underlined that inspectors would appreciate hav-
ing more trainings on the application of the Zoos Directive, including on animal welfare requirements 
and the assessment of conservation measures. 

The  Good Practices  Document  should  be  translated and actively disseminated at EU and national 
levels in order to be useful to all MSCAs and zoo operators across the EU. 

It is important as a political message that the Zoos Directive is maintained. 

4.2  ZOOS FEDERATIONS 
Ten  zoos  federations487  were  interviewed  and  reported  the  following  points  as  positive  and  negative 
elements of the implementation of the Directive.  

On the positive points, the interviewed zoos federations overall recognized that the Zoos Directive has 
introduced a widely accepted legal framework which provides minimum requirements with which 
zoos must comply. This framework has forced zoos to think in terms of conservation programs and 
education is a big asset. Besides, the Zoos Directive clearly points out the importance of zoos in soci-
ety. 

Regarding existing issues, the interviewed zoos federations underlined that insufficient action by the 
European  Commission  led  to  poor  coordination  and  harmonization  between  Member  States.  They 
reported that MSCAs need to be supported in implementation (e.g. stakeholder platform), because of 
their insufficient capacity and expertise. It would be appreciated  if the Commission could even lead 
inspections in the Member States. In relation to this point, the zoos federations stressed that the lack of 
reporting  and  monitoring  requirements  hamper the proper implementation of the Directive.  Such  re-
ports would potentially provide the baseline and data that is currently critically lacking on the status of 
EU  zoos.  Within  an  implementation  framework  led  by  the  European  Commission,  the  creation  of  a 
platform of national stakeholders would be instrumental in improving the coordination and harmoniza-
tion of practices among MS. Still related to the action of the European Commission, numerous inter-
viewees stressed that the Good Practices Document should be translated and disseminated in order to 
be  useful  to  all  MSCAs  and  zoo  operators  across  the  EU.  Many  zoo  operators  are  not  aware  of  the 
existence of the Document. 

At national level, the zoos federations reported that the work and standards established by regional 
federations of zoos should be more systematically recognized and referred to by the national legisla-
tion. Generally, given their limited resources and expertise, national governments would benefit from 
closer cooperation with national zoo associations in all zoo and wildlife related matters. MSCAs gen-
erally lack adequate resources for managing the licensing and inspections procedures. Their training is 
insufficient  and  often  no  requirement  exists  regarding  the  content  of  inspections.  Those  aspects  are 
overlooked by the Directive’s requirements. 

Another point related to the content of the Directive concerns the definition of “zoo”. A reviewed or 
clarified definition of “zoo” would be welcome. 

Finally, further financial support would allow smaller institutions to lead or participate to conservation 
projects and public education. 

487 Inclduing EAZA and EAAM reported above under the category « EU and international stakeholder ». 

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4.3  NGOS 
The eight NGOs488 that were interviewed underlined the following positive and negative aspects.  

Three  main  positive  achievements  of  the  Directive  were  reported  during  the  interviews  with  NGO 
representatives. Firstly, the adoption of the Directive established the minimum requirements that all 
zoos across the EU should comply with to hold a licence. In that sense, the EU Zoos Directive created 
the legal framework which constitutes the key and often sole incentive for MS and zoo operators to 
incorporate conservation objectives in their operation. As a result, participation of zoos to research 
and conservation programmes has been improved. The quality of the information provided to the 
public has been generally improved. Zoos Directive led to an increased attractiveness of zoos for the 
public,  increased  education  and  awareness  about  biodiversity  conservation  and,  not  the  least,  to 
improved  animal  care  and  welfare  (through  the  increase  of  enclosure  size,  addition  of  furnishing 
and enrichments). Finally, the Directive creates additional leverage and pressure on national authori-
ties to properly implement a legislation on zoos.  

Regarding points that did not work well in the implementation of the Directive or which would require 
further improvements, the NGOs highlighted six important points:  

1.  The absence of reporting and monitoring requirements allows Member States to have al-
most no implementation measures in relation to the Directive and renders extremely difficult 
to assess the progress made. In that respect, the European Commission was very slow at react-
ing to existing infringements from the Member States (e.g. lack and poor transposition of the 
Directive). 

2.  The  loose  wording  of  the  Directive  is  generally  considered  as  too  weak  to  ensure  that  high 
standards are applied in zoos. The wording of the Directive was particularly criticized regard-
ing the definition of zoos (‘significant number of species’) and Article 3, first indent. It was 
repeatedly reported that the Directive should have higher standards in order to ensure that all 
zoos actively contribute to biodiversity conservation. Most NGOs consider that the options of 
Article 3, first indent, should be cumulative requirements. 

3.  The Directive contains no requirement on the  content of inspections or qualification of in-
spectors. Hence it gives too much margin of interpretation to inspectors. NGOs reported that 
most  inspectors  are  not  qualified  to  assess  the  appropriateness  of  animal  accommodations, 
even  less  qualified  to  assess  the  existence  of  conservation  programmes  whether  it  is  infor-
mation, research, training, or conservation programmes. According to this group of stakehold-
ers, inspectors are, at best, veterinarians with a multitude of other tasks related to animal wel-
fare  (e.g.  livestock,  pet  shops,  etc.).  Hence  many  welfare  issues  go  unnoticed.  Additionally, 
evaluating a conservation or education programme to see if it complies with the directive will 
be totally out of their comfort zone as they never received proper training (i.e. university lev-
el) on these issues. 

4.  According  to  some  NGOs,  the  Directive  should  contain  an  explicit  prohibition  of  animal 
performance, given that such performances are not in line with the objectives of conservation 
of wild animals. 

5.  The implementation  of the Directive should be supported  by  stricter sanctions. NGOs  sug-
gested  that  stronger  liability  should  be  systematically  required  in  case  of  closure  of  a  zoo. 
There also should be a mechanism sanctioning the MS in case of abandoned wild animals. 
6.  The Good Practices Document should be translated in order to be useful to all MSCAs and 
zoo operators across the EU. Many zoo operators are not aware of the existence of the Docu-
ment. 

488 Including Born Free and Eurogroup for Animals, reported above as « EU and international stakeholders ». 

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ANNEX VIIA – INTERVIEW QUESTIONS 

Question 

Target 

Link with targeted online 
questionnaire 

Effectiveness 
Question 27.  What progress have Member States 
made  over  time  towards  achieving  the  objectives 
set  out  in  the  Directive  and  the  related  transposed 
national  legislations  (to  protect  wild  fauna  and  to 
conserve  biodiversity/to  strengthen  the  role  of  zoos 
in the conservation of biodiversity)? Could you pro-
vide evidence?  
Question 28.  What  has  worked  well  and  what 
hasn’t  in  the  implementation  of  the  Directive  and 
why? Which factors contributed or stood in the way 
of achieving the Directive objectives? 

Question 29. 
Are  you  aware  of  specific  actions 
by  stakeholders  which  contributed  or  impeded  the 
requirements  of  the  Directive?  Any  good  or  bad 
practice examples? 
Question 30. 
How  have  the  conservation  related 
activities  (research  programmes,  public  awareness 
raising, accommodation) of zoos changed with the 
adoption of the Directive? 
Question 31. 
Beyond  the  objectives  of  biodiversi-
ty conservation and protection of wild fauna, have 
you  observed  other  significant  changes,  positive  or 
negative,  resulting  from  the  adoption  and  imple-
mentation of the Directive? 

Question 32. 
Has  the  formulation  of  the  Directive 
(e.g.  definition  of  ‘zoos’,  conservation  measures 
listed  in  Article  3,  either-or-option  of  Article  3  (1)) 
been  problematic  in  your  experience?  Does  na-
tional law formulate more specific or more stringent 
requirements?  If  so,  does  this  efficiently  address 
these shortcomings? 
Question 33.  Does  the  licensing  system  in  your 
country  work  properly?  Can  you  explain  why  –  or 
why not? In particular, do the authorities have suffi-
cient capacity, knowledge and resources? 
Question 34. 
How  did  the  implementation  and 
enforcement  of  the  Directive  by  Member  States 
competent authorities evolve in your Member State 
over the time? 
Question 35. 
How  are  closures  of  zoos  handled 
at  national  level  in  practice?  Do  you  have  specific 
examples  of  actions 
the  dispos-
al/relocation of animals?  
Question 36. 
Is  the  EU  Zoos  Directive  Good 
Practices Document used by competent authorities 
to enhance their understanding of the Directive?  
Efficiency 
Question 37. 
In  order  to  ensure  compliance 
with  the  Zoo  Directive,  did  zoos  incur  additional 
one-off  costs  (i.e.  excluding  costs  that  would  have 
occurred also in the absence of legislation), such as 
hiring of personnel, or investments for the renovation 

taken 

for 

Zoo federation 
MSCA 
NGO 

Zoos  questionnaire  :  ques-
tions 25-42; 107-113 
MSCAs  questionnaire  :  ques-
tions 112-126 

Zoo federation 
MSCA 
NGO 

Zoo federation 
MSCA 
NGO 

Zoo federation 
MSCA 
NGO 

Zoo federation 
MSCA 
NGO 

Zoo federation 
MSCA 
NGO 

Zoo federation 
MSCA 
NGO 

Zoo federation 
MSCA 
NGO 

Zoo federation 
MSCA 
NGO 

Zoos  questionnaire  :  ques-
tions 76, 116 
MSCAs  questionnaire  :  ques-
tions 35-71 ; 82-85 ; 123-126 
NGOs&Federation  question-
naire : questions 39-41 ; 83-84 
Zoos  questionnaire  :  ques-
tions 25-32 ; 36-42 ; 107-113 
MSCAs  questionnaire  :  ques-
tions 112-126 
Overall answers 

Zoos questionnaire : question 
73 
MSCAs  questionnaire  :  ques-
tion 79 
NGO&  federations  question-
naire : question 41. 
Zoos questionnaire : question 
116 
MSCAs  questionnaire  :  ques-
tions 7-24  
NGOs&Federation  question-
naire : questions 45-47 

MSCAs  questionnaire  :  ques-
tions 25-71. 
NGOs  &  federations  ques-
tionnaire : questions 31-45. 
MSCAs  questionnaire  :  ques-
tions 25-71. 
NGOs  &  federations  ques-
tionnaire : questions 31-45. 
MSCA  questionnaire:  ques-
tions 67-68 

MSCA 

- 

Zoo federation 
Zoo 

Zoos  questionnaire  :  ques-
tions 80-97 
MSCAs  questionnaire  :  ques-
tions 86-100 
NGOs& 

federations  ques-

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of  enclosures,  provisions  of  information,  etc.?  If  so, 
which are the most relevant additional costs? Could 
you  provide  quantitative  evidence/figures  or  at 
least  the  magnitude  of  costs,  based  on  specific 
examples?  
Question 38. 
Did  zoos  experience  an  increase 
of recurrent costs (e.g. costs for training, information 
exchange, awareness raising, etc.) that would have 
not been borne in absence of the Zoos Directive? If 
so,  which  are  the  most  relevant  additional  costs? 
Could you provide quantitative evidence/figures or 
at  least  the  magnitude  of  costs,  based  on  specific 
examples? 
Question 39. 
[For  zoos,  zoos  federations]  To  what 
extent  did  the  Zoos  Directive  imply  additional  ad-
ministrative  costs  related  to  licencing  and  inspec-
tion procedures? Could you provide information on 
the procedures carried out by zoos that trigger ad-
ditional costs and on the magnitude of these costs?  
Are you aware of missing revenues due to delays in 
the licensing procedure?  
Question 40. 
 [For  MSCAs]  To  what  extent  did 
the  Directive  imply  additional  costs  for  the  MSCA 
(costs  related  to  the  licensing  and  inspection  sys-
tem, monitoring of the compliance  with the legisla-
tion,  closure  of  zoos  and  relocation  of  animals, 
etc.)? Which are the most relevant additional costs? 
Could  you  provide  information  on  the  procedures 
that  trigger additional costs? Could you please de-
tail  the  steps  of  the  procedures  (including  number 
of man days needed and frequency)?  
Question 41. 
What  are  the  benefits  brought 
about  by  the  Directive?  Could  you  provide  quanti-
tative  evidence/figures  or  at  least  the  magnitudes 
for particular benefits?  

Question 42. 
Could  you  give  examples  of  eco-
nomic  benefits  for  zoos  or  socio-economic  benefits 
for  citizens  (e.g.  increased  visitor  number  as  Zoos 
Directive improved quality of zoos, creation of jobs, 
better  recreation  opportunities  for  citizens)?  Could 
you  provide  quantitative  evidence/figures  or  at 
least the magnitudes for particular benefits? 
Question 43. 
Could  you  provide  evidence  re-
garding  the  relation  between  costs  and  benefits 
brought  about  by  the  Directive?  Are  the  costs  pro-
portionate  or  disproportionate  compared  to  the 
benefits and why? 

Question 44. 
Are  availability  and  access  to 
funding  a  constraint  or  support?  Does  the  Zoo  Di-
rective  facilitate  or  enhance  chances  for  zoos  in 
applying for funding for biodiversity or conservation 
activities?  Which  kind  of  funding  programmes  at 
national,  EU  or  international  level  are  mostly  fre-
quently used by zoos for conservation projects?  
Relevance 
Question 45. 
Is the Zoo Directive in line with the 
evolution  of  the  EU  and  global  objectives  and  tar-
gets concerning conservation of biodiversity? Which 
are  the  most  important  needs  in  this  field  and  how 

tionnaire : 48-56 

Zoo federation 
Zoo 

Zoo federation 
Zoo 
MSCA 

Zoos  questionnaire  :  ques-
tions 80-97 
MSCAs  questionnaire  :  ques-
tions 86-100 
fede-
NGOs& 
rations questionnaire : 48-56 

Zoos  questionnaire  :  ques-
tions 80-97 
MSCAs  questionnaire  :  ques-
tions 86-100 
NGOs& 
tions questionnaire : 48-56 

federa-

Zoo federation 
Zoo 
MSCA 

Zoo federation 
Zoo 

Zoo federation 
Zoo 
MSCA 

Zoo federation 
Zoo 

Zoos  questionnaire  :  ques-
tions 80-97 
MSCAs  questionnaire  :  ques-
tions 86-100 
NGOs& 
fede-
rations questionnaire : 48-56 
Zoos  questionnaire  :  ques-
tions 80-97 
MSCAs  questionnaire  :  ques-
tions 86-100 
fede-
NGOs& 
rations questionnaire : 48-56 

Zoos questionnaire : question 
91 - 93. 
MSCAs  questionnaire  :  ques-
tions 92 - 94. 
NGOs& 
fede-
rations questionnaire : 51 -53. 
- 

Zoo federation 
MSCA 
NGO 

Zoos questionnaire : question 
102-104. 
MSCAs  questionnaire  :  ques-
tions 109-111. 

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are they addressed by the Directive? 

Question 46. 
How  well  adapted  is  the  Zoos  Di-
rective  to  technical  and  scientific  progress  in  the 
field  of biodiversity conservation,  and  relation  to in-
situ and ex-situ conservation? 

Zoo federation 
MSCA 
NGO 

NGOs  &  federations  ques-
tionnaire: questions 65-67. 
Zoos questionnaire : question 
102-104. 
MSCAs  questionnaire  :  ques-
tions 109-111. 
NGOs  &  federations  ques-
tionnaire: questions 65-67. 

Zoos  questionnaire  :  ques-
tions 100-101. 
MSCAs  questionnaire  :  ques-
tions 101-106. 
NGOs  &  federations  ques-
tionnaire: questions 59-62. 

Zoo federation 
MSCA 

- In particular, do you think there are incon-

Coherence 
Question 47. 
Have  you  observed  any  inconsist-
encies or overlaps between the requirements of the 
Zoos  Directive  and  those  of  other  EU/  international 
policies  and  legislation  on  biodiversity  conservation 
and animal welfare?  
 
sistencies with the IAS Regulation? 
Question 48. 
- Do you think that there are over-
laps, resulting in additional administrative burden? In 
particular,  do  you  consider  there  are  overlaps  be-
tween  the  Zoos  Directive  and  Directive  92/65/EEC 
on  animal  health  requirements489  or  the  national 
transposing  legislation,  in  particular  legally  binding 
standards  for  accommodation,  e.g.  different  in-
spection procedures?  
Question 49. 
[For  MSCAs]  Have  you  experienced 
any  positive  interfaces  and  synergies  between  the 
Zoos  Directive  and  other  EU/  international  policies 
and  legislation  on  biodiversity  conservation  and 
animal  welfare?  Can  the  implementation  of  the 
Zoos  Directive  support  the  objectives  pursued  by 
these  policies  and  legislation,  and  reciprocally?  For 
example,  are  you  aware  of  any  conservation  pro-
grammes  or  programmes  for  reintroducing  species 
covered  by  the  Habitats  Directive  undertaken  by 
zoos  or  of  zoos  taking  part  in  in  situ  conservation 
measures  of  species  covered  by  the  Habitats  or 
Birds  Directive?  Are  you  aware  of  educational  pro-
grammes  undertaken  by  zoos,  addressing  Natura 
2000? Are you aware of any other such instances?   
Question 50. 
[For Zoo federations, zoos] Are you 
aware  of  any  positive  or  negative  effects  of  the 
Zoos  Directive  on  the  EU  internal  market  and  the 
creation of an economic level playing field for zoos 
as  economic  operators?  Could  you  provide  evi-
dence for these effects? 
Question 51. 
Are  you  aware  of  any  significant 
discrepancies  and  differences  in  the  implementa-
tion  of  the  Zoos  Directive  among  Member  States, 
e.g.  concerning  costs,  benefits,  level  of  penalties, 
which  could  be  an  obstacle  to  the  creation  of  a 
level –playing field for zoo operators across the EU? 
EU Added Value 
Question 52. 
 What  was  the  situation  regarding 
the contribution of zoos to biodiversity conservation 
in  your  country/in  the  EU  at  the  moment  of  the 
adoption of the Zoos Directive and to what extent is 
the current situation due to the Directive? 
Question 53. 

Zoo federation 
MSCA 

Zoos  questionnaire  :  ques-
tions 100-101. 
MSCAs  questionnaire  :  ques-
tions 101-106. 
NGOs  &  federations  ques-
tionnaire: questions 59-62. 

Zoo federation 
MSCA 

Zoo federation 
MSCA 
NGO 

Zoos  questionnaire  :  ques-
tions 100-101. 
MSCAs  questionnaire  :  ques-
tions 101-106. 
NGOs  &  federations  ques-
tionnaire: questions 59-62. 

Zoos  questionnaire  :  ques-
tions 107-108 
MSCAs questionnaire : 
Questions 7-23 ; 112-122  
NGOs  &  federations  ques-
tionnaire:  questions  70-75 ; 
56 

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Question 54. 
Do  you  deem  a  Zoos  Directive 
necessary  to  make  sure  that  zoos  contribute  to  the 
conservation of biodiversity? Please specify the rea-
sons why or why not. What would be the likely situa-
tion without the Zoos Directive being in place? 

Zoo federation 
MSCA 
NGO 

Question 55. 
Could  the  same  objectives  have 
been  achieved  under  national/international  con-
ventions  or  programmes?  If  not,  which  aspects  of 
the Directive would not be covered? 

Zoo federation 
MSCA 
NGO 

Zoos  questionnaire  :  ques-
tions 109-110. 
MSCAs  questionnaire  :  ques-
tions 116-117. 
NGOs  &  federations  ques-
tionnaire:  questions  74-77, 
56. 
Zoos  questionnaire  :  ques-
tions 111-112. 
MSCAs  questionnaire  :  ques-
tions 118-119. 
NGOs  &  federations  ques-
tionnaire: 78-79 

Overall assessment/Final remarks 
Question 56. 
 What  works  well  and  what  does 
not in the current legislation on  the  keeping of  wild 
animals  in  zoos?  Do  you  have  specific  recommen-
dations for improvements? 

Zoo federation 
MSCA 
NGO 

_ 

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ANNEX VIII – PUBLIC CONSULTATION REPORT 

1 

INTRODUCTION 

The public consultation had the objective to get the views and perceptions of a wide set of stakehold-
ers on the contribution of the Directive to strengthen the role of zoos and enhance biodiversity conser-
vation.  The  public  consultation  intended  to  enlarge  the  scope  of  the  consultation  beyond  the  stake-
holders consulted in the 14 selected Member States, and give stakeholders from other countries and 
citizens the opportunity to express their opinion.  

Our support for the public consultation was threefold: firstly, the development of the questionnaire in 
cooperation with the European Commission, secondly, assistance in setting up and disseminating the 
public  consultation,  and  finally,  the  drafting  of  this  report  (public  consultation  report)  providing  an 
overview of the number of responses, a brief analysis of the answers as well as the problems encoun-
tered. 

The questionnaire followed closely the logic of the REFIT exercise to obtain feedback on the elements 
investigated in the evaluation, i.e. in line with the five evaluation criteria. The questions were aimed at 
collecting opinions and input on the different evaluation questions, in order to easily evaluate the out-
come of the public consultation per evaluation question and strengthen the evidence base. 

The  public  consultation  was  primarily  conceived  as  a  complementary  tool,  to  supplement  the  infor-
mation  gathered  through  the  other  tools  (in  particular  the  targeted  questionnaires  and  interviews). 
Questions were drafted in a way that ensures the manageability and usefulness of the answers, and to 
relate to the awareness of citizens and their perceptions on the implementation of the Directive’s re-
quirements.  

The questions were drafted in close cooperation with the European Commission, both within DG ENV 
and with the Secretariat General, following a Steering Group meeting held in July 2016. 

The public consultation focused on ten key questions. The questions were closed questions in order to 
ensure the comparability of data and to facilitate its analysis (possibility to provide limited input, i.e. 
limited number of words, to complement closed questions, for instance, for multiple choice questions 
‘other; please specify’). Questions 1 – 19 are introductory questions aimed at obtaining an understand-
ing of the respondents’ profiles. Questions 20  – 29 constitute the core questions of the consultation. 
Questions 20, 21, 22, 24, 25, 27 and 28 are closed questions. Within these closed questions, questions 
20, 21, 22, 24, 25 and 28 contain numerous sub-items (up to 13 sub-items). Questions 19, 23, 26 and 
29 allowed respondents to specify the mention of “Other” items in questions 18, 22, 25 and 28. The 
full questionnaire is presented in Annex III to this report. 

This report outlines the methodology used for analysing the results as well as the challenges encoun-
tered (Section 2); provides an overview of the profile of respondents (Section 2.3.2.1); and contains an 
analysis of the results of the core questions on each of the five evaluation criteria: effectiveness (Sec-
tion 4), efficiency (Section 5), relevance (Section 6), coherence (Section 7) and EU added value (Sec-
tion 8). 

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2  METHODOLOGY 

2.1 

THE SURVEY TOOL 

The public consultation was carried out using the EU Survey. This is the Commission’s online survey 
management tool, which is used to conduct multilingual online public consultations. The questionnaire 
was provided in all EU languages. The individual results of the consultation were downloaded in Ex-
cel format.  

Some (minor) problems were encountered during the process, e.g. draft answers saved 
by  the  respondents,  but  not  submitted,  identification  of  the  right  language  by  the 
respondents, links broken for a limited period of time. These were eventually resolved so 
that the full data set could be analysed. 

2.2 

THE ANALYSIS 

All core questions (questions 20 - 29) were analysed from four different angles, first considering the 
general trends based on all received answers, then using three break-downs: 

  Per  type  of  stakeholder  i.e.  individual,  zoo  operator,  business  or  business  representative,  non-
governmental organisation (‘NGO’), organisation or association other than NGO, government or 
public  authority,  European  institution  or  agency,  academic/research  institute,  other.  This  break-
down was based on the answers provided by the respondent to question 3 of the public consulta-
tion (i.e. “I am replying to this questionnaire as...”). 

  Per country in which the respondent is based, i.e. all 28 EU Member States or non-EU country. 
This break-down depends on the answer provided by the respondent to question 8 of the public 
consultation (i.e. “In which Member State are you based?). This analysis allows us to identify dif-
ferences  or  similarities  across  Member  States,  and  between  respondents  based  in  the  EU  or  in 
non-EU countries; 

  Depending on whether the respondent stated that she/he visits zoos or not. This break-down 
relied  on  the  answer  provided  by  the  respondent  to  question  18  of  the  public  consultation  (i.e. 
“What are your main reasons for visiting a zoo?”). Question 18 provided respondents with multi-
ple-choices composed of the six following options: 1. I don't visit zoos; 2. Professional reasons; 
3. Recreation (e.g. seeing exotic/wild animals, animal shows); 4. Learning about nature, animals 
and their habitats, and biodiversity conservation; 5. Teaching about nature, animals and their hab-
itats,  and  biodiversity  conservation;  6.  Other.  The  results  brought  39  different  combinations  of 
reasons. The break-down was simplified to distinguish the assessments made by two groups: re-
spondents that flagged the option “I don’t visit zoos” and respondents that indicated any reasons 
for visiting zoos.  

The report mostly presents results in absolute numbers of respondents in order to provide a picture as 
objective as possible, which reflects the size of stakeholder groups. Generally, data are visualized by 
using a 100% stacked bar representation in order to facilitate the comparison across the different cate-
gories of respondents. On this basis, percentages used in the body of the text were rounded up or down 
to the nearest whole number for ease of comparison. This explains why the sums may deviate slightly 
from 100%. 

2.3 

LIMITATIONS TO THE METHOD AND USE OF RESULTS 

Some limitations can be observed, both in the method used to gather information in itself, and in rela-
tion to the analysis of the results. Such limitations affect mainly the representativeness and reliability 
of the findings presented in this report.   

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2.3.1  Challenges linked to the exercise of the public consultation 

As  in  all  public  consultations  that  are  conducted  by  internet,  some  population  groups  have  a  higher 
degree  of  access  to  the  consultation  than  others  (e.g.,  elderly  people  with  no  IT  access,  people  not 
connected to the network). Also, the consultation did not pre-select those who could reply, unlike, for 
instance, the opinion polls conducted for the Eurobarometer. Instead, the consultation was made wide-
ly available to anyone with an interest in the subject and is therefore not statistically representative of 
the EU population as a whole or of individual Member States. 

2.3.2  Challenges relating to the analysis of results 

2.3.2.1 

Influence on answers by interest groups  

Several  interest  groups  (mainly  animal  welfare  or  zoos  organisations)  have  provided  their  members 
and/or the wider public with guidance on how to answer the consultation.  

Two NGOs involved in animal welfare (Born Free490 and Eurogroup for Animals491) disseminated on 
the  web  suggested  replies  to  the  public  consultation.  The  guidance  was  also  disseminated  through 
other EU/International associations (such as ADI- Animal Defender International492), and other asso-
ciations at national level (such as Animal Public493, active in Germany).494  

A very limited number of respondents however followed all indications for the closed questions: 

 

 

36 respondents followed the indications of Born Free (1.5% of the total number of respondents); 
4 respondents followed the indications of Eurogroup for Animals (0.17% of  the total number of 
respondents). 

The situation is different regarding the  semi-open fields, that offered to respondents to give “other” 
information  in  questions  23,  26  and  29.  In  these  instances,  a  larger  number  of  responses  appears  to 
follow  the  guidance  provided  by  the  campaign  promoted  by  Born  Free495.  Moreover,  responses  to 
semi-open fields reveal that further campaigns have been launched by other interest groups, including 
zoos associations both at EU and Member State level.  

In total, under question 23, 277 out of the 488 respondents to that question (56%) provided answers 
that  appear  to  follow  pre-made  answers  by  some  stakeholders.  Under  question  26,  363  out  of  443 
stakeholders (81%) provided pre-made answers. Under question 29, 335 out of 400 (84%) respondents 
gave answers issued from external guidance. In summary, out of the total respondents, only a limited 
number of stakeholders provided input in semi-open fields but, in these cases, most of them appear to 
be  influenced  by  different  interest  groups.  Moreover,  it  should  be  noticed  that  campaigns  appear  to 
have guided the open replies provided by different groups of stakeholders: individuals, NGOs, other 
associations as well as zoos operators.  

It  is  not  possible  to  assess  the  impact  of  these  campaigns  on  the overall  results  in  a  precise  manner 
because some respondents may have been influenced by the guidance provided by one group without 
following the full set of prescribed responses, or because the guidance did not necessarily provide a 

490http://www.bornfree.org.uk/fileadmin/user_upload/files/zoo_check/EU_Zoo_Inquiry/Public_consultation_on_Zoo_Directive_REFIT.pdf. 
491 http://www.eurogroupforanimals.org/wp-content/uploads/2016/10/Suggested-Replies.pdf. 
492 http://www.ad-international.org/animals_in_entertainment/go.php?id=4264&ssi=12). Suggested replies are the same as those provided by 
Eurogroup for Animals. 
493 Suggested replies are the same provided by BornFree (http://www.animal-public.de/europas-zootiere-brauchen-ihre-hilfe/). 
494 It is likely that additional examples could be found on other websites not identified by the project team. 
495 In the guidance published online, Eurogroup for Animals did not provide suggestions for the semi-open fields. The number of responses 
that can be attributed to the Born Free campaign varies from question to question (161 replies in Q23; around 100 replies in Q26, 146 replies 
in Q29). Details are presented in the detailed analysis of each question.  

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full set of responses. Some respondents may also have answered to closed questions in the same way 
as such guidance by coincidence.  

However, on the basis of the data provided above, the influence of campaigns appears to be very lim-
ited. The proportion of answers following a complete pre-determined set of closed answers being neg-
ligible, this variable was not taken into account in the analysis. 

Regarding  semi-open  questions,  the  report  identifies  identical  reply  patterns  (corresponding  to  the 
recommendations provided by interest groups), and takes them into account in the analysis of the rele-
vant sections of this report (section 6.1.1 for question 23; section 5.1.1 for question 26; section 7.1.1 
for question 29). 

It should be mentioned that several organisations/websites have also disseminated the information on 
the public consultation without any recommended replies496. This factor suggests that a large visibility 
and dissemination of the public consultation has actually been achieved.  

2.3.2.2  Break-downs 

The results were analysed with the aim to ascertain the general trends and, in parallel, to explore the 
possible  relations  between  the  respondents’  profiles  and  response  patterns  (i.e.  determining,  to  the 
extent possible, the reasons why certain respondents reply in a certain way).  

To  this  end,  data  has  been  disaggregated,  firstly,  by  categories  of  stakeholders.  This  break-down 
allows  us  to  understand  the  positioning  of  different  stakeholder  groups  and  possible  patterns,  com-
monalities and differences. In addition, as explained in Section 2.2, the data has been disaggregated by 
country of the respondents and by zoos visitors/non visitors.  

Regarding the break-down by country, it should be mentioned that: 

  There are large discrepancies in the number of respondents from one country to another (ranging 
from 796  respondents in Germany to one in Luxembourg, Estonia and Croatia (see Section  3.2 
below). For this reason, the possibility to compare results across countries is very limited, the rep-
resentativeness of the replies originating from some countries (with one or few respondents) be-
ing obviously limited.  

  The  results  by  country  appear  to  be  influenced  by  the  type  of  stakeholders  prevailing  in  each 
country.  Especially  in  Germany  and  the  UK  (the  two  countries  with  the  highest  number  of  re-
spondents),  some  stakeholder  categories  are  over-represented  (partially  because  of  campaigns), 
and this pattern has influenced the results. Animal welfare NGOs have been particularly active in 
the UK, and in many instances in the analysis, a strong correlation exists between NGOs replies 
and British ones. Similarly, professional associations seem to be particularly represented in Ger-
man  replies.  Such  correlations,  where  they  could  be  identified,  were  mentioned  in  the  analysis. 
They nevertheless significantly reduce the pertinence of the analysis on a country basis. 

Regarding the break-down depending on whether the respondents visit or do not visit zoos, similar 
observations can be made: 
  The  difference  in  the size  of  the two groups  analysed (600  respondents not visiting 
zoos  vs.  1697  respondents  visiting  zoos)  implies  a  limited  possibility  for  comparing 
the two groups. 

  Also here, a strong correlation can be observed between the defence of animal wel-
fare and the absence of visits to zoos. Respondents under that category have there-
fore usually a similar pattern of answers by NGOs, thus limiting the interest of such 

496 Examples include: Daily Express Online; Interel; Marine Connection; The Zoo Scientist; VdZ; Landau Zoo.  

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analysis.   

In Sections 4 to 9, the break-downs by country and by zoos visitors/non-visitors are reported for com-
pleteness of information. However, it is important to bear these explanations in mind, as the conclu-
sions presented need in many cases to be nuanced due to this specific context.  

Finally, the consultation document included questions on  main field of activity (question 11), main 
field  of  interest  (question  13),  and  main  reasons  for  visiting  a  zoo  (question  18).  These  questions 
allowed us to collect further information on the profile of the respondents. However, since, these ques-
tions were designed as multiple-choice questions, it was not possible to disaggregated results accord-
ingly,  given  the  important  interlinkages  between  the  offered  options  and  a  high  number  of  possible 
combinations (184 for question 11; 173 for question 13 and 39 for question 18). These questions were 
hence mainly used to map stakeholders rather than to carry out subsequent break-down analysis. An 
analysis based on a break-down by, for instance, main field of activity, would have required a group-
ing of combinations in order to be manageable. Such grouping would necessarily have been arbitrary, 
and thus would have weakened the reliability of the results and the robustness of the conclusions. Be-
sides, there is no guarantee that such analysis would have brought useful keys to understand the results 
of the consultation.  

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3  PROFILE OF RESPONDENTS 

The public consultation received 2297 answers.  

3.1 

TYPE OF STAKEHOLDERS 

The main categories of respondents are individuals (zoo visitors) with 1944 answers, and zoos opera-
tors with 148 answers.  

Figure 44: Types of respondents to the public consultation (in shares of total number of respondents, n=2297) 

1,65% 

0,91%  0,78% 

0,70% 

0,30% 

4,57% 

6,44% 

84,63% 

Individual (e.g. zoo visitor)

Zoo operator

Other

Non-governmental organisation

Business or business representative

Academic/research institute

Organisation or association (other
than NGO)

Government or public authority

105 respondents chose the category ‘other’ types of respondents. Among these, 46 can be grouped as 
zoos and aquarium workers, 14 as persons working with animals but not as zoos employees (e.g. vet-
erinarian, animal trainer, wildlife rehabilitator, zoo consultants), 6 as academics/scientists (biologists, 
ethologists). A large number of individuals did not recognise themselves in the category ‘individuals 
(e.g.  zoo  visitors)’  because  they  are  opposed  to  animal  captivity  or  more  generally  concerned  about 
animal welfare. 14 individuals mentioned clearly that they refuse to visit zoos and 12 can be consid-
ered as animal welfare activists or supporters. The remaining 12 comprise a large variety of individu-
als  including  photojournalists,  other  media  workers,  teachers  etc.  were  included  in  this  category  re-
spondents who considered themselves as ‘citizens’ or ‘members of the public’, probably in opposition 
to ‘zoo visitors’ but without mentioning it specifically.  

Among the 353 organisations (all types of respondents except individuals), the majority indicated that 
they operate at international level.  

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Figure 45: Answers to the public consultation, level at which organisation operate (in absolute numbers) 

International

Local

National

Regional

EU

41 

32 

40

0

20

3.2  COUNTRY 

67 

65 

148 

60

80

100

120

140

160

The largest groups of respondents are from Germany, the United Kingdom, Non-EU countries, Spain 
and the Netherlands. German and British respondents represent 60% of the respondents.  

Other countries show a very low number of replies, from one to three respondents (Luxembourg, Es-
tonia, Croatia, Malta, Lithuania, Slovenia, Bulgaria, Slovak Republic). In these cases, the disaggregat-
ed results should be considered with caution.  

Table 60: Number of respondents to the public consultation, per Member States (in absolute numbers) 

Member State 
Germany 
United Kingdom 
Non-EU country 
Spain 
Netherlands 
France 
Italy 
Belgium 
Denmark 
Portugal 
Sweden 
Austria 
Ireland 
Romania 

Nb of respondents  
796 
612 
214 
157 
118 
68 
51 
43 
39 
38 
31 
25 
16 
16 

Member State 
Czech Republic 
Greece 
Poland 
Finland 
Hungary 
Malta 
Lithuania 
Slovenia 
Bulgaria 
Slovak Republic 
Luxembourg 
Estonia 
Croatia 
- 

Nb of respondents 
15 
14 
13 
8 
6 
3 
3 
3 
3 
2 
1 
1 
1 
- 

Answers from non-EU countries mainly come from the United States (99 answers), Australia (19 an-
swers), Canada (14 answers) and Switzerland (11 answers)497. As the question asked in which country 
the  respondents  were  based,  some  of  these  respondents  can  be  European  citizens  living  outside  Eu-
rope.  

3.3  FIELD OF ACTIVITY 

Most respondents described their field of activities as being ‘animal welfare’ (769 respondents), edu-
cation  (620  respondents)  and  environment,  nature  (600  respondents)  or  none  of  the  categories  pro-
posed (651 respondents). This was a multiple-choice question and therefore total numbers of respond-
ents in each category do not add up to the total number of respondents.  

497 Respondents are also based in South Africa (5), the Channel Islands (5), New Zealand (3), Norway (3), Argentina (2), the United Arab 
Emirates (2), China (2), Singapore (1), Malaysia (1), Chile (1), Vietnam (1), Israel (1), Colombia (1), India (1), Saudi Arabia (1), Mexico (1).  

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Figure 46: Main field of activity of respondents to the public consultation (in absolute numbers) 

769 

651 

620 

600 

354 

308 

298 

271 

224 

195 

0

100

200

300

400

500

600

700

800

900

Animal welfare

No activities in any of the fields

Education

Environment, nature

Zoo management

Biodiversity (ex-situ)

Biodiversity (in-situ)

Recreation

Tourism

Other

3.4  FIELD OF INTEREST 

Most respondents described their field of interest as being ‘animal welfare’ (1566 respondents), ‘Envi-
ronment  and  nature’  (1438  respondents)  and  biodiversity  –  in  situ  conservation  (895  respondents). 
This was a multiple-choice question and therefore total numbers of respondents in each category do 
not add up to the total number of respondents.  

Figure 47: Main field of interest of respondents to the public consultation (in absolute numbers) 

Animal welfare
Environment, nature
Biodiversity (in-situ)
Education
Biodiversity (ex-situ)
Zoo management
Recreation
Tourism
None of those
Other

286 

241 

81 

51 

895 

761 

600 

484 

1566 

1438 

0

200

400

600

800

1000

1200

1400

1600

1800

3.5  MEMBERSHIP 

The majority of respondents is not a member of any organisation relevant to the topic of the consulta-
tion. However, a large number of respondents declared being members of an animal welfare organisa-
tion (809 respondents) and a nature conservation organisation (696 respondents). 521 are members of 
a zoo association. This was a multiple-choice question and therefore total numbers of respondents in 
each category do not add up to the total number of respondents. 

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Figure 48: Respondents’ memberships in organisations relevant to the topic of the public consultation (in absolute 
numbers) 

I’m not member of any organisation relevant to the topic 

Animal welfare

Nature conservation

Zoos association

Other

126 

903 

809 

696 

521 

0

100 200 300 400 500 600 700 800 900 1000

3.6  FAMILIARITY WITH THE DIRECTIVE 

The  majority  of  respondents  is  slightly  familiar  with  the  Zoos  Directive  or  aware  of  the  Directive 
without specific knowledge on its provisions (1612).  

Figure 49: Familiarity with the Zoos Directive of respondents to the public consultation (in absolute numbers) 

Slightly familiar

I’ve heard about the Zoos Directive, but I’m not familiar 
with its provisions 

911 

701 

I don't know the Zoos Directive

Very familiar

367 

318 

0

100 200 300 400 500 600 700 800 900 1000

This  overall  limited  level  of  familiarity  is  due  to  the  high  share  of  individuals  with  no  or  limited 
knowledge of the Directive among the respondents. This is due to the nature and audience of the pub-
lic  consultation.  The  table  below  illustrates  how  this  level  of  familiarity  varies  among  the  different 
groups of stakeholders.  

Figure 50: Answers to question 17 of the public consultation “How familiar are you with the Directive?” (in absolute 
number of respondents, per type of stakeholder) 

Zoo operator
Other (please specify below)
Organisation or association (other than NGO)
Non-governmental organisation
Individual (e.g. zoo visitor)
Government or public authority
Business or business representative

3 

15 

8 
3 
4 

46 

12 

21 

7 

347 

2 

2 

6 

638 

46 

14 

2 

5 

84 

14 

30 

5 

13 

784 

175 

3 

8 

0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%

I don't know the Zoos Directive

I’ve heard about the Zoos Directive, but I’m not familiar with its provisions 

Slightly familiar

Very familiar

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3.7  REASONS FOR VISITING A ZOO 

As one of the reasons for visiting zoos, 701 respondents indicated that they visit zoos for recreation 
and  681  respondents  indicated  learning  or  teaching  about  nature,  animals  and  biodiversity.  600  re-
spondents have indicated however that they do not visit zoos. This was a multiple-choice question and 
therefore total numbers of respondents in each category do not add up to the total number of respond-
ents (i.e. 2297). 

Figure 51: Respondents’ reasons for visiting a zoo per type of stakeholder 

I don't visit zoos

Professional reasons

Recreation

Learning/teaching about nature, animals and their
habitats, biodiversity conservation

600 

523 

701 

681 

0

100

200

300

400

500

600

700

800

When grouped per type of stakeholder, the results, as presented in the figure below, show that most 
respondents who do no visit zoos are individuals (559 out of 1944 individual respondents and 559 out 
of 600 respondents who do not visit zoos). 

Figure  52:  Answers  to  question  18  of  the  public  consultation  “What  are  your  main  reasons  for  visiting  a  zoo?”  in 
absolute number of respondents 

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

100%

Business

2 

Zoo operator

0 

14 

122 

Individual

559 

291 

Public authority

0 

5 

NGO

Other organisation

6 

6 

Other

27 

20 

20 

51 

4 

40 

594 

1 

10 

58 

590 

3 

7 

8 

27 

11 

7 

22 

I don't visit zoos

Professional reasons

Learning/teaching about nature, animals and their habitats, biodiversity conservation

Recreation

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4  EFFECTIVENESS  

Effectiveness corresponds to the assessment of the extent to which a certain legal provision, act or set 
of acts has achieved the objectives that it was intended to achieve. This question constitutes an essen-
tial element of the evaluation, and several of the questions asked in the public consultation relate to 
this criterion. More particularly, question 20 and question 21 are relevant in the context of assessing 
the  progress  of  the  Directive  towards  its  objectives.  Other  questions,  especially  questions  22  to  26, 
incidentally deal with the impact of EU rules on biodiversity conservation and the protection of wild 
fauna, but the answers to these questions are analysed under other Sections of this report.   

4.1 

TO  WHAT  EXTENT  DO  YOU  AGREE  OR  DISAGREE  WITH  THE  FOLLOWING  STATE-
MENTS REGARDING ZOOS IN YOUR COUNTRY (QUESTION 20)? 

Question 20 intends to measure the impact of the Directive by asking the respondents about their per-
sonal  experience  on  the  actual  implementation  of  the  Directive’s  requirements.  This  covers  several 
elements: 

Information on species and their habitats is usually well presented; 

a. 
b.  After a zoo visit, I know more about conservation of wild animals, protected species, threat-

ened species; 

c.  After a zoo visit, I know more about biodiversity and conservation of nature in general; 
d.  I  have  noticed  improvements  of  education  activities  (e.g.  school  visits,  educational  shows) 

provided by zoos over the last 15 years; 
I have noticed improvements in research activities carried out by zoos over the last 15 years; 

e. 
f.  Animals live in conditions that satisfy their needs; 
g.  I have noticed improvements in the size and design of spaces where animals are kept over the 

last 15 years; 

In the zoos I’ve visited, I received information on the species and/or its conservation status; 

h.  Animal shows are adapted to animals’ natural behaviours; 
i. 
j.  Zoos visits encourage visitors to become more engaged in the protection of species; 
k.  Zoos visits encourage visitors to become more engaged in the protection of biodiversity and 

nature in general; 

l.  Zoos are adequately designed to prevent the escape of animals. 

These various statements can be grouped under different types:  

  The implementation of Article 3 measures aimed at impacting the public: 

  Level of awareness - Questions 20 (b) and (c)); 
  Education activities- Questions 20 (a), (d), (h) to (k) 

  The implementation of other Article 3 measures which can be observed by the public: 

  Accommodation and care – Questions 20(f), (g), (h) 
 

Prevention of escape- Question 20(l). 

In  addition,  some  of  the  questions  seek  specifically  to  obtain  information  on  the  perception  of  re-
spondents on the progress made towards the achievement of the Directive’s objectives during the im-
plementation  period  (‘I have noticed improvements […] over the last 15 years’-Questions 20(d), (e) 
and (g)).  

4.1.1  General trends 

As  indicated  above,  the  public  consultation  document  provides  12  statements  relating  to  the  imple-

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mentation of the Zoos Directive. Stakeholders were asked to provide indications on their level of ad-
hesion to these statements (totally disagree, somewhat disagree, somewhat agree, totally agree, don’t 
know).  

As  shown  in  Figure  53,  the  majority  of  respondents  agree  with  most  statements,  showing  overall  a 
positive perception of the achievement of the Directives’ objectives, with some reservations, especial-
ly in relation to animal accommodation and care.  

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Figure 53: Answer to question 20 of the public consultation “To what extent do you agree with the following state-
ments?” in absolute number of respondents 

0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%

20a.Information on species and their habitats is usually well
presented

78 

253 

258 

895 

20b.After a zoo visit I know more about conservation of wild
animals, protected species,

60 

422 

316 

683 

813 

816 

20c.After a zoo visit I know more about biodiversity and
conservation of nature in gener

64 

452 

531 

513 

737 

20d.I have noticed improvements of education activities
(e.g. school visits, educational

213 

293 

203 

602 

986 

20e.I have noticed improvements in research activities
carried out by zoos over the last

266 

516 

243 

410 

862 

20f. Animals live in conditions that satisfy their needs

15 

955 

243 

498 

586 

20g. I have noticed improvements in the size and design of
spaces where animals are kept

66 

395 

303 

574 

959 

20h. Animal shows are adapted to animals' natural
behaviours

77 

1020 

223 

378 

599 

20i. In the zoos I’ve visited, I received information on the 
species and/or its conservat 

84 

253 

289 

743 

928 

20j. Zoo visits encourage visitors to become more engaged
in the protection of species

50 

529 

493 

412 

813 

20k. Zoo visits encourage visitors to become more engaged
in the protection of biodiversi

50 

562 

499 

426 

760 

20l. Zoos are adequately designed to prevent the escape of
animals

123 

243 

248 

678 

1005 

Don't know

Totally disagree

Somewhat disagree

Somewhat agree

Totally agree

The highest level of positive perception can be observed in relation to two main points: 

  Adequate prevention of escape of animals: 44% of the respondents fully agreed and 30% some-

what agreed on the fact that zoos are adequately designed to prevent escape (point 20l); 

  Adequate level of education: 72% of the respondents indicated having received information on 
species and conservation (point 20i), and 74% considered (fully or partly) the information of spe-
cies  and  their  habitats  well  presented  (point  20a).  In addition,  a  high  proportion  of  respondents 

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(43%  ‘totally’/  26%  ‘somewhat’)  observed  improvements  in  the  educational  activities  provided 
by zoos in the past 15 years. (point 20d). 

Views are more nuanced, though in majority positive, in relation to:  

  The level of awareness on species: 66% (of which 36% fully) agreed to the fact that they know 
more  about  wild  animals  and  protected  species  after  a  visit  to  the  zoo  (point  20b),  while  53% 
agreed (33% fully) that zoo visits encourage visitors to become more engaged in the protection of 
species (point 20j);  

  The  level  of  awareness  on  biodiversity  conservation  in  general:  54%  (of  which  32%  fully) 
agreed to the fact that they know more about biodiversity and conservation after a visit to the zoo 
(point 20c), and 52% agreed (33% fully) that zoo visits encourage visitors to become  more en-
gaged in the protection of biodiversity (point 20k). 

  Progress achieved in relation to research: 56% of the respondents (of which 38% fully) noticed 

improvements in research activities carried out by zoos over the last 15 years (point 20e).  

Finally, the conditions of animals in zoos was overall negatively assessed by a majority of respond-
ents: 

  54%  of  the  respondents,  including  44%  totally,  did  not  adhere  to  the  observation  that  animal 

shows were adapted to the animals’ natural behaviours (point 20h). 

  Regarding  accommodation,  53%  of  the  respondents,  including  42%  totally,  disagreed  with  the 
fact that animals live in conditions that satisfy their needs (point 20f). It should nevertheless be 
noted in the latter point that 67% (of which 42% totally) observed improvements in the size and 
design of spaces where animals are kept over the last 15 years.  

4.1.2  Distribution per type of stakeholders 

Even though, as explained above, the level of appreciation of the contribution of the Directive to its 
objectives is overall assessed positively, as illustrated in Figure 54 and Table 61, there is a high level 
of discrepancy between the answers provided by the different types of stakeholders.  

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Figure  54: Answer to question 20 of the public consultation “To what extent do you agree with the following state-
ment?”  per  share  of  respondents  who  agree  to  the  statements  proposed,  per  type  of  stakeholders.  Percentages  are 
calculated on the number of respondents that expressed an opinion (i.e. “Don’t know” is excluded)  

100%

90%

80%

70%

60%

50%

40%

30%

20%

10%

0%

20a

20b

20c

20d

20e

20f

20g

20h

20i

20j

20k

20l

Individual

Business

Zoo operator

Public authority

NGO

Other organisation

Other

Table  61:  Answer  to  question  20  of  the  public  consultation  “To  what  extent  do  you  agree  with  the  following  state-
ment?” - Share of respondents who replied “Totally agree” or “Somewhat agree”, per type of stakeholder. Percent-
ages are calculated on the number of respondents that expressed an opinion (i.e. “Don’t know” is excluded) 

Type of stakeholder 

Business 

Public 
authority 

Individual 

NGO 

Other  

org. 

Zoo opera-
tor 

Other 

86% 
(n=7) 

76% 
(n=1875

70% 
(n=37) 

79% 
(n=33) 

92% 
(n=98) 

76% 
(n=148) 

20a.Information on spe-
cies and their habitats is 
usually well presented 

20b.After a zoo visit I know 
more about conservation 
of wild animals, protected 
species, 

20c.After a zoo visit I know 
more about biodiversity 
and conservation of na-
ture in general 

20d.I have noticed im-
provements of education 
activities (e.g. school vis-
its, educational 

20e.I have noticed im-
provements in research 
activities carried out by 
zoos over the last 

95% 

(n=21) 

76% 

(n=21) 

)  

100% 
(n=7) 

65% 
(n=1896
) 

70% 
(n=20) 

100% 
(n=7) 

100% 
(n=19) 

100% 
(n=7) 

83% 
(n=18) 

100% 
(n=7) 

53% 
(n=1891
) 

74% 
(n=1750
) 

59% 
(n=1695
) 

56% 
(n=36) 

76% 
(n=33) 

90% 
(n=97) 

71% 
(n=147) 

51% 
(n=37) 

64% 
(n=33) 

88% 
(n=98) 

62% (n= 
147) 

76% 
(n=34) 

84% 
(n=32) 

93% 
(n=94) 

80% 
(n=148) 

53% 
(n=34) 

78% 
(n=32) 

93% 
(n=97) 

69% 
(n=148) 

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Type of stakeholder 

Business 

Public 
authority 

Individual 

NGO 

Other  

org. 

Zoo opera-
tor 

Other 

20f. Animals live in condi-
tions that satisfy their 
needs 

20g. I have noticed im-
provements in the size 
and design of spaces 
where animals are kept  

20h. Animal shows are 
adapted to animals' natu-
ral behaviours 

20i. In the zoos I’ve visited, 
I received information on 
the species and/or its 
conservation 

20j. Zoo visits encourage 
visitors to become more 
engaged in the protection 
of species 

20k. Zoo visits encourage 
visitors to become more 
engaged in the protection 
of biodiversity 

20l. Zoos are adequately 
designed to prevent the 
escape of animals 

62% 
(n=21) 

100% 
(n=7) 

90% 
(n=20) 

100% 
(n=7) 

71% 
(n=21) 

67% 
(n=6) 

84% 
(n=19)  

100% 
(n=7) 

62% 
(n=21) 

100% 
(n=7) 

57% 
(n=21) 

100% 
(n=7) 

95% 
(n=21) 

100% 
(n=7) 

43% 
(n=1933
) 

66% 
(n=1889
) 

40% 
(n=1881
) 

74% 
(n=1873
) 

51% 
(n=1905
) 

49% 
(n=1905
) 

76% 
(n=1831
) 

41% 
(n=37) 

62% 
(n=34) 

90% 
(n=103) 

62% 
(n=147) 

72% 
(n=36) 

84% 
(n=32) 

93% 
(n=99) 

73% 
(n=148) 

38% 
(n=37) 

55% (n= 
31) 

86% 
(n=99) 

55% 
(n=145) 

72% 
(n=36) 

91% 
(n=32) 

93% 
(n=98) 

77% 
(n=148) 

33% 
(n=36) 

72% 
(n=32) 

88% 
(n=98) 

63% 
(n=148) 

36% 
(n=36) 

69% 
(n=32) 

89% 
(n=98) 

61% 
(n=148) 

65% 
(n=37) 

88% 
(n=32) 

94% 
(n=98) 

73% 
(n=148) 

On the one hand, public authorities and zoo operators usually consider that the implementation of the 
Directive’s objectives is successful. On average, public authorities agree (fully or partly) at 96% with 
the  statements  provided  in  question  20,  and  91%  of  the  responding  zoo  operators  agree  with  these 
statements.  The  lowest  rate  of  adhesion  for  both  types  of  stakeholders  is  for  point  20h  on  animal 
shows (respectively 67% for authorities and 86% for zoo operators). 

On  the  other  hand,  only  55%  of  the  NGOs  and  60%  of  the  individual  respondents  agree  with  the 
statements of question 20. In terms of sub-questions, the lowest rate for NGOs corresponds to 33% of 
the responding NGOs agreeing to the statement provided in point 20j ‘zoo visits encourage visitors to 
become more engaged in the protection of species’, and the lowest rate for individuals (40%) relates to 
point  20h  on  shows.  In  addition,  it  should  be  mentioned  that,  in  contrast  with  public  authorities 
(100%) and zoo operators (90%), only a minority of NGOs (41%) and individuals (43%) agreed with 
the statement that animals live in conditions that satisfy their needs (point 20f). The same stakeholders 
nevertheless  observed  in majority (respectively 72%  and 66%)  an improvement on the accommoda-
tion  of  animals  kept  in  zoos  (point  20g),  thus  showing  a  certain  consensus  among  the  stakeholders, 
regardless of their type, on progress achieved in animal welfare in zoos over the implementation peri-
od.    

The  highest  level  of  adhesion  for  NGOs  corresponds  to  point  20d  on  improvements  in  educational 
activities  (76%),  and  for  individuals  to  point  20a  on  the  presentation  of  information  on  species  and 
their habitats (76%). In spite of these positive assessments in relation to education and awareness rais-
ing,  NGOs  and  individuals  still  have  a  rather  negative  perception  about  the  increase  in  knowledge 
after a visit to  a zoo (point 20 b- 56% for NGOs  and 65% for individuals- and  point 20c- 51% and 
53%) and possible behavioural changes triggered by a visit (point 20j- 33% and 51% and point 20k- 
36% and 49%). Once again, this perception is strikingly  different from that expressed by public au-

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thorities and zoos operators, who have assessed in vast majority such measures positively (100% for 
all points listed above for public authorities and between 88 and 90% for zoos operators). These re-
sults  would  tend  to  indicate  that  educational  measures  are  not  as  successful  among  visitors  as  per-
ceived by public authorities and zoos.  

Other stakeholders have less clear-cut views. Business-oriented respondents, other organisations and 
‘other’ respondents agree to the statements of Article 20 respectively at an average of 79%, 75% and 
68%. For each of these groups, at least a majority of respondents has agreed to each and every state-
ment. More details per type of stakeholders for each sub-question can be found in Annex I.  

4.1.3  Distribution per country 

Figure 55 and Table 62 below show the distribution of replies by geographical distribution of the re-
spondents (Member States/non-EU country). As in the sub-section above, the figure and table present 
only the share of respondents who flagged the reply options “Totally agree” or “Somewhat agree”. A 
full overview is presented in Annex I. 

Figure 55 presents the level of agreement with all question 20 statements as an average. This shows an 
overall positive appreciation of the implementation of the Directive’s objectives in 16 out of 27 Mem-
ber States/non-EU countries, with the  highest scores in the Netherlands (89%), Germany (79%) and 
the Slovak Republic (79%). Respondents of 11 of the Member States agreed at less than 50% to the 
statements  provided.  This  includes  countries  with  a  relatively  high  response  rate,  such  as  Belgium 
(37%), France (43%) and Spain (28%). The average level of agreement was particularly low in Bul-
garia (18%), Slovenia (22%) and Malta (25%). Here, and even more in Table 62, the trends observed 
by  Member  States  need  to  be  nuanced,  as  previously  explained,  due  to  potential  issues  in  terms  of 
representativeness of the sample of each country.  

Figure 55: Answer to question 20 of the public consultation- Share of respondents who agreed with the statements of 
Question 20, on average across Questions 20a to 20l 

100%
90%
80%
70%
60%
50%
40%
30%
20%
10%
0%

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Table 62: Answer to question 20 of the public consultation “To what extent do you agree with the following statements?” - Share of respondents who flagged the reply options “Total-
ly agree” or “Somewhat agree”, per Member State/non-EU Country. Percentages and, in brackets, absolute number of total respondents per Member State excluding “No opinion” 

MS 

20a 

20b 

20c 

20d 

20e 

20f 

20g 

20h 

20i 

20j 

20k 

20l 

Austria 

84% (n=25) 

72%(n=25) 

60%(n=25) 

88%(n=24) 

70%(n=23) 

60%(n=25) 

92%(n=25) 

57%(n=23) 

92%(n=25) 

70%(n=23) 

64%(n=25) 

87%(n=23) 

Belgium 

55%(n=40) 

39%(n=41) 

27%(n=41) 

49%(n=35) 

45%(n=33) 

23%(n=43) 

43%(n=40) 

15%(n=41) 

45%(n=42) 

26%(n=43) 

21%(n=43) 

62%(n=39) 

Bulgaria 

33%(n=3) 

0%(n=3) 

0%(n=3) 

33%(n=3) 

0%(n=2) 

0%(n=3) 

33%(n=3) 

0%(n=3) 

50%(n=2) 

0%(n=3) 

0%(n=3) 

67%(n=3) 

Croatia 

100%(n=1) 

100%(n=1) 

0%(n=1) 

0%(n=0) 

0%(n=0) 

0%(n=1) 

0%(n=1) 

0%(n=1) 

0%(n=1) 

100%(n=1) 

100%(n=1) 

0%(n=0) 

Czech R. 

86%(n=14) 

79%(n=14) 

64%(n=14) 

93%(n=15) 

86%(n=14) 

60%(n=15) 

80%(n=15) 

64%(n=14) 

79%(n=14) 

67%(n=15) 

60%(n=15) 

87%(n=15) 

Denmark 

69%(n=39) 

66%(n=38) 

55%(n=38) 

72%(n=36) 

62%(n=34) 

50%(n=38) 

67%(n=39) 

45%(n=38) 

72%(n=39) 

50%(n=38) 

54%(n=39) 

71%(n=34) 

Estonia 

100%(n=1) 

100%(n=1) 

0%(n=1) 

100%(n=1) 

0%(n=1) 

0%(n=1) 

100%(n=1) 

0%(n=1) 

100%(n=1) 

0%(n=1) 

0%(n=1) 

100%(n=1) 

Finland 

50%(n=8) 

38%(n=8) 

14%(n=7) 

29%(n=7) 

50%(n=8) 

13%(n=8) 

29%(n=7) 

13%(n=8) 

63%(n=8) 

38%(n=8) 

25%(n=8) 

86%(n=7) 

France 

60%(n=68) 

43%(n=68) 

26%(n=68) 

59%(n=61) 

53%(n=57) 

24%(n=67) 

49%(n=67) 

19%(n=68) 

56%(n=68) 

27%(n=67) 

27%(n=67) 

72%(n=65) 

Germany 

90%(n=777) 

81%(n=786) 

74%(n=782) 

88%(n=731) 

77%(n=689) 

69%(n=793) 

86%(n=780) 

66%(n=776) 

87%(n=774) 

71%(n=782) 

70%(n=781) 

90%(n=762) 

Greece 

71%(n=14) 

71%(n=14) 

64%(n=14) 

71%(n=14) 

58%(n=12) 

62%(n=13) 

86%(n=14) 

57%(n=14) 

79%(n=14) 

64%(n=14) 

64%(n=14) 

69%(n=13) 

Hungary 

100%(n=5) 

100%(n=6) 

33%(n=6) 

80%(n=5) 

40%(n=5) 

33%(n=6) 

67%(n=6) 

17%(n=6) 

100%(n=6) 

50%(n=6) 

50%(n=6) 

83%(n=6) 

Ireland 

87%(n=15) 

50%(n=16) 

44%(n=16) 

80%(n=15) 

60%(n=15) 

19%(n=16) 

60%(n=15) 

29%(n=14) 

67%(n=15) 

33%(n=15) 

43%(n=14) 

67%(n=12) 

Italy 

80%(n=50) 

71%(n=51) 

57%(n=51) 

81%(n=48) 

58%(n=48) 

33%(n=49) 

59%(n=51) 

23%(n=40) 

67%(n=49) 

51%(n=51) 

47%(n=51) 

80%(n=49) 

Lithuania 

33%(n=3) 

33%(n=3) 

33%(n=3) 

67%(n=3) 

33%(n=3) 

0%(n=3) 

33%(n=3) 

0%(n=3) 

67%(n=3) 

33%(n=3) 

33%(n=3) 

100%(n=3) 

Luxembg 

100%(n=1) 

0%(n=1) 

100%(n=1) 

100%(n=1) 

100%(n=1) 

0%(n=1) 

100%(n=1) 

0%(n=1) 

100%(n=1) 

100%(n=1) 

100%(n=1) 

100%(n=1) 

Malta 

50%(n=2) 

50%(n=2) 

0%(n=2) 

50%(n=2) 

50%(n=2) 

0%(n=2) 

0%(n=2) 

0%(n=2) 

50%(n=2) 

50%(n=2) 

0%(n=2) 

0%(n=2) 

Netherlds 

93%(n=118) 

88%(n=117) 

85%(n=117) 

97%(n=113) 

94%(n=113) 

85%(n=118) 

94%(n=116) 

76%(n=115) 

94%(n=117) 

86%(n=117) 

85%(n=117) 

96%(n=115) 

Poland 

31%(n=13) 

23%(n=13) 

15%(n=13) 

50%(n=12) 

31%(n=13) 

15%(n=13) 

23%(n=13) 

17%(n=12) 

38%(n=13) 

15%(n=13) 

15%(n=13) 

67%(n=12) 

Portugal 

81%(n=36) 

68%(n=38) 

63%(n=38) 

81%(n=37) 

70%(n=37) 

63%(n=38) 

71%(n=38) 

61%(n=38) 

81%(n=37) 

62%(n=37) 

62%(n=37) 

81%(n=36) 

Romania 

75%(n=16) 

63%(n=16) 

63%(n=16) 

81%(n=16) 

64%(n=14) 

63%(n=16) 

69%(n=16) 

40%(n=10) 

69%(n=16) 

63%(n=16) 

63%(n=16) 

93%(n=14) 

Slovakia 

100%(n=2) 

100%(n=2) 

50%(n=2) 

100%(n=1) 

100%(n=1) 

50%(n=2) 

100%(n=1) 

50%(n=2) 

100%(n=2) 

50%(n=2) 

50%(n=2) 

100%(n=2) 

Slovenia 

67%(n=3) 

33%(n=3) 

0%(n=3) 

0%(n=2) 

0%(n=2) 

0%(n=3) 

0%(n=3) 

33%(n=3) 

67%(n=3) 

0%(n=3) 

0%(n=3) 

67%(n=3) 

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MS 

20a 

20b 

20c 

20d 

20e 

20f 

20g 

20h 

20i 

20j 

20k 

20l 

Spain 

44%(n=151) 

32%(n=155) 

18%(n=156) 

42%(n=145) 

23%(n=142) 

10%(n=157) 

29%(n=153) 

6%(n=156) 

44%(n=153) 

15%(n=156) 

15%(n=156) 

60%(n=149) 

Sweden 

71%(n=31) 

68%(n=31) 

68%(n=31) 

74%(n=27) 

78%(n=27) 

61%(n=31) 

74%(n=31) 

53%(n=30) 

81%(n=31) 

65%(n=31) 

60%(n=30) 

90%(n=29) 

UK 

Non-EU  

73%(n=580) 

61%(n=577) 

44%(n=578) 

72%(n=535) 

53%(n=537) 

29%(n=607) 

60%(n=583) 

27%(n=590) 

74%(n=569) 

44%(n=590) 

41%(n=589) 

66%(n=573) 

69%(n=203) 

60%(n=207) 

53%(n=206) 

67%(n=195) 

58%(n=198) 

44%(n=213) 

58%(n=207) 

39%(n=211) 

65%(n=208) 

49%(n=209) 

47%(n=210) 

69%(n=206) 

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Table 62 presents an overview of the level of agreement by statement. It reflects once again the posi-
tive  answers  (‘Totally  agree’  and  ‘Somewhat  agree’).  In  spite  of  the  reservations  expressed  above, 
when looking at the answers provided in the countries with the highest level of response (i.e., Germa-
ny, the United Kingdom, the Netherlands), the same trends as the overall trends observed under Sec-
tion 5.1.1. The level of positive assessment is the highest in ten countries in relation to the prevention 
of escape (point 20l), and in four countries (the Czech Republic, Denmark, Italy and the Netherlands) 
in  relation  to  the  improvement  in  education  activities  (point  20d).  A  strong  adhesion  also  exists  in 
relation to research in Germany, Hungary and Ireland (point 20a). The strongest reservations can be 
observed in relation to animal welfare and animal shows in most countries. In particular, in all coun-
tries but four, the statement on animal shows (point 20h) is the least adhered to (though this rate is still 
high in the Netherlands- 76% or France-66% for instance). In the four remaining countries (the Czech 
Republic, Ireland, Poland and Slovenia), point 20f (living conditions of animals) has the lowest score. 
In contrast, it is worth noting that Greece registers its highest rate of agreement with point 20g on im-
provements in the size and design of spaces where animals are kept.       

4.1.4  Distribution depending on whether the respondent visit a zoo or not 

This section provides an overview of the answers patterns between respondents that declared to visit 
zoos for different reasons and respondents who do not visit zoos. Figure 56 below presents the share 
of respondents who flagged the reply options “Totally agree” or “Somewhat agree”, by distinguishing 
between respondents visiting zoos and respondents not visiting zoos. 

Figure 56: Answer to question 20 of the public consultation “To what extent do you agree with the following state-
ments?” - Share of respondents who flagged the reply options “Totally agree” or “Somewhat agree”, per respondents 
visiting zoos or not. Percentages are calculated on the number of respondents that expressed an opinion (i.e. “No 
opinion” is excluded) 

100%

90%

80%

70%

60%

50%

40%

30%

20%

10%

0%

20a

20e

20c

20b

20d

20f

20g

20h

20i

20j

20k

20k

I don't visit zoos

I visit zoos

As illustrated in this Figure 56, there is a significant difference in the responses provided by the two 
types  of  stakeholders.  On  average,  for  the  12  statements,  there  is  a  76%  agreement  rate  among  re-
spondents visiting zoos. The rate drops to 24% for persons who do not visit zoos. The biggest differ-
ences  can  be  observed  for  statements  20f  (animal  living  conditions-  63%  and  3%  respectively)  and 
20h (animal shows- 59% and 2% respectively).  

4.1.5  Key points 

  Under  Question  20,  the  public  consultation  document  provides  12  statements  corresponding  to 
indicators of the effective implementation of the Zoos Directive. Overall, respondents tended to 

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agree with these statements, suggesting a good level of effectiveness of the Directive. There was 
nevertheless, on average, a higher rate of positive perceptions among public authorities and zoos 
operators than among NGOs and individual respondents.  
In  general,  respondents  considered  that  educational  measures  and  measures  relating  to  the 
prevention of escape were best implemented. This was true of all types of stakeholders, includ-
ing for NGOs and individual respondents.   

 

  The level of adhesion to the statements relating to the living conditions of animals and the con-
tribution of animal shows was significantly lower. In relation to animal shows, all types of stake-
holders,  including  public  authorities,  showed  a  disagreement  or  a  limited  agreement  with  the 
statement that shows are adapted to animals’ natural behaviour. The disagreement is particularly 
obvious among respondents which do not visit zoos.  

  The geographical pattern is not very conclusive, as it generally shows a higher level of agreement 
in the Netherlands and Germany, and a lesser level in the UK, corresponding to the types of re-
spondents present in these countries (respectively, mainly zoo operators and NGOs).  

4.2  DO  YOU  THINK  THE  FOLLOWING  ACTIVITIES  ARE  SUFFICIENTLY  PROMOTED  IN 

ZOOS ACROSS THE EU (QUESTION 21)? 

Question 21 aims at measuring the public perception of the implementation of the Article 3 conserva-
tion measures in zoos. To that end, the respondents’ opinion is asked in relation to the promotion of 
eight activities corresponding to the Article 3 measures: 

a.  Research on species conservation issues; 
b.  Training on relevant species conservation skills; 
c.  Exchange of information relating to species conservation, between zoos, authorities, other or-

ganisations; 

d.  Provide education on and raise awareness of biodiversity and broader nature protection topics; 
e.  Provide education on and raise awareness of species, wild animals and their natural habitats; 
f.  Provide information on exhibited species and their habitats; 
g.  Keep animals under appropriate conditions with good veterinary care; 
h.  Collect data on animals in zoos. 

Points a to c correspond to the first indent of Article 3. Points d to f correspond to the second indent of 
Article 3. Point g corresponds to the third indent, and point h to the last indent (up-to-date records).  

4.2.1  General trends 

The  public  consultation  document  asks  the  respondents  to  indicate  whether  they  think  that the  eight 
activities listed above are sufficiently promoted, with three possible answers (‘yes, no’, ‘no opinion’).   

Figure 57 provides an overview of the number of responses for each possible answer and per activity.  

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Figure  57:  Answer  to  question  21  of  the  public  consultation  “Do  you  think  the  following  activities  are  sufficiently 
promoted in zoos across the EU?” in absolute number of respondents 

0

200

400

600

800

1000 1200 1400 1600

21a.  Research on species conservation issues

21b. Training on relevant species conservation skills

21c. Exchange of information relating to species…

21d. Provide education on and raise awareness of…

21e. Provide education on and raise awareness of…

21f. Provide information on exhibited species and their…

21g. Keep animals under appropriate conditions with…

21h. Collect data on the animals in the zoo

No opinion

No

Yes

In addition, Figure 58 indicates the percentage of answers of each type for each activity.  

Figure  58:  Answer  to  question  21  of  the  public  consultation  “Do  you  think  the  following  activities  are  sufficiently 
promoted in zoos across the EU?” in percentage of respondents 

0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%

21a.  Research on species conservation issues

13% 

43% 

21b. Training on relevant species conservation skills

21c. Exchange of information relating to species
conservation, between zoos, authorities, other…
21d. Provide education on and raise awareness of
biodiversity and broader nature protection topics
21e. Provide education on and raise awareness of
species, wild animals and their natural habitats

21f. Provide information on exhibited species and their
habitats
21g. Keep animals under appropriate conditions with
good veterinary care

24% 

26% 

34% 

26% 

9% 

34% 

7% 

31% 

7% 

23% 

70% 

6% 

46% 

44% 

41% 

48% 

57% 

62% 

48% 

54% 

21h. Collect data on the animals in the zoo

29% 

17% 

No opinion

No

Yes

As can be seen from Figure 57 and Figure 58, all activities have been assessed predominantly posi-
tively.  For  half  of  the  activities,  a  majority  of  respondents  considered  that  the  activities  were  suffi-
ciently promoted. These relate primarily to the provision of information and education: 

  Providing information on exhibited species, wild animals and their natural habitats: 70% of posi-

tive answers (point 21 f); 

  Providing  education  on  and  raise  awareness  of  species,  wild  animals  and  their  natural  habitats: 

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62% of positive answer (point 21 e);  

  Providing education on and raise awareness of biodiversity and broader nature protection topics: 

57% of positive answers (point 21 d).  

Positive  assessment  of  these  activities  is  consistent  with  the  answers  provided  to  question  20  in 
relation to the same topic (see Section 4.1.1 above). In addition, the collection of data on animals in 
zoos was also assessed positively (54% of positive assessment).  

The highest level of negative answers related to: 

  Animal conditions and care (point 21g): 46% of negative answers;  
  Research in species conservation issues (point 21a): 43% of negative answers. 

The high proportion of respondents that consider that the promotion of animals’ accommodation and 
care in zoos  is not sufficient is also consistent with the trends identified in question 20 (see Section 
4.1.1 above).  

Research should, like other specific activities (e.g. training, exchange of information and collection of 
data),  be  less  visible  for  the  wide  public,  and  hence  subject  to  a  higher  proportion  of  ‘no  opinion’, 
similarly to what is observed for these other activities. The high rate of negative answers is therefore 
particularly striking.    

4.2.2  Distribution per type of stakeholders 

Figure  59  and  Table  63  provide,  for  each  statement,  the  level  of  positive  answers  for  each  type  of 
stakeholders. A more complete information, with ratios for all three answers and all three activities is 
provided in Annex I.   

Figure  59:  Answers  to  question  21  of  the  public  consultation  “Do  you  think  the  following  activities  are  sufficiently 
promoted in zoos across the EU?” per share of respondents who replied ‘yes’. Percentages are calculated on the num-
ber of respondents that expressed an opinion (i.e. “No opinion/don’t know” is excluded). 

100%

90%

80%

70%

60%

50%

40%

30%

20%

10%

0%

21a

21b

21c

21d

21e

21f

21g

21h

Individual

Business

Zoo operator

Public authority

NGO

Other organisation

Other

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Table 63: Answers to question 21 of the public consultation “Do you think the following activities are sufficiently 
promoted in zoos across the EU?” per share of respondents who replied ‘yes’. Percentages are calculated on the num-
ber of respondents that expressed an opinion (i.e. “No opinion/don’t know” is excluded). 

s
s
e
n
si
Bu

74% 
(n=19) 

81% 
(n=16) 

74% 
(n=19) 

u-
a

c
i

bl
u
P

y
t
i

or
h
t

83% 
(n=6) 

83% 
(n=6) 

86% 
(n=7) 

al
u
d
vi
di
n

I

GO 
N

g.
or

r
e
h
Ot

or
at
r
e
p
o
o
o
Z

r
e
h
Ot

47% 
(n=1675) 

33% 
(n=33) 

53% 
(n=30) 

87% 
(n=94) 

59% 
(n=143) 

52% 
(n=1642) 

36% 
(n=25) 

64% 
(n=28) 

82% 
(n=87) 

52% 
(n=137) 

62% 
(n=1402) 

52% 
(n=23) 

73% 
(n=26) 

96% 
(n=88) 

61% 
(n=143) 

80% 
(n=20) 

83% 
(n=6) 

61% 
(n=1755) 

54% 
(n=35) 

61% 
(n=33) 

90% 
(n=96) 

64% 
(n=144) 

86% 
(n=21) 

83% 
(n=6) 

64% 
(n=1802) 

56% 
(n=36) 

66% 
(n=32) 

96% 
(n=96) 

66% 
(n=144) 

90% 
(n=20) 

76% 
(n=17) 

100% 
(n=7) 

100% 
(n=7) 

74% 
(n=1795) 

57% 
(n=37) 

66% 
(n=32) 

96% 
(n=93) 

74% 
(n=146) 

47% 
(n=1818) 

35% 
(n=37) 

61% 
(n=33) 

95% 
(n=97) 

61% 
(n=147) 

21a.  Research on species conser-
vation issues 

21b. Training on relevant species 
conservation skills 

21c. Exchange of information relat-
ing to species conservation, be-
tween zoos, authorities, other or-
ganisations 

21d. Provide education on and 
raise awareness of biodiversity and 
broader nature protection topics 

21e. Provide education on and 
raise awareness of species, wild 
animals and their natural habitats 

21f. Provide information on exhibit-
ed species and their habitats 

21g. Keep animals under appropri-
ate conditions with good veterinary 
care 

21h. Collect data on the animals in 
the zoo 

82% 
(n=17) 

100% 
(n=7) 

74% 
(n=1337) 

65% 
(n=23) 

70% 
(n=23) 

97% 
(n=78) 

72% 
(n=144) 

Figure  59  shows  a  particularly  positive  perception  of  the  implementation  of  Article  3  measures 
among  public  authorities,  zoo  operators  and  business,  and  a  less  positive  one  among  individuals, 
NGOs and other organisations. On average, responding zoos operators expressing an opinion gave at 
92%  positive  answers  and  public  authorities  90%,  while  NGOs  had  an  average  of  51%  of  negative 
answers. Individuals expressed 60% of positive answers on average.  

Table 63 illustrates more clearly the trends among the different types per activity. The bold numbers 
correspond to the highest percentage of positive answers for each of these activities. The numbers in 
italics are the lowest percentages of positive answers.  

The  highest  rates  of  agreement  are  always  with  public  authorities  or  zoo  operators.  Among  these 
two groups, a correlation can be observed between the highest positive response rates and the level of 
involvement or control of each type of stakeholders on a given activity. For points 21b (training), 21f 
(information), 21g (animal accommodation and care) and 21h (data collection), most, if not all, of the 
authorities considered that the promotion of these activities was sufficient. For points 21a (research), 
21c (exchange of information), 21d and e (education), zoos operators represented the highest rate of 
positive answers. The rate of positive answers does not go below 83% (for research and education) for 
public authorities and below 82% (training) for zoo operators.    

While  NGOs have the lowest rate of  positive appreciation  for all activities, this level is particularly 
low  in  relation  to  research  (33%),  training  (36%)  and  animal  accommodation  and  care  (35%).  The 
highest rate of positive answers for NGOs is in relation to data collection (65%).     
Individuals expressing an opinion are more or less in-between these two extremes, with an average of 

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60% of positive answers, with the highest appreciation for the provision of information on species and 
their habitats (point 21f) and for data collection (point 21h), with a 74% positive response rate in both 
cases. Their lowest level of positive answers relates to research (point 21a) and animal accommoda-
tion and care (point 21g), with a rate of positive answers of 47% for the two instances.     

4.2.3  Distribution per country  

Figure 60 and Table 64 below show the distribution of replies by geographical distribution of the re-
spondents (Member States/non-EU country). As in the sub-section above, the figure and table present 
only the share of respondents who expressed a positive opinion. A full overview is presented in Annex 
I. 

Figure  60  presents  the  level  of  positive  perception  with  all  activities  listed  under  question  21  as  an 
average. This shows an overall positive appreciation of  the implementation of the Directive’s objec-
tives in 15498 out of 27 Member States/non-EU countries, with the highest scores in the Netherlands 
(89%),  Germany  (79%)  and  Austria  (79%).  Respondents  of  12499  of  the  Member  States  assessed  on 
average negatively (less than 50% of positive answers) the promotion of the activities listed in Ques-
tion 21. In particular, the respondents of Croatia, Estonia and Malta all considered that the promotion 
of none of the activities listed was sufficient (0%). The rate of positive responses was also very low in 
Slovenia (13%) and Poland (25%).  

Figure 60: Answer to question 21 of the public consultation- Share of respondents who think that the activities listed 
in Question 21 are sufficiently promoted, on average across Questions 21a to 21h, per Member State/non-EU country. 

100%

90%

80%

70%

60%

50%

40%

30%

20%

10%

0%

a
i
r
t
s
u
A

i

m
u
g
e
B

l

i

a
n
o
t
s
E

d
n
a
n
i
F

l

e
c
n
a
r
F

k
r
a
m
n
e
D

y
n
a
m
r
e
G

e
c
e
e
r
G

y
r
a
g
n
u
H

d
n
a
e
r
I

l

y
l
a
t
I

i

a
n
a
u
h
t
i
L

a
i
r
a
g
u
B

l

a
i
t
a
o
r
C

c
i
l

b
u
p
e
R
h
c
e
z
C

a
t
l
a
M

g
r
u
o
b
m
e
x
u
L

s
d
n
a
l
r
e
h
t
e
N

y
r
t
n
u
o
c
U
E
-
n
o
N

d
n
a
o
P

l

l

a
g
u
t
r
o
P

i

a
n
a
m
o
R

c
i
l

b
u
p
e
R
k
a
v
o
l
S

i

a
n
e
v
o
l
S

i

n
a
p
S

n
e
d
e
w
S

i

m
o
d
g
n
K
d
e
t
i
n
U

498 Austria, Czech Republic, Denmark, Germany, Greece, Hungary, Italy, Lithuania, Luxembourg, the Netherlands, non-EU countries, Portu-
gal, Romania, Slovakia and Sweden.  
499 Belgium, Bulgaria, Croatia, Estonia, Finland, France, Ireland, Malta, Poland, Slovenia, Spain and the UK.  

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Table 64: Answer to question 21 of the public consultation- Share of respondents who think that the activities listed in Question 21 are sufficiently promoted, per Member States/non-
EU countries, and per activity. Percentages and, in brackets, absolute number of total respondents per Member State excluding “No opinion”. 

MS 

Austria 

Belgium 

Bulgaria 

Croatia 

21a 

21b 

21c 

21d 

21e 

21f 

21g 

21h 

68% (n=22) 

81% (n=21) 

81% (n=21) 

75% (n=24) 

83% (n=24) 

88% (n=25) 

67% (n=24) 

90% (n=20) 

17% (n=36) 

20% (n=35) 

36% (n=25) 

37% (n=38) 

39% (n=38) 

54% (n=39) 

22% (n=41) 

48% (n=23) 

0% (n=1) 

0% (n=0) 

0% (n=1) 

0% (n=0) 

50% (n=2) 

50% (n=2) 

50% (n=2) 

50% (n=2) 

0% (n=3) 

100% (n=1) 

0% (n=0) 

0% (n=0) 

0% (n=0) 

0% (n=0) 

0% (n=1) 

0% (n=0) 

Czech Republic 

53% (n=15) 

62% (n=13) 

77% (n=13) 

73% (n=15) 

67% (n=15) 

80% (n=15) 

73% (n=15) 

83% (n=12) 

Denmark 

49% (n=37) 

45% (n=31) 

59% (n=32) 

58% (n=38) 

62% (n=37) 

70% (n=37) 

51% (n=37) 

70% (n=30) 

Estonia 

Finland 

France 

0% (n=1) 

N/A (n=0) 

N/A (n=0) 

0% (n=1) 

0% (n=1) 

0% (n=1) 

0% (n=1) 

N/A (n=0) 

29% (n=7) 

29% (n=7) 

50% (n=6) 

17% (n=6) 

14% (n=7) 

43% (n=7) 

13% (n=8) 

50% (n=6) 

34% (n=59) 

22% (n=54) 

48% (n=50) 

47% (n=62) 

46% (n=63) 

60% (n=60) 

34% (n=64) 

52% (n=46) 

Germany 

69% (n=704) 

78% (n=638) 

81% (n=647) 

78% (n=740) 

80% (n=759) 

85% (n=765) 

71% (n=768) 

89% (n=639) 

Greece 

Hungary 

Ireland 

Italy 

54% (n=13) 

67% (n=12) 

82% (n=11) 

58% (n=12) 

67% (n=12) 

85% (n=13) 

62% (n=13) 

63% (n=8) 

25% (n=4) 

33% (n=3) 

50% (n=2) 

80% (n=5) 

100% (n=5) 

100% (n=6) 

20% (n=5) 

50% (n=2) 

33% (n=15) 

33% (n=12) 

43% (n=14) 

43% (n=14) 

44% (n=16) 

67% (n=15) 

23% (n=13) 

42% (n=12) 

50% (n=44) 

43% (n=40) 

70% (n=37) 

50% (n=46) 

56% (n=48) 

71% (n=48) 

49% (n=45) 

68% (n=34) 

Lithuania 

50% (n=2) 

50% (n=2) 

50% (n=2) 

33% (n=3) 

33% (n=3) 

100% (n=3) 

33% (n=3) 

50% (n=2) 

Luxembourg 

100% (n=1) 

0% (n=1) 

100% (n=1) 

100% (n=1) 

100% (n=1) 

100% (n=1) 

0% (n=1) 

100% (n=1) 

Malta 

0% (n=2) 

0% (n=2) 

N/A (n=0) 

0% (n=1) 

0% (n=3) 

0% (n=2) 

0% (n=3) 

N/A (n=0) 

Netherlands 

85% (n=113) 

83% (n=111) 

89% (n=108) 

89% (n=112) 

89% (n=112) 

95% (n=113) 

87% (n=117) 

95% (n=110) 

Poland 

Portugal 

Romania 

15% (n=13) 

9% (n=11) 

40% (n=5) 

17% (n=12) 

17% (n=12) 

36% (n=11) 

17% (n=12) 

50% (n=4) 

57% (n=35) 

61% (n=36) 

79% (n=34) 

73% (n=37) 

78% (n=36) 

86% (n=37) 

68% (n=37) 

87% (n=31) 

64% (n=11) 

55% (n=11) 

83% (n=12) 

77% (n=13) 

77% (n=13) 

87% (n=15) 

79% (n=14) 

77% (n=13) 

Slovak Republic 

100% (n=1) 

100% (n=1) 

50% (n=2) 

50% (n=2) 

50% (n=2) 

100% (n=2) 

50% (n=2) 

50% (n=2) 

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Slovenia 

Spain 

Sweden 

0% (n=3) 

0% (n=3) 

0% (n=3) 

0% (n=3) 

0% (n=3) 

33% (n=3) 

0% (n=3) 

67% (n=3) 

18% (n=128) 

17% (n=109) 

27% (n=94) 

30% (n=145) 

33% (n=150) 

49% (n=144) 

17% (n=149) 

47% (n=91) 

59% (n=29) 

63% (n=27) 

77% (n=26) 

70% (n=30) 

67% (n=30) 

78% (n=27) 

55% (n=29) 

65% (n=26) 

United Kingdom 

33% (n=534) 

33% (n=413) 

46% (n=405) 

52% (n=547) 

60% (n=558) 

69% (n=556) 

32% (n=562) 

65% (n=372) 

Non-EU country 

49% (n=170) 

48% (n=147) 

58% (n=156) 

61% (n=180) 

62% (n=187) 

70% (n=183) 

47% (n=186) 

71% (n=141) 

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Table 63 presents an overview of the level of positive answer by activity. When looking at the answers 
provided  in  the  countries  with  the  highest  level  of  response  (i.e.,  Germany,  the  United  Kingdom, 
Spain, the Netherlands and France), they show similar trends, with the highest rate of positive answers 
for  point  21f  (information  on  species)  and  point  21h  (data  collection).  The  trends  are  similar  in  all 
other countries. Overall, 13 countries500 expressed their highest level of adhesion with point 21f, and 
eight  Member  States501  and  the  non-EU  countries  with  21h.  The  lowest  rates  are  achieved  for  point 
20a (research) in Belgium, the Czech Republic, Germany, Greece, Poland and Portugal, for point 21b 
(training) in Denmark, France, Italy, the Netherlands (with 83% positive assessment though), Romania 
and Spain (17% positive assessment), and finally for point 21g (animal accommodation and care) in 
Austria, Finland (13% positive assessment), Hungary, Ireland, Spain, Sweden (with 55% positive as-
sessment though), the United Kingdom and non-EU countries.    

4.2.4  Distribution depending on whether the respondent visit a zoo or not 

This section provides an overview of the answers patterns between respondents that declared to visit 
zoos for different reasons and respondents who do not visit zoos. Figure 61 below presents the share 
of respondents who think that the activities listed in question 21 are sufficiently promoted, by distin-
guishing between respondents visiting zoos and respondents not visiting zoos. 

Figure 61: Answer to question 21 of the public consultation - Share of respondents who think that the activities listed 
in Question 21 are sufficiently promoted, depending on whether they visit zoos or not. Percentages are calculated on 
the number of respondents that expressed an opinion (i.e. “No opinion” is excluded) 

100%

90%

80%

70%

60%

50%

40%

30%

20%

10%

0%

21a

21b

21c

21d

21e

21f

21g

21h

I don't visit zoos

I visit zoos

As illustrated in this Figure 61, the difference in the responses provided by the two types of stakehold-
ers  is  very  noticeable.  On  average,  there  is  a  75%  rate  of  positive  appreciation  among  respondents 
visiting zoos across the eight activities. The rate is only of 22% for persons who do not visit zoos. The 
biggest differences can be observed for activities 21c (exchange of information- 78% and 16% respec-
tively) and 21g (animal accommodation and care- 67% and 7% respectively).  

500 Belgium, Denmark, France, Greece, Hungary, Ireland, Italy, Lithuania, the Netherlands, Romania, Spain, Sweden and the UK. 
501 Austria, Bulgaria, the Czech Republic, Finland, Germany, Poland, Portugal and Slovenia. 

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4.2.5  Key points 

 

  Overall, the activities listed in question 21, and which correspond to the activities resulting for the 
implementation of the Article 3  measures, have been considered as being sufficiently promoted 
by the persons who responded to the public consultation. The perception of the implementation of 
Article 3 measures is particularly positive among public authorities, zoo operators and business. It 
is  less  positive  among  individuals,  NGOs  and  other  organisations.  On  average,  92%  of  the  re-
sponding zoos operators expressing an opinion and 90% of the responding public authorities gave 
a positive appreciation of the activities listed, while the appreciation was negative for 51% of the 
responding NGOs. Individuals considered the activities listed as sufficiently promoted at 60% on 
average.   
In particular, the implementation of the activities relating to information (point 21f) and educa-
tion (points 21 d and e) were positively assessed. This was especially the case among zoo opera-
tors and public authorities. Comparable results can be found when looking at the Member States 
with the highest number of respondents, point 21f received the highest rates of positive answers 
among the listed activities in these countries.  
In contrast, the level of negative answers was relatively high in relation to animal conditions and 
care (point 21g), with on average 46% of negative answers among all stakeholders. NGOs and 
individuals  in  particular  expressed  a  negative  perception  as  to  the  sufficient  promotion  of 
measures related to this activity, with respectively 35% and 47% of positive answers. The suffi-
cient promotion of training had the weakest positive rate among zoo operators (82%) and public 
authorities (83%).  

 

  The  rate  of  persons  who  used  the  ‘no  opinion’  option  was  understandably  higher  for  activities 
which related to more ‘technical’ activities (e.g. research, training, exchange of information and 
collection of data), the implementation of which is more difficult to assess for a non-specialized 
audience. However, for the stakeholders expressing an opinion, the level of positive answers was 
particularly low in relation to research (point 21a) among NGOs (33% of positive opinions) and 
individuals (47% of positive opinions).    

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5  EFFICIENCY 

The public consultation explored the perception of stakeholders on the extent of the benefits brought 
by the Zoos Directive benefits (questions 25 and 26, Section 5.1) and investigated how costs compare 
with the benefits (question 27, Section 5.2).  

5.1 

TO WHAT EXTENT DO YOU CONSIDER THAT THE DIRECTIVE HAS BROUGHT THE FOL-
LOWING BENEFITS (QUESTIONS 25-26)? 

The public consultation aimed at collecting opinions on the benefits produced with the implementation 
of the Zoos Directive. To this end, in question 25, stakeholders have been asked to assess the extent of 
a range of expected benefits, across different areas (from benefits on biodiversity conservation to ben-
efits on public awareness, increased recreational opportunities, tourism, etc.). The possibility for add-
ing other relevant benefits has been also provided, through the field “Other” (question 26).  

5.1.1  General trends 

The public consultation document has identified 13 potential benefits of the Zoos Directive and asked 
stakeholders  to  provide  their  opinion  on  the  magnitude  of  each  benefit.  As  shown  in  Figure  62,  the 
majority of respondents believe that significant or crucial benefits have been achieved in most of the 
13 fields listed.  

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Figure 62: Answer to question 25 of the public consultation “To what extent do you consider that the Directive has 
brought the following benefits?”, in absolute numbers of respondents 

25m. Improved licensing and inspection schemes of zoos

408 

224 

284 

683 

698 

25l. Increased offer of cultural and recreational opportunities to
the public

746 

318 

445 

616 

172 

25k.Increased employment in areas where zoos are located

523 

309 

428 

25j. Increased tourism

620 

310 

410 

908 

817 

129 

140 

25i. Ensured a coherent legal framework for zoos to operate
across the EU

414 

183 

243 

744 

713 

25h. Created legal certainty for zoos as businesses

745 

176 

247 

617 

512 

25g. Benefits for conditions under which animals are kept and
standard of animal husbandry

261 

257 

459 

25f. Benefits for higher engagement of the public/stakeholders in
biodiversity protection and other nature protection activities

305 

254 

443 

932 

944 

388 

351 

25e. Benefits for positive changes of behaviour towards
biodiversity protection

296 

257 

581 

942 

221 

25d.Benefits for public education and better knowledge on
biodiversity

286 

217 

450 

25c.Benefits for ex-situ conservation efforts

372 

190 

415 

973 

949 

371 

371 

25b. Benefits for protecting species from extinction

275 

232 

677 

684 

429 

25a. Benefits for overall biodiversity conservation

331 

205 

460 

729 

572 

0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%

No opinion

Not at all

Minor benefits

Significant benefits

Crucial benefits

In almost all cases, 50% or more of the stakeholders considered the benefits achieved as significant or 
crucial. Exceptions are benefits in terms of: 

 

 

Increased offer of cultural and recreational opportunities (point 25l); 
Increased tourism (point 25j); 
Increased employment in areas where zoos are located (point 25k);  

 
  Benefits for protecting species from extinction (point 25b). 

In all these cases, a high number of stakeholders have not provided an answer, while less than 50% of 
the respondents have rated these benefits as crucial or significant.  

At the other hand of the spectrum, there seem to be a large agreement among stakeholders on the abil-
ity  of  the  Zoos  Directive  to:  ensure  a  coherent  legal  framework  for  zoos  to  operate  across  the  EU 
(point  25i);  ensure  improved  licensing  and  inspection  schemes  of  zoos  (25m);  and  promote  public 
education  and  better  knowledge  on  biodiversity  (point  25d).  The  benefits  in  these  fields  have  been 
rated as significant or crucial by 63% to 59% of the respondents.  

Table 65 reports a simplified presentation of the data mentioned above and fully presented in  Figure 
62. For each category of benefit, it shows the share of stakeholders having not provided an opinion, 
and the share of stakeholders having rated the different benefits as poorly (i.e. “No or minor benefits”) 
or fully achieved (i.e. “Significant or crucial benefits”). The categories of benefits at the ends of spec-
trum are highlighted.  

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Table 65: Answer to question 25 of the public consultation “To what extent do you consider that the Directive has 
brought the following benefits?” (% on total respondents) 

No opinion  No or mi-
nor bene-
fits 

Significant 
or crucial 
benefits 

Significant or crucial benefits ≥ 50% of total respondents 

25i. Ensured a coherent legal framework for zoos to operate 
across the EU 
25m. Improved licensing and inspection schemes of zoos 

25d.Benefits for public education and better knowledge on 
biodiversity 
25a. Benefits for overall biodiversity conservation 

25g. Benefits for conditions under which animals are kept and 
standard of animal husbandry 
25c.Benefits for ex-situ conservation efforts 

25f. Benefits for higher engagement of the public/stakeholders 
in biodiversity protection and other nature protection activities 
25e. Benefits for positive changes of behaviour towards biodi-
versity protection 
Significant or crucial benefits < 50% of total respondents 

25h. Created legal certainty for zoos as businesses 

25b. Benefits for protecting species from extinction 

25k.Increased employment in areas where zoos are located 

25j. Increased tourism 

25l. Increased offer of cultural and recreational opportunities 
to the public 

18.0% 

18% 

12.5% 

14.4% 

11.4% 

16.2% 

13.3% 

12.9% 

32.4% 

12.0% 

22.8% 

27.0% 

32.5% 

19% 

22% 

29% 

29% 

31% 

26% 

30% 

36% 

18% 

40% 

32% 

31% 

33% 

63% 

60% 

59% 

57% 

57% 

57% 

56% 

51% 

49% 

48% 

45% 

42% 

34% 

In general terms, this data suggests how the Zoos Directive has produced marginal benefits on zoos as 
economic operators but also for boosting economic activities around them. Instead, the most notable 
benefits appear to be related to the creation of a common legal framework across the EU, improved 
systems for licensing and inspections (missing in most of the Member States before the entering into 
force of the Zoos Directive), and better knowledge on biodiversity among the public.  

In addition, 443 stakeholders provided input on “Other benefits” in the form of open comments (ques-
tion 26). Most of the comments are repeated several times, indicating that these were likely influenced 
by guidance from interest groups.  

In Table 66 below, we report the repeated comments identified, and information on their frequency, 
languages  used,  main  categories  of  stakeholders  having  used  those  repeated  comments  and  their 
Member State of origin. However, two elements make it difficult to establish the exact number of re-
peated comments influenced by interest groups:  

 

 

firstly,  while  in  some  cases,  these  comments  are  repeated  in  exactly  the  same  words,  in  other 
cases, variations can be observed;  
secondly,  repeated  comments  appear  in  different  languages,  making  an  exact  comparison  more 
difficult.  

Therefore, Table 66 represents our best estimate, while we are aware that a margin of error exists. 

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Table 66: Analysis of the open comments to question 26 of the public consultation (“To what extent do you consider 
that the Directive has brought the following benefits? – If Other, please specify”) and identification of repeated com-
ments  

Comment 
1) Recognising that each animal species has specific 
welfare needs, regardless of location, EU-wide, scien-
tifically-validated  animal  husbandry  standards  will 
ensure  animals  are  appropriately  kept  in  zoos  (rec-
ommended answer by Born Free and Animal Public – 
in German).  
2) Harmonisation and standardization on EU level. An 
EU legislative act is necessary to help raising the pub-
lic role of zoos and to contribute efficiently and signif-
icantly to biodiversity conservation 
3)  The  EU  Directive  supports  the  public  perception 
and  role  of  zoos  in  nature  conservation  and  species 
protection 
4) Establishing stricter rules for animal welfare 
5)  A  European  law  is  needed  to  promote  the  public 
role  of  zoos  and  contribute  to  the  preservation  of 
biodiversity  

6) Establishing animal husbandry standards  

TOTAL  

Number 
100  

Percentage 
22.6% 

83  

79  

20  
to 
14  (not  possible 
establish  whether  all 
are 
repeated  com-
ments) 
to 
67  (not  possible 
establish  whether  all 
are 
repeated  com-
ments) 
363 

18.7% 

17.8% 

4.5% 
3.2%rs. 

15.1%. 

81.9% 

Overall, according to the estimate presented in the table above, 363 are repeated comments, account-
ing for approximately 82% of all open comments to question 26.  

Regardless the influence of interest groups, the comments on benefits brought by the Zoos Directive 
point to the ability of the Directive to the promote harmonization at EU level and help raise: standards 
for animal keeping (point 1 in the table above); the role and public perception of zoos as entities con-
tributing to biodiversity conservation and protection of species (points 2, 3 and 5). 

Moreover,  and  importantly,  a  high  number  of  stakeholders  have  pointed  out  the  importance  of  the 
Zoos Directive for the establishment of animal husbandry standards (points 1 and 6) and introducing 
stricter rules for animal welfare (point 5).  

Although  the  primary  objective  of  the  Zoos  Directive  is  related  to  conservation  of  biodiversity  and 
animal welfare is outside the scope of the intervention, one of the main benefits of the Zoos Directive, 
as perceived by stakeholders, has been the improvement of husbandry standards and its contribution to 
welfare of animals in zoos, currently not covered by other animal welfare legislation.502 

Regarding the remaining  74 comments, the analysis aimed  at identifying  the range of statements by 
going through all the comments, in order to identify a range of key categories and determine which 
statements appeared most frequently. 

The following categories have been identified: 

 

Firstly,  a  set  of  comments,  not  classified  as  “repeated  comments”  originating  from  campaigns, 

502 Article 3, third indent, of the Zoos Directive requires zoos to accommodate animals under conditions which “aim to satisfy the biological 
and conservation requirements of the individual species” and to maintain “maintaining a high standard of animal husbandry”. In line with the 
general aim of the Zoos Directive, this provision is intended to pursue conservation objectives. 

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points to benefits related to: 

 

 

 

harmonization  at  the  EU  level,  favouring  both  the  establishment  of  standards  for  animal 
keeping,  and  a  framework  for  conservation,  research  and  public  engagement  by  zoos  (10 
comments); 
 
the establishment of standards for keeping animals in European Zoos (19 comments).  
Secondly, recurrent comments revealing a negative opinion and pointing to issues, rather than to 
benefits achieved. These comments can be divided in two categories: 
  Comments claiming the lack of proper enforcement of the Zoos Directive, which translates 
into poor conditions for animal kept in zoos and calls for a better monitoring of the rules and 
application of sanctions (7 comments).  Specific examples (of Member States failing to en-
force the legislation or Zoos) have been also mentioned in two comments.  

  Comments  expressing  a  more  general  and  negative  position  against  zoos  as  such.  These 
comments (29) points to the bad conditions in which animals are kept in zoos, or support the 
view that animals should live in their natural environment and, therefore, do not recognize 
the conservation role of zoos. These comments mainly come from individuals. 

Finally, some specific (not recurrent) comments have been encountered. Among these, two com-
ments have highlighted the following benefits:  
 
Promoting adequate tracking of animal data within the EU Zoos and help transparency; 
  The  establishment  of  a  legislation  on  zoos  provides  the  possibility  for  animal  activists  to 

challenge poor animal welfare and request for remedies against breaches of the rules.  

5.1.2  Distribution per type of stakeholders 

Table  67  below  provides  an  overview  of  the  opinion  of  the  different  stakeholder  categories  on  the 
benefits achieved by the Zoos Directive. 

In  order  to  provide  a  synthetic  overview,  the  table  presents,  per  each  type  of  stakeholder,  only  the 
share of respondents who flagged the reply options “Significant Benefits” or “Crucial Benefits”. Per-
centages  are  calculated  on  the  number  of  respondents  that  expressed  an  opinion  (i.e.  excluding  the 
respondents that flagged “No opinion”). A complete overview is presented in Annex I.  

Table 67: Answer to question 25 of the public consultation “To what extent do you consider that the Directive has 
brought the following benefits?” - Share of respondents who flagged the reply options “Significant Benefits” or “Cru-
cial Benefits”, per type of stakeholder. Percentages and, in brackets, absolute number of total respondents per stake-
holder excluding “No opinion” 

Type of stakeholder 

Business 

Public 
authority 

Individual 

NGO 

Other 
organ-
isation 

Zoo 
operator 

Other 

25a. Benefits for 
overall biodiversity 
conservation 
25b. Benefits for 
protecting species 
from extinction 
25c. Benefits for ex-
situ conservation 
efforts 
25d. Benefits for 
public education 
and better 
knowledge on bio-
diversity 
25e. Benefits for 

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61% 
(n=18) 

56% 
(n=18) 

76% 
(n=17) 

83% 
(n=6) 

71% 
(n=7) 

71% 
(n=7) 

65% 
(n=1658) 

58% 
(n=33) 

61% 
(n=28) 

84% 
(n=135) 

64% 
(n=88) 

53% 
(n=1709) 

38% 
(n=32) 

55% 
(n=29) 

80% 
(n=133) 

62% 
(n=94) 

67% 
(n=1613) 

80% 
(n=30) 

72% 
(n=29) 

85% 
(n=136) 

69% 
(n=93) 

78% 
(n=18) 
59% 

86% 
(n=7) 
71% 

65% 
(n=1696) 
58% 

64% 
(n=33) 
67% 

69% 
(n=29) 
66% 

85% 
(n=137) 
57% 

67% 
(n=91) 
57% 

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positive changes of 
behaviour towards 
biodiversity protec-
tion 
25f. Benefits for 
higher engagement 
of the pub-
lic/stakeholders in 
biodiversity protec-
tion and other na-
ture protection ac-
tivities 
25g. Benefits for 
conditions under 
which animals are 
kept and standard 
of animal husband-
ry 
25h. Created legal 
certainty for zoos as 
businesses 
25i. Ensured a co-
herent legal frame-
work for zoos to 
operate across the 
EU 
25j. Increased tour-
ism 
25k. Increased em-
ployment in areas 
where zoos are 
located 
25l. Increased offer 
of cultural and rec-
reational opportuni-
ties to the public 
25m. Improved 
licensing and in-
spection schemes 
of zoos 

(n=17) 

(n=7) 

(n=1688) 

(n=33) 

(n=29) 

(n=135) 

(n=92) 

71% 
(n=17) 

71% 
(n=7) 

64% 
(n=1679) 

64% 
(n=33) 

68% 
(n=28) 

76% 
(n=137) 

65% 
(n=91) 

59% 
(n=17) 

76% 
(n=17) 

100% 
(n=7) 

100% 
(n=7) 

63% 
(n=1719) 

72% 
(n=32) 

72% 
(n=29) 

76% 
(n=136) 

68% 
(n=96) 

71% 
(n=1269) 

91% 
(n=22) 

77% 
(n=26) 

86% 
(n=133) 

73% 
(n=78) 

83% 
(n=18) 
56% 
(n=16) 

100% 
(n=7) 
100% 
(n=5) 

76% 
(n=1572) 
58% 
(n=1425) 

84% 
(n=31) 
63% 
(n=24) 

89% 
(n=28) 
65% 
(n=26) 

90% 
(n=137) 
51% 
(n=110) 

74% 
(n=90) 
48% 
(n=71) 

65% 
(n=17) 

67% 
(n=6) 

58% 
(n=1496) 

50% 
(n=26) 

68% 
(n=25) 

61% 
(n=131) 

51% 
(n=73) 

50% 
(n=16) 

67% 
(n=6) 

50% 
(n=1292) 

47% 
(n=19) 

54% 
(n=24) 

55% 
(n=121) 

52% 
(n=73) 

72% 
(n=18) 

100% 
(n=7) 

71% 
(n=1587) 

89% 
(n=28) 

82% 
(n=28) 

89% 
(n=137) 

73% 
(n=84) 

Looking  at  the  general  results,  the  benefits  stemming  from  the  establishment  of  a  coherent  legal 
framework (point 25i) rank high among all the stakeholder groups. In particular, for businesses, indi-
viduals,  zoo  operators  and  other  organisations  and  stakeholders503,  the  creation  of  a  coherent  legal 
framework is considered as the most important benefit achieved.  

Looking at the results across different stakeholder categories, it is interesting to note how only a slight 
majority of zoo operators and businesses perceive the benefits of the Zoos Directive on the economic 
dimension (i.e. in terms of increased employment, tourism, cultural and recreational opportunities to 
the public, respectively points 25.k, 25j and 25.l). The share of businesses and zoos operators perceiv-
ing significant or crucial benefits in these fields ranges between 51% and 65%. These shares are the 
lowest ones, if the replies provided by businesses and zoo operators in relation to other categories of 
benefits are considered. In parallel, NGOs appear to consider the benefits of cultural and recreational 
opportunities to the public (point 25l.) and in terms of improved licensing and inspection schemes of 

503 The stakeholder category “Other” includes academics/scientists, animal welfare activists, zoo/aquarium workers, other people working 
with animals.  

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zoos (point 25m) as particularly significant. 

5.1.3  Distribution per country 

Table  68  below  shows  the  distribution  of  the  replies  per  each  field  of  benefits  and  by  geographical 
distribution  of  the  respondents  (Member  States/non-EU  country).  As  in  the  Section  above,  the  table 
presents only the share of respondents who flagged the reply options “Significant Benefits” or “Cru-
cial Benefits”. A complete overview is presented in Annex I.  

Due to the differences in the size of the sample per each Member State, divergences emerge. However, 
focusing  on  Member  States  with  the  highest  number  of  respondents  (Germany,  the  Netherlands, 
France, Spain and United Kingdom), the benefits in terms “Coherent legal framework for zoos to op-
erate across the EU” (25i) are perceived as significant or crucial by the highest shares of respondents 
across the three countries.  

Moreover, as compared to Germany and the Netherlands, a lower share of respondents from the UK, 
France and Spain tend to attribute significant or crucial benefits across all the categories of benefits.  
In general terms, results confirm the trends noticed across other questions of the public consultation: 
while respondents from some counties (such as Czech Republic, Germany, the Netherlands and Portu-
gal) tend to provide a positive opinion on the results achieved with the Zoos Directive, other countries 
(such as Belgium, France and Spain) share a more negative view on its achievements. 

In this case, a more negative view appears to prevail also among respondents from non-EU countries. 
The share of respondents from non-EU countries rating the different benefits as significant or crucial 
is on average lower. However, a higher tendency not to provide an opinion among respondents outside 
the EU (see detailed tables in Annex I) should also be mentioned.  

Milieu Ltd  
Brussels  

Evaluation Study to support the evaluation of the Zoos Directive 
Annexes to Final Report – August 2017/ 601 

 
 
 
 
 
 
 
 
Table 68: Answer to question 25 of the public consultation “To what extent do you consider that the Directive has brought the following benefits?” - Share of respondents who flagged 
the reply options “Significant Benefits” or “Crucial Benefits”, per Member State/non-EU Country. Percentages and, in brackets, absolute number of total respondents per Member 
State excluding “No opinion” 

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86% 
(n=21) 
45% 
(n=40) 

73% 
(n=22) 
51% 
(n=41) 

81% 
(n=21) 
49% 
(n=37) 

82% 
(n=22) 
47% 
(n=38) 

82% 
(n=22) 
47% 
(n=38) 

71% 
(n=21) 
44% 
(n=39) 

77% 
(n=22) 
53% 
(n=40) 

83% 
(n=18) 
65% 
(n=31) 

90% 
(n=20) 
63% 
(n=35) 

79% 
(n=19) 
31% 
(n=35) 

79% 
(n=19) 
33% 
(n=30) 

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75% 
(n=20) 
40% 
(n=30) 

n
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84% 
(n=19) 
58% 
(n=33) 

0% (n=2) 

0% (n=2) 

0% (n=2) 

0% (n=2) 

0% (n=2) 

50% (n=2) 

0% (n=2) 

0% (n=1) 

0% (n=2) 

0% (n=2) 

0% (n=2) 

0% (n=2) 

0% (n=2) 

0% (n=0) 
92% 
(n=12) 
72% 
(n=32) 
100% 
(n=1) 

43% (n=7) 
52% 
(n=56) 
75% 
(n=697) 
54% 
(n=13) 

0% (n=0) 
75% 
(n=12) 
55% 
(n=33) 

0% (n=1) 

43% (n=7) 
42% 
(n=57) 
66% 
(n=719) 
54% 
(n=13) 

0% (n=0) 
83% 
(n=12) 
66% 
(n=32) 
100% 
(n=1) 

33% (n=6) 
50% 
(n=56) 
78% 
(n=675) 
67% 
(n=12) 

0% (n=0) 
92% 
(n=12) 
73% 
(n=33) 
100% 
(n=1) 

33% (n=6) 
60% 
(n=58) 
73% 
(n=714) 
62% 
(n=13) 

0% (n=0) 
42% 
(n=12) 
53% 
(n=32) 
100% 
(n=1) 

33% (n=6) 
47% 
(n=57) 
71% 
(n=708) 
62% 
(n=13) 

0% (n=1) 
92% 
(n=12) 
67% 
(n=33) 
100% 
(n=1) 

17% (n=6) 
47% 
(n=55) 
74% 
(n=712) 
62% 
(n=13) 

0% (n=1) 
50% 
(n=12) 
56% 
(n=34) 
100% 
(n=1) 

29% (n=7) 
44% 
(n=61) 
80% 
(n=724) 
69% 
(n=13) 

0% (n=0) 
100% 
(n=10) 
73% 
(n=30) 

0% (n=0) 

67% (n=6) 
62% 
(n=42) 
83% 
(n=582) 
73% 
(n=11) 

Hungary 

80% (n=5) 

50% (n=6) 

80% (n=5) 

80% (n=5) 

60% (n=5) 

80% (n=5) 

75% (n=4) 

67% (n=3) 

Milieu Ltd  
Brussels  

0% (n=0) 
92% 
(n=12) 
71% 
(n=34) 
100% 
(n=1) 

67% (n=6) 
67% 
(n=55) 
86% 
(n=659) 
77% 
(n=13) 
100% 
(n=6) 

0% (n=0) 

44% (n=9) 
41% 
(n=27) 
100% 
(n=1) 

33% (n=6) 
49% 
(n=47) 
65% 
(n=660) 
50% 
(n=10) 

0% (n=0) 
58% 
(n=12) 
43% 
(n=30) 
100% 
(n=1) 

29% (n=7) 
49% 
(n=49) 
65% 
(n=651) 
67% 
(n=12) 

50% (n=4) 

80% (n=5) 

0% (n=0) 

29% (n=7) 
38% 
(n=24) 

0% (n=0) 

14% (n=7) 
36% 
(n=45) 
66% 
(n=629) 
60% 
(n=10) 
100% 
(n=1) 

0% (n=0) 
83% 
(n=12) 
70% 
(n=30) 
100% 
(n=1) 

40% (n=5) 
68% 
(n=50) 
80% 
(n=670) 
77% 
(n=13) 
100% 
(n=5) 

Evaluation Study to support the evaluation of the Zoos Directive 
Annexes to Final Report – August 2017/ 602 

MS 

Re-

Austria 

Belgium 

Bulgaria 

Croatia 
Czech 
public 

Denmark 

Estonia 

Finland 

France 

Germany 

Greece 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Ireland 

Italy 

Lithuania 

Luxembourg 

Malta 

Netherlands 

Poland 

Portugal 

Romania 
Slovak 
public 

Slovenia 

Re-

Spain 

Sweden 
United  King-
dom 
Non-EU 
country 

Milieu Ltd  
Brussels  

62% 
(n=13) 
39% 
(n=44) 

40% 
(n=15) 
45% 
(n=47) 

54% 
(n=13) 
56% 
(n=45) 

67% 
(n=15) 
51% 
(n=47) 

53% 
(n=15) 
45% 
(n=47) 

57% 
(n=14) 
48% 
(n=44) 

77% 
(n=13) 
38% 
(n=47) 

67% (n=3) 
100% 
(n=1) 

33% (n=3) 
100% 
(n=1) 

67% (n=3) 
100% 
(n=1) 

67% (n=3) 
100% 
(n=1) 

67% (n=3) 

67% (n=3) 

0% (n=1) 
84% 
(n=112) 
33% 
(n=12) 
79% 
(n=34) 
80% 
(n=15) 
100% 
(n=2) 

0% (n=3) 
50% 
(n=138) 
64% 
(n=25) 
60% 
(n=520) 
64% 
(n=157) 

50% (n=2) 
84% 
(n=113) 
33% 
(n=12) 
71% 
(n=34) 
80% 
(n=15) 
100% 
(n=2) 

0% (n=3) 
29% 
(n=139) 
65% 
(n=26) 
42% 
(n=533) 
53% 
(n=164) 

0% (n=0) 
91% 
(n=111) 
67% 
(n=12) 
85% 
(n=33) 
80% 
(n=15) 
100% 
(n=2) 

0% (n=3) 
53% 
(n=133) 
80% 
(n=25) 
61% 
(n=511) 
63% 
(n=159) 

0% (n=1) 

0% (n=1) 
34% 
(n=113) 
50% 
(n=12) 
49% 
(n=35) 
33% 
(n=15) 

0% (n=1) 
85% 
(n=114) 
75% 
(n=12) 
85% 
(n=34) 
73% 
(n=15) 

50% (n=2) 

50% (n=2) 

0% (n=3) 
47% 
(n=139) 
72% 
(n=25) 
61% 
(n=532) 
65% 
(n=164) 

0% (n=3) 
45% 
(n=139) 
31% 
(n=26) 
54% 
(n=531) 
63% 
(n=162) 

0% (n=1) 
100% 
(n=1) 
85% 
(n=113) 
33% 
(n=12) 
82% 
(n=34) 
75% 
(n=16) 
100% 
(n=2) 

0% (n=3) 
42% 
(n=136) 
69% 
(n=26) 
59% 
(n=525) 
64% 
(n=162) 

64% 
(n=11) 
51% 
(n=41) 

45% 
(n=11) 
36% 
(n=36) 

77% 
(n=13) 
51% 
(n=43) 

64% 
(n=11) 
43% 
(n=35) 
100% 
(n=1) 

0% (n=1) 

50% (n=2) 
92% 
(n=104) 
73% 
(n=11) 
90% 
(n=30) 
73% 
(n=15) 

50% (n=2) 

67% (n=3) 
53% 
(n=95) 
87% 
(n=23) 
58% 
(n=358) 
71% 
(n=127) 

75% 
(n=12) 
65% 
(n=43) 

67% (n=3) 
100% 
(n=1) 

50% (n=2) 
94% 
(n=112) 
90% 
(n=10) 
88% 
(n=34) 
88% 
(n=16) 
100% 
(n=2) 

67% (n=3) 
61% 
(n=124) 
88% 
(n=26) 
69% 
(n=502) 
73% 
(n=150) 

67% (n=3) 
100% 
(n=1) 
100% 
(n=2) 
37% 
(n=113) 
75% 
(n=12) 
51% 
(n=35) 
31% 
(n=16) 
100% 
(n=2) 

0% (n=3) 
47% 
(n=135) 
42% 
(n=26) 
63% 
(n=542) 
65% 
(n=165) 

45% 
(n=11) 
57% 
(n=37) 
100% 
(n=2) 

0% (n=1) 

0% (n=1) 
51% 
(n=55) 

60% (n=5) 
50% 
(n=22) 

38% (n=8) 

67% (n=3) 
100% 
(n=1) 

0% (n=1) 
75% 
(n=106) 
30% 
(n=10) 
76% 
(n=33) 
67% 
(n=15) 

50% (n=2) 

0% (n=1) 

0% (n=1) 
52% 
(n=56) 

17% (n=6) 
50% 
(n=22) 
60% 
(n=10) 

50% (n=2) 

50% (n=2) 

50% (n=2) 

33% (n=3) 
43% 
(n=124) 
57% 
(n=14) 
54% 
(n=440) 
61% 
(n=132) 

33% (n=3) 
35% 
(n=124) 
86% 
(n=21) 
53% 
(n=451) 
61% 
(n=134) 

33% (n=3) 
28% 
(n=100) 
33% 
(n=15) 
35% 
(n=388) 
62% 
(n=123) 

67% (n=3) 
100% 
(n=1) 

50% (n=2) 
88% 
(n=113) 
100% 
(n=8) 
94% 
(n=34) 
80% 
(n=15) 
100% 
(n=2) 

0% (n=3) 
55% 
(n=124) 
83% 
(n=23) 
66% 
(n=509) 
71% 
(n=156) 

Evaluation Study to support the evaluation of the Zoos Directive 
Annexes to Final Report – August 2017/ 603 

 
 
 
5.1.4  Distribution depending on whether the respondent visits zoos or not 

Finally, a comparison is presented between the respondents that declared to visit zoos and respondents 
that do not visit zoos. The Figure below present the share of respondents who flagged the reply op-
tions “Significant Benefits” or “Crucial Benefits”, by distinguishing between respondents visiting zoos 
and respondents not visiting zoos.  

The  data  suggests  a  general  more  positive  opinion  on  the  benefits  achieved  by  the  Zoos  Directive 
among zoo visitors. However, this result is affected by the different size of the two groups considered 
(600 respondents not visiting zoos vs. 1697 respondents visiting zoos), as well as the higher tendency 
of respondents not visiting zoos to flag the “No opinion” option. However, it is of note that respond-
ents not visiting zoos, while expressing a generally negative opinion on the effectiveness of the Zoos 
Directive (see Question 20, Section 4.1.4), have a positive opinion on the benefits brought in the 40% 
of cases (on average).   

Figure 63: Answer to question 25 of the public consultation “To what extent do you consider that the Directive has 
brought the following benefits?” - Share of respondents who flagged the reply options “Significant Benefits” or “Cru-
cial Benefits”, per respondents visiting zoos or not. Percentages are calculated on the number of respondents that 
expressed an opinion (i.e. “No opinion” is excluded) 

100%

90%

80%

70%

60%

50%

40%

30%

20%

10%

0%

25a

25b

25c

25d

25e

25f

25g

25h

25i

25j

25k

25l

25m

I don't visit zoos

I visit zoos

5.1.5  Key points 

  According to the results of the public consultation, the Zoos  Directive has produced  significant 
benefits across different fields and, especially, in terms of: creation of a common legal framework 
across the EU; improved systems for licensing and inspections (missing in most of the Member 
States before the entering into force of the Zoos Directive); promotion of better knowledge on bi-
odiversity among the public. The benefits on economic activities around zoos, i.e. on increased 
employment, tourism, cultural and recreational opportunities for the public appear less relevant. 
This opinion is largely shared also by zoo operators and businesses that have replied to the public 
consultation.  

  Moreover, open comments on “Other benefits” produced by the Zoos Directive place further em-
phasis on some aspects, considered as key achievements: the ability of the Directive to promote 
harmonization at EU level, enhance the role and public perception of zoos as entities contributing 
to  biodiversity  conservation,  and  help  raise  standards  for  animal  keeping.  Concerning  the  last 
point, it is interesting to note that stakeholders have also pointed out the importance of Directive 
in establishing rules for animal welfare, an objective that is not directly pursued by the Zoos Di-
rective (primarily focused on conservation of biodiversity). However, it should be mentioned that 

Milieu Ltd  
Brussels  

Evaluation Study to support the evaluation of the Zoos Directive 
Annexes to Final Report – August 2017/ 604 

 
 
 
 
 
 
a few open comments have also pointed to the lack of proper enforcement of the Zoos Directive, 
with consequences in terms of poor conditions for animal kept in zoos (7 out of 443 comments 
provided), while a number of replies have expressed a more general and negative position against 
zoos as such (29 comments). 

5.2 

IN YOUR VIEW, HOW DO THE COSTS OF IMPLEMENTATION OF THE ZOOS DIRECTIVE 
COMPARE  WITH  THE  BENEFITS  BROUGHT  ABOUT  FROM  THEIR  IMPLEMENTATION 
(QUESTION 27)? 

Question 27 asks the opinion of stakeholders on the balance between costs and benefits brought by the 
Zoos  Directive.  It  is  worth  mentioning  that  the  consultation  document  provided  respondents  with 
background information on the possible additional costs that might have been prompted by the Zoos 
Directive. 

5.2.1  General trends 

Respondents were asked to rate the balance between costs and benefits brought by the Zoos Directive. 
As shown in the Figure below, the majority of respondents support the opinion that benefits exceed 
the costs of implementation by far (1041 respondents or 45.3% of total respondents) or to a certain 
extent (185 respondents or 8.1% of total respondents). Overall, the share of stakeholders stating that 
benefits are higher compared to the costs represent 53.4% of the total respondents to the public consul-
tation. This share increases to 68.8% if only stakeholders that expressed an opinion for this question 
are counted (i.e. 1781 stakeholders, excluding respondents that flagged “No opinion”).  
8.7% of respondents (or 119 stakeholders) expressed a neutral opinion (i.e. that the costs of implemen-
tation are more or less equal to the benefits), while 15.5% of respondents considered the costs as ex-
ceeding the benefits (i.e. 356 stakeholders). 

Figure 64: Answer to question 27 of the public consultation “In your view, how do the costs of implementation of the 
Zoos Directive compare with the benefits brought about from their implementation” in absolute numbers of respond-
ents) 

The benefits far exceed the costs of implementation

1041 

The benefits are somewhat greater than the costs of
implementation

The costs of implementation are more or less equal to
the benefits

The costs of implementation are somewhat greater than
the benefits

The costs of implementation far exceed the benefits

185 

199 

174 

182 

No opinion

516 

0

200

400

600

800

1000

1200

5.2.2  Distribution per type of stakeholder 

The feedback on the costs and benefits of the Zoos Directive does not significantly vary depending on 
the stakeholder category.  

It is interesting to note that the majority of zoos operators (i.e., the category of stakeholders likely to 
be affected by possible additional costs, together with governments) declares that the benefits far ex-
ceed or are somewhat greater than the costs (94 zoo operators out of 148 or 63.5% of total).  

Milieu Ltd  
Brussels  

Evaluation Study to support the evaluation of the Zoos Directive 
Annexes to Final Report – August 2017/ 605 

 
 
 
 
 
 
 
 
 
Regarding  public  authorities  (expected  to  bear  costs  for  the  implementation  and  running  of  the  li-
censing and inspection system), four respondents (out of seven) state that benefits far exceed the costs. 
However, the size of the sample does not enable generalisation.  

The  remaining  stakeholder  categories  (although  not  expected  to  be  directly  affected  by  increased 
costs) share the view that the benefits are greater than the costs, or that the balance between benefits 
and costs is neutral.  

In particular, looking at the replies provided by individuals (the most represented group of respond-
ents), 52.7% of them (or 1,024) think that benefits are greater than costs, and 8.8% (or 171) think that 
there is balance between the two elements. Overall, considering that a high number of individuals did 
not provide an answer, only 15.2% of the respondents belonging to this category (or 296) expressed a 
negative opinion on the balance between costs and benefits.  

Figure 65: Answer to question 27 of the public consultation “In your view, how do the costs of implementation of the 
Zoos Directive compare with the benefits brought about from their implementation”, in absolute numbers of re-

Zoo operator

18 

9 

15 

12 

24 

Other (please specify below)

26 

5 

8 

9 

12 

Organisation or association (other than NGO)

Non-governmental organisation

6 

8 

5 

3 

3 

4 

1 

7 

2 

2 

Individual (e.g. zoo visitor)

453 

160 

136 

171 

141 

70 

45 

13 

18 

883 

4 

Government or public authority

2 

Business or business representative

3 

2 

1 

5 

1 

2 

8 

0%

10%

20%

30%

40%

50%

60%

70%

80%

90% 100%

No opinion

The costs of implementation far exceed the benefits

The costs of implementation are somewhat greater than the benefits

The costs of implementation are more or less equal to the benefits

The benefits are somewhat greater than the costs of implementation

The benefits far exceed the costs of implementation

spondents, per type of stakeholder 

5.2.3  Distribution per country  

Looking at the geographical distribution of the respondents (across the Member States and in non-EU 
countries), the opinion that “benefits far exceed the costs of implementation” is the most frequent op-
tion among respondents from non-EU countries and across most of the Member States.  

This result is confirmed in Member States represented in a large number of responses, such as: Ger-
many, where 48% of the 796 respondents stated that benefits far exceed costs; the United Kingdom, 
with 42% of 612 respondents; and The Netherlands, with 58% of 118 respondents. The only exception 
is Slovenia, where respondents appear to support the option that costs far exceed benefits; however, 
this Member State is represented by only three respondents, which share a general less positive feed-
back on the benefits achieved with the implementation of the Directive (see also Section 5.1.3 above). 

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Table 69: Answer to question 27 of the public consultation “In your view, how do the costs of implementation of the 
Zoos Directive compare with the benefits brought about from their implementation” (% and absolute numbers of 
respondents), per Member State/Non-EU country 

Member 
State 

No opinion 

The bene-
fits far 
exceed 
the costs 
of imple-
mentation 

The costs 
of imple-
mentation 
are more 
or less 
equal to 
the bene-
fits 

The costs 
of imple-
mentation 
are 
somewhat 
greater 
than the 
benefits 

The costs 
of imple-
mentation 
far ex-
ceed the 
benefits 

Total 
number 
of re-
spond-
ents 

The bene-
fits are 
somewhat 
greater 
than the 
costs of 
imple-
mentation 
4% 
7% 
33% 
0% 
0% 
18% 
0% 
38% 
6% 
5% 
0% 
0% 
13% 
6% 
0% 
0% 
0% 
8% 
15% 
13% 
13% 
0% 
0% 
4% 
16% 
12% 
7% 

60% 
37% 
33% 
0% 
60% 
33% 
100% 
13% 
43% 
48% 
43% 
50% 
50% 
35% 
67% 
100% 
33% 
58% 
62% 
55% 
50% 
50% 
33% 
41% 
39% 
42% 
44% 

Austria 
Belgium 
Bulgaria 
Croatia 
Czech Rep. 
Denmark 
Estonia 
Finland 
France 
Germany 
Greece 
Hungary 
Ireland 
Italy 
Lithuania 
Luxembourg 
Malta 
Netherlands 
Poland 
Portugal 
Romania 
Slovakia 
Slovenia 
Spain 
Sweden 
UK 
Non-EU 
country 
Total 

12% 
42% 
0% 
100% 
20% 
31% 
0% 
13% 
25% 
19% 
14% 
33% 
6% 
18% 
0% 
0% 
33% 
17% 
23% 
18% 
19% 
50% 
0% 
35% 
32% 
23% 
26% 

8% 
2% 
33% 
0% 
7% 
10% 
0% 
13% 
6% 
9% 
21% 
0% 
25% 
8% 
0% 
0% 
33% 
3% 
0% 
0% 
0% 
0% 
0% 
8% 
6% 
9% 
12% 

9% 

8% 
5% 
0% 
0% 
0% 
5% 
0% 
13% 
7% 
12% 
7% 
17% 
6% 
8% 
0% 
0% 
0% 
4% 
0% 
3% 
6% 
0% 
0% 
4% 
6% 
6% 
5% 

8% 

8% 
7% 
0% 
0% 
13% 
3% 
0% 
13% 
13% 
7% 
14% 
0% 
0% 
25% 
33% 
0% 
0% 
8% 
0% 
11% 
13% 
0% 
67% 
6% 
0% 
8% 
6% 

8% 

25 
43 
3 
1 
15 
39 
1 
8 
68 
796 
14 
6 
16 
51 
3 
1 
3 
118 
13 
38 
16 
2 
3 
157 
31 
612 
214 

2297 

22% 

8% 

45% 

5.2.4  Distribution depending on whether the respondent visits zoos or not 

Finally, respondents that declared to visit zoos for several reasons share the general view that the Di-
rective brought benefits greater than its costs (56.6% or 960 out of 1,697 total respondents). Respond-
ents that declared not to visit zoos show a less positive feedback (44.3% or 266 out of 600 total re-
spondents);  however,  the  sample  of  respondents  not  visiting  zoos  is  significantly  smaller  (600  re-
spondents in total), while the high number of no opinion further affects the result (33.6% of total or 
202).  

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Figure 66: Answer to question 27 of the public consultation “In your view, how do the costs of implementation of the 
Zoos Directive compare with the benefits brought about from their implementation”, in absolute numbers of re-
spondents, per respondents visiting zoos or not 

I visit zoos

314 

154 

806 

149 

147 

127 

I don't visit zoos

202 

31 

235 

50 

27 

55 

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

100%

No opinion

The benefits are somewhat greater than the costs of implementation

The benefits far exceed the costs of implementation

The costs of implementation are more or less equal to the benefits

The costs of implementation are somewhat greater than the benefits

The costs of implementation far exceed the benefits

5.2.5  Key points 

  The  Zoos  Directive  has  likely  implied  additional  costs  related  to  its  implementation,  both  for 
zoos (such as investments and recurrent costs, such as costs for the renovation of the enclosures, 
provision  of  information  on  exhibited  animals,  costs  to  run  research  programs,  training,  aware-
ness raising and educational activities, etc.), and for Member State authorities, requested to set up 
a licensing and inspection system and regularly monitor the implementation of the EU Directive 
(actions,  in  most  of  the  cases,  not  required  by  national  legislation  before  the  application  of  the 
Zoos Directive)504.  
In parallel, stakeholders agree on the fact that the Zoos Directive has brought a range of benefits, 
especially in terms of harmonized and improved animal husbandry, public education on biodiver-
sity, improved behaviour towards biodiversity protection and conservation (see Section 5.1).  
In this context, benefits of the Zoos Directive are thought to be greater than the costs of its im-
plementation.  The  results  of  the  public  consultation  clearly  support  this  perception.  Moreover, 
and interestingly, the large majority of zoo operators, despite being the category likely to be the 
most affected by increasing costs (together with Member State authorities or governments), con-
sider benefits as exceeding the costs. 

 

 

504 The examples of costs mentioned in this paragraph represent assumptions on the likely additional costs, defined on the basis of the provi-
sions of the Zoos Directive and the obligations introduced.  

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6  RELEVANCE 

The public consultation explored, in questions 22 and 23, the perception of stakeholders on the rele-
vance of EU-wide rules on a certain number of matters of biodiversity conservation and zoo manage-
ment currently regulated by the Directive. 

6.1  HOW IMPORTANT DO YOU THINK EU-WIDE RULES ON ZOOS ARE ON THE FOLLOW-

ING MATTERS (QUESTIONS 22 - 23)? 

The public consultation aimed at collecting opinions on the importance and current relevance of cer-
tain  topics  related  to  biodiversity  conservation  and  zoo  management  covered by  the  Zoos  Directive. 
To this end, in question 22, stakeholders have been asked to assess the importance of a series of sub-
jects that were identified in line with the intervention logic of the Directive, namely:  

a.  Protecting Europe's threatened species (point 22a); 
b.  Protecting globally threatened species (point 22b); 
c.  Captive breeding (i.e. breeding of animals outside their natural habitats) of threatened species 

in Europe and globally (point 22c); 

d.  Reintroduction of species into the wild (point 22d); 
e.  Keeping animals under appropriate conditions with good veterinary care (point 22e); 
f.  Making zoos shift from pure exhibition to modern conservation centres, where education, re-

search, captive breeding and reintroduction programmes are undertaken (point 22f); 

g.  Avoiding the escape of animals (point 22g); 
h.  Increasing awareness of the wider public on biodiversity and nature protection by offering ed-

ucation and information on these topics (point 22h); 

i.  Keeping appropriate, shareable data records of the zoo's animals (point 22i). 

The possibility for adding other relevant aspects was also provided, through the field “Other” (ques-
tion 23). 

6.1.1  General trends 

Between 1597 and 2121 of the 2297 respondents (70-92%) think that EU-wide rules are important or 
very important on the points listed in question 22 of the public consultation.  

As illustrated in Figure 66 below, the strongest consensus relates to point e “Keeping animals under 
appropriate conditions with good veterinary care” for which 1943 respondents out of 2297 (85%) con-
sider it very important and 178 (8%) important to have EU-wide rules on the subject.  

The two points for which views are slightly more nuanced are: 

  Captive breeding (i.e. breeding of animals outside their natural habitats) of threatened species in 
Europe and globally: 459 respondents (20%) consider the existence of EU-wide rules as “partly 
important” and 172 (7%) consider it not important. 

  Reintroduction of species into the wild:  361 respondents (16%) consider it partly important and 

111 (5%) consider it not important to have EU-wide rules on the subject. 

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Figure 67: Answers to question 22 of the public consultation “How important do you think EU-wide rules on zoos are 
on the following matters?” in absolute number of respondents 

0%

20%

40%

60%

80%

100%

22a. Protecting Europe's threatened species

101 

134 

487 

22b. Protecting globally threatened species

106 

131 

454 

1536 

1569 

22c. Captive breeding (i.e. breeding of animals outside their natural
habitats) of threatened species in Europe and globally

172 

459 

440 

1157 

22d. Reintroduction of species into the wild

111 

361 

381 

1409 

22e. Keeping animals under appropriate conditions with good
veterinary care

79 

70 

178 

1943 

22f. Making zoos shift from pure exhibition to modern conservation
centres, where education, research, captive breeding and
reintroduction programmes are undertaken

119 

119 

255 

1762 

22g. Avoiding the escape of animals

69 

136 

476 

22h. Increasing awareness of the wider public on biodiversity and
nature protection by offering education and information on these
topics

94 

113 

470 

1525 

1578 

22i. Keeping appropriate, shareable data records of the zoo's
animals

82 

107 

637 

1376 

No opinion

Not important

Partly important

Important

Very important

488 respondents answered to question 23 which allowed them to add other aspects for which the Zoos 
Directive is important. 277 out of those 488 respondents provided answers that appear to follow pre-
made answers by some stakeholders. The two identified patterns suggested the following answers (in 
English or other languages): 

Table 70: Answers provided to Question 23 of the public consultation ‘Please specify other’ – Absolute numbers and 
percentage on the total number of answers to Question 23 (n=488) clearly influenced by public campaigns 

Typical answer 
Encouraging zoos to meet standards and/or to become 
accredited members of a  national or regional zoo asso-
ciation 
Animal  shows  are  adapted  to  animals’  natural  behav-
iour/  Recognising  that  each  animal  species  has  specific 
natural  behaviours,  and  the  public  education  require-
ment on zoos; animals used in shows should only perform 
natural behaviours. 
TOTAL  

Number 
116 

Percentage 
23.7% 

161 

33% 

277 

56.7% 

The remaining 211 answers are listed in Annex II. In a nutshell, these highlight one of the following 
points of view – which constitute statements rather than answers to the public consultation question: 

  Zoos are money-driven business that have entertainment as a priority and are not real conserva-

tion centres, nor educational ones; 

  All zoos should be closed because they do not contribute to biodiversity, only sanctuary and wild-

life reserves should be allowed; 

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  Zoos are backwards institutions mistreating animals; 
  Zoos should better comply with national and European standards. 

6.1.2  Distribution per type of stakeholders  

The majority of respondents in all stakeholder groups considered that EU-wide rules are important or 
very important on all the points listed in question 22 of the public consultation. Figure 68 below illus-
trates  this  support.  As  the  figure  shows,  the  strongest  support  from  stakeholders  who  answered  to 
question 22 of the public consultation was found in relation to the aspects related to the management 
of  zoos,  namely  to  keeping  animals  under  appropriate  conditions  with  good  veterinary  care  (point 
22e);  making  zoos  shift  from  pure  exhibition  to  modern  conservation  centres,  where  education,  re-
search, captive breeding and reintroduction programmes are undertaken (point 22f); avoiding the es-
cape of animals (point 22g); increasing awareness of the wider public on biodiversity and nature pro-
tection  by  offering  education  and  information  on  these  topics  (point  22h);  and  keeping  appropriate, 
shareable data records of the zoo's animals (point 22i).  

Slightly  more  nuanced  views  were  expressed  regarding  the  importance  of  EU-wide  rules  for  wider 
conservation  actions  of  zoos  such  as  protecting  Europe's  threatened  species  (point  22a);  protecting 
globally threatened species (point 22b); captive breeding (i.e. breeding of animals outside their natural 
habitats) of threatened species in Europe and globally (point 22c); and reintroduction of species into 
the  wild  (point  22d).  In  particular,  EU  regulation  on  captive  breeding  was  reported  by  6  out  of  38 
NGOs (16%) as non-important and by 13 out of 38 (34%) as partly important only.  

Figure 68: Answers to question 22 of the public consultation “How important do you think EU-wide rules on zoos are 
on the following matters?” per share of respondents who think that it is important or very important to have EU-wide 
rules on the following matters, per type of stakeholder. Percentages are calculated on the number of respondents that 
expressed an opinion (i.e. “No opinion/don’t know” is excluded). 

100%

90%

80%

70%

60%

50%

40%

30%

20%

10%

0%

22a

22b

22c

22d

22e

22f

22g

22h

22i

Individual (n=1910)

Business (n=21)

Zoo operator (n=147)

Public authority (n=7)

NGO (n=38)

Other organisation (n=33) Other (n=102)

In order to provide a synthetic overview complementary to the figure above, Table 71 below presents, 
per type of stakeholder, the shares of respondents who chose the reply options “Important” or “Very 
important”.  Percentages  are  calculated  on  the  number  of  respondents  that  expressed  an  opinion  (i.e. 
excluding the respondents that opted for “No opinion”). A complete overview is presented in Annex I. 
The highest shares of support are underlined in bold. 

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Table 71: Answers to question 22 of the public consultation “How important do you think EU-wide rules on zoos are 
on the following matters?” (per share of respondents who think that it is important or very important to have EU-
wide rules on the following matters, per type of stakeholder). Percentages are calculated on the number of respond-
ents that expressed an opinion (i.e. “No opinion/don’t know” is excluded). 

22a 

22b 

22c 

22d 

22e 

22f 

22g 

22h 

22i 

Business  

86% 
(n=21) 

Public 
authority  

86% 
(n=7) 

Individual   90% 

(n=1910) 

87% 
(n=38) 

94% 
(n=33) 

NGO  

Other 
organisa-
tion  

Other  

81% 
(n=21) 

71% 
(n=7) 

81% 
(n=21) 

86% 
(n=7) 

90% 
(n=21) 

86% 
(n=7) 

100% 
(n=21) 

100% 
(n=7) 

86% 
(n=21) 

100% 
(n=7) 

85% 
(n=20) 

100% 
(n=7) 

90% 
(n=21) 

100% 
(n=7) 

95% 
(n=20) 

100% 
(n=7) 

89% 
(n=1912) 

69% 
(n=1884) 

78% 
(n=1918) 

93% 
(n=1920) 

89% 
(n=1905) 

90% 
(n=1860) 

90% 
(n=1910) 

91% 
(n=1860) 

84% 
(n=38) 

94% 
(n=33) 

50% 
(n=38) 

88% 
(n=33) 

71% 
(n=38) 

85% 
(n=34) 

100% 
(n=38) 

97% 
(n=34) 

95% 
(n=38) 

94% 
(n=34) 

92% 
(n=37) 

85% 
(n=33) 

92% 
(n=37) 

88% 
(n=33) 

95% 
(n=37) 

94% 
(n=31) 

87% 
(n=102) 

86% 
(n=102) 

81% 
(n=98) 

81% 
(n=98) 

97% 
(n=103) 

90% 
(n=102) 

94% 
(n=101) 

93% 
(n=99) 

97% 
(n=99) 

Zoo  oper-
ator  

92% 
(n=147) 

95% 
(n=147) 

95% 
(n=147) 

88% 
(n=146) 

98% 
(n=147) 

93% 
(n=148) 

93% 
(n=148) 

94% 
(n=148) 

94% 
(n=148) 

As illustrated in Figure 68 and Table 71 above, the stakeholder group that demonstrated the most sup-
port to the existence of EU-wide rules on the topic are zoo operators: 135 out of 147 (92%) consider 
them  important  or  very  important  for  protecting  Europe's  threatened  species  (point  22a);  139  out  of 
147  (95%)  for  protecting  globally  threatened  species  (point  22b);  139  out  of  147  (95%)  for  captive 
breeding (point 22c); 129 out of 146 (88%) for the reintroduction of species into the wild (point 22d); 
144  out  of  147  (98%)  for  keeping  animals  under  appropriate  conditions  with  good  veterinary  care 
(point 22e); 137 out of 148 (93%) for making zoos shift from pure exhibition to modern conservation 
centres (point 22f); 138 out of 148 (93%) for avoiding the escape of animals (point 22g); and 139 out 
of 148 (94%) for increasing awareness of the wider public on biodiversity and nature protection (point 
22g). 

While in majority still supporting the existence and importance of EU-wide rules on these matters, the 
stakeholder group that demonstrated the relatively least support is the group composed of NGOs:  33 
out of 38 (87%) consider them important or very important for protecting Europe's threatened species 
(point 22a); 32  out of  38 (84%)  for  protecting  globally threatened  species  (point  22b); 19 out  of  38 
(50%) for captive breeding (point 22c); 27 out of 38 (71%) for  the reintroduction of species into the 
wild (point 22d); 38 out of 38 (98%) for keeping animals under appropriate conditions with good vet-
erinary  care  (point  22e);  36  out  of  38  (95%)  for  making  zoos  shift  from  pure  exhibition  to  modern 
conservation centres (point 22f); 34 out of 37 (92%) for avoiding the escape of animals (point 22g); 
and 34 out of 37 (92%) for increasing awareness of the wider public on biodiversity and nature protec-
tion (point 22g).  

The existence of EU-wide rules for keeping animals under appropriate conditions with good veterinary 
care  (point  22e)  benefits  from  the  strongest  support  among  all  stakeholder  groups:  between  93  and 
100% of the different stakeholder groups consider it as important or very important. 

The answers from stakeholders are the most mixed with relation to the existence of EU-wide rules on 
captive breeding of species (point 22c), as pointed out in figure 26 below. 

As the figure illustrates, the absolute majority of stakeholders consider such rules as either partly im-
portant  (459  out  of  2228  stakeholders,  i.e.  20%),  important  (440 out  of  2228,  i.e.  20%)  or  very  im-
portant  (1157  out  of  2228,  i.e.  52%).  Only  8%  of  stakeholders  (172  out  of  2228)  reported  that  EU-

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rules on captive breeding were not important, with the highest share among non-governmental organi-
sations (6 out of 38 NGOs, i.e. 15%). 

Figure 69: Answers to question 22 of the public consultation “How important do you think EU-wide rules on zoos are 
on the following matters? c. Captive breeding (i.e. breeding of animals outside their natural habitats) of threatened 
species in Europe and globally” (in absolute number of respondents, per type of stakeholder). Percentages are calcu-
lated on the number of respondents that expressed an opinion (i.e. “No opinion/don’t know” is excluded). 

Zoo operator

2 
1 

6 

22 

117 

Other (please specify below)

7 

Organisation or association (other than NGO)

1 

1 

11 

8 

3 

Non-governmental organisation

6 

21 

13 

13 

4 

Individual (e.g. zoo visitor)

60 

154 

422 

372 

Government or public authority

1 

Business or business representative

1 

3 

3 

5 

58 

16 

15 

936 

3 

12 

0%

10% 20% 30% 40% 50% 60% 70% 80% 90% 100%

No opinion

Not important

Partly important

Important

Very important

The detailed figures and graphs per sub-question and per stakeholder group are available in Annex I. 

6.1.3  Distribution per country 

The figure below presents a synthetic overview of the extent to which stakeholders of each country on 
average think that EU wide-rules are important or very important on all points listed in question 22 of 
the public consultation. According to the averaged answers of respondents, minimum 65% of stake-
holders think that EU-rules are needed in 26 out of 28 Member States.  

Figure 70: Answers to question 22 of the public consultation “How important do you think EU-wide rules on zoos are 
on the following matters?” as averaged shares of respondents who think that it is important or very important to have 
EU-wide  rules  on  the  points  listed  in  question  22,  per  Member  State,  percentages  are  calculated  on  the  number  of 
respondents that expressed an opinion (i.e. “No opinion/don’t know” is excluded). 

100%
90%
80%
70%
60%
50%
40%
30%
20%
10%
0%

Table 72 below summarizes the importance of the points listed in question 22 of the public consulta-

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tion per country of stakeholders. The table presents, per type of stakeholder, the shares of respondents 
who chose the reply options “Important” or “Very important”. Percentages are calculated on the num-
ber of respondents that expressed an opinion (i.e. excluding the respondents that opted for “No opin-
ion”).  A  complete  overview  is  presented  in  Annex  I.  In  italics  are  highlighted  the  lowest  rates  of 
agreement of the public (i.e. activities would not take place at all or unlikely to take place without EU 
rules).  

It appears that the regulation of captive breeding at EU level (point 22c) is considered as one of/ the 
least important matters for regulation in all countries but Poland, the Netherlands, Slovakia and Slove-
nia. Polish and Slovakian stakeholders consider regulation on that matter more important than on an-
other  point,  i.e.  “avoiding  escape  of  animals”  (point  22g).  On  the  contrary,  the  highest  positive  re-
sponse rate among Spanish respondents concerned avoiding escape (considered relevant by 78% of the 
Spanish  respondents).  Dutch  respondents  considered  reintroduction  of  species  into  the  wild  (point 
22d) as the least relevant point (though still considered relevant by 89% of the respondents). Among 
the countries with the highest response rate (the Netherlands, Germany, the United Kingdom) as well 
as among non-EU countries, a significant number of respondents flagged the keeping of animals under 
appropriate conditions as particularly relevant (respectively 99%, 97%, 95% and 95%).   

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Table 72: Answers to question 22 of the public consultation, per share of respondents who think that it is important or very important to have EU-wide rules on the points listed in 
question 22, per Member State). Percentages and, in brackets, absolute number of total respondents per Member State excluding “No opinion” 

MS 
Austria 
Belgium 
Bulgaria 
Croatia 
Czech Rep. 
Denmark 
Estonia 
Finland 
France 
Germany 
Greece 
Hungary 
Ireland 
Italy 
Lithuania 
Luxembourg 
Malta 
Netherlands 
Poland 
Portugal 
Romania 
Slovakia 
Slovenia 
Spain 
Sweden 
UK 
Non-EU  

22a 
100%(n=25) 
90%(n=40) 
67%(n=3) 
0%(n=1) 
100%(n=15) 
86%(n=37) 
100%(n=1) 
50%(n=8) 
79%(n=67) 
94%(n=793) 
93%(n=14) 
100%(n=6) 
88%(n=16) 
94%(n=51) 
67%(n=3) 
100%(n=1) 
100%(n=3) 
96%(n=118) 
75%(n=12) 
95%(n=37) 
88%(n=16) 
100%(n=2) 
33%(n=3) 
67%(n=151) 
93%(n=29) 
89%(n=599) 
90%(n=207) 

22b 
100%(n=25) 
88%(n=40) 
67%(n=3) 
0%(n=1) 
100%(n=15) 
82%(n=38) 
100%(n=1) 
50%(n=8) 
79%(n=67) 
94%(n=793) 
93%(n=14) 
100%(n=6) 
88%(n=16) 
94%(n=48) 
67%(n=3) 
100%(n=1) 
100%(n=3) 
96%(n=118) 
75%(n=12) 
97%(n=36) 
88%(n=16) 
100%(n=2) 
33%(n=3) 
65%(n=152) 
93%(n=29) 
89%(n=603) 
90%(n=207) 

22c 
80%(n=25) 
65%(n=40) 
67%(n=3) 
N/A (n=0) 
80%(n=15) 
77%(n=35) 
0%(n=1) 
50%(n=8) 
61%(n=66) 
79%(n=786) 
71%(n=14) 
50%(n=6) 
63%(n=16) 
78%(n=46) 
67%(n=3) 
100%(n=1) 
100%(n=2) 
96%(n=118) 
92%(n=12) 
81%(n=37) 
75%(n=16) 
100%(n=2) 
33%(n=3) 
50%(n=141) 
80%(n=30) 
63%(n=600) 
70%(n=202) 

22d 
84%(n=25) 
83%(n=40) 
100%(n=3) 
0%(n=1) 
80%(n=15) 
78%(n=37) 
0%(n=1) 
71%(n=7) 
66%(n=68) 
87%(n=795) 
77%(n=13) 
67%(n=6) 
80%(n=15) 
88%(n=48) 
67%(n=3) 
100%(n=1) 
100%(n=2) 
89%(n=117) 
82%(n=11) 
86%(n=37) 
75%(n=16) 
100%(n=2) 
33%(n=3) 
52%(n=153) 
80%(n=30) 
75%(n=604) 
80%(n=209) 

22e 
100%(n=25) 
88%(n=41) 
100%(n=3) 
0%(n=1) 
100%(n=15) 
89%(n=38) 
100%(n=1) 
75%(n=8) 
84%(n=68) 
97%(n=794) 
93%(n=14) 
83%(n=6) 
100%(n=16) 
94%(n=48) 
67%(n=3) 
100%(n=1) 
100%(n=3) 
99%(n=115) 
92%(n=12) 
97%(n=37) 
88%(n=16) 
100%(n=2) 
50%(n=2) 
69%(n=152) 
90%(n=30) 
95%(n=607) 
95%(n=212) 

22f 
92%(n=24) 
83%(n=40) 
100%(n=3) 
N/A (n=0) 
93%(n=15) 
89%(n=38) 
100%(n=1) 
75%(n=8) 
79%(n=67) 
92%(n=786) 
92%(n=13) 
83%(n=6) 
100%(n=16) 
90%(n=48) 
67%(n=3) 
100%(n=1) 
100%(n=3) 
95%(n=115) 
92%(n=12) 
97%(n=37) 
88%(n=16) 
100%(n=2) 
67%(n=3) 
68%(n=151) 
90%(n=30) 
92%(n=606) 
88%(n=211) 

22g 
96%(n=25) 
84%(n=37) 
67%(n=3) 
N/A (n=0) 
93%(n=15) 
81%(n=36) 
100%(n=1) 
71%(n=7) 
87%(n=60) 
91%(n=783) 
83%(n=12) 
83%(n=6) 
100%(n=16) 
98%(n=48) 
100%(n=3) 
N/A (n=0) 
100%(n=3) 
94%(n=114) 
58%(n=12) 
94%(n=36) 
81%(n=16) 
50%(n=2) 
33%(n=3) 
78%(n=142) 
93%(n=28) 
94%(n=593) 
93%(n=205) 

22h 
96%(n=25) 
85%(n=41) 
100%(n=3) 
0%(n=1) 
100%(n=15) 
87%(n=38) 
100%(n=1) 
63%(n=8) 
79%(n=67) 
95%(n=787) 
86%(n=14) 
100%(n=6) 
94%(n=16) 
94%(n=48) 
67%(n=3) 
100%(n=1) 
100%(n=3) 
96%(n=114) 
92%(n=12) 
97%(n=37) 
81%(n=16) 
100%(n=2) 
67%(n=3) 
68%(n=153) 
93%(n=30) 
92%(n=602) 
90%(n=209) 

22i 
92%(n=24) 
76%(n=38) 
100%(n=3) 
N/A (n=0) 
93%(n=15) 
97%(n=35) 
100%(n=1) 
83%(n=6) 
82%(n=65) 
93%(n=777) 
86%(n=14) 
100%(n=5) 
100%(n=16) 
91%(n=45) 
100%(n=3) 
0%(n=1) 
100%(n=3) 
95%(n=116) 
92%(n=12) 
92%(n=37) 
81%(n=16) 
100%(n=2) 
0%(n=3) 
75%(n=139) 
89%(n=28) 
94%(n=595) 
93%(n=203) 

The detailed figures and graphs per sub-question and per stakeholder group are available in Annex I. 

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6.1.4  Distribution depending on whether the respondent visits zoos or not 

Respondents  who  do  not  visit  zoos  are  systematically  less  inclined  to  think  that  EU-wide  rules  are 
needed on all points listed in question 22 of the public consultation, as illustrated in Figure 71 below. 
The difference between those groups of stakeholders is the greatest regarding the regulation of captive 
breeding at EU level. However, it should be noted that for this question, there is only a small differ-
ence between the two stakeholder groups. Also the vast majority of respondents not visiting zoos re-
gard EU-wide rules as important or very important.  

Figure 71: Answers to question 22 of the public consultation “How important do you think EU-wide rules on zoos are 
on the following matters?” per share of respondents who think that it is important or very important to have EU-wide 
rules on the points listed in question 22, depending on whether respondents visit zoos or not (question 18 of the public 
consultation). Percentages are calculated on the number of respondents that expressed an opinion (i.e. “No opin-
ion/don’t know” is excluded). 

100%

80%

60%

40%

20%

0%

22a

22b

22c

22d

22e

22f

22g

22h

22i

22j

I don't visit zoos

I visit zoos

The figure below provides further details regarding the assessment of stakeholders on the importance 
of EU-wide rules on the captive breeding of species. 1356 out of 1672 respondents (83%) who visit 
zoos and have an opinion on the question consider the matter important or very important. In contrast, 
69% of respondents (404 out of 582) who do not visit zoos and have an opinion on the matter share 
that perspective.  

Figure 72: Answers to question 22 of the public consultation “How important do you think EU-wide rules on zoos are 
on the following matters? c.  Captive breeding (i.e. breeding of animals outside their natural habitats) of threatened 
species in Europe and globally” per share of respondents who think that it is important or very important to have EU-
wide rules on the points listed in question 22, depending on whether respondents visit zoos or not (question 18 of the 
public consultation) 

22c. Captive breeding (i.e. breeding of animals outside their natural habitats) of 
threatened species in Europe and globally  

I visit zoos

25 

58 

258 

355 

1001 

I don't visit zoos

44 

114 

201 

85 

156 

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

100%

No opinion

Not important

Partly important

Important

Very important

The detailed figures and graphs per sub-question and per stakeholder group are available in Annex I. 

6.1.5  Key points 

  Between  1597  and  2121  of  the  2297  respondents  (70-92%)  think  that  EU-wide  rules  are  im-

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 

portant or very important on all the points listed in question 22 of the public consultation.  
  The  strongest  consensus  relates  to  point  e  “Keeping  animals  under  appropriate  conditions 
with  good  veterinary  care”  for  which  1943 out  of  2297  (85%)  consider  it  very  important  and 
178 (8%) important to have EU-wide rules on the subject. 
Slightly more nuanced views concern  captive breeding (i.e. breeding of animals outside their 
natural habitats) of threatened species in Europe and globally; and reintroduction of species into 
the wild. On the first point (i.e. captive breeding), 459 out of 2297 respondents (20%) consider 
the existence of EU-wide rules as “partly important” and 172 (7%) consider it not important. Re-
garding the second point (i.e. reintroduction of species into the wild), 361 out of 2297 respond-
ents (16%) consider it partly important and 111 (5%) consider it not important to have EU-wide 
rules on the subject. 

  Break-downs  analysis  shows  that  a  greater  share  of  NGOs  and  respondents  who  do  not  visit 

zoos think that EU-wide rules on captive breeding are partly important or not important. 

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7  COHERENCE 

The public consultation looks at the perception of the public on the positive (synergies) and negative 
(gaps and overlaps) aspects of the articulation between the Zoos Directive and other EU and interna-
tional legal acts or policy documents, in the final questions of the document (questions 28 and 29). In 
addition, it should be mentioned that the answers to question 25 on benefits is also relevant in the con-
text of analysing the level-playing field, covered under the coherence analysis. 

7.1 

IS  THE  ZOOS  DIRECTIVE  CONSISTENT  WITH  AND  MUTUALLY  SUPPORTIVE  OF  THE 
FOLLOWING  LEGAL  AND  NON-LEGAL  INTERVENTIONS  OR  DO  YOU  SEE  SIGNIFI-
CANT GAPS OR OVERLAPS (QUESTIONS 28 – 29)? 

The  public  consultation  aimed  at  collecting  opinions  on  the  interactions  of  the  Zoos  Directive  with 
other acts and documents being implemented in the EU. To this end, in question 28, stakeholders have 
been asked to assess interactions in the implementation of the Zoos Directive and: 

  Two international conventions: the Convention on Biological Diversity (CBD) and the Conven-

 

tion on the International Trade in Endangered Species of wild fauna and flora (CITES); 
Six  EU  legal  acts:  Directive  79/409/EEC  (the  Birds  Directive)  and  Directive  92/43/EEC  (the 
Habitats Directive), Regulation (EC) No. 1143/2014 on Invasive Alien Species (the IAS Regula-
tion), Regulation (EC) No. 1739/2005 on animal health requirements for the movement of circus 
animals between Member States (the Circus animals Regulation),  Directive 92/65/EEC on ani-
mals health requirements governing trade in and imports into the Community of animals, semen, 
ova and embryos not subject to animal health requirements laid down in specific rules referred to 
in  Annex  A(I)  to  Directive  90/425/EEC  (the  Animal  Health  Directive)  and  Directive 
90/425/EEC concerning veterinary and zoo technical checks applicable in intra-Community trade 
in certain live animals and products with a view to the completion of the internal market;     

  Two national-level tools: National species action plans and National animal welfare acts; 
  Three  tools  provided  by  stakeholders:  the  European  Code  of  Conduct  on  zoological  gardens 
and aquaria and invasive alien species from EAZA, the IUCN Technical guidelines for the man-
agement of ex situ populations for conservation and the WAZA World Zoos and Aquarium Con-
servation Strategies.   

The possibility to name additional relevant legal or non-legal interventions was also provided, through 
the field “Other” (Question 29).  

For each of these tools, the respondents were asked whether they observed consistency and/or mutual 
support, gaps or overlaps.  

7.1.1  General trends 

Figure 73 below presents an overview of the responses provided for each of the 12 interventions listed 
in  question  28.    The  ratio  of  respondents  who  did  not  have  an  opinion  on  interactions  between  the 
Zoos Directive and other tools is particularly high. This is understandable, as it requires being familiar 
with the tools listed, which implies a certain level of technical or legal knowledge, whereas the consul-
tation rather targeted the wider public.  

Besides  this  main  result,  other  trends  can  be  observed.  The  respondents  who  expressed  an  opinion 
overall considered that the tools were consistent and/or mutually supportive. The highest proportion 
of respondents considering the tools mutually supportive can be observed in relation to: 

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Stakeholders tools: the WAZA Strategies (44%) and the EAZA Code of Conduct (41%); 

 
  EU Directives: The Animal Health Directive 92/65/EEC (39%) and the Birds and Habitats Direc-

tives (39%), as well as Directive 90/425/EEC on veterinary and zoo technical checks. 

However,  for  some  of  the  tools  listed,  the  proportion  of  respondents  observing  gaps  exceeded  the 
number of respondents observing consistency. It is the case for: 

  The IAS Regulation: 31% of the respondents considered that there was a gap, against 22%  ob-

serving consistency; 

  National species action plans in EU Member States: 27% against 21% 
  National animal welfare acts: 30% against 25%. 

This  ‘negative  ratio’  between  positive  and  negative  answers  indicates  that  the  respondents  have  ob-
served a problem of coherence in the implementation of the Zoos Directive and of these instruments. 
This nevertheless needs to be nuanced in relation to the national species action plans, where the level 
of respondents who did not have an opinion was particularly high (45%). 

In addition, the results show the highest rate of respondents identifying gaps in relation to the CITES 
Convention (15% of the respondents) and in relation to the Circus Animals Regulation (15% as well). 

Finally, only a small proportion of respondents observed  overlaps between the tools mentioned and 
the Zoos Directive. This may be due to the fact that, as pointed out by some stakeholders, the concept 
was unclear to them. 

Figure 73: Answers to question 28 of the public consultation “Is the Zoos Directive consistent with and mutually sup-
portive of the following legal and non-legal interventions or do you see significant gaps or overlaps?” in absolute 
number of respondents 

28l. WAZA World Zoo and Aquarium Conservation Strategies

28j. European code of conduct on zoological gardens and aquaria and
invasive alien species (Council of Europe, Invasive alien Specialist…

28f. Council Directive 92/65/EEC of 13 July 1992

28b.  Birds Directive, 1979 (Council Directive 79/409/EEC) and Habitats
Directive, 1992 (Council Directive 92/43/EEC)

28g.Council Directive 90/425/EEC of 26 June 1990

28c. Convention on international trade in endangered species of wild
flora and fauna (CITES), embraced by Council Regulation No 338/97

28k.IUCN technical guidelines for the management of ex-situ
populations for conservation

28a. Convention on biological Diversity (CBD)/Aichi targets

28e.  Commission regulation No 1739/2005 of 21 October 2005

0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%

38% 

40% 

44% 

45% 

43% 

14% 

14% 

13% 

13% 

15% 

44% 

41% 

39% 

39% 

38% 

5% 

4% 

4% 

4% 

4% 

36% 

16% 

32% 

15% 

42% 

44% 

43% 

23% 

22% 

18% 

30% 

31% 

30% 

5% 

3% 

25% 

15% 

25% 

9% 

28i. National animal welfare acts

36% 

28h.National species action plans in EU Member States

28d.Regulation 1143/2014 on invasive alien species

45% 

42% 

27% 

31% 

21% 

7% 

22% 

5% 

No opinion

Gaps

Consistent and/or Mutually supportive

Overlaps

Question 29 provided the possibility to specify the option ‘other’ provided in question 28m. For a total 

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of 1052 persons selecting the option ‘other’ in question 28m, only 38% provided an opinion. Among 
those,  a  large  majority  of  the  respondents  expressing  an  opinion  referred  to  consistency  and  mutual 
support with other tools. The overview is provided in the Table 73 below. 

Table 73: Answer to Question 28m of the public consultation “Is the Zoos Directive consistent with and mutually 
supportive of the following legal and non-legal interventions or do you see significant gaps or overlaps? ‘Other’” in 
number of respondents, and percentage of respondents to Question 28m. 

Answer 

Number of respondents 

Percentage  of  the  number  of  respondents 
to Question 28m 

No opinion 
Consistent and/or Mutually 
supportive 
Gaps 
Overlaps 
TOTAL 

650 
333 

59 
10 
1052 

62% 
32% 

6% 
1% 
100% 

Among the 402 respondents providing an opinion, 400 specified their answers in question 29. Among 
the replies, certain similarities can be observed in the text of 335 of the answers provided, suggesting 
that these answers were issued from guidance provided by interest groups (see Section 2.3.2.1 above). 
Three different patterns in answers to question 29 have been identified, and are clearly inspired from 
guidance issued by interest groups. The proportion of respondents to question 29 which provided such 
response are summarised below: 

Table 74: Answers provided to Question 29 of the public consultation ‘Please specify other’ – Absolute numbers and 
percentage on the total number of answers to Question 29 (n=400) clearly influenced by public campaigns 

Answer provided (in full or in part) 
“National wild animal husbandry standards” Recognising each species has 
specific welfare needs, scientifically-validated animal husbandry standards 
will ensure animals are kept appropriately in zoos. 
EAZA Standards on Accommodation of animals, Research, Conservation 
and Conservation Education and Best Practice Guidelines (+ BIAZA Animal 
Transfer Policy in 21 occurrences). 
Both, and sometimes one of these two answers:  
1. Providing more EU funding to zoos  
2. No systematic transfer from EU legislation on agriculture or nature protec-
tion to the keeping of animals in zoos.  
TOTAL  

Number 
146 

Percentage  
36,5% 

97 

24.25% 

92 

23% 

 335 

83.75% 

The first two answers support the observation of a mutual support and/or consistency under question 
28m. For the last answer, there is no clear correlation between the answer provided here and one type 
of  answer  under  question 28m,  which  would  tend  to  show  that, as  the  formulation  indicates,  the  re-
spondents intended to use the open field to give a message outside the structure provided by the closed 
questions,  rather  than  to  support  one  specific  observation  of  coherence  with  other  instruments.  The 
other answers to question 29 can be summarised as follows: 

Table 75: Answers to question 29 of the public consultation ‘Please specify other’ – Categories and proportion of 
isolated answers  

Answer provided (in full or in part) 

Animal welfare messages- not directly related to the question 
‘Don't know’/ ‘No’/ ‘No answer’ 
Other answers not related to the question 
Other valid answers (not from campaigns) 
TOTAL  

The four valid answers relate to: 

Number 
31 
21 
9 
4 
65 

Percentage  
7,75 
5,25 
2,25 
1 
16.25% 

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  A gap between the Directive and Article 13 of Title II of the TFEU (one answer); 
  A gap between the Directive and the German Wildlife Association 2016 Certification Handbook 

for the Quality Campaign in Environmental Education 505 (two answers).  

  Consistency with the Convention on Biological Diversity (one answer), which was already cov-

ered under option 28a.  

7.1.2  Distribution per type of stakeholders 

This Section analyses the results of question 28 in relation to gaps and overlaps. For a more complete 
overview, please see Annex I to this report.  

In relation to gaps, Figure 74 shows that gaps were identified by different groups, depending on the 
instrument at stake.  

Figure 74: Answer to question 28 of the public consultation- Share of respondents who think that there are gaps be-
tween the Zoos Directive and the following instruments, per type of stakeholders. Percentages are calculated on the 
number of respondents that expressed an opinion (i.e. “No opinion/don’t know” is excluded). 

100%

90%

80%

70%

60%

50%

40%

30%

20%

10%

0%

28a

28b

28c

28d

28e

28f

28g

28h

28i

28j

28k

28l

Individual

Business

Zoo operator

Public authority

NGO

Other organisation

Other

An  important  proportion  of  NGOs  identified  gaps  in  relation  to  national  species  action  plans  (point 
28h- 76%), national animal welfare acts (point 28i- 68%), as well as in relation to the IUCN guidelines 
(point 28k- 46%). In relation to these guidelines, it is worth mentioning that all groups, but zoo opera-
tors and public authorities, pointed to gaps. 

All stakeholders, except for NGOs, and in particular ‘other’ types of stakeholders (68%), zoo opera-
tors (64%), businesses (53%) and individuals (53%), identified gaps in relation to the IAS Regula-
tion (point 28d). 

Public authorities identified gaps only for five instruments, and only to a limited extent, except for 
the IAS Regulation (43% of responding public authorities). 
Finally, a majority of individuals expressed concerns in relation to gaps between the Zoos  Directive 
and the IAS Regulation (point 28d- 53%), the national plans and welfare acts (points 28h- 52% and 

505 DWV Zertifizierungshandbuch 2016 zur Qualitätsoffensive Umweltbildung 

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28i-  50%).  A  high  proportion  of  individuals  also  mentioned  the IUCN  guidelines  (point  28k-  46%), 
but also, unlike other groups, in relation to the CBD and Aichi Targets (point 28a- 44% of responding 
individuals expressing an opinion).      

As  mentioned  in  the  previous  section,  only  a  limited  proportion  of  the  respondents  raised  issues  in 
relation  to  overlaps  between  the  Zoos  Directive  and  other  instruments,  as  illustrated  by  Figure  75 
below. 

Figure 75: Answer to question 28 of the public consultation- Share of respondents who think that there are overlaps 
between the Zoos Directive and the following instruments, per type of stakeholders. Percentages are calculated on the 
number of respondents that expressed an opinion (i.e. “No opinion/don’t know” is excluded). 

100%

90%

80%

70%

60%

50%

40%

30%

20%

10%

0%

28a

28b

28c

28d

28e

28f

28g

28h

28i

28j

28k

28l

Individual

Business

Zoo operator

Public authority

NGO

Other organisation

Other

It was mainly NGOs identifying overlaps, in relation to CITES and the CITES Regulation (point 28c- 
39% of NGOs expressing an opinion) and to the Circus Animals Regulation (point 28e- 43%). To a 
lesser  extent,  individuals  also  mentioned  overlaps  with  the  same  instruments.  Where  NGOs  men-
tioned  gaps,  ‘others’  and  ‘other  organisations’  observed  overlaps  between  the  Zoos  Directive  and 
national animal welfare acts (point 28i- respectively 25% and 22%). Finally, public authorities indi-
cated  overlaps  mainly  with  the  CBD  and  Aichi  Targets  (point 28a-  17%),  and  with  national  species 
action plans (point 28h- 20%).      

7.1.3  Distribution per country 

As the previous one, this section focuses on the results of question 28 in relation to gaps and overlaps. 
A more complete overview is presented in Annex I.  

In terms of gaps, looking at the countries where most respondents are (Germany, the UK, Spain, the 
Netherlands and non-EU countries) in Table 76, a similar pattern can be observed in Germany and the 
Netherlands, where gaps were identified primarily in relation to the IAS Regulation. This is consistent 
with  the  fact  that  most  respondents  in  these  countries  are  zoos  operators  and  other  organisations.  In 
contrast, respondents in Spain, in the UK and in non-EU countries raised issues primarily relating to 
gaps between the Zoos Directive and national species action plans and national animal welfare acts. 
This correlates with the main type of respondents in these countries, i.e. NGOs and individuals.   

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Table 76: Answer to question 28 of the public consultation- Share of respondents who think that there are gaps between the Zoos Directive and the following instruments. Percentages 
and, in brackets, absolute number of total respondents per Member State excluding “No opinion” 

28a. 
CBD/Aichi 
targets 

28b.   
Birds and 
Habitats 
Directives 

28c.  
CITES and 
Regulation 
No 338/97  

28d. 
IAS Regu-
lation  

28e.  Cir-
cus ani-
mals 
Regulation  

28f. Animal 
health 
Directive  

15%(n=13) 
35%(n=20) 
0%(n=1) 
N/A (n=0) 
22%(n=9) 
44%(n=18) 
0%(n=1) 
50%(n=2) 
53%(n=32) 
31%(n=497
) 
56%(n=9) 
33%(n=3) 
57%(n=7) 
42%(n=24) 
50%(n=2) 
0%(n=1) 
50%(n=2) 
5%(n=83) 
44%(n=9) 
8%(n=26) 
17%(n=12) 

0%(n=1) 
100%(n=1) 
72%(n=75) 
12%(n=17) 
58%(n=322
) 
48%(n=88) 

6%(n=16) 
45%(n=20) 
0%(n=1) 
N/A (n=0) 
0%(n=9) 
25%(n=20) 
0%(n=1) 
67%(n=3) 
38%(n=34) 
17%(n=506
) 
44%(n=9) 
0%(n=3) 
50%(n=8) 
27%(n=22) 
0%(n=2) 
0%(n=1) 
100%(n=1) 
5%(n=82) 
0%(n=10) 
4%(n=26) 
17%(n=12) 

0%(n=1) 
100%(n=1) 
31%(n=68) 
24%(n=17) 
35%(n=320
) 
28%(n=78) 

11%(n=18) 
48%(n=23) 
0%(n=1) 
N/A (n=0) 
0%(n=9) 
22%(n=23) 
0%(n=1) 
25%(n=4) 
36%(n=42) 
16%(n=548
) 
50%(n=10) 
0%(n=3) 
67%(n=9) 
46%(n=26) 
0%(n=2) 
0%(n=1) 
0%(n=1) 
9%(n=94) 
0%(n=11) 
14%(n=29) 
9%(n=11) 

0%(n=1) 
100%(n=1) 
30%(n=77) 
26%(n=19) 
38%(n=391
) 
34%(n=117
) 

60%(n=15) 
47%(n=19) 
0%(n=1) 
N/A (n=0) 
63%(n=8) 
67%(n=21) 
0%(n=1) 
50%(n=2) 
56%(n=36) 
58%(n=515
) 
71%(n=7) 
33%(n=3) 
56%(n=9) 
56%(n=27) 
0%(n=3) 
0%(n=1) 
50%(n=2) 
74%(n=88) 
25%(n=8) 
71%(n=28) 
100%(n=11
) 
0%(n=1) 
100%(n=1) 
39%(n=76) 
88%(n=16) 
45%(n=339
) 
36%(n=90) 

14%(n=14) 
56%(n=18) 
0%(n=2) 
N/A (n=0) 
0%(n=8) 
35%(n=20) 
0%(n=1) 
50%(n=4) 
49%(n=37) 
21%(n=482
) 
50%(n=8) 
25%(n=4) 
75%(n=8) 
52%(n=25) 
0%(n=2) 
0%(n=1) 
50%(n=2) 
10%(n=81) 
13%(n=8) 
15%(n=26) 
18%(n=11) 

0%(n=1) 
100%(n=1) 
36%(n=76) 
29%(n=17) 
43%(n=351
) 
43%(n=93) 

7%(n=15) 
33%(n=18) 
0%(n=1) 
N/A (n=0) 
0%(n=8) 
32%(n=22) 
0%(n=1) 
50%(n=2) 
39%(n=31) 
15%(n=488
) 
50%(n=8) 
0%(n=3) 
38%(n=8) 
30%(n=23) 
0%(n=2) 
0%(n=1) 
0%(n=1) 
6%(n=86) 
0%(n=8) 
11%(n=28) 
18%(n=11) 

0%(n=1) 
100%(n=1) 
34%(n=67) 
19%(n=16) 
34%(n=340
) 
34%(n=90) 

28g. Di-
rective 
90/425/EE
C  

6%(n=16) 
35%(n=17) 
100%(n=1) 
N/A (n=0) 
0%(n=9) 
27%(n=22) 
0%(n=1) 
0%(n=2) 
42%(n=36) 
16%(n=495
) 
43%(n=7) 
33%(n=3) 
44%(n=9) 
38%(n=24) 
50%(n=2) 
0%(n=1) 
0%(n=1) 
5%(n=85) 
0%(n=8) 
21%(n=28) 
25%(n=12) 

0%(n=1) 
100%(n=1) 
36%(n=72) 
19%(n=16) 
39%(n=340
) 
33%(n=93) 

28h. 
National 
species 
action 
plans  
38%(n=16) 
64%(n=22) 
0%(n=1) 
N/A (n=0) 
33%(n=6) 
50%(n=20) 
100%(n=1) 
20%(n=5) 
57%(n=35) 
31%(n=513
) 
71%(n=7) 
100%(n=3) 
83%(n=6) 
65%(n=23) 
100%(n=3) 
0%(n=1) 
0%(n=1) 
8%(n=48) 
75%(n=8) 
73%(n=15) 
40%(n=5) 

0%(n=1) 
100%(n=1) 
72%(n=75) 
38%(n=13) 
74%(n=341
) 
53%(n=95) 

28i. Na-
tional 
animal 
welfare 
acts 
26%(n=19) 
46%(n=26) 
0%(n=1) 
N/A (n=0) 
25%(n=8) 
54%(n=24) 
100%(n=1) 
60%(n=5) 
60%(n=45) 
34%(n=583
) 
44%(n=9) 
67%(n=3) 
50%(n=10) 
62%(n=26) 
67%(n=3) 
0%(n=1) 
0%(n=1) 
6%(n=54) 
75%(n=8) 
50%(n=16) 
33%(n=9) 

0%(n=1) 
67%(n=3) 
81%(n=80) 
28%(n=18) 
62%(n=402
) 
48%(n=108
) 

28j.  
European 
code of 
conduct  

28k. 
IUCN 
technical 
guidelines  

28l.  
WAZA 
Strategies 

6%(n=16) 
32%(n=19) 
0%(n=1) 
N/A (n=0) 
11%(n=9) 
30%(n=23) 
0%(n=1) 
33%(n=3) 
41%(n=37) 
19%(n=535
) 
40%(n=10) 
0%(n=3) 
43%(n=7) 
26%(n=23) 
0%(n=2) 
0%(n=1) 
0%(n=1) 
3%(n=89) 
13%(n=8) 
11%(n=27) 
25%(n=12) 

0%(n=1) 
100%(n=1) 
32%(n=73) 
11%(n=18) 
33%(n=354
) 
26%(n=93) 

8%(n=13) 
32%(n=19) 
100%(n=1) 
N/A (n=0) 
20%(n=10) 
42%(n=24) 
100%(n=1) 
67%(n=3) 
54%(n=35) 
27%(n=505
) 
55%(n=11) 
67%(n=3) 
43%(n=7) 
46%(n=24) 
50%(n=2) 
0%(n=1) 
N/A (n=0) 
3%(n=87) 
0%(n=8) 
19%(n=27) 
18%(n=11) 

0%(n=1) 
100%(n=1) 
72%(n=74) 
17%(n=18) 
59%(n=359
) 
50%(n=92) 

0%(n=16) 
24%(n=21) 
100%(n=1) 
N/A (n=0) 
0%(n=10) 
30%(n=23) 
0%(n=1) 
25%(n=4) 
40%(n=40) 
16%(n=548
) 
50%(n=10) 
0%(n=4) 
29%(n=7) 
27%(n=22) 
0%(n=2) 
0%(n=1) 
0%(n=1) 
4%(n=90) 
14%(n=7) 
7%(n=27) 
17%(n=12) 

0%(n=1) 
100%(n=1) 
34%(n=74) 
10%(n=20) 
33%(n=370
) 
25%(n=114
) 

Evaluation Study to support the evaluation of the Zoos Directive 
Annexes to Final Report – August 2017/ 623 

Austria 
Belgium 
Bulgaria 
Croatia 
Czech Rep. 
Denmark 
Estonia 
Finland 
France 
Germany 

Greece 
Hungary 
Ireland 
Italy 
Lithuania 
Luxembg 
Malta 
Netherlds 
Poland 
Portugal 
Romania 

Slovakia 
Slovenia 
Spain 
Sweden 
UK 

Non-EU  

Milieu Ltd  
Brussels  

 
 
 
 
 
As for overlaps, as can be seen in Table 77 below, in the same countries, CITES (point 28c) and the Circus Animal Regulation (point 28e) are, by far, the 
main instruments considered as overlapping with the Zoos Directive. The only exception is the Netherlands. The number of Dutch respondents identifying 
these two instruments as overlapping with the Directive is very restricted. However, they have considered to an important extent that overlaps were occurring 
with their national species action plans and national welfare acts.    

Table 77: Answer to question 28 of the public consultation- Share of respondents who think that there are overlaps between the Zoos Directive and the following instruments. Per-
centages are calculated on the number of respondents that expressed an opinion (i.e. “No opinion/don’t know” is excluded).  

28a. 
CBD/Aichi 
targets 

28b.   
Birds and 
Habitats 
Directives 

28c.  
CITES and 
Regulation 
No 338/97  

28d. 
IAS Regu-
lation  

28e.  Cir-
cus ani-
mals 
Regulation  

28f. Animal 
health 
Directive  

13%(n=16) 
5%(n=20) 
0%(n=1) 
N/A (n=0) 
11%(n=9) 
0%(n=20) 
0%(n=1) 
0%(n=3) 
6%(n=34) 
9%(n=506) 

0%(n=9) 
0%(n=3) 
0%(n=8) 
5%(n=22) 
0%(n=2) 
0%(n=1) 
0%(n=1) 
6%(n=82) 
10%(n=10) 
8%(n=26) 
0%(n=12) 
0%(n=1) 
0%(n=1) 
12%(n=68) 
0%(n=17) 
4%(n=320) 

33%(n=18) 
13%(n=23) 
0%(n=1) 
N/A (n=0) 
33%(n=9) 
13%(n=23) 
100%(n=1) 
25%(n=4) 
24%(n=42) 
20%(n=548
) 
10%(n=10) 
67%(n=3) 
11%(n=9) 
19%(n=26) 
50%(n=2) 
0%(n=1) 
100%(n=1) 
6%(n=94) 
9%(n=11) 
17%(n=29) 
0%(n=11) 
0%(n=1) 
0%(n=1) 
53%(n=77) 
0%(n=19) 
31%(n=391

13%(n=15) 
5%(n=19) 
0%(n=1) 
N/A (n=0) 
0%(n=8) 
5%(n=21) 
0%(n=1) 
0%(n=2) 
8%(n=36) 
9%(n=515) 

0%(n=7) 
0%(n=3) 
0%(n=9) 
7%(n=27) 
0%(n=3) 
0%(n=1) 
50%(n=2) 
9%(n=88) 
13%(n=8) 
0%(n=28) 
0%(n=11) 
0%(n=1) 
0%(n=1) 
9%(n=76) 
0%(n=16) 
7%(n=339) 

14%(n=14) 
11%(n=18) 
0%(n=2) 
N/A (n=0) 
25%(n=8) 
20%(n=20) 
100%(n=1) 
0%(n=4) 
32%(n=37) 
22%(n=482
) 
13%(n=8) 
50%(n=4) 
25%(n=8) 
20%(n=25) 
50%(n=2) 
0%(n=1) 
50%(n=2) 
6%(n=81) 
13%(n=8) 
15%(n=26) 
0%(n=11) 
0%(n=1) 
0%(n=1) 
51%(n=76) 
0%(n=17) 
33%(n=351

7%(n=15) 
6%(n=18) 
0%(n=1) 
N/A (n=0) 
0%(n=8) 
5%(n=22) 
0%(n=1) 
0%(n=2) 
3%(n=31) 
8%(n=488) 

0%(n=8) 
0%(n=3) 
13%(n=8) 
0%(n=23) 
0%(n=2) 
0%(n=1) 
100%(n=1) 
7%(n=86) 
13%(n=8) 
4%(n=28) 
0%(n=11) 
0%(n=1) 
0%(n=1) 
9%(n=67) 
0%(n=16) 
7%(n=340) 

8%(n=13) 
Austria 
5%(n=20) 
Belgium 
0%(n=1) 
Bulgaria 
Croatia 
N/A (n=0) 
Czech Rep.  11%(n=9) 
0%(n=18) 
Denmark 
0%(n=1) 
Estonia 
0%(n=2) 
Finland 
13%(n=32) 
France 
6%(n=497) 
Germany 

0%(n=9) 
33%(n=3) 
0%(n=7) 
8%(n=24) 
0%(n=2) 
0%(n=1) 
0%(n=2) 
5%(n=83) 
11%(n=9) 
8%(n=26) 
0%(n=12) 
0%(n=1) 
0%(n=1) 
12%(n=75) 
0%(n=17) 
2%(n=322) 

Greece 
Hungary 
Ireland 
Italy 
Lithuania 
Luxembg 
Malta 
Netherlds 
Poland 
Portugal 
Romania 
Slovakia 
Slovenia 
Spain 
Sweden 
UK 

Milieu Ltd  
Brussels  

28g. Di-
rective 
90/425/EE
C  

13%(n=16) 
6%(n=17) 
0%(n=1) 
N/A (n=0) 
11%(n=9) 
5%(n=22) 
0%(n=1) 
0%(n=2) 
6%(n=36) 
8%(n=495) 

0%(n=7) 
0%(n=3) 
11%(n=9) 
0%(n=24) 
0%(n=2) 
0%(n=1) 
100%(n=1) 
6%(n=85) 
13%(n=8) 
0%(n=28) 
0%(n=12) 
0%(n=1) 
0%(n=1) 
11%(n=72) 
0%(n=16) 
5%(n=340) 

28h. 
National 
species 
action 
plans  
6%(n=16) 
9%(n=22) 
0%(n=1) 
N/A (n=0) 
50%(n=6) 
25%(n=20) 
0%(n=1) 
20%(n=5) 
14%(n=35) 
11%(n=513
) 
0%(n=7) 
0%(n=3) 
0%(n=6) 
22%(n=23) 
0%(n=3) 
0%(n=1) 
100%(n=1) 
60%(n=48) 
13%(n=8) 
0%(n=15) 
20%(n=5) 
0%(n=1) 
0%(n=1) 
12%(n=75) 
31%(n=13) 
7%(n=341) 

28i. Na-
tional 
animal 
welfare 
acts 
16%(n=19) 
12%(n=26) 
0%(n=1) 
N/A (n=0) 
38%(n=8) 
25%(n=24) 
0%(n=1) 
20%(n=5) 
9%(n=45) 
12%(n=583
) 
0%(n=9) 
33%(n=3) 
10%(n=10) 
15%(n=26) 
0%(n=3) 
0%(n=1) 
100%(n=1) 
59%(n=54) 
13%(n=8) 
13%(n=16) 
11%(n=9) 
0%(n=1) 
33%(n=3) 
9%(n=80) 
44%(n=18) 
9%(n=402) 

28j.  
European 
code of 
conduct  

28k. 
IUCN 
technical 
guidelines  

28l.  
WAZA 
Strategies 

13%(n=16) 
5%(n=19) 
0%(n=1) 
N/A (n=0) 
0%(n=9) 
4%(n=23) 
0%(n=1) 
0%(n=3) 
11%(n=37) 
8%(n=535) 

0%(n=10) 
0%(n=3) 
0%(n=7) 
0%(n=23) 
0%(n=2) 
0%(n=1) 
100%(n=1) 
10%(n=89) 
13%(n=8) 
0%(n=27) 
0%(n=12) 
0%(n=1) 
0%(n=1) 
8%(n=73) 
0%(n=18) 
6%(n=354) 

15%(n=13) 
11%(n=19) 
0%(n=1) 
N/A (n=0) 
10%(n=10) 
0%(n=24) 
0%(n=1) 
0%(n=3) 
14%(n=35) 
9%(n=505) 

9%(n=11) 
0%(n=3) 
0%(n=7) 
4%(n=24) 
0%(n=2) 
0%(n=1) 
0%(n=0) 
6%(n=87) 
13%(n=8) 
0%(n=27) 
0%(n=11) 
0%(n=1) 
0%(n=1) 
12%(n=74) 
0%(n=18) 
6%(n=359) 

19%(n=16) 
5%(n=21) 
0%(n=1) 
N/A (n=0) 
10%(n=10) 
0%(n=23) 
0%(n=1) 
0%(n=4) 
10%(n=40) 
8%(n=548) 

0%(n=10) 
25%(n=4) 
0%(n=7) 
0%(n=22) 
0%(n=2) 
0%(n=1) 
100%(n=1) 
10%(n=90) 
14%(n=7) 
0%(n=27) 
0%(n=12) 
0%(n=1) 
0%(n=1) 
7%(n=74) 
10%(n=20) 
7%(n=370) 

Evaluation Study to support the evaluation of the Zoos Directive 
Annexes to Final Report – August 2017/ 624 

 
 
 
 
28a. 
CBD/Aichi 
targets 

28b.   
Birds and 
Habitats 
Directives 

28c.  
CITES and 
Regulation 
No 338/97  

28d. 
IAS Regu-
lation  

Non-EU  

9%(n=88) 

12%(n=78) 

) 
26%(n=117
) 

9%(n=90) 

28e.  Cir-
cus ani-
mals 
Regulation  

) 
30%(n=93) 

28f. Animal 
health 
Directive  

28g. Di-
rective 
90/425/EE
C  

28h. 
National 
species 
action 
plans  

28i. Na-
tional 
animal 
welfare 
acts 

28j.  
European 
code of 
conduct  

28k. 
IUCN 
technical 
guidelines  

28l.  
WAZA 
Strategies 

9%(n=90) 

11%(n=93) 

15%(n=95) 

16%(n=108
) 

15%(n=93) 

15%(n=92) 

13%(n=114
) 

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Evaluation Study to support the evaluation of the Zoos Directive 
Annexes to Final Report – August 2017/ 625 

 
 
 
 
 
It is indeed particularly interesting to look at the results of the consultation distributed by country in 
relation to national instruments (i.e. points 28h and i), while keeping in mind the differences in the 
number of respondents by country.  

A majority of respondents identified gaps between the Directive and national instruments in more than 
half of the Member States (Belgium, Denmark, Estonia (one respondent), Finland, France, Greece, 
Hungary, Ireland, Italy, Lithuania, Poland, Portugal, Slovenia, Spain and the UK). A majority of re-
spondents pointed to overlaps between the Directive and their national instruments in far less Member 
States: in the Czech Republic (in relation to the national species action plan), in Malta (three respond-
ents) and in the Netherlands. The rate was also quite high in Sweden.  

Looking  at  the  results  obtained  both  in  terms  of  gaps  and  overlaps  in  relation  to  these  two  points, 
while focusing on countries where it can be considered that the sample is sufficiently high to provide 
some elements of representativeness (n>30), criticism seems to be higher on the consistency between 
national instruments and the Directive in countries like Spain, Italy, Denmark, the UK, France and 
Sweden (on average between 35% and 44% of the respondents pointing to gaps or overlaps in these 
countries).     

7.1.4  Distribution depending on whether the respondent visits zoos or not 

Since coherence is based mainly on a prior knowledge of the legal acts and policy documents listed, 
there is in our view little correlation, if at all, between being a zoo visitor and assessing the application 
of the various texts listed in question 28. The analysis here is therefore of limited relevance.  

One  potentially  interesting  observation  can  however  be  drawn  from  Figure  76  below,  looking  at  re-
spondents  observing  overlaps  between  the  Directive  and  the  various  instruments  listed.  The  figure 
illustrates a significant difference in the rates of zoos visitors and  those who do not visit zoos, with 
much higher rates of respondents pointing to issues among persons who do not visit zoos. Criticism is 
particularly high among non-visitors in relation to the coherence between the Zoos Directive and: 

  National plans (81%) and animal welfare acts (78%) 
  The IUCN guidelines (79%) 
  The CBD and Aichi Targets (78%).  

Figure 76: Answer to question 28 of the public consultation- Share of respondents who think that there are gaps be-
tween the Zoos Directive and the following instruments, depending on whether they visit zoos or not. Percentages are 
calculated on the number of respondents that expressed an opinion (i.e. “No opinion/don’t know” is excluded). 

90%
80%
70%
60%
50%
40%
30%
20%
10%
0%

28a

28b

28c

28d

28e

28f

28g

28h

28i

28j

28k

28l

I don't visit zoos

I visit zoos

All other elements of answers according to this criterion are presented in Annex I.   

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Evaluation Study to support the evaluation of the Zoos Directive 
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7.1.5  Key points 

  Question 28 of the public consultation looks at the perception of the public on synergies, gaps and 
overlaps aspects of the articulation between the Zoos Directive and 12 other EU and international 
legal  acts  or  policy  documents.  Answering  this  question  required  a  prior  knowledge  of  the  in-
struments mentioned. The level of responses expressing an opinion was therefore logically quite 
low (on average, 57% of respondents to question 28 across all sub-questions 28a to 28m).  
In general, the respondents expressing an opinion considered the instruments listed as being con-
sistent or mutually supportive with the Directive. A more significant proportion of people not vis-
iting zoos pointed to gaps (57% on average), as compared to persons visiting zoos (27% on aver-
age).  

 

  On the one hand, the following tools were considered consistent and/or mutually supportive with 

the Directive: 
 

the European Code of Conduct on zoological gardens and aquaria and invasive alien species 
from EAZA and the and the WAZA Strategies;   

  Directive  79/409/EEC  (the  Birds  Directive)  and  Directive  92/43/EEC  (the  Habi-
tats Directive), Directive 92/65/EEC on animals’ health and Directive 90/425/EEC 
concerning veterinary and zoo technical checks.     

  On the other hand, several instruments were pointed as sources of inconsistencies with the Zoos 

Directive. In particular:  
  Regulation (EC) No. 1143/2014 on Invasive Alien Species (the IAS Regulation);  
  Regulation  (EC)  No.  1739/2005  on  animal  health  requirements  for  the  move-
ment of circus animals between Member States (the Circus Animals Regulation); 

  National species action plans and National animal welfare acts.  
The IAS Regulation was pointed as lacking consistency (gap) by all types of stakeholders, but 
most notably by zoos operators and businesses, while the Circus Animals Regulation was main-
ly mentioned by NGOs and individuals.  
The national species action plans and national animal welfare acts were identified as sources 
of  inconsistencies  with  the  Zoos  Directive  in  specific  countries,  such  as  Spain,  Italy,  Denmark, 
the UK, France and Sweden.  
To a lesser extent, the IUCN Technical guidelines were considered as inconsistent (gap) with the 
Zoos Directive by specific groups, and in particular, NGOs and individuals, as well as British and 
Spanish respondents, and persons who do not visit zoos. 

  Question  29,  as  an  open  question,  allowed  to  identify  three  distinctive  patterns  in  the  types  of 
responses provided, thus indicating results based on guidance by external sources. Out of the 
400  answers  provided  to  question  29,  36.5%  corresponded  to  animal  welfare  concerns  and 
24.25%  referred 
to  EAZA  standards,  both  being  considered  as  mutually  consistent 
with/supportive of the Zoos Directive.   23% (in nearly all cases provided in German) related to 
concerns about EU funding to zoos and coherence between EU regulations on zoos and on nature 
protection  and  agriculture.  These  replies  didn't  show  any  link  to  the  question  of  consisten-
cy/gaps/overlaps  with  the  Directive.    In  total,  335  answers  were  clearly  inspired  by  external 
sources. This represents however a small proportion of the number of respondents to the previous 
question 28m on which Question 29 follows up (31% of 1052 respondents), and an even smaller 
share of the total number of respondents to the public consultation (14.5% of 2297 respondents).          

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8  EU ADDED VALUE 

The public consultation explored the perception of stakeholders on the consequences of not having an 
EU legislation on activities required by the Zoos Directive (question 24, Section 8.1). Answers to oth-
er questions of the public consultation will constitute valuable input for the assessment of the EU add-
ed  value  of  the  Directive,  namely  the  answers  to  questions  22,  23,  25  and  26  (see  Sections  5.1  and 
6.1). 

8.1 

IN  YOUR OPINION, WOULD THE FOLLOWING  ACTIVITIES TAKE  PLACE WITHOUT  EU 
LEGISLATION ON ZOOS (QUESTION 24)? 

The public consultation aimed at collecting opinions on the perceived consequences of not having an 
EU legislative framework on zoos.  To this end, in question 24, stakeholders have been asked to assess 
the likelihood that certain activities take place without an EU legislation on zoos. The activities were 
identified in line with the intervention logic of the Directive, and are namely:   

a.  To fulfil EU's global commitments on biodiversity (point 24a); 
b.  Captive  breeding  of  threatened  species  (i.e.  species  on  European  and  global  red  lists)  (point 

24b); 

c.  Reintroduction of species into the wild (point 24c); 
d.  Research on conservation issues (point 24d); 
e.  Training on relevant conservation skills (point 24e); 
f.  Exchange of information relating to species conservation (point 24f); 
g.  Public education on and awareness of biodiversity conservation and nature (point 24g); 
h.  Public  education  on  and  awareness  of  conservation  of  species,  wild  animals  and  habitats 

(point 24h); 

i.  Provide information on exhibited species and their habitats (point 24i); 
j.  Provide information on broader biodiversity and nature protection topics (point 24j); 
k.  Keeping animals under appropriate conditions with good veterinary care (point 24k); 
l.  Prevent escape of animals and intrusion of outside pests and vermin (point 24l); 
m.  Keeping appropriate, sharable data records of the zoos' animals (point 24m). 

Stakeholders  were  asked 
ly/likely/unlikely/not take place at all in the absence of an EU legislation.   

indicate  whether 

they 

to 

thought  such  activities  would  certain-

8.1.1  General trends 

In question 24 of the public consultation, the public was asked “Would the following activities take 
place without EU legislation on zoos?”. As Figure 77 below illustrates, the views of stakeholders are 
mixed on nearly all the points listed in question 24 of the public consultation.  

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Figure  77:  Answers  to  question  24  of  the  public  consultation  “In  your  opinion,  would  the  following  activities  take 
place without EU legislation on zoos?” in absolute number of respondents. (“No opinion/don’t know” is excluded). 

0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%

24a. To fulfil EU's global commitments on biodiversity

457 

899 

580 

179 

24b.Captive breeding of threatened species (i.e. species on
European and global red lists)

191 

620 

873 

481 

24c. Reintroduction of species into the wild

408 

24d. Research on conservation issues

24e. Training on relevant conservation skills

24f. Exchange of information relating to species conservation

24g. Public education on and awareness of biodiversity
conservation and nature

24h. Public education on and awareness of conservation of
species, wild animals and habitats

772 

673 

580 

735 

695 

800 

523 

826 

487 

473 

443 

577 

578 

439 

675 

675 

716 

280 

338 

302 

383 

360 

371 

478 

24i.Provide information on exhibited species and their habitats

192 

377 

1151 

24j.  Provide information on broader biodiversity and nature
protection topics
24k. Keeping animals under appropriate conditions with good
veterinary care
24l. Prevent escape of animals and intrusion of outside pests
and vermin
24m. Keeping appropriate, sharable data records of the zoos'
animals

298 

901 

684 

303 

608 

476 

738 

179 

382 

1130 

386 

480 

277 

861 

685 

302 

Not at all

Unlikely

Likely

Certainly

Table 78 below summarises which activities stakeholders think would take place without EU-rules on 
the matter, and which would not. Further details are provided further down in this section. 

Table 78: Activities that would take place or not in the absence of EU rules, according to answers to question 24 of the 
public consultation 

Activities would take place 

Captive  breeding  of  threatened  species  (i.e. 
species  on  European  and  global  red  lists)  (point 
24b) 
Exchange of information relating to species con-
servation (point 24f) 
Provide  information  on  broader  biodiversity  and 
nature protection topics (point 24j) 
Prevent  escape  of  animals  and  intrusion  of  out-
side pests and vermin (point 24l) 

/ 

/ 

Activities are likely not to take place/would certainly not 
take place 
To  fulfil  EU's  global  commitments  on  biodiversity 
(point 24a) 

Reintroduction of species into the wild (point 24c) 

Research on conservation issues (point 24d) 

Training on relevant conservation skills (point 24e) 

Public education on and awareness of biodiversi-
ty conservation and nature (point 24g) 
Public education on and awareness of conserva-
tion  of  species,  wild  animals  and  habitats  (point 
24h) 

According to respondents to the public consultation, two activities are likely or certain to take place in 
zoos without the existence of EU-rules: (i) providing information on exhibited species and their habi-
tats (1629 out of 2198 respondents expressing an opinion); (ii) preventing escape of animals and intru-

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sion of outside pests and vermin (1610 out of 2171). Conversely, according to the public, the activity 
that is most likely not to take place in the absence of EU rules regards the fulfilment of EU’s commit-
ments on biodiversity: out of 2115 respondents, 457 think it would not take place at all (21%) and 899 
think it is unlikely (42%). Regarding the provision by zoos of information on broader biodiversity and 
nature protection topics, out of 2186 respondents, 298 think that it would not happen at all (13%) and 
901 that it is unlikely (41%). 

8.1.2  Distribution per type of stakeholders 

As the figure below illustrates through a synthetic overview per sub-question of the opinion of each 
stakeholder group, the opinion of the public varies significantly depending on the type of stakeholders. 
Mirroring the general trends described in the previous section, the activities that, based on an average 
of the answers of all stakeholder groups, are the most likely to take place regardless of the existence of 
EU rules are: (i) provide information on exhibited species and their habitats and (ii) prevent escape of 
animals and intrusion of outside pests and vermin. By contrast, the activity that is the least likely to 
take place is the fulfilment of EU’s global commitment on biodiversity.  

Figure 78: Answers to question 24 of the public consultation “In your opinion, would the following activities take 
place without EU legislation on zoos?”  per share of respondents who think that it is likely or certain to have EU-wide 
rules on the following matters, per type of stakeholder. Percentages are calculated on the number of respondents that 
expressed an opinion (i.e. “No opinion/don’t know” is excluded). 

100%

90%

80%

70%

60%

50%

40%

30%

20%

10%

0%

24a

24b

24c

24d

24e

24f

24g

24h

24i

24j

24k

24l

24m

Business

Zoo operator

Individual

Public authority

NGO

Other organisation

Other

As illustrated in Figure 78, public authorities tend to have a higher confidence than all other stake-
holder groups in the fact that these activities would take place regardless of the existence of EU-wide 
rules on the matter. For four activities, 100% of public authorities think  that these would take place 
without EU-rules. The activities are the following: 

 

 

 

 

exchange of information relating to species conservation,  
providing information on exhibited species and their habitats,  
providing information on broader biodiversity and nature protection topics, and  
keeping animals under appropriate conditions with good veterinary care.  

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Zoo operators seem to overall share the views of  public authorities with some exceptions. By con-
trast,  zoo  operators  think  it  more  likely  than  the  public  authorities  that,  without  EU-rules,  activities 
would take place on (i) captive breeding of threatened species (i.e. species on European and global red 
lists); (ii) training on relevant conservation  skills; (iii) preventing escape of animals and intrusion of 
outside  pests  and  vermin;  and  (iv)  keeping  appropriate,  sharable  data  records  of  the  zoos'  animals. 
Conversely, zoo operators think it less likely than public authorities that, without EU rules, activities 
would take place on all other points.  

In  contrast,  the  opinions  expressed  by  NGOs  demonstrated  the  least  confidence  that  those  activities 
would take place without EU-rules. 9 out of 36 NGOs (25%) think that it is certain that the EU’s glob-
al commitments on biodiversity would not be achieved; additional 19 out of 36 (52%) think that it is 
unlikely. Regarding training on relevant conservation skills, 12 out of 35 NGOs (34%) think that these 
would not place at all without EU-rules and 13 other (37%) think that it is unlikely. Regarding activi-
ties on public education on and awareness of conservation of species, wild animals and habitats, 8 out 
of 35 NGOs (23%) think that these would not place at all without EU-rules and 14 other (40%) think 
that it is unlikely. 

The opinion of individual respondents is closer to the ones expressed by NGOs than the one of zoo 
operators and public authorities. 

8.1.3  Distribution per country 

Table 79 below presents an overview of the public opinion on all the points listed in question 24 of the 
public consultation, broken-down per country of the respondent. In italics are highlighted the lowest 
rates  of  agreement  of  the  public  (i.e.  activities  would  not  take  place  at  all  or  unlikely  to  take  place 
without EU rules) and in bold are the highest rates of support (i.e. activities are likely or certain to take 
place without EU rules).  

The results of this break-down correspond with the trends identified above. On the one hand, regard-
less of the country of origin of the respondent, stakeholders think that the activity that is the least like-
ly to take place without EU rules is the fulfilment of EU’s global commitment to biodiversity conser-
vation (point 24a). On the other hand, stakeholders think that the two activities that are most likely to 
be  maintained  without  EU  rules  are:  firstly,  preventing  escape  of  animals  and  intrusion  of  outside 
pests and vermin (point 24l), and secondly, providing information on exhibited species and their habi-
tats (point 24i).  

Some countries do not follow this general trend. For the Czech Republic and Hungary, stakeholders 
reported that the activity that is most likely not to take place is research on conservation issues (point 
24d). In Finland and Austria, it is keeping animals under appropriate conditions with good veterinary 
care (point 24k). Regarding Greece, providing information on broader biodiversity and nature protec-
tion topics (point 24j) and keeping appropriate, sharable data records of the zoos' animals (point 24m) 
were  reported  as  unlikely  to  be  carried  out  without  EU  rules.  French  respondents  also  assessed  that 
keeping appropriate, sharable data records was likely not to take place (point 24m). For Ireland, it is 
activities related to the reintroduction of species into the wild that are the least likely to continue (point 
24c). With regards to the activities that are likely to take place without EU rules, Belgian, Dutch and 
Finnish respondents think that captive breeding of threatened species (point 24b) is likely to take place 
without EU rules. 

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Table 79: Answers to question 24 of the public consultation “In your opinion, would the following activities take place without EU legislation on zoos?” (per share of respondents who 
think that it is likely or certain that the following activities would take place without EU rules, per country). Percentages are calculated on the number of respondents that expressed 
an opinion (i.e. “No opinion/don’t know” is excluded). 

Austria 
Belgium 
Bulgaria 
Croatia 
Czech Rep. 
Denmark 
Estonia 
Finland 
France 
Germany 
Greece 
Hungary 
Ireland 
Italy 
Lithuania 
Luxembg 
Malta 
Netherlds 
Poland 
Portugal 
Romania 
Slovakia 
Slovenia 
Spain 
Sweden 
UK 
Non-EU  

24a 
52%(n=25) 
19%(n=37) 
0%(n=3) 
N/A(n=0) 
21%(n=14) 
29%(n=34) 
0%(n=1) 
43%(n=7) 
26%(n=66) 
63%(n=757) 
23%(n=13) 
0%(n=5) 
7%(n=15) 
38%(n=48) 
67%(n=3) 
0%(n=1) 
0%(n=3) 
18%(n=108) 
17%(n=12) 
12%(n=34) 
19%(n=16) 
50%(n=2) 
33%(n=3) 
17%(n=135) 
12%(n=26) 
15%(n=559) 
34%(n=188) 

24b 
72%(n=25) 
67%(n=39) 
0%(n=3) 
0%(n=1) 
71%(n=14) 
66%(n=35) 
0%(n=1) 
71%(n=7) 
58%(n=64) 
76%(n=774) 
57%(n=14) 
60%(n=5) 
43%(n=14) 
58%(n=50) 
67%(n=3) 
0%(n=1) 
33%(n=3) 
89%(n=114) 
54%(n=13) 
77%(n=35) 
69%(n=16) 
50%(n=2) 
33%(n=3) 
32%(n=138) 
80%(n=30) 
49%(n=568) 
52%(n=193) 

24c 
54%(n=24) 
27%(n=37) 
0%(n=3) 
0%(n=1) 
60%(n=15) 
41%(n=37) 
0%(n=1) 
38%(n=8) 
38%(n=66) 
65%(n=779) 
38%(n=13) 
20%(n=5) 
0%(n=15) 
46%(n=50) 
33%(n=3) 
0%(n=1) 
0%(n=3) 
82%(n=114) 
23%(n=13) 
61%(n=36) 
60%(n=15) 
100%(n=1) 
33%(n=3) 
21%(n=149) 
54%(n=28) 
27%(n=580) 
37%(n=195) 

24d 
64%(n=25) 
33%(n=39) 
0%(n=3) 
N/A (n=0) 
20%(n=15) 
42%(n=36) 
0%(n=1) 
38%(n=8) 
37%(n=65) 
71%(n=776) 
31%(n=13) 
0%(n=4) 
25%(n=16) 
53%(n=49) 
33%(n=3) 
0%(n=1) 
0%(n=3) 
33%(n=112) 
31%(n=13) 
31%(n=36) 
20%(n=15) 
50%(n=2) 
33%(n=3) 
25%(n=146) 
27%(n=30) 
33%(n=583) 
42%(n=196) 

24e 
64%(n=25) 
38%(n=37) 
33%(n=3) 
0%(n=1) 
47%(n=15) 
54%(n=35) 
0%(n=1) 
25%(n=8) 
40%(n=63) 
71%(n=759) 
29%(n=14) 
25%(n=4) 
25%(n=16) 
55%(n=49) 
0%(n=3) 
0%(n=1) 
33%(n=3) 
80%(n=112) 
31%(n=13) 
61%(n=36) 
60%(n=15) 
50%(n=2) 
33%(n=3) 
25%(n=146) 
50%(n=26) 
33%(n=571) 
40%(n=194) 

24f 
71%(n=24) 
39%(n=36) 
0%(n=3) 
0%(n=1) 
71%(n=14) 
49%(n=35) 
0%(n=1) 
57%(n=7) 
51%(n=65) 
73%(n=777) 
57%(n=14) 
40%(n=5) 
38%(n=16) 
57%(n=51) 
33%(n=3) 
0%(n=1) 
50%(n=2) 
88%(n=113) 
62%(n=13) 
72%(n=36) 
56%(n=16) 
50%(n=2) 
33%(n=3) 
37%(n=143) 
64%(n=25) 
34%(n=573) 
46%(n=196) 

24g 
67%(n=24) 
37%(n=38) 
33%(n=3) 
0%(n=1) 
29%(n=14) 
31%(n=35) 
0%(n=1) 
33%(n=6) 
45%(n=65) 
71%(n=775) 
46%(n=13) 
20%(n=5) 
38%(n=16) 
46%(n=50) 
0%(n=3) 
0%(n=1) 
0%(n=3) 
33%(n=116) 
31%(n=13) 
24%(n=37) 
25%(n=16) 
100%(n=2) 
33%(n=3) 
26%(n=146) 
21%(n=29) 
32%(n=577) 
44%(n=198) 

24h 
67%(n=24) 
30%(n=40) 
33%(n=3) 
0%(n=1) 
29%(n=14) 
31%(n=36) 
0%(n=1) 
33%(n=6) 
38%(n=65) 
71%(n=778) 
43%(n=14) 
25%(n=4) 
31%(n=16) 
51%(n=51) 
0%(n=3) 
0%(n=1) 
0%(n=3) 
34%(n=116) 
31%(n=13) 
32%(n=37) 
31%(n=16) 
100%(n=2) 
33%(n=3) 
29%(n=146) 
24%(n=29) 
39%(n=580) 
45%(n=199) 

24i 
88%(n=25) 
54%(n=41) 
100%(n=3) 
N/A (n=0) 
79%(n=14) 
70%(n=37) 
100%(n=1) 
71%(n=7) 
66%(n=65) 
85%(n=778) 
64%(n=14) 
100%(n=5) 
67%(n=15) 
73%(n=51) 
67%(n=3) 
0%(n=1) 
33%(n=3) 
90%(n=115) 
54%(n=13) 
83%(n=36) 
75%(n=16) 
100%(n=2) 
67%(n=3) 
54%(n=145) 
86%(n=28) 
65%(n=580) 
68%(n=197) 

24j 
64%(n=25) 
38%(n=40) 
33%(n=3) 
0%(n=1) 
21%(n=14) 
35%(n=34) 
0%(n=1) 
29%(n=7) 
37%(n=63) 
70%(n=775) 
21%(n=14) 
20%(n=5) 
19%(n=16) 
41%(n=51) 
0%(n=3) 
0%(n=1) 
0%(n=3) 
30%(n=115) 
31%(n=13) 
31%(n=36) 
31%(n=16) 
100%(n=2) 
33%(n=3) 
28%(n=143) 
22%(n=27) 
27%(n=578) 
41%(n=197) 

24k 
52%(n=25) 
37%(n=41) 
67%(n=3) 
0%(n=1) 
60%(n=15) 
54%(n=37) 
0%(n=1) 
14%(n=7) 
33%(n=66) 
69%(n=781) 
46%(n=13) 
20%(n=5) 
29%(n=14) 
52%(n=50) 
33%(n=3) 
0%(n=1) 
0%(n=3) 
82%(n=116) 
31%(n=13) 
69%(n=36) 
75%(n=16) 
50%(n=2) 
33%(n=3) 
27%(n=146) 
54%(n=28) 
32%(n=585) 
42%(n=197) 

24l 
88%(n=25) 
66%(n=38) 
100%(n=3) 
N/A (n=0) 
80%(n=15) 
76%(n=34) 
100%(n=1) 
67%(n=6) 
62%(n=65) 
86%(n=774) 
54%(n=13) 
80%(n=5) 
50%(n=14) 
77%(n=48) 
100%(n=3) 
100%(n=1) 
0%(n=3) 
87%(n=115) 
75%(n=12) 
92%(n=36) 
94%(n=16) 
50%(n=2) 
67%(n=3) 
57%(n=143) 
76%(n=29) 
64%(n=575) 
62%(n=192) 

24m 
72%(n=25) 
29%(n=35) 
67%(n=3) 
N/A (n=0) 
47%(n=15) 
34%(n=32) 
0%(n=1) 
33%(n=6) 
24%(n=62) 
68%(n=751) 
21%(n=14) 
40%(n=5) 
20%(n=15) 
43%(n=49) 
0%(n=2) 
0%(n=1) 
33%(n=3) 
33%(n=116) 
62%(n=13) 
36%(n=36) 
44%(n=16) 
50%(n=2) 
67%(n=3) 
26%(n=141) 
19%(n=27) 
34%(n=559) 
41%(n=193) 

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8.1.4  Distribution depending on whether the respondent visits zoos or not 

In  general,  respondents  who  do  not  visit  zoos  are  much  more  pessimistic  that  activities  would  take 
place  without  EU  legislation  on  zoos.  The  answers  to  question  24  of  the  public  consultation  widely 
differ  (between  30  and  44%  gap)  depending  on  whether  respondents  visit  zoos  or  not,  as  the  figure 
below illustrates. The smallest gap concerns the fact that providing information on exhibited species 
and their habitats (point 24i) is likely to take place without EU rules: respondents of both categories 
(279 out of 545 non-visitors; 1350 out of 1653 of visitors) think that such activity would take place. 
The largest gaps were found in relation to reintroduction of species into the wild (point 24c) and train-
ing on relevant conservation skills (point 24e). With regards to the reintroduction of species into the 
wild, 477 out of 552 (86%) respondents who do not visit zoos think that reintroduction of species is 
unlikely  to/will  not  at  all  take  place  without  EU-rules;  while  703  out  of  1643  (42%)  of  respondents 
who visit zoos had that assessment. On training, 444 out of 545 (81%) of respondents who do not visit 
zoos think that this activity is unlikely to/will not at all take place; while only 609 out of 1610 (37%) 
of respondents who visit zoos share that view. 

Figure 79: Answers to question 24 of the public consultation “In your opinion, would the following activities take 
place without EU legislation on zoos?” per share of respondents who think that it is likely or certain that the following 
activities would take place without EU rules, depending on whether respondents visit zoos or not (question 18 of the 
public consultation). Percentages are calculated on the number of respondents that expressed an opinion (i.e. “No 
opinion/don’t know” is excluded). 

100%
90%
80%
70%
60%
50%
40%
30%
20%
10%
0%

24a

24b

24c

24d

24e

24f

24g

24h

24i

24j

24k

24l

24m

I don't visit zoos

I visit zoos

8.1.5  Key points 

  According  to  the  respondents  to  the  public  consultation,  two  activities  are  likely  or  certain  to 

take place in zoos without the existence of EU-rules:  
 

Providing information on exhibited species and their habitats (1629 out of 2198 respond-
ents who gave their opinion);  

  Preventing escape of animals and intrusion of outside pests and vermin (1610 out of 2171).  
  Activity that is most unlikely to occur in the absence of EU rules regards the fulfilment of EU’s 
commitments on biodiversity: out of 2115 respondents, 457 think it would not take place at all 
(21%) and 899 think it is unlikely (42%).  

  Regarding the provision by zoos of information on broader biodiversity and nature protection 
topics, out of 2186 respondents, 298 think that it would not happen at all (13%) and 901 that it is 
unlikely (41%). 

  Those trends are confirmed through all break-downs (per type of stakeholders, country and zoo 
visits).  The  most  striking  differences  are  linked  to the  fact  that  respondents  are  zoos  visitors  or 
not. The largest gaps were found in relation to reintroduction of species into the wild and training 
on  relevant  conservation  skills.  With  regards  to  the  reintroduction  of  species  into  the  wild,  477 
out of 552 (86%) respondents who do not visit zoos think that reintroduction of species is unlike-

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ly to/will not at all take place without EU-rules; while 703 out of 1643 (42%) of respondents who 
visit zoos had that assessment. On training, 444 out of 545 (81%) of respondents who do not visit 
zoos think that this activity is unlikely to/will  not at all take place; while only  609 out of 1610 
(37%) of respondents who visit zoos share that view. 

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9  CONCLUSIONS 

The public consultation’s purpose was to obtain the views and perceptions of a wide set of stakehold-
ers on the contribution of the Directive to strengthen the role of zoos and enhance biodiversity conser-
vation,  including  stakeholders  that  were  not  consulted  in  the  targeted  consultation,  i.e.  stakeholders 
from other countries than the 14 selected for questionnaires, as well as EU citizens across the EU-28.  

The  public  consultation  received  2297  answers.  The  main  categories  of  respondents  are  individuals 
(zoo  visitors)  with  1944  answers,  and  zoos  operators  with  148  answers.  105  respondents  chose  the 
category  ‘other’  types  of  respondents  (including  zoos  and  aquarium  workers,  persons  working  with 
animals, academics/scientists). The largest groups of respondents are from Germany, the United King-
dom, Non-EU countries, Spain and the Netherlands. German and British respondents represent 60% of 
the respondents.  

Several  interest  groups  (mainly  animal  welfare  or  zoos  organisations)  have  provided  their  members 
and/or the wider public with guidance on how to answer the consultation. The analysis of answers to 
the  consultation  suggests  that  only  a  limited  number  of  stakeholders  followed  completely  the  pre-
determined set of answers provided by the interest groups, thus  suggesting that the influence of such 
groups over the results of the consultation remains minimal.  

In terms of effectiveness, respondents to the consultation assessed positively the achievements of the 
Directive’s objectives. On average, the rate of positive perceptions among public authorities and zoos 
operators was higher than among NGOs and individual respondents. In general, all respondents con-
sidered that educational measures and measures relating to the prevention of escape were best imple-
mented.  The  level  of  adhesion  to  the  statements  relating  to  the  living  conditions  of  animals  and  the 
contribution  of  animal  shows  was  significantly  lower.  In  addition,  activities  resulting  for  the  imple-
mentation of the Article 3 measures have been considered as being sufficiently promoted by the per-
sons  who  responded  to  the  public  consultation.  The  perception  of  the  implementation  of  Article  3 
measures is particularly positive among public authorities, zoo operators and business, especially for 
activities  relating  to  information.  Perception  is  however  less  positive  among  individuals,  NGOs  and 
other organisations, in particular in relation to animal conditions and care.  

As regards efficiency, one the one hand, the consultation shows that the Zoos Directive has produced 
significant benefits in terms of creation of a common legal framework across the EU; improved sys-
tems for licensing and inspections and promotion of better knowledge on biodiversity among the pub-
lic. The benefits on economic activities around zoos appear less relevant. On the other hand, the Di-
rective has also implied additional costs related to its implementation, both for zoos (e.g. costs for the 
renovation of the enclosures, costs to run research programs, educational activities), and for Member 
State authorities (for setting up a licensing and inspection system and monitoring its implementation). 
Overall,  benefits of the Zoos Directive  appear nevertheless greater than the costs of its implementa-
tion.  The  results  of  the  public  consultation  clearly,  including  responses  provided  by  zoos  operators, 
support this perception.  

In relation to relevance, a vast majority of respondents considers EU-wide rules as important or very 
important. This is especially the case regarding  the keeping of animals under appropriate conditions 
with good veterinary care. The views of stakeholders are more nuanced on the relevance of rules on 
captive breeding and reintroduction of species into the wild. A greater share of NGOs and respondents 
who  do  not  visit  zoos  think  that  EU-wide  rules  on  captive  breeding  are  partly  important  or  not  im-
portant.   

The answers to the coherence related questions of the consultation did not reveal major problems of 
gaps  or  overlaps  between  the  Zoos  Directive  and  other  EU  instruments.  Respondents  expressing  an 
opinion overall considered the instruments listed as being consistent or mutually supportive with the 
Directive. Issues were raised mainly in relation to the IAS Regulation, where zoos operators and busi-

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nesses pointed to gaps, and to the Circus Animals Regulation, where NGOs and individuals observed 
inconsistencies. The national species action plans and national animal welfare acts were also identified 
as sources of inconsistencies with the Zoos Directive in specific countries, such as Spain, Italy, Den-
mark, the UK, France and Sweden. 

Finally, regarding EU added value, respondents to the public consultation considered that the provi-
sion of information on exhibited species and their habitats and the prevention of escape were the two 
activities most likely to take place in zoos without the existence of EU-rules. However, they consid-
ered that activities concerning the fulfilment of EU’s commitments on biodiversity by zoos were most 
unlikely to occur in the absence of EU rules. Likewise, they estimated that zoos would most likely not 
provide information on broader biodiversity and nature protection topics without the Directive.  

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ANNEX VIIIA – PUBLIC CONSULTATION QUESTIONNAIRE 

Public consultation as part of the REFIT evaluation of the 
Zoos Directive 

Fields marked with * are mandatory. 

Public consultation as part of the REFIT evaluation of the Zoos 

Directive (Council Directive 1999/22/EC relating to the keeping 

of wild animals in zoos) 

The evaluation is part of the European Commission's Regulatory Fitness and Performance Pro-

gramme (REFIT). This programme involves a comprehensive, evidence-based assessment of 

whether the current regulatory framework is proportionate and fit for purpose, and delivering as ex-

pected. 

With this evaluation, the European Commission (Directorate General for Environment) will assess 

the results achieved by the EU legislation on zoos (Directive 1999/22/EC relating to the keeping of 

wild animals in zoos, hereinafter the ‘Zoos Directive’). This Directive aims to improve the protec-

tion of wild animals and strengthen the role of zoos in preserving biodiversity. 

The aim of this consultation is to gather the views of interested parties and the wider public on the 

current EU legislation on zoos (the ‘Zoos Directive’), and input on which aspects work well and 

which ones do not. 

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We will use your responses to help us assess the current situation, ensuring that as many opinions 

as possible are taken into account. It is therefore important that you complete this questionnaire as 

fully as possible. 

Further information on the evaluation and the different activities it involves can be consulted on the 

Commission’s evaluation website . 

Directive 1999/22/EC relating to the keeping of wild animals in zoos (‘Zoos 
Directive’) 

The objective of the Zoos Directive is to promote the conservation of wild animal species (i.e. 

maintain or restore the species’ populations at a favourable level), thereby strengthening the role 

of zoos in the conservation of biodiversity. 

To achieve these objectives, Member States are responsible for setting up a licensing and inspec-

tion system of zoos. This system aims to ensure that zoos put in place adequate conservation 

measures, including appropriate accommodation of the animals. 

In order to obtain and keep a licence, zoos have to carry out the following conservation 

measures: 

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Participate in one or more of the following: Research benefitting conservation, training in rel-

evant conservation skills, exchange of information relating to species conservation, breeding 

of animals outside their natural habitats, reintroduction of bred species into the wild; 

Promote public education on and awareness raising of conservation topics (for exam-

ple  by  providing  information  about  the  species  exhibited  and  their  natural  environ-

ments); 

Keep animals under appropriate conditions with good veterinary care; 

Prevent the escape of animals which can negatively impact the local ecosystems, and the intru-

sion of pests from outside that can adversely affect zoo animals; 

Keep appropriate and sharable data records of the zoo’s animals. 

Structure of the questionnaire 

All questions are based on the Roadmap for the REFIT evaluation of the Zoos Directive. For meth-

odological reasons, all questions are compulsory. However, it is possible to answer 'no opinion' or 

'don't know'. Free text boxes enable you to give additional answers to the options provided in a mul-

ti-choice reply. 

Replies  may be submitted in  any EU official  language.  Given possible delays  in translating com-

ments  submitted  in  some  languages,  contributions  in  English  are  welcome,  as  they  will  help  the 

Commission to process the survey more swiftly. 

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You may interrupt your session at any time and continue answering at a later stage. Once you have 

submitted your answers online, you will be able to download a copy of the completed question-

naire. 

Important notice on the publication of contributions 

Replies to this public consultation will be published on the European Commission's website (for fur-

ther information, please consult the privacy statement). 

Please note: regardless of the option chosen below, your contribution may be subject to a request 

for access to documents under Regulation 1049/2001 on public access to European Parliament, 

Council and Commission documents. In such cases, the request will be assessed against the condi-

tions set out in the Regulation and in accordance with applicable data protection rules. 

1  

* 

Please indicate whether your reply: 

   Can be published, including your name or that of your organisation (I consent to publi-
cation of all information in my contribution and I declare that none of it is under copy-
right restrictions that prevent publication) 

   Can be published in an anonymous way (I consent to publication of all information in my 
contribution except my name/the name of my organisation, and I declare that none of it is 
under copyright restrictions that prevent publication) 

   Cannot be published but only used for statistical and analytical purposes 

Background information 

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2 
* 

Please indicate here the language that you will use in your replies: 

   Bulgarian 
Croatian 

Czech 

   Danish 
Dutch 
English 

   Estonian 
Finnish 

French 
German 
Greek 

   Hungarian 

Irish 

   Italian 
Latvian 
   Lithuanian 
Maltese  Po-

lish 

   Portuguese 
Romanian 

Slovak 

      Slovene 
Spanish 

Swedish 

3 
* 

I am replying to this questionnaire as... 

   Individual (e.g. zoo visitor) 
  Zoo operator 
   Business or business representative 

Non-governmental organisation 

   Organisation or association (other than NGO) 

Government or public authority 

   European institution or agency 

Academic/research institute 

   Other (please specify below) 

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4 
* 

Please specify "other". 

200 character(s) maximum 

5 
* 
What is your name or the name of your organisation? 

* 6 

Are you registered in the EU Transparency Register? 

In the interests of transparency, organisations, networks, platforms or self-employed individu-
als engaged in activities aimed at influencing the EU decision making process have been in-
vited to provide the public with relevant information about themselves, by registering in 
Transparency Register and subscribing to its Code of Conduct. 

Please note: If the organisation is not registered, the submission is published separately 
from the registered organisations. During the analysis of replies to a consultation, contri-
butions from respondents who choose not to register will be treated as individual contribu-
tions (unless the contributors are recognised as representative stakeholders through Treaty 
provisions, European Social Dialogue, Art. 154-155 TFEU). 

If your organisation is not registered, you have the opportunity to register now. 

   Yes 
   No 

7 
If yes, what is your EU Transparency Register ID number? 

100 character(s) maximum 

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8 
* 

In which Member State are you based? 

   Austria 
Belgium 
Bulgaria 
Croatia 
Cyprus 
   Czech Republic 
  Denmark 
   Estonia 

Finland 
France 
Germany 
Greece 
Hungary 
Ireland 
ly 

Ita-

   Latvia 
   Lithuania 
   Luxembourg 
Malta 
   Netherlands 

Poland 

   Portugal 
Romania 
   Slovak Republic 
  Slovenia 
   Spain 
Sweden 

   United Kingdom 
  Non-EU country 

9  Please specify the country. 

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10 

* 

At which level do you operate? 

   International 
EU 
      National 
Regional 
Local 

11 

* 

Which of the following topics best describe your main field of activity? 

Please select one or more answers 

   Environment, nature 
  Zoo management 
   Biodiversity, in-situ conservation (conservation of species in their natural envi-

ronment) 

   Biodiversity, ex-situ conservation (conservation of species outside their natural envi-

ronment) 

   Animal welfare 
  Education 
   Recreation 

Tourism 

   Other (please specify below) 
   I don’t carry out activities in any of the fields above 

12 

* 

Please specify "other". 

200 character(s) maximum 

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13 

* 

Regardless of your field of activity, which of the following topics best describe your 
main field of interest? 

Please select one or more answers 
   Environment, nature 
  Zoo management 
   Biodiversity, in-situ conservation (conservation of species in their natural envi-

ronment) 

   Biodiversity, ex-situ conservation (conservation of species outside their natural envi-

ronment) 

   Animal welfare 
  Education 
   Recreation 

Tourism 

   Other (please specify below) 

None of those 

14 

* 

Please specify "other". 

200 character(s) maximum 

15 

* 

Are you a member of any organisation active in the following fields? 

   Nature conservation 
  Animal welfare 
   Zoos association 
   Other (please specify below) 
   I’m not member of any organisation relevant to the topic 

16 

* 

Please specify "other". 

200 character(s) maximum 

Questionnaire 

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17 

* 

How familiar are you with the Zoos Directive? 

   I don't know the Zoos Directive 
   I’ve heard about the Zoos Directive, but I’m not familiar with its provisions 

Slightly familiar 
   Very familiar 

18 

* 

What are your main reasons for visiting a zoo? 

   Recreation (e.g. seeing exotic/wild animals, animal shows) 
      Learning  about  nature,  animals  and  their  habitats,  biodiversity  conservation 

Teaching  about  nature,  animals  and  their  habitats,  biodiversity  conservation 
fessional reasons 

    Pro-

   Other (please specify below) 

I don't visit zoos 

19 

* 

Please specify "other". 

300 character(s) maximum 

20 

To what extent do you agree or disagree with the following statements regarding 
zoos in your country? 

Totally 

Somewhat 

Somewhat 

Totally 

disagree 

disagree 

agree 

agree 

Don't 

know 

*Information on 
species and their 
habitats is usually 
well presented 

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*After a zoo visit I 
know more about 
conservation of 
wild animals, pro-
tected species, 
threatened spe-
cies 

*After a zoo visit I 
know more about 
biodiversity and 
conservation of 
nature in general 

*I have noticed 
improvements of 

education activi-

ties (e.g. school 

visits, educa-

tional shows) 

provided by 

zoos over the 

last 15 years 

*I have noticed 
improvements in 
research activities 
carried out by 
zoos over the last 
15 years 

*Animals live in 
conditions that 
satisfy their needs 

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*I have noticed 
improvements in 
the size and de-
sign of spaces 
where animals are 
kept over the last 
15 years 

*Animal shows 
are adapted to 
animals' natural 
behaviours 

*In the zoos I’ve 
visited, I received 
information on the 
species and/or its 
conservation sta-
tus 

*Zoo visits en-
courage visitors to 
become more en-
gaged in the pro-
tection of species 

*Zoo visits en-
courage visitors to 
become more en-
gaged in the pro-
tection of biodi-
versity and nature 
in general 

*Zoos are ade-
quately designed 
to prevent the es-
cape of animals 

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21 

Do you think the following activities are sufficiently promoted in zoos across the 
EU? 

Background information – Under the Zoos Directive Member States have to establish 

a licencing and inspection system of existing and new zoos in order to ensure that zoos 

meet the following provisions: 

Participate in one or more of the following: research benefitting conservation, train-

ing in relevant conservation skills, exchange of information relating to species con-

servation, breeding of animals outside their natural habitats, reintroduction of bred 

species into the wild; 

Promote public education on and awareness raising of conservation topics (for exam-

ple  by  providing  information  about  the  species  exhibited  and  their  natural  environ-

ments); 

Keep animals under appropriate conditions with good veterinary care; 

Prevent the escape of animals which can negatively impact the local ecosystems, 

and the intrusion of pests from outside that can adversely affect zoo animals; 

Keep appropriate and sharable data records of the zoo’s animals. 

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Yes 

No 

No opinion 

*Research on species conservation issues 

*Training on relevant species conservation skills 

*Exchange of information relating to species 
conservation, between zoos, authorities, other 
organisations 

*Provide education on and raise awareness of 
biodiversity and broader nature protection topics 

*Provide education on and raise awareness of 
species, wild animals and their natural habitats 

*Provide information on exhibited species and 
their habitats 

*Keep animals under appropriate conditions with 
good veterinary care 

*Collect data on the animals in the zoo 

22 

How important do you think EU-wide rules on zoos are on the following matters? 

Background information - The overall objectives of the Directive are to protect wild spe-

cies and to conserve biodiversity. The Directive aims to strengthen the role of zoos in the 

conservation of biodiversity by provisions relating to zoos and to Member State authorities. 

Not im-

portant 

Partly 

important 

Important 

Very im-

portant 

No 

opinion 

*Protecting 
Europe's 

threatened 

species 

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*Protecting 
globally 

threatened 

species 

*Captive 
breeding (i.e. 

breeding of an-

imals outside 

their natural 

habitats) of 

threatened 

species in Eu-

rope and glob-

ally 

*Reintroduction 
of species into 

the wild 

*Keeping 
animals under 

appropriate 

conditions with 

good veterinary 

care 

*Making zoos 
shift from pure 

exhibition to 

modern conser-

vation centres, 

where educa-

tion, research, 

captive breeding 

and reintroduc-

tion pro-

grammes are 

undertaken 

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*Avoiding the 
escape of an-
imals 

*Increasing 
awareness of 

the wider public 

on biodiversity 

and nature pro-

tection by offer-

ing education 

and information 

on these topics 

*Keeping 
appropriate, 

sharable data 

records of the 

zoo’s animals 

Other (please 

specify below) 

23  Please specify "other". 

200 character(s) maximum 

24 

In your opinion, would the following activities take place without EU legislation on 
zoos? 

Not 

at all 

Unlikely 

Likely 

Certainly 

No 

opinion 

*To fulfil EU's global 
commitments on bi-
odiversity 

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*Captive breeding of 
threatened species (i.e. 
species on European 
and global red lists) 

*Reintroduction of 
species into the wild 

*Research on con-
servation issues 

*Training on relevant 
conservation skills 

*Exchange of infor-
mation relating to 
species conservation 

*Public education on 
and awareness of bio-
diversity conservation 
and nature 

*Public education on 
and awareness of con-
servation of species, 
wild animals and habi-
tats 

*Provide information on 
exhibited species and 
their habitats 

*Provide  information  on 
broader biodiversity and 
nature protection topics 

*Keeping animals under 
appropriate conditions 
with good veterinary 
care 

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*Prevent escape of an-
imals and intrusion of 
outside pests and ver-
min 

*Keeping appropriate, 
sharable data records 
of the zoos' animals 

25 

To what extent do you consider that the Directive has brought the following bene-
fits? 

Not 

at 

all 

Minor 

Significant 

Crucial 

No 

benefits 

benefits 

benefits 

opinion 

*Benefits for overall 
biodiversity conser-
vation 

*Benefits for pro-
tecting species 
from extinction 

*Benefits for ex-situ 
conservation efforts 

*Benefits for public 
education and better 
knowledge on biodi-
versity 

*Benefits for positive 
changes of behaviour 
towards biodiversity 
protection 

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*Benefits for higher 
engagement of the 
public/stakeholders in 
biodiversity protection 
and other nature pro-
tection activities 

*Benefits for condi-
tions under which 
animals are kept 
and standard of an-
imal husbandry 

*Created legal cer-
tainty for zoos as 
businesses 

*Ensured a coherent 
legal framework for 
zoos to operate 
across the EU 

*Increased tourism 

*Increased 
employment in areas 

where zoos are lo-

cated 

*Increased offer of 
cultural and rec-
reational opportu-
nities to the public 

*Improved licensing 
and inspection 
schemes of zoos 

Other (please specify 

below) 

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26 

* 

Please specify "other" 

400 character(s) maximum 

27 

* 

In your view, how do the costs of implementation of the Zoos Directive compare 
with the benefits brought about from their implementation? 

Background information - The implementation of the Zoos Directive and the related 
licensing and inspection system by Member States could have prompted additional costs 
for: 

Zoos, such as investments (e.g. costs for the renovation of the enclosures, provision 

of information on exhibited animals, improvement of spaces were animals are kept 

and/or displayed, systems to prevent escape of animals and/or intrusion of outside 

pests and vermin, and systems for the collection of information on animals kept), and 

recurrent costs (e.g. to run research programmes, training, awareness raising and ed-

ucational activities, collecting data). These costs may have been incurred by zoos in 

order to ensure the compliance of the zoo with the requirements introduced; 

Member State authorities, such as costs for licensing and inspections, costs for the 

closure of non-compliant zoos and the accommodation of animals, etc. 

   The costs of implementation are more or less equal to the benefits 

costs of implementation are somewhat greater than the benefits 
of implementation far exceed the benefits 

  The 
  The costs 

   The benefits are somewhat greater than the costs of implementation 

The benefits far exceed the costs of implementation 

   No opinion 

28 

Is the Zoos Directive consistent with and mutually supportive of the following legal 
and non-legal interventions or do you see significant gaps or overlaps? 

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Consistent 

and/or 

Mutually 

supportive 

Gaps 

Overlaps 

No 

opinion 

*Convention on biological 
Diversity (CBD)/Aichi targets 

*Birds Directive, 1979 
(Council Directive 
79/409/EEC) and Habitats 
Directive, 1992 (Council 
Directive 92/43/EEC) 

*Convention on international 
trade in endangered species 
of wild flora and fauna ( 
CITES), embraced by 
Council Regulation No 
338/97 on the protection of 
species and wild fauna and 
flora by regulating trade 

*Regulation 1143/2014 on 
invasive alien species 

*Commission regulation No 
1739/2005 of 21 October 
2005 laying down animal 
health requirements for the 
movement of circus animals 
between Member States 

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*Council Directive 
92/65/EEC of 13 July 1992 

laying down animal health 

requirements governing 

trade in and imports into the 

Community of animals, se-

men, ova and embryos not 

subject to animal health re-

quirements laid down in 

specific rules referred to in 

annex A (I) to Directive 

90/425/EEC 

*Council Directive 
90/425/EEC of 26 June 
1990 concerning veterinary 
and zoo technical checks 
applicable in 

intra-Community trade in 

certain live animals and 

products with a view to the 

completion of the internal 

market 

*National species action 
plans in EU Member States 

*National animal welfare 
acts 

*European code of conduct 
on zoological gardens and 
aquaria and invasive alien 
species (Council of Europe, 
Invasive alien Specialist 
Group, EAZA) 

*IUCN technical guidelines 
for the management of 

ex-situ populations for 

conservation 

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*WAZA World Zoo and 
Aquarium Conservation 
Strategies 

Other (please specify below) 

29 

* 

Please specify "other". 

200 character(s) maximum 

Final remarks 

If you are aware of specific documents that should be taken into account in the evi-

dence gathering process, please submit them through the evaluation website. 

Thank you for your participation! 

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ANNEX IX – WORKSHOP REPORT 

INTRODUCTION 

This report presents the work that was carried out regarding the organisation of the workshop under 
the  project  on  an  evaluation  study  to  support  the  Commission’s  evaluation  of  the  Zoos  Directive 
(Directive 1999/22/EC). The lead for this task was Milieu with significant contribution of VetEffecT. 
The purpose of the workshop was to present the main findings of the Draft Evaluation Report and to 
provide  an  opportunity  for  important  stakeholders  to  input  on  the  conclusions  on  the  effectiveness, 
efficiency,  relevance  and  coherence  of  the  Directive,  through  a  robust  debate  and  an  informative 
exchange  of  opinions.  At  the  workshop,  the  study  team  presented  the  main  findings  of  the  draft 
evaluation report as a basis for the discussion. Stakeholders were asked to focus and provide input in 
particular on any existing gaps or misrepresentations that they identified in the study’s findings.  

The workshop was a one-day event in Brussels, held on 16 May 2017 in the “Charlemagne” building 
of the European Commission (Rue de la Loi, 170, 1040 – Brussels). The workshop was designed to 
accommodate 100 participants from the following target stakeholder groups: Member States, NGOs, 
sectoral  representatives  and  academia.  The  workshop  was  supported  by  interpretation  in  English, 
French, German, Italian and Spanish. 

This  report  contains  the  agenda  of  the  workshop  (Section  1),  the  list  of  participants  (Section  2),  the 
workshop  materials  (Section  3),  a  summary  of  the  dicussions  (Section  4)  and  the  way  in  which 
feedback from stakeholders will taken into account for the Final Evaluation Report  (Section 5). The 
Annexes contain the list of participants (Annex I), the Workshop Background Note (Annex II) and the 
presentations (Annex III). 

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1  AGENDA 

The agenda of the workshop was drafted in collaboration with the European Commission with a view 
to  ensure  meaningful  feedback  from  stakeholders.  The  presentations  were  done  by  the  European 
Commission, to introduce the study and  the purpose of the workshop, and  by members of the study 
team,  to  present  key  findings  of  the  Draft  Evaluation  Report.  It  was  agreed  with  the  European 
Commission  that  no  additional  speakers  were  required  or  break-out  sessions  organised  in  order  to 
optimise the time available for plenary discussion with the stakeholders. The discussions were chaired 
by the European Commission (Micheal O’Briain). The detailed agenda is reproduced below. 

Table 80 – Agenda of the Workshop 

8:30 - 9:30 
9:30 - 10:15 

Welcome coffee - Registration 
Introductory session 

Introductory  speech:  Humberto  Delgado  Rosa,  European  Commission,  Directorate  D  – 
Natural Capital 
Approach and methodology: Milieu 
Opportunity for initial feedback from participants 

10:15 - 16:00  Emerging Findings 

For each session: - Presentation/Introduction and overview of the evidence and key issues 
by Milieu; perspectives/reactions from the audience. 
All sessions were chaired by the Commission. 

10:15 - 11:45  Effectiveness 

This session focused on the extent to which the objectives of the Zoos Directive have been 
met,  and  any  significant  factors  which  may  have  contributed  to  or  inhibited  progress 
towards meeting those objectives. 

11:45 - 12:30  Efficiency 

This session considered evidence on the costs and administrative burden associated with the 
Directive,  whether  they  are  reasonable  and  proportionate  to  the  results  achieved,  and  any 
evidence of excessive costs or unnecessary administrative burdens and the reasons for them. 

12:30 - 14:00  Lunch break 
14:00 - 15:00  Coherence and Relevance 

This session considered the coherence of the legislation with other policies and legislation, 
including complementarities and/or contradictions that might be standing in the way of their 
effective  implementation  or  preventing  the  achievement  of  their  objectives.  It  will  also 
cover  the  correspondence  between  the  objectives  of  the  Directive  and  the  current  (legal, 
policy and scientific) situation. 

15:00 - 16:00  EU added value 

This  session  focused  on  the  extent  to  which  the  objectives  of  the  Zoos  Directive  are 
consistent with the needs of species, whether the Directives have made a difference beyond 
what would have happened if they had not existed and if so, how. 

16:00 - 16:30  Coffee break 
16:30 - 17:00 

Final discussion and concluding remarks 

Feedback from participants 
Concluding remarks Commission 

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2  PARTICIPANTS 

The selection and invitation of the workshop participants is crucial to the success of the workshop to 
ensure  that  the  results  have  been  rigorously  tested.  The  study  team  discussed  this  issue  with  DG 
Environment and ensured that selected invitees were informed of the workshop and its date as soon as 
possible. The key stakeholders to be invited to the event were from different sectors and institutions, 
including amongst others:  

  Representatives  of  the  European  Commission,  across  policy  units  in  e.g.  DG  ENV,  DG 

GROW, DG TRADE, DG DEVCO, DG EAC, DG RTD and the Secretariat General; 

  Representatives  of  Member  States,  including  governments  and  agencies,  regional  and  local 
authorities, environmental / nature conservation authorities and other relevant authorities (e.g. 
inspectorates); 

  Sectoral representatives (such as zoo operators.); 
  NGO representatives and civil society;.  

The  study  team  based  the  invite  list  on  the  stakeholders  contacted  for  the  targeted  surveys.  The 
contacted  stakeholders  were  encouraged  to  disseminate  the  invitation  to  any  relevant  stakeholder. 
Given  the  limited  number  of  possible  participants  (i.e.  100),  it  was  however  clearly  stated  that 
participation could, if needed, be limited to a maximum of one representative per organisation. 

Registration to the workshop was done online through a registration form based on Google forms. The 
registration  form  was  open  between  27  February  and  10  May  2017.  Stakeholders  first  had  the 
possibility to highlight their interest in the workshop and provide all relevant information (profile of 
stakeholder, security details for accessing workshop facilites). Upon review of the list of registrations, 
the  study  team  sent  confirmation  of  registration.  The  timeline  for  contacting  and  informing 
stakeholders  about  the  workshop  is  illustrated  in  the  Table  below.  The  full  list  of  the  81  attending 
participants (including the study team and the European Commission) is presented in Annex I to this 
report. 

Table 81 – Contacts with workshop participants 

Date 

Contact 

27.02 

Sent out invitations (personalized emails) and link to the registration form to:  

  Competent Authorities (MSCA) (49); 
  Survey participants: NGOs, Zoos, Zoo associations, Other federations (80); 
  Experts/Academia (7). 

10.03 

Sent out reminders to all non-responding contacts 

20.03 

Sent out reminders (personalized emails) to non-responding competent authorities 

23.03 
- … 

Sent  confirmation  of  attendance  emails  after  Commission  approval,  including  venue  and  logistical 
details 

28.03  Disseminating  reminders  supported  by  European  Commission  letter  to  non-responding  competent 

authorities 

02.05 

Sent  out  the  Agenda  and  Workshop  Background  Note  (see  section  3  on  workshop  materials)  to  all 
confirmed participants (including a reminder of the venue and logistical details for the meeting). These 
two  documents  were  also  sent  progressively  to  newly  confirmed  participants,  alongside  the 
confirmation email. 

10.05 

Sent out the meeting’s presentations and list of participants to all confirmed participants (as well as the 
agenda and background document anew, as a reminder) (see section 3 on workshop materials).  

15.05 

Sent out an email to all participants reminding them about the venue address and access.  

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3  WORKSHOP MATERIALS 

To ensure meaningful discussions focused on the findings (and  gaps) of the study team, participants 
were provided with a range of  materials informing  them on the progress done on this study  and the 
findings reached: 

  All  reports  and  documents  provided  on  the  website  dedicated  to  the  evaluation  exercise506, 

including: 

o  The evaluation roadmap; 
o  The reference database; 
o  The Targeted Surveys Report; 
o  The Interviews Report; 
o  The Public Consultation Report. 

  The Workshop Background Note that summarized the findings of the Draft Evaluation Report 
(see Annex II) was communicated to all participants to the workshop two weeks ahead of the 
workshop (i.e. on 2 May 2017); 

  All the presentations prepared by the study team (see Annex III) were sent to the participants 

one week ahead of the workshop (i.e. on 10 May 2017). 

506 http://ec.europa.eu/environment/nature/legislation/refitzoosdirective/index_en.htm  

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4  SUMMARY OF DISCUSSIONS 

The discussions on all the agenda items were structured in the following manner: 

1.  Introduction  and  chairing  by  the  European  Commission  (Humberto  Delgado  Rosa  for  the 

introduction; Michael O’ Briain for the other points); 

2.  Presentation by the study team of the emerging findings (see presentations in Annex III); 
3.  Discussion chaired by the European Commission. 

The following sections summarize the key points expressed during the discussions. 

4.1  GENERAL DISCUSSION 

4.1.1  Welcome speech 

Welcome speech by Humberto Delgado Rosa (European Commission, Director of Directorate 
D – Natural Capital) 

  Looking back at the situation in 1980, many zoos did not meet any standards, very few 
zoos had concerns on conservation. Only five out of 12 MS had legislation on zoos, more 
focused on animal welfare and licensing than on conservation activities. 

  The  greatest  efforts  for  the  conservation  and  sustainable  use  of  biodiversity  must  of 
course focus primarily on measures in the wild. This is reflected in EU nature legislation 
(Birds and Habitats Directives), EC wildlife trade regulations implementing  CITES, the 
IAS  Regulation,  the  EU  2020  biodiversity  goals  and  of  global  action  under  the 
Convention on Biological Diversity & other international agreements. 

  However,  as  more  species  and  habitats  decline  and  an  increasing  number  of  wild 
populations need management, the role of ex situ conservation becomes more important. 
The Zoos Directive responds to these needs by implementing Article 9 of the CBD which 
lays down the requirements for ex situ conservation. 

  The  first  key  findings  from  the  evaluation  study  show  that  a  licencing  and  inspection 
system has been established in all 14 Member States subject to the evaluation. Zoos are 
implementing  conservation  measures  required  under  Article  3  of  the  Directive  but  to  a 
different extent.  The Zoos Directive created  a common legal framework with  minimum 
requirements applicable to all zoos with positive effects mainly on zoos which were not 
part  of  zoo  associations.  However,  implementation  and  enforcement  issues  remain  and 
the  overall  impact  of  the  Directive  on  the  protection  of  wild  fauna  and  conservation  of 
biodiversity is subject to debate.The purpose of the evaluation exercise is to look at what 
worked,  what  did  not  work  in  the  implementation  of  the  Directive,  and  why.  Which 
objectives  were  achieved,  which  were  not.  The  study  of  the  consultants  gathers  the 
evidence and provides findings upon which the evaluation carried out by the Commission 
will be based. 

  Many  stakeholders  provided  constructive  inputs  to  the  study  through  the  different 
consultation processes. The workshop is the last consultation to discuss the results of the 
evidence gathered and the findings of the study. All relevant information can be found on 
the REFIT evaluation website.  

  The  objective  of  the  workshop  is  to  identify  missing  information  and  potential 

misinterpretations. 

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4.1.2  Approach and methodology 

Presentation by Nathy Rass-Masson (Milieu Ltd) (see Workshop Background Note in Annex II 
and slides in Annex III) 

4.1.3  Discussion 

  Objectives  of  the  study  -  The  study  will  be  the  key  source  of  information  for  the 
Commission  to  evaluate  the  Directive.  It  is  important  to  obtain  as  comprehensive  and 
representative  data  in  this  study  as  possible  in  order  to  allow  a  meaningful  evaluation 
process  by  the  Commission.  Focus  of  the  Commission  is  to  answer  to  the  4  evaluation 
questions  on  effectiveness  to  understand  the  progress  made  compared  to  general  and 
specific  objectives  set  in  the  Directive.  Key  mechanisms  in  place  are  the  licensing  and 
inspection  systems  applicable  to  all  zoos.  Evidence  gathering  is  therefore  heavily 
dependent on the feedback from the Member States’ Competent authorities and the zoos 
community. Unfortunately, the contributing zoos are a very small sample of the overall 
EU zoos community. This is a point that both the study team and the Commission bear in 
mind.  This  being  said,  it  is  key  to  ensure  peer  review  through  this  workshop  of  the 
findings achieved on this basis.  

  Data  collection  and  monitoring  -  The  360  Species  database  could  be  used  to  (partly) 
tackle the issue of lack of historical data. The system gathers more than 40 years of data 
on species conservation in hundreds of zoos. The Aichi Target 19 underlined that species 
data  is  essential:  Species  360  partly  addresses  that  need,  although  it  focuses  on  ex-situ 
conservation. Only EAZA members are required to take part in 360 Species system – this 
system  is  worth  mentioning  as  a  tool  for  all  zoos  to  report  and  monitor  their  zoos 
collections. 

  Data  limitations  on  surveys  -  The  number  and  types  of  zoos  that  responded  to  the 
targeted surveys is not representative of the situation in all EU zoos. 70 zoos represent a 
limited  number,  among  which  there  is  a  strong  overrepresentation  of  EAZA  zoos  (37) 
compared  to  the  share  of  EU  zoos  that  are  members  of  EAZA  (circa  17%).  The  study 
must  underline  this  limitation  in  relation  to  the  findings  based  on  the  answers  to  the 
targeted survey of zoos.  

  Questionnaires from other actors - Zoos received several questionnaires also from other 
actors  (such  as  NGOs)  outside  the  scope  of  this  evaluation.  This  was  reported  by  a 
stakeholder as a cause for confusion. This situation led to uncertainty as to the use of the 
answers, and induced some reluctance in providing too extensive information.  

  Positive impacts - The background note seems to overlook some of the positive impacts 
of  the  Zoos  Directive  on  biodiversity  conservation,  in  particular  regarding  financial 
contribution  to  conservation  projects,  e.g.  EAZA  invested  about  EUR  9,7  million  in 
projects across many countries. 

  MS  selection  -  The  selection  of  14  Member  States  for  the  targeted  survey  and 
interviews  is  a  consequence  of  the  terms  of  reference  for  the  study  that  the 
contractors had to follow and represent a wide variety of EU countries, although 
only half of them.  However, the public consultation and evidence gathering were open 
to stakeholders of all 28 Member States. All stakeholders were invited to provide further 
evidence and inputs in writing by 30 May 2017. 

  Wording and access to public consultation – Some zoos visitors found it very difficult to 
access and answer to the public consultation. Its accessibility and its drafting  may have 
been too complex for a wide public. 

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  Reaching  out  to  stakeholders  -  The  overall  consensus  reached  during  this  workshop 
should not underestimate that the key difficulty is to access and convince the stakeholders 
who have not shown interest in participating in the evaluation process. 

4.2  EFFECTIVENESS 

4.2.1  Presentation 

Valentina Parziale and Nathy Rass-Masson (Milieu Ltd) (see Workshop Background Note in 
Annex II and slides in Annex III) 

4.2.2  Discussion 

  Licensing  and  inspection  requirements  -  Implementation  of  licensing  and  inspection 
requirements  is  challenging  for  competent  authorities  in  terms  of  the  resources  and 
knowledge that must be mobilized. It was reported that there are still many non-compliant 
zoos  across  the  EU,  which  leads  to  unfair  and  unacceptable  competition  for  well 
performing and dedicated zoos.  

  Further support from zoos associations - Stakeholders in general underlined the need to 
translate and disseminate the Good Practices Document, to set up a platform for exchange 
to  identify  means  of  improving  licensing  and  inspection;  and  further  support  for 
inspection.  In  some  aspects  EAZA  and  national  zoo  federations  could  support 
competent authorities and contribute to this support to the implementation of the Zoos 
Directive,  although conflict  of interest  should be prevented, leaving the  authority 
fully in hands of the competent authorities. 
Importance of captive breeding - Captive breeding had an impact on wider conservation 
–  which  the  background  note  does  not  stress  sufficiently.  68  species  targeted  by 
conservation measures saw an improvement in their conservation status, in 17 cases zoos 
were involved.. 25% of conservation measures were due to captive breeding. This points 
to  the  importance  of  the  role  of  zoos  in  wider  biodiversity  conservation.  The  incentive 
induced by the Directive for zoos to further engage in conservation is critical.  

 

  Complexity  of  conservation  -  Conservation  is  a  complex  issue:  the  background  note 
seems  to  overlook  the  scale  of  conservation’s  impacts.  The  Directive  itself  focuses  on 
macro-scale  conservation  (species  and  habitats  conservations).  Essential  components  of 
conservation  successes  include  the  management  of  the  supply  chain  and  consumer 
demand on problematic resources. The assessment of the Directive seems to only look at 
the  success  criteria  related  to  public  education  and  awareness  raising  –  which  are  only 
some of the essential components of conservation successes: others should be considered. 
It was mentioned that the EU can have a huge impact on several CBD Targets, including 
Target  19  on  knowledge  improved,  shared  and  applied.  In  this  regard,  the  Commission 
mentioned that the study is focused on the implementation of the Zoos Directive and its 
achievements  rather  than  the  overall  EU  policy  in  the  area  of  conservation.  It  was  also 
specified  by  the  Contractor  that  the  study  does  not  look  at  the  content  of  conservation 
measures or at single conservation  measures adopted by individual zoos (that is outside 
the scope). The logic of the Zoos Directive is to set up licensing and inspection systems 
that ensure conservation measures are included as part of zoos activities. 

  Research - Stakeholders felt that zoos research performance was judged too negatively in 
the key findings. Zoos perform a lot of research that might not be immediately visible and 
might  not  always  be  published.  Zoos  are  often  not  considered  as  co-authors  by 
academics. There's a huge contribution of zoos to research on veterinary issues. 

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  Animal  welfare  -  To  ensure  conservation,  it  is  important  to  have  healthy  animals.  The 
conditions  under  which  animals  are  kept  in  zoos  therefore  cannot  be  ignored. 
Stakeholders  indicated  the  general  need  for  measurable  indicators  to  evaluate  the 
implementation of Article 3 measures (e.g. biological indicators like natural behaviour for 
Article  3  3rd indent).  However,  it  was  noted  that  the  consultant  did  not  consider  animal 
welfare as specific study target, but that the focus was on the Zoos Directive's main goal 
of biodiversity conservation.  

  EC support – Bearing in mind that the Zoos Directive is strongly based on the principle 
of  subsidiarity,  which  implies  that  limited  means  of  action  were  conferred  to  the  EC, 
stakeholders urged the Commission to further support MS and zoos in implementation:  
o  Through  funding  – including increase visibility of available funding  instruments to 

zoos. 

o  Through  enforcement.  Infringement  procedures  triggered  important  changes  and 

improvements of implementation; and increased standards e.g. Iberian lynx. 
  Through greater involvement in coordination, for instance by ensuring translation of the 
Good  Practices  Document,  which  was  acknowledged  as  extremely  useful  to  the 
implementation  of  the  Directive,  and  dissemination  of  the  Document,  by  setting  up  a 
platform for exchange of information between stakeholders (in particular for inspectors/ 
enforcement authorities). Entertainment - Entertainment in zoos (e.g. animal shows) did 
not  seem  covered  in  the  background  note;  nor  does  it  focus  on  whether  or  not  animals 
display natural behaviour. In this respect, it was reported that the 3rd indent of Article 3 is 
extremely vague. 

  MSCAs knowledge and resources limitations - MSCAs struggle to have the appropriate 
knowledge  to  properly  carry  out  inspections.  It  is  a  very  specialist  field  for  which 
consultation  of  experts  and  coordination  are  needed.  In  this  regard,  a  stakeholder 
suggested  the  creation  of  a  database  of  international  experts  in  order  to  support  and 
improve licensing and inspections, while ensuring independence. It is important to reach 
out  to  MSCAs  to  understand  their  needs  and  constraints  in  terms  of  resources  and 
knowledge. Training are not adapted to the gaps and needs of each MSCA. This point is 
developed  in  the  2016  Born  Free  report  on  training  needs  of  MSCAs.  The  report 
underlines  the  serious  lack  of  knowledge,  expertise  and  resources  of  MSCAs.  More 
comprehensive and coordinated training program is needed.  

 

  Other positive impacts – It was noted that the increase in the number of members of zoos 
associations can be linked to the Zoos Directive that urged zoos to increase conservation 
activities. 
Interlinkages between in  situ and ex situ conservation - The interlinkages between in-
situ and ex-situ conservation projects ran by zoos are extremely important. Such projects 
are  however  not  well  documented,  hence  a  limited  public  awareness  of  the  existing 
interlinkages.  

  Understanding of in situ conservation  – In situ conservation in the background note is 
very  much  focused  on  re-introduction  of  species.  In-situ  conservation  mostly  covers 
protection of wild population and a wider range of measures which should be reflected. In 
that  respect,  re-introduction  of  species  is  exceptional  and  minor.  The  most  important 
contribution of zoos to biodiversity conservation is through the protection of wild species 
still in the wild. The EAZA database provides many examples of such actions. It was also 
mentioned  that  zoos  work  a  lot  with  local  or  regional  authorities  to  contribute  to  the 
protection of local protected areas or species (examples of amphibians threatened by the 
chytrid fungus, protection of vultures, captive breeding of hamsters, corncrakes). 

  Education - With the continued growth in the share of urban population, providing links 
to  wildlife  has  become  increasingly  important.  The  best  places  for  such  connection  are 
zoos – rather than natural habitats. Climate change will heavily impact wild populations 

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that can easily be protected in zoos, such as amphibians. The educational impact of zoos 
is  published  and  documented.  It  is  clear  from  research  that  zoo  visitors  are  much  more 
aware of the  value of wildlife compared  to non-visitors. Research shows that providing 
species  information  is  not  sufficient  to  induce  behaviour  changes.  This  finding  is  quite 
recent  and  changes  in  the  information  provided  to  the  public  and  zoos  educational 
programmes  are  taking  place  at  the  moment.  However,  while  it  is  hard  to  achieve  and 
measure long-term changes in behaviour due to zoos visits, smaller achievements should 
be recognised as well, such as cherishing  nature. It was otherwise  mentioned that long-
term  impact  on  behaviour  is  questioned  in  the  study.  Research  demonstrated  that 
educational programs of zoos are more effective than school education. Zoos are asked by 
international  conservation  bodies  (e.g.  IUCN)  to  step  in  conservation  activities:  this 
recognises  the  role  of  zoos  at  an  international  scale.  Finally,  the  background  note 
contained  only  questions  to  quantitatively  assess  education  measures  in  zoos  –  without 
consideration of quality and content. It would be useful to have better understanding of 
the content of the education programmes – although it is beyond the scope of this study. 
  Enforcement  –  All  stakeholders  considered  that  the  Zoos  Directive  is  a  very  important 
piece  of  legislation:  it  ensures  consistency  in  performance,  status  and  standards.  The 
background note however seems to overestimate the progress achieved in enforcement: a 
lot  of  improvements  remains  to  be  done.  This  assessment  is  backed-up  by  the  EU  Zoo 
Inquiry that Born Free carried out across EU zoos.  

 
  Contributing factors – The study should acknowledge the role of: 

o  NGOs in providing valuable information directly to MSCAs, and in giving training 
to  e.g.  veterinarians  and  other  practitioners  (e.g.  Born  Free  in  collaboration  with 
EAZA).  

o  The  study  should  not  judge  zoos  too  harshly.  No  zoo  was  created  from  the  outset 
with the primary objective of promoting conservation. But zoos increasingly include 
those  objectives,  and  carry  out  numerous  relevant  activities.  The  importance  of 
conservation  activities  in  zoos  at  a  small  scale,  i.e.,  at  local  level,  should  also  be 
mentioned.  

o  The  work  done  by  veterinarians  in  zoos  is  also  a  significant  contribution  to 
conservation. Veterinarians carry out substantial research, including in the context of 
the One Plan Approach. This may however not be very visible because their work is 
not published in conservation oriented reviews. 

  Hindering factors  

o 

It  was  underlined  that  the  alternative  wording  of  Article  3,  first  indent,  of  the 
Directive constitutes a factor hindering its effectiveness. Only some Member States 
e.g. Italy have established all the measures of Article 3, first indent, as mandatory. 
The  wording  of  Article  3,  3rd  indent,  was  felt  by  several  stakeholders  to  be  vague 
and to allow for abuse and misinterpretations. 

o  Article  2  should  include  clearer  requirements  for  exemptions.  This  seems  to  be 

particularly problematic in Italy. 

o  The  broad  definition  of  ‘zoos’  might  limit  the  effectiveness  of  the  Zoos  Directive. 
Zoos  as  defined  and  regulated  by  the  Zoos  Directive  should  have  conservation 
activities, and should not only be decent animal enclosures. On the other hand, some 
stakeholders expressed the opinion that the Directive should be extended to cover all 
institutions that have wild animals in human care, including sanctuaries.  

  Call  for  more  regulation  –  The  Zoos  Directive  triggered  the  adoption  of  legislative 
measures  at  national  level.  Some  national  stakeholders  said  that  more  stringent/binding 
means of improving implementation should be considered. 

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4.3  EFFICIENCY 

4.3.1  Presentation 

Valentina Parziale (Milieu Ltd) – (see Workshop Background Note in Annex II and slides in 
Annex III) 

4.3.2  Discussion 

  Data limitations – It is acknowledged by the Commission that given the lack of reporting 
and monitoring obligation, very limited information was available on costs. Besides, all 
legislative actions have costs. The focus of the study is on disproportionate, unnecessary 
costs. The study tried to isolate costs of Zoos Directive compared to other legislations. It 
was  made  as  clear  as  possible  in  questionnaires  and  interviews.  But  it  is  difficult  for 
stakeholders  to  disentangle  the  different  costs.  Hence  no  clear  quantitative  finding  was 
produced regarding the costs triggered by implementation. 

 

  Proportionality of costs and overall efficiency– In the light of the increased focus in the 
fight against illegal trade, the inspection and licensing schemes required by the Directive 
are increasingly essential. The costs induced by the legislation definitely seem necessary. 
Concerning the costs that competent authorities must bear, measures to reduce them are 
possible,  such  as  the  combination  of  inspections  by  different  authorities.    Costs  of 
implementing  Zoos  Directive  are  very  low  compared  to  costs  under  other  legislations 
(animal welfare laws for instance). It was also mentioned that the Zoos Directive is the 
most  efficient  instrument  possible  for MS  to  implement  Article  9  of  the  CBD.  There  is 
still a lot to do, but the Zoos Directive was the most efficient tool – with very low costs. 
Involvement  of  zoos  and  zoos  association  in  the  licensing  and  inspection  system:  the 
Dutch example of self-screening of its zoos by the Dutch Zoo association was mentioned 
as a good practice to reduce costs and effort for competent authorities as they could work 
more  risk-based  and  focus  more  on  zoos  without  such  self-inspection.  A  multi-
stakeholder  process  to  support  licensing  and  inspection  was  mentioned  as  an  option  to 
increase  efficiency.  It  was  nevertheless  pointed  out  that  it  should  not  give  rise  to 
overrepresentation of the interests of particular stakeholders’ group (i.e. animal welfare, 
zoos associations). A committee of experts to support MSCAs in the implementation of 
the  Directive  was  suggested.  It  was  suggested  that  regional  federations  could  also 
contribute, especially in states where there are no national federations, or where national 
federations  do  not  have  a  screening  process.  A  non-decisive  role  as  advisor  to  the 
competent authorities was considered important to ensure impartiality. 

  Costs of ex-situ conservation - The costs of ex-situ breeding are hard to tackle, only zoos 

can take care of it – this should be further underlined in the report.  

  Closure  of  zoos  -  Zoo  closures  induce  important  costs  for  society.  Often  no  rehoming 
options  are  introduced  by  zoos;  and  NGOs  and  rescue  centres  will  be  involved  in  the 
relocation  of  animals.  This  cost  should  not  be  placed  on  citizens  to  address  animal 
welfare aspects. Article 6  on closure of zoos places too much responsibility on a single 
MSCA/department.  Further  support  from  guidance  document  is  needed.  A  multi-
stakeholder  approach  should  be  favoured  in  order  to  keep  the  process  as  transparent  as 
possible – for both closure and inspection. 

  Organisation  of  MSCAs  -  Often  competencies  are  shared  across  different  ministries 
(agriculture/environment).  When  responsibility  is  shared,  there  tends  to  be  a  lack  of 
coordination and exchange among the competent authorities. There is also often a lack of 
communication between zoos and authorities. Observations by MSCAs pointed out: 

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o  Italy  -  The  Italian  Environment  Ministry  is  the  only  competent  authority  for  the 
implementation of the Directive. But it cooperates with experts from other ministries 
as support for the implementation. 

o  Belgium  -  Differences  singling  out  Belgium  compared  to  other  countries  can  be 
explained by the fact that Belgium already had a system in place before the adoption 
of the Zoos Directive. Hence no cost could be pointed as due to the implementation 
of  the  Directive  itself.  The  supervision  of  zoos  and welfare  is  a  shared  priority  for 
many  authorities  in  Belgium,  and  competences  are  divided  between  different 
ministers.  They  try  to  cooperate,  but  sometimes  the  objectives  of  what  the 
supervision  entails  are  not  clear.  Some  objectives  lack  clarity,  such  as  on  animal 
welfare. Therefore, there is room for improvement for them: to clarify the objectives 
of  the  Directive  will  facilitate  supervision.  The  problem  is  that  the  wording  of  the 
Directive is not without ambiguity.  

4.4  COHERENCE 

4.4.1  Presentation 

Nathy Rass-Masson (Milieu Ltd) – (see Workshop Background Note in Annex II and slides in 
Annex III) 

4.4.2  Discussion 

  The  Directive  is  coherent  with  EU  legislation  on  biodiversity  and  animal  welfare.  No 

 

issues of incoherence were raised. 
IAS  Regulation  –  The  implementation  of  the  Directive  is  fully  coherent  with  the  IAS 
Regulation so far, but some stakeholders consider that inconsistencies might occur in the 
future when other species may be included in the IAS list. Therefore, coherence between 
the two acts should be monitored also in the future. 

  Balai  Directive  -  The  Zoos  Directive  and  the  Balai  Directive  strengthen  each  other 
through the licensing requirements and the need to guarantee high quality  veterinary care. 
Both instruments are important and mutually reinforcing. 

4.5  RELEVANCE 

4.5.1  Presentation 

Philip  McGowan  (VetEffecT)  –  (see  Workshop  Background  Note  in  Annex  II  and  slides  in 
Annex III) 

4.5.2  Discussion 

 

  Biodiversity crisis – There is an increased importance of ex-situ conservation in the light of 
the biodiversity crisis. Zoos and zoos associations are relevant actors to highlight it to the 
attention of the public. The biodiversity crisis shows that zoos might hold species that are 
not yet threatened but that can become threatened in the near future. 
Implementation of CITES - It is important to underline the relevance of the Zoos Directive 
for the implementation of CITES. Zoos and record keeping have a very important role in 
fighting  illegal  trafficking.  Record  keeping  in  a  shareable  format  should  be  part  of  the 
requirements of the Directive. It is also a key material for policy-maker to enable informed 
decision  making.  The  Article  3  record  keeping  is  too  broad,  and  does  not  allow 
connectivity of information. The key benefit of record keeping is to share the information. 

  Cross-border  aspects  –  There  is  an  international  component  to  the  exchange  of  data.  An 
international framework should be put in place and interphases should be better used. 

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  Academic research and the role of zoos - Academia could generate better and more useful 
research for practitioners and zoos. The amount of research available is not reflected in the 
background  note.  There  is  a  huge  increase  of  research  on  wildlife  in  controlled 
environment  offered  by  zoos.  The  relevance  of  zoos  in  that  sphere  should  be  further 
emphasised. There is a wide range of academic research on wildlife. It is a varied and quite 
dispersed  literature.  Historically,  zoos  have  not  always  been  given  co-authorship  on 
research taking place in their facilities. This might lead to underestimating the amount of 
research  carried  out  by  zoos.  What  would  be  more  useful  is  to  have  a  holistic  research 
strategy for zoos. 

  Management  plans  and  captive  breeding-  To  improve  contribution  of  zoos  to 
conservation,  zoos  could  adopt  well-developed  management  plans  and  Member  States 
could  set  up  wild  animal  management  plans  at  national  level.  The  EU  Zoo  Inquiry 
concluded  that  zoos  underperform  when  it  comes  to  species  conservation,  information 
provided to the public, educational programmes, share of threatened species, participation 
in coordinated breeding programmes. Some stakeholder called for an EU wide strategy or a 
centralised  multi-stakeholder  process  identifying  which  species  need  conservation 
measures how, where, by whom. Some participants argued that focus should be placed on 
EU  threatened  species  –  which  are  currently  underrepresented  in  zoos.  Depending  on 
numbers  presented,  between  5%  and  27%  of  EU  threatened  species  are  in  zoos.  The 
opinions on the value of keeping non-threatened species in zoos varied. For some, species 
that are not yet vulnerable should also be prioritised in captive breeding to avoid losing an 
opportunity  to  ensure  their  protection,  and  species  of  least  concern  can  also  have  a 
conservation  value  for  their  endangered  relatives.  For  others,  captive  breeding  is  not  the 
best answer for threatened species, and there is a need to carefully review where resources 
are placed to ensure the best use.  

  The framework nature of the Directive – there is a benefit to the fact that the Directive is a 
framework act and not too prescriptive. Because of its framework nature, the Directive can 
adapt to new developments.  

4.6  EU ADDED VALUE 

4.6.1  Presentation 

Lucie Meura (Milieu Ltd) – (see Workshop Background Note in Annex II and slides in Annex 
III) 

4.6.2  Discussion 

  Progress  in  harmonization  -  EU  legislation  was  an  important  catalyst  for  adoption  of 
legislation at national level, and, though the Zoos Directive leaves an important margin of 
interpretation, there is a certain level of harmonization through minimum standards.  
The existence of the Directive has raised political interest and action. The Zoos Directive 
is a framework that pushes implementation not only by MSCAs but also at the level of 
cities  and  communities.  An  EU  Directive  makes  a  big  difference.  A  tremendous  gap 
remains  among  zoos  in  particular  in  respect  of  conservation.  Most  conservation  and 
coordination  take  place  through  EAZA  and  other  associations.  A  noticeable  gap  exists 
between  zoos  that  are  members  of  associations  and  zoos  that  are  not  members:  the 
Directive is key in bridging this gap. The difference is made obvious in countries outside 
of  the  EU  where  no  legislation  ensures  that  minimum  requirements  are  applied  to  all 
zoos. 

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  Cross-border nature of conservation issues - Conservation is not a national issue; it is an 
international  issue  with  important  cross-border  implications.  It  should  not  be  left  to 
national levels.  

  Role of EC –The EC has an important role to play through enforcement procedures, but 
also in ensuring the data can be gathered, monitored and exchanged. Given the principle 
of  subsidiarity,  the  role  of  the  EC  is  limited  but  stakeholders  expressed  the  view  that 
further  coordination  would  be  useful,  maybe  in  line  with  the  coordination  implemented 
by DG SANCO on food. 

  Consequences of removal of the Directive - Removing the Directive would have many 
unpredictable outcomes. Zoos that are part of organisations are likely to keep standards. 
Others will not. The gap between “good” and “bad” zoos would be expected to increase. 
Illegal trade would be expected  to soar. Animal welfare would be  expected  to collapse. 
Similarly, gaps would be expected to appear between Member States: Member States that 
went beyond the requirements of the Directive and effectively implemented it are likely 
to  keep  the  existing  legislation.  On  the  other  hand,  authorities  that  struggle  with 
implementation  might  get  rid  of  the  Zoos  Directive's  requirements.  There  was  broad 
consensus of stakeholders at the workshop that the instrument should be kept – supported 
by increased enforcement  and implementation. Besides, the Zoos Directive is needed to 
keep and raise veterinarian standards. 

4.7  NEXT STEPS 

Conclusions – summary of the key points: 

  Translation of Good Practices Document would be welcome by all stakeholders; 
  The Zoos Directive is not only still relevant, but is considered as more needed than ever in 

the context of the biodiversity crisis; 

  Stakeholders demonstrated a strong commitment to better implementation of the Directive; 
  Many good practices and good examples exist; 
  Overall a strategy is needed for holistic (ex situ and in situ) conservation. 

Next steps: 

  The study is about to be finalised. The feedback of stakeholders will be used exclusively 

for fine-tuning the current findings.  

  Targeted comments regarding the key findings, gaps, misrepresentations, missing evidence 

can be submitted by 30th May to zoos.directive@milieu.be  

  The study will be finalised by mid-July 2017. 
  This  will  be  used  by  the  Commission,  who  will  finalise  the  evaluation,  which  will  be 
published  as  a  Staff  Working  Document  ,  following  consultations  with  all  relevant 
Commission servicesThe aim is to publish this by the end of the year 2017. 

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5 

INCLUSION OF STAKEHOLDERS’ FEEDBACK 

The  points  raised  during  the  discussions  will  be  taken  into  account  for  the  revision  of  the  Draft 
Evaluation Report and the submission of the Final Evaluation Report in July 2017.  

Stakeholders were also encouraged to submit additional written comments by the 30th May 2017 to the 
functional email address of the study team (i.e. zoos.directive@milieu.be). Stakeholders were asked to 
submit  concise  comments  targeted  to  any  missing  information,  gaps  or  misrepresentation  that  they 
identified in the findings. The table below provides an overview of the comments that were received. 

Stakeholder 

Evaluation criteria  Topics covered 

MSCAs 

IT MSCA 

NL MSCA 

Federations 

Effectiveness  
Efficiency 

Wording of the Directive 
Involvement of federations in licensing and inspections 
Good Practice Document 

Efficiency 

Number of man days for inspection 

French  association  of 
zoological 
parks 
(AFdPZ) 

Effectiveness 
Relevance 
Coherence 

Wording of the Directive 
Involvement of NGOs in licensing and inspections 
Good Practice Document 
Closure of zoos 
Impact  of  zoos  on  biodiversity  conservation  through 
education of visitors, financing and holding of other than 
threatened species. 
IAS Regulation 

German  Wildlife  Park 
Association 

NGOs 

AssoVegan 

All criteria 

Completed survey addressed to zoos federations 

N/A 

Importance of animal welfare, and negative impact of zoos 
on conservation of biodiversity. 

Orca Research Trust and 
Fre morgan Foundation 

Effectiveness 

Points  to  be  clarified  in  the  wording  of  the  Directive  + 
Good Practice Document 

Endcap 

N/A 

Dolphinaria-Free Europe  N/A 

Born Free 

N/A 

Zoos 

Position  statement  on  the  EU  Zoos  Directive  REFIT 
Evaluation 

Position  statement  on  the  EU  Zoos  Directive  REFIT 
Evaluation 

Position  statement  on  the  EU  Zoos  Directive  REFIT 
Evaluation 

Zoological  Society  of 
East Anglia 

Effectiveness 

Emphasis on problems of implementation: importance and 
weakness of inspections. 

Academia 

Olivier 
University 
Montpellier 

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Duriez- 
of 

Effectiveness 

The  secondary  effect  of 
the 
importance  and  impact  of  a  successful  collaboration 
between  scientists  and  zoos  for  research  on  biology  and 
conservation of birds of prey 

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ANNEX I – LIST OF PARTICIPANTS 

No 

Surname 

Name 

Affiliation 

1  AGUZZI 

2  ALMUNIA 

3  ANDREWS 
4  ANGELINI 
5  ANSONE 

Irene 

Javier 

Brad 
Gaia 
Liene 

6  AVESANI ZABORRA  Cesare 
Sophie 
7  AYLMER 
Gary 
8  BATTERS 

9  CASTROGIOVANNI 

Federico 

10  CHRISTOFI 
11  CIRILLO 
12  CONDE OVANDO 

13  CRESS 
14  DELGADO ROSA 
15  DE RUIGH 

16  DI SILVESTRE 
17  DIEZ 

18  DOMB 
19  DUPONT 
20  EBERHADTNE 
BALOGH 

21  ENCKE 
22  ENDRE 

23  ERNY 
24  GODDARD 
25  GOERRES 

26  GRIFFITH 

Athena 
Pier Paolo 
Dalia 

Douglas 
Humberto 
Lisette 

Ilaria 
Alberto 

Eric 
Claire 
Anita 

Dag 
Papp 

Cécile 
Samantha 
Ute 

Myfanwy 

27  GRUNWELL 

Lily 

28  GRUSCHWITZ 

Michael 

29  HEß 

Karoline 

30  HÖGGREN 
31  EIRINAIOU 

32  FAGES 
33  KLAAS 

34  KÖGLER 

Mats 
Kallirroi 

Chloé 
Kristi 

Julia 

Public official, Zoo Commission, Ministry of environment, 
protection of the territory and of the Sea 
Responsible for research, education and conservation, Loro 
Parque, Spain 
President, European Association for Aquatic Mammals 
Campaigner, wild animals, LAV Animal Protection, Italy 
Veterinary and Food Department, Head of Division of Animal 
Welfare, Ministry of Agriculture 
Italian Association of Zoos and Aquaria - UIZA 
Parliamentary Assistant, European Parliament 
Council Member, British and Irish Association of Zoos and 
Aquariums 
Legal advisor, Ministry of environment, protection of the 
territory and of the Sea 
Consultant, Milieu Ltd 
Vice President, Animalisti Italiani Onlus, Italy 
Associate Professor (Max Planck/University of Southern 
Denmark)/Director of Science (Species360) 
Executive Director, World Association of Zoos and Aquariums 
Director, Directorate D – Natural Capital, DG Environment 
Chairman, WILDLANDS Adventure Zoo Emmen, The 
Netherlands 
Wildlife Programme Leader, Eurogroup for Animals 
NGO official contact point for zoos set up by the Spanish 
Ministry, ANDA (INFOZOOS) 
Chairman, PAIRI DAIZA, Belgium 
Consultant, Milieu Ltd 
Referent, Environmental Affairs, Nyíregyházi Allatpark 
Nonprofit Kft., Hungary 
Director, Tiergarten der Stadt Nürnberg, Germany 
Vice director of zoology, Nyíregyházi Állatpark Nonprofit Kft, 
Hungary 
Executive Director, French Association of Zoos 
Programmes Officer, The Born Free Foundation 
Administrative Agent, Directorate D – Natural Capital, Entity 3 
Nature Protection, DG Environment 
Executive Director, European Association of Zoos and Aquaria 
(EAZA) 
Research and communications intern, The Born Free 
Foundation 
EU-Representative of Environment and Agriculture, Ministry 
of Environment and Agriculture - Saxony 
Department for Species Protection, Federal Ministry for the 
Environment, Nature Conservation, Building and Nuclear 
Safety 
Director/CEO, Nordens Ark Foundation, Sweden 
Internaitonal Affairs, PanHellenic Animal Welfare and 
Environmental Federation 
Consultant, Milieu Ltd 
Head of section, Counsellor for environment, Permanent 
Representation of Estonia to the EU 
Deputy Executive Director, Association of the Zoological 
Gardens (Verband der Zoologischen Gärten (VdZ)) 

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35  KONIECZNA 
36  KORCZAK 
37  LAWRENZ 

Magdalena 
Malgorzata 
Arne 

Vice Head, Poznan Zoo, Poland 
Expert, General Directorate for Environmental Protection 
Chair of the veterinary committee, European Association of 
Zoos and Aquaria (EAZA) 
CEO, Zoomarine, Italy 

Renato 
Jean-Louis  Manager of the falconry team, Grand Parc du Puy du Fou, 

38  LENZI 
39  LIÈGEOIS 

40  LISKER 
41  LOIR 
42  MACH 

Rosina 
Joël 
Jiri 

43  MALJKOVIC 

Davorka 

44  MANTECA 
45  MCGOWAN 
46  MCKEOWN 

47  MEURA 
48  MOORE 

49  MORENO 

50  MORITZ 

51  NOTARO 

52  NUIJTEN 

53  O'BRIAIN 

54  PANDURSKA 

55  PANINI 

56  PARZIALE 
57  PEREBOOM 

58  PFENDER 
59  RASS-MASSON 
60  ROOSE 

61  ROSSI-CROY 
62  SANDERSON 

63  SCHALLER 
64  SCHMIDT 

65  SCHRIJVER 
66  SOTO-LARGO 
67  STEFANOVA 
68  SVAMPA 

69  TAVZES 

70  THORPE 
71  TURNER 

Xavier 
Philip 
Sean 

Lucie 
Alan 

María 

Johanna 

Nicola 

Jacobus 
(Daniel) 
Michael 

Elena 

Laura 

Valentina 
Jeffrey 

David 
Nathy 
Eveline 

Cornelia 
Stephanie 

Marek 
Harald 

Remco 
Barbara 
Diana 
Gloria 

Branka 

Susannah 
Daniel 

France 
Board Member, Free Morgan Foundation 
Veterinary Expert, Public Service of Wallonia - Animal welfare 
Head of Unit of International Conventions, Deputy Director, 
Department of Species Protection and Implementation of 
International Commitments, Ministry of Environment 
Vice director, Head of research and development, Zoological 
Garden of Zagreb, Croatia 
Researcher, Autonomous University of Barcelona, Spain 
Consultant, VetEffect 
Director, Fota Wildlife Park, Ireland & Vice-Chair of the 
British and Irish Association of Zoos and Aquariums 
Consultant, Milieu Ltd 
Assistant Principal, Zoo Licensing, Department of Arts, 
Heritage, Regional, Rural & Gaeltacht Affairs 
Scientific Expert, Spanish Foundation for Advice and Defense 
of the Animals (FAADA) 
Head of Animal Welfare department, Bavarian Health and 
Food Safety Authority 
Head of Unit, Directorate D – Natural Capital, Entity 3 Nature 
Protection, DG Environment 
EU Policy Manager, Planckendael Zoo, Belgium 

Deputy Head of Unit, Directorate D – Natural Capital, Entity 3 
Nature Protection, DG Environment 
Senior expert European Programmes and Projects, Municipality 
of Blagoevgrad, Bulgaria 
Wild animals-projects and research, LAV Animal Protection, 
Italy 
Consultant, Milieu Ltd 
Professor of Conservation Genetics (including Zoo Population 
Management), University of Antwerp, Belgium 
Policy Manager, Whale and Dolphin Conservation (WDC) 
Consultant, Milieu Ltd 
Policy advisor - exotic and laboratory animal, Flemish 
Environment, Nature and Energy Department 
Delegate, FVE 
Executive Director, European Association of Zoo and Wildlife 
Veterinarians 
Parliamentary Assistant, European Parliament 
General Curator/ Head Collection Management, Rotterdam 
Zoo, The Netherlands 
Consultant, VetEffect 
Spanish Ministry of Environment 
Chief Expert Ecologist, Blagoevgrad Municipality, Bulgaria 
Scientific Consultant for EAZA and International Relations, 
Parco Faunistico La Torbiera, Italy 
Undersecretary, Ministry of the environment and spatial 
planning 
Zoologist, University of Birmingham, United Kingdom 
Associate Director, The Born Free Foundation 

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72  VAN DEN STEEN 

Wendy 

73  VAN AGGELEN 

Marielle 

74  VAN DER MEER 

Laura 

75  VERGOSSEN-OTTEN  Alide 
Ingrid 
76  VISSER 
Eckhard 
77  WIESENTHAL 

78  WIESENTHAL 

Pascale 

79  WÜNNEMANN 
80  ZGRABCZYNSKA 
81  ZODROW 

Klaus 
Ewa 
Laura 

Animal Welfare (Dienst Dierenwelzijn) – Flemish 
Environment, Nature and Energy Department 
Director, Dutch Zoos association (Nederlandse Vereniging van 
Dierentuinen) 
Legal representative, European Association of Aquatic 
Mammals 
Policy Officer Animal Welfare, Ministry of Economic Affairs 
Founder & Principal Scientist, Orca Research Trust 
President, German Wildlife Park Association (Deutscher 
Wildgehegeverband e.V.) 
Ethologist (Wolf specialist), Member of the Scientific Advisory 
Board, German Wildlife Park Association (Deutscher 
Wildgehegeverband e.V.) 
CEO, Zoo Heidelberg, Germany 
Head, Poznan Zoo, Poland 
CEO, animal public e.V. 

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ANNEX II - WORKSHOP BACKGROUND NOTE 

INTRODUCTION 

The Zoos Directive 

Directive  1999/22/EC,  relating  to  the  keeping  of  wild  animals  in  zoos  (the  ‘Zoos  Directive’),  was 
adopted on 29 March 1999 and came into force in 2002. The Directive aims to fulfil the obligations 
deriving  from  the  1992  Convention  on  Biological  Diversity  (CBD)  to  adopt  measures  for  ex  situ 
conservation. Its objectives are ‘to protect wild fauna and to conserve biodiversity by providing for the 
adoption of measures by Member States for the licensing and inspection of zoos in the EU. In order to 
achieve these objectives, the Directive focuses on the role of Member States’ authorities in putting in 
place  a  system  for  inspection  and  licensing  of  zoos  to  ensure  that  zoos  implement  the  conservation 
measures listed in Article 3. 

The REFIT Programme and the evaluation study 

As  part  of  its  Smart  Regulation  policy,  the  Commission  initiated  the  Regulatory  Fitness  and 
Performance Programme (REFIT); a rolling programme that keeps the entire body of EU legislation 
under review and aims at making EU law more simple and less costly. The Zoos Directive is covered 
under the REFIT programme, meaning that its implementation needs to be evaluated by the European 
Commission.  

Milieu Ltd and VetEffecT were awarded a contract in June 2016 to carry out a study supporting the 
Commission in this evaluation. Based on the Commission REFIT Roadmap setting out the scope and 
terms  of  reference  of  the  Zoos  Directive  evaluation507,  the  purpose  of  this  supporting  study  was  to 
assess  the  relevance,  effectiveness,  efficiency,  coherence  and  EU  added  value  of  the  Directive  (the 
study is articulated around these five ‘evaluation criteria’, further divided in 16 ‘evaluation questions’) 
and  to  provide  an  evidence-based  judgement  to  support  the  REFIT  evaluation  carried  out  by  the 
Commission to inform future decisions relating to EU biodiversity policy and ex-situ conservation in 
particular.  

Methodology and sources of information 

The study gathered all available evidence in order to answer the 16 evaluation questions of the REFIT 
Roadmap.  To  this  end,  it  included  a  literature  review,  targeted  surveys  aimed  at  key  stakeholder 
groups  (i.e.  Member  States  competent  authorities  (MSCAs),  zoo  operators,  NGOs  and  zoo 
federations), in-depth interviews and a public consultation. The targeted surveys and interviews, and 
part of the documentary review, focused on 14 Member States (Belgium, Bulgaria, Cyprus, the Czech 
Republic,  Denmark,  France,  Ireland,  Italy,  Germany,  Lithuania,  the  Netherlands,  Poland,  Portugal, 
Spain) selected as representative case studies508. This in-depth research in the 14 Member States was 
complemented by the public consultation and general literature review, in order to broaden the scope 
and geographical coverage of the evaluation study to all Member States. 

The  targeted  surveys  received  answers  from  the  competent  authorities  of  the  14  selected  Member 
States, 13 NGOs, 13 zoo federations, 70 zoos and one expert509. In-depth interviews were carried out 
with  44  stakeholders  (13  MSCAs,  8  zoo  federations,  6  NGOs,  9  zoo  operators  and  8  EU  and 
international  stakeholders).  The  public  consultation  received  2297  answers  (1944  answers  from 

507 http://ec.europa.eu/smart-regulation/roadmaps/docs/2016_env_071_zoos_directive_evaluation_en.pdf  
508 This sample allowed the study to cover half of the EU Member States, and has been defined with the aim of satisfying the following main 
criteria: a mix of both smaller and larger (or densely populated) Member States, with a significant number of zoos; geographical coverage of 
the EU (balancing North/South, West/East) and of different administrative models (e.g. federal and centralised states, etc.); a combination of 
older and newer EU Member States , to assess different implementation periods; general availability of information, and different progress 
towards the implementation of the Zoos Directive, including Member States where issues related to the implementation of the EU legislation 
have been raised. 
509 39 NGOs were contacted (response rate = 59%); 22 zoo federations contacted (response rate = 33%); 514 zoos contacted (response rate = 
14%); 10 contacted experts, academia (response rate = 10%). 

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individuals,  148  from  zoo  operators,  21  from  business  or  business  representatives,  7  from  public 
authorities,  38  from  NGOs,  34  from  other  associations  and  105  “other”).  The  results  of  all 
consultations are published on the dedicated consultation website510. 

Purpose of the workshop 

The consortium presented its draft key findings to the European Commission in the first trimester of 
2017.  The  purpose  of  the  workshop  is  to  share  these  findings  of  the  supporting  REFIT  evaluation 
study  with  representatives  of  governments  and  stakeholders,  including  representatives  from  relevant 
economic  sectors  and  non-governmental  organisations  at  both  EU  and  national  level  directly 
concerned with implementation of the Zoos Directive to ensure that: 

important findings are not overlooked in the conclusions; 
there is no misrepresentation of evidence in findings; 
adequate regard is given to the different inputs and the evidence that supports different views. 

This Study will be a key contribution to the Zoos Directive evaluation, whose findings are intended to 
provide a solid and informed basis for any follow-up actions. 

In  order  to  enable  constructive  and  informed  discussions  during  the  workshop,  this  Background 
Workshop  Document  presents  the  key  findings  of  the  Study  per  evaluation  criteria.  Each  section 
contains  an  introduction  on  the  scope  of  the  criterion,  an  overview  of  the  sources  used,  the 
methodological challenges that were faced and the key findings underlined by the analysis.  

KEY FINDINGS 

Effectiveness 

This  section  analyses  the  extent  to  which  the  general  and  specific  objectives  of  the  Zoos  Directive 
have been achieved, notably:  

Protect wild fauna and conserve biodiversity by strengthening the role of zoos in the conservation of 

biodiversity (general objective);  

Ensure  that  zoos  implement  Article  3  conservation  measures  (i.e.  research  and  training  on 
conservation, exchange of information, captive breeding, repopulation or reintroduction into the 
wild;  promotion  of  public  education  and  awareness;  accommodation  of  animals  satisfying  the 
biological  and  conservation  requirements  and  a  high  standard  of  animal  husbandry;  prevent  of 
escapes  in  order  to  avoid  threats  to  indigenous  species  and  of  intrusion  of  outside  pest  and 
vermin;  keeping  appropriate  records  of  the  zoo’s  collection)  and  that  closures  of  zoos  are 
appropriately handled (specific objectives). 

In  order  to  achieve  these  objectives,  the  Zoos  Directive  places  obligations  on  Member  States 
authorities,  which  are  required  to  set  up  inspection  and  licensing  systems  and,  thus,  ensure  that  all 
zoos implement Article 3 conservation measures as a condition for them to operate and be open to the 
public.  The  setting  up  of  adequate  licensing  and  inspection  systems  and  the  implementation  of 
conservation  measures  by zoos  are  expected  to  result  in  a  strengthened  role  for  zoos  in  biodiversity 
conservation, increased knowledge and public awareness in relation to the conservation of biodiversity 
and, ultimately, in the protection of wild species and prevention of biodiversity loss.  

The  analysis  is  based  on  literature  and  documentary  review,  data  and  information  collected  through 
the targeted surveys and interviews, and the results of the public consultation.  

The supporting study was constrained by the limited amount of information on the baseline situation 
(i.e. before the entry into force of the Zoos Directive) and the lack of data on the implementation of 
the  Zoos  Directive,  as  there  is  no  reporting  obligation  for  Member  States  under  the  Directive. 

510 http://ec.europa.eu/environment/nature/legislation/refitzoosdirective/index_en.htm  

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Information  was  therefore  mainly  obtained  through  consultations  with  stakeholders.  In  spite  of  this, 
two  main issues still limit the analysis: the lack of reliable data on the performance of the licensing 
and inspection system (including the lack of historical data), which has only been partly offset through 
the targeted consultation with MSCAs; and a high representation of zoos belonging to zoo federations 
(and particularly to EAZA) among the respondents to the targeted survey, which can lead to bias in the 
evidence collected on application of conservation measures by zoos.  

Nevertheless,  the  combination  and  triangulation  of  sources  has  allowed  us  to  draw  general 
conclusions. The results of the analysis show that progress has been made towards the achievement of 
the general and specific objectives of the Zoos Directive, although open issues remain, especially in 
relation to its inconsistent application across the EU Member States and to the capacity of the Member 
States  to  implement  and  enforce  a  fully  effective  licensing  and  inspection  system.  The  following 
paragraphs discuss in more detail the achievements and open issues, along with the contributing and 
impeding factors.  

Achievements and contributing factors 

Little  information  exists  on  the  status  of  zoos  in  the  EU  and  the  activities  promoted  prior  to  the 
adoption  of  the  Zoos  Directive.  However,  a  comprehensive  and  consistent  approach  to  ex-situ 
conservation  was  generally  missing  in  the  EU.  In  1993, only  five511  out  of  the  then  twelve  Member 
States  had  relevant  legislation  on  the  subject,  although  it  was  not  focused  on  conservation 
objectives512.  Moreover,  the  European  Survey  of  Zoological  Collections513,  conducted  five  years 
earlier  in  12  Member  States514,  found  that  there  was  no  widely  used  definition  of  ‘zoo’,  limited 
information  was  available  on  the  number  of  zoos  in  existence,  and  few  zoos  broadly  met  ‘the 
standards  required  by  international  guidelines  of  modern  zoo  practice  in  the  areas  of  animal 
husbandry, species conservation and public education’, whilst a considerable number did not meet any 
acceptable  standards.  The  survey  also  found  that  there  was  little  significant  consideration  of  the 
conservation  activities  or  potential  of  zoos.  Against  this  baseline,  the  Zoos  Directive  has 
represented an important step forward.  

There  have  been  initial  delays  and  issues  in  the  transposition  and  implementation  of  the  EU 
legislation515.  However,  Member  States  have  gradually  overcome  these  issues  and  have  established 
legislative and practical conditions to ensure the implementation and enforcement of the Directive, 
by identifying the entities subject to regulation, designating competent authorities and defining roles 
and procedures for the licensing and inspection of zoos (including periodical monitoring inspections).  

In  order  to  ensure  that  zoos  implement  conservation  measures,  most  Member  States  have  set  up  a 
structured process for inspection, by using  inspection forms that contain the elements mentioned in 
Article 3 and, in some cases, go beyond the measures defined in Article 3, by establishing additional 
requirements for visitors’ safety, or standards for animal accommodation (both as binding  minimum 
standards for the accommodation of animals or not binding guidelines516). 

In addition, out of the 14 Member States selected for the evaluation study, eight (Belgium, Bulgaria, 
Czech Republic, Denmark, Ireland, the Netherlands, Poland and Portugal517) make use of specialised 
external  experts  (mostly  experts  from  zoo  associations,  or  retired  zoo  experts  that  participate  on  a 
personal  basis  in  zoo  commissions)  in  inspections.  In  the  absence  of  detailed  criteria  for  assessing 

511 Belgium, Denmark, France, Spain, United-Kingdom.  
512 European Parliament. 1993. Second report of the Committee on the Environment, Public Health and Consumer Protection on the Com-
mission proposal for a Council Directive laying down minimum standards for the keeping of animals in zoos (COM (91) 0177 final-C3-
0340/91). Strasbourg: European Parliament. 
513 W Travers, et R Straton. 1988. European Survey of Zoological Collections. Zoo Check contract for EEC (contract 6681 (87) 07. 
514 Namely Belgium, Denmark, France, Germany, Greece, Ireland, Italy, Luxembourg, the Netherlands, Portugal, Spain and the United 
Kingdom. 
515 In 2002, the European Commission launched an infringement procedure for non-communication of national transposition against eight 
Member States (Germany, Denmark, Spain, France, Ireland, Italy, the Netherlands and Portugal). Subsequently, other infringement proce-
dures for non-conformity with the Zoos Directive or bad implementation were launched against three of the 14 Member States in the sample. 
Other infringements were launched by the European Commission for bad application of the Directive, 
516 Binding: Bulgaria, Belgium, Italy, Lithuania, Poland; non-binding: Germany and Ireland. 
517 In Germany and Spain, external expertise is activated, respectively, in exceptional circumstances or depending on the Region.  

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whether  zoos  respect  their  legal  obligations,  the  recourse  to  external  expertise  can  represent  an 
important  means  to  ensure  that  the  assessment  is  adequate.  Some  Member  States  have  also  issued 
guidance  documents  (e.g.  Ireland  and  the  Netherlands)  for  inspections,  or  are  active  in  the 
organisation  of  workshops  and  trainings  addressed  to  inspectors,  in  order  to  improve  the  effective 
implementation of conservation measures across EU zoos (e.g. Bulgaria, Spain and Ireland). 

Understanding to what extent the licensing and inspection systems set up by the Member States have 
been  translated  into  an  improved  conservation  role  among  EU  zoos  is  challenging  given  the  lack  of 
consolidated  data  on  the  activities  performed  by  EU  zoos  and  thus,  on  their  contribution  to  the 
conservation  of  biodiversity.  However,  our  survey  addressed  to  zoos  provides  some  indications. 
Results show that many zoos implement several conservation measures and participate in research (52 
out  of  70),  in  training  in  conservation  skills  (35  out  of  70),  or  conservation  breeding  programmes. 
Regarding the latter point, out of 70, 44 zoos are involved in two breeding programmes coordinated by 
EAZA;  the  European  Endangered  Species  Programme  (EEP)  and  European  Stud  Books  (ESB),  518. 
Moreover, it is interesting to note that several of the zoos participating in these programmes are non-
EAZA facilities519.  

Most of the zoos surveyed have also defined a written education strategy (51 out of 70) and have set 
up the conditions necessary to ensure the application of high standards of animal husbandry (through 
environmental  enrichment  measures,  implemented  by  39  zoos  out  of  70;  in-house  or  external 
veterinarians available, respectively, in 58 and 45 zoos).  

These  achievements  also  concern  small-medium  entities  operating  in  different  Member  States. 
Although  data  collected  does  not  enable  a  solid  comparison,  participation  in  conservation  measures 
does  not  appear  to  be  limited  to  EAZA  zoos  or  to  zoos  belonging  to  national  or  international 
federations, which are typically more involved in conservation activities520. 

Moreover, a majority of respondents to the public consultation consider that the different conservation 
measures  defined  in  the  Zoos  Directive  are  sufficiently  promoted  across  the  EU,  and  improvements 
have been noticed in the past 15 years in relation to educational activities provided by zoos and in the 
size  and  design  of  spaces  where  animals  are  kept521.  Specifically,  positive  feedback  was  given  in 
relation to the activities of zoos aimed at providing information and raising awareness of species, wild 
animals  and  their  natural  habitats522.  Moreover,  72%  of  the  respondents  to  the  public  consultation 
indicated  they  received  information  on  species  and  conservation  during  a  visit,  and  74%  considered 
(fully or partly) the information of species and their habitats well presented. 

Finally,  the  Zoos  Directive  represents  an  important  instrument  contributing  to  the  overarching 
objectives set at European and global level for the protection of wild fauna and the conservation of 
biodiversity  (in  particular,  in  the  EU  Biodiversity  Strategy,  the  Birds  and  Habitats  Directives,  the 
Convention  on  Biological  Diversity  -  CBD523  and  the  CITES).  For  example,  more  than  80  LIFE 
Nature projects have included ex situ measures; between 1995 and 2014, 17 zoos have been involved 

518 EEP and ESB are breeding programmes, coordinated by EAZA, which aim at “conserving healthy populations of animals in captivity 
while safeguarding the genetic health of the animals under the care” of their zoos (EAZA Conservation Programmes. 
http://www.eaza.net/conservation/programmes/). 
519 According to the results of the survey, 10 non-EAZA zoos take part in EEP (out of the total 44 zoos participating in this programme) and 
11 non-EAZA zoos take part in ESB (out of the total 45 zoos participating in this programme). In this regard, EAZA pointed out that partici-
pation of non-EAZA zoos in these programmes has increased in the last years with, in 2015, almost 50% of zoos participating in this pro-
grammes being non-EAZA facilities (interview carried out during the study). 
520 Among the 70 zoos replying to the survey, only 6 zoos reported not to belong to any federation and 11 did not provide information about 
their membership to any federation. Although this small sample does not allow us to draw conclusions, it appears that also this group of zoos 
take part in several of the conservation measures defined by Article 3. For example: almost half of these zoos (8 out of 17) participate in 
research projects; most of them (13 out of 17) take part in information sharing activities; 11 out of 17 have a written education strategy; and 
16 out of 17 have a record keeping system of the zoo’s collection. 
521 69% of the respondents (or 1,588) observed improvements in the educational activities provided by zoos in the past 15 years; 66% of the 
respondents (or 1,533) observed improvements in the size and design of spaces where animals are kept.  
522 Particularly positive feedback is provided in relation to the following conservation measures: providing information on exhibited species, 
wild animals and their natural habitats: 70% or 1,607 of positive answers; providing education on and raise awareness of species, wild ani-
mals and their natural habitats: 62% or 1,424 of positive answer.  
Less positive feedback is related to: Animal conditions and care (point 21g): 46% or 1,056 of negative answers; research in species conserva-
tion issues (point 21a): 43% or 987 of negative answers. 
523 i.e. the Zoos Directive directly implements ex situ conservation measures envisaged under Article 9 of the CBD. 

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in LIFE projects and contributed to conservation actions supported by this programme524. In addition, 
over 300 species included in the Annexes to the Birds and Habitats Directives, and which are among 
Europe’s most vulnerable species, have benefited from such projects525.  

Overall,  we  conclude  that the  Zoos  Directive  has  been  successful  in  introducing  rules  on  a  subject 
which had previously been largely unregulated and has driven the establishment of licensing and 
inspection  systems  aimed  at  ensuring  that  common  minimum  standards  are  in  place  in  EU  zoos. 
Moreover,  although  available  evidence  is  scarce  and  not  conclusive,  the  data  collected  through  the 
public and targeted consultations suggests that EU zoos are participating in different conservation 
measures,  including  research  and  captive  breeding  programmes,  offering  better  animal  husbandry 
conditions,  and  to  promoting  education  and  awareness  among  visitors  and  the  general  public. 
Compared  to  the  baseline  situation,  when  the  limited  information  available  pointed  to  the  lack  of 
conservation  focus  and  acceptable  standards  among  EU  zoos,  progress  has  been  achieved,  with 
improved standards across EU zoos and participation in conservation of biodiversity.  
Moreover, according to some stakeholders526, substantial positive effects of the Zoos Directive can be 
observed  in  relation  to  the  accommodation  and  housing  conditions  of  animals  (including 
environmental enrichment measures, consideration of species specific needs, etc.), directly leading to 
better conditions across the EU for animals in zoos. As mentioned above, several Member States have 
integrated minimum standards in their legislation for animal accommodation, or provided non-binding 
guidance on this matter.  

These  are  all  significant  achievements  prompted  by  the  Zoos  Directive,  along  with  several 
contributing factors. The European Commission has partly compensated the lack of a monitoring and 
reporting system and the earlier lack of guidance on the implementation of the Zoos Directive through 
the launch of several infringements procedures527, and the publication of the Good Practice Document 
in 2015. Moreover, funding opportunities are available to zoos through programmes such as LIFE and 
ERASMUS. In addition, several stakeholders have contributed to the effective implementation of the 
Zoos Directive: 

While  the  Zoos  Directive  has  provided  a  framework  of  minimum  requirements  to  apply  across  EU 
zoos,  Member  States  have  provided  for  additional  requirements  in  the  transposing  legislation 
(e.g.  more  detailed  definition  of  zoos,  or  more  detailed  description  of  Article  3  measures 
including  animal  accommodation  standards).  Moreover,  as  mentioned  above,  the  preparation  of 
guidance documents and the organisation of training and workshops has significantly contributed 
to the application of the zoo legislation and the achievement of the Directive’s objectives. 

EU  and  national  zoo  and  aquaria  federations  (particularly  EAZA)  have  also  been  very  active  in 
supporting  the  implementation  of  the  Zoos  Directive,  through  their  membership  requirements, 
standards,  training,  breeding  programmes,  workshop  and  conferences  and  public  awareness 
raising  activities.  Similarly,  international  stakeholders  (IUCN,  WAZA)  have  adopted  key 
documents assisting the implementation of the Directive (e.g. IUCN Technical Guidelines on the 
Management  of  Ex  Situ  Populations  for  Conservation  or  the  World  Zoo  and  Aquarium 
Conservation Strategy).  

NGOs  have  played  an  important  role  in  monitoring  the  implementation  of  the  Directive’s 
requirements (a key area of work for NGOs active in this field such as Born Free, promoter of an 
independent EU Zoo Inquiry), informing the public and raising awareness.  

Finally,  actions  taken  by  individual  zoos  as  part  of  their  commitments  and  response  to  changing 
attitudes  among  visitors,  have  been  a  driver  behind  the  changes  observed  and  the  increasing 
attention to conservation of biodiversity. 

Open issues and related impeding factors 

524 Information provided by the European Commission, DG Environment.  
525 European Commission. 2011. LIFE preventing species extinction- Safeguarding endangered flora and fauna through ex-situ conservation. 
European Commission. 
526 In particular, 8 stakeholders (zoos, zoo federations and MSCAs) out of the 44 interviewed.  
527 27 infringement actions and five pilot procedures. 

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The assessment has identified several open issues related to the transposition, practical implementation 
and enforcement of the Zoos Directive.   

A  first  point  relates  to  the  licensing  and  inspection  systems  set  up  in  the  Member  States  and  the 
inconsistent  application  of  the  requirements  across  the  EU.  Member  State’s  enforcement 
authorities  use  inspection  forms  and  inspections  usually  cover  the  proper  implementation  of  the 
conservation  measures  listed  in  Article  3  of  the  Directive.  However,  enforcement  authorities  have 
rarely  detailed  or  specified  the  requirements  of  Article  3  in  terms  of  operational  criteria  and 
measurable  parameters.  When  this  has  been  done,  detailed  criteria  mainly  relate  to  minimum 
requirements  for  animal  accommodation  and  other  aspects,  such  as  safety  of  visitors,  which  are  not 
directly relevant to the conservation objectives pursued by the Zoos Directive. This approach can be 
explained  by  the  wide  differences  among  zoo  collections  (making  it  difficult  to  define  and  apply 
standard  criteria).  Nevertheless,  it  remains  difficult  to  assess  how,  in  practice,  it  is  ensured  that 
conservation measures are implemented by zoos, and there is the risk of inconsistent application of the 
requirements, both across Member States and within each Member State (when the inspection system 
is managed at local or regional level).  

The  inconsistent  application  is  also  explained  by  the  lack  of  monitoring  and  of  reporting 
requirements,  and  the  absence  of  other  instruments  to  coordinate  actions  between  Member  States, 
such as a forum for exchange among Member State Competent Authorities. The Commission's Good 
Practice Document on the Zoos Directive has been an important instrument in this regard. However, it 
has  only  been  issued  in  2015  and  has  been  disseminated  and  used  at  a  level  that  is  not  yet  fully 
satisfactory (due to its limited visibility and absence of translation in national languages). 

Secondly,  closure  of  non-compliant  zoos  remains  an  exceptional  measure,  and  Member  States’ 
authorities  have  resorted  to  it  in  only  a  few  cases.  The  accommodation  of  animals  under  adequate 
conditions  in  the  case  of  closure  of  a  zoo  remains  a  significant  challenge  for  authorities,  even  in 
Member States where solutions for the relocation of animals have been put in place (mainly based on 
the  cooperation  between  the  authorities,  zoo  owners  and/or  NGOs).  In  addition,  the  economic 
influence of zoos at local level might sometimes explain why authorities do not resort to the closure of 
non-compliant zoos.  

Thirdly and more generally, concerns remain about the effectiveness of enforcement of the legislation 
on  zoos.  Some  stakeholders  (especially  NGOs  but,  to  some  extent,  also  a  limited  number  of  zoos) 
point out that unlicensed zoos still operate in the EU. This would indicate that Member States do not 
only fail to close non-compliant zoos, but are also unable to identify all entities that should be subject 
to the legislation 528.  

The possibility of verifying these claims is out of the scope of our evaluation. However, shortcomings 
affecting  the  proper  implementation  and  enforcement  of  the  Zoos  Directive  have  been  identified: 
stakeholders (including Member States, zoos, zoo federations, NGOs and experts reached through the 
targeted consultation) seem to agree on the fact that the full effectiveness of the current licensing and 
inspection  systems  is  hindered  by  a  lack  of  resources  and  capacity.  In  most  Member  States, 
inspectors in charge of zoos are usually also in charge of enforcing other legislations (animals used for 
scientific  purposes,  exotic  animals,  companion  animals,  farms,  transport,  slaughter,  food  safety, 
animal  health,  epidemics  control,  environmental  and  safety  risks).  Consequently,  this  means  that 
human  and  financial  resources  allocated  to  the  inspection  of  zoos  are  limited.  It  also  means  that 
inspectors do not necessarily have a sufficient knowledge and understanding of conservation activities 
undertaken by zoos, and of the specific requirements that apply to them.  

Summary: achievement of the objectives of the Zoos Directive 

Overall, the main achievements, against the general and specific objectives of the Zoos Directive, can 
be summarised as follows:  

In  line  with  the  activities  promoted  by the  Zoos  Directive  and  the  expected  outputs,  Member  States 

528 This is also in line with conclusions of the Born Free EU Zoo Inquiry 2016 (in course of publication). 

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have set up operational licensing and inspection systems, in order to ensure that zoos implement 
conservation  measures  and  that  cases  of  non-compliance  are  handled.  However,  although 
progress  has  been  achieved,  the  study  supporting  the  evaluation  has  also  highlighted  that 
implementation and enforcement issues remain.  

The  establishment  of  licensing  and  inspection  systems  is  expected  to  translate  into  the  actual 
implementation  of  conservation  measures  by  all  zoos  (i.e.  the  expected  result  of  the  Zoos 
Directive). Although available evidence does not allow us to draw overall conclusions, the data 
collected during this study shows that zoos apply conservation measures (as defined in Article 3 
of  the  Zoos  Directive)  at  different  degrees  and  in  accordance  with  their  capacity.  The  focus  of 
zoos’ activities is mostly on information exchange, captive breeding, education activities for the 
general public and keeping of animals under appropriate conditions. Moreover, the feedback from 
the  public  consultation  points  to  gradual  improvements  observed  across  EU  zoos  in  the  last  15 
years,  especially  in  relation  to  educational  activities  and  the  size  and  design  of  spaces  where 
animals  are  kept.  As  mentioned  above,  and  further  discussed  under  “EU  Added  Value”,  this 
progress has been prompted by the Zoos Directive, but other contributing factors have also played 
a role (e.g. the action of zoo federations, NGOs and zoo owners).  

Finally,  the  overall  impact  of  the  Directive  on  protection  of  wild  fauna  and  conservation  of 
biodiversity  (as  outlined  in  its  Article  1)  is  hard  to  measure,  as  no  studies  and  very  limited 
scientific  literature  exist.  According  to  available  literature,  the  overall  contribution  of  zoos  to 
biodiversity conservation through research, training, captive breeding or reintroductions remains 
limited.  However,  this  issue  is  debated  within  the  scientific  community  and,  therefore,  existing 
evidence  is  not  conclusive.  In  parallel,  it  is  safe  to  say  that  the  Zoos  Directive  represents  an 
essential condition for the achievement of the general objectives set at European and global level 
(particularly  with  the  CBD)  in  relation  to  the  protection  of  wild  fauna  and  conservation  of 
biodiversity.  

Efficiency 

Efficiency  is  a  comparison  between  inputs  used  in  a  certain  activity  and  the  outputs  and  results 
produced. This section addresses the range of regulatory costs implied by the implementation of the 
Directive,  and  whether  these  costs  are  reasonable  and  proportionate  compared  to  the  benefits 
delivered. It also identifies the factors driving costs and whether unnecessary burdens result from the 
Directive’s implementation. 

The analysis focuses on the costs accrued for both Member State authorities (in charge of setting up 
and  implementing  the  licensing  and  inspection  system),  and  zoos  (required  to  implement  a  set  of 
conservation measures and undergo inspection and licensing procedures), and the benefits that can be 
attributed  to  the  Zoos  Directive  across  different  fields  (i.e.  in  terms  of  biodiversity  conservation, 
public education, increased visitor numbers and opportunities for the local economy).  

The  analysis  is  based  on  the  investigation  of  the  licensing  and  inspection  system  in  the  selected  14 
Member States, and on the information collected through stakeholder consultations (targeted surveys 
and  interviews,  and  public  consultation).  The  possibility  to  quantify  the  costs  and  benefits  remains 
limited due to the following factors: 

The  lack  of  literature  and  any  independent  assessment  on  the  topic,  which  would  have  provided  a 

point of reference. 

The paucity and low quality of information provided by stakeholders and, importantly, the difficulty to 
attribute  the costs  and  benefits  to  the Zoos  Directive.  Generally,  both  Member  State  authorities 
and  zoos  were  unable  to  identify  the  costs  directly  due  to  the  Zoos  Directive,  a  factor  which 
strongly  limits  the  possibility  to  provide  validated  and  shared  estimates  of  the  costs.  Similar 
considerations are valid in relation to the benefits. 

Costs and benefits of the Zoos Directive 

By  introducing  a  licensing  and  inspection  system,  the  Zoos  Directive  has  resulted  in  an  increase  in 
costs for both Member State competent authorities and zoos, respectively for the enforcement of the 

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legislation and the application of the requirements related to conservation measures. However, despite 
the lack of reliable data, the extent of increased costs appears relatively limited.  

On  the  one  hand,  for  Member  State  authorities,  new  or  additional  costs  (compared  to  the  situation 
before  the  entry  into  force  of  the  Zoos  Directive)  are  borne  in  relation  to  the  treatment  of  license 
applications, and for the preparation, execution and follow-up of inspections. The magnitude of these 
costs largely vary across Member States depending on the organisation of the licensing and inspection 
system (frequency of the inspections, number of inspectors involved in each on-site visit, existence of 
a pre-inspection phase). Where estimates have been provided, however, the resources fully dedicated 
to the enforcement of the Zoos Directive appear relatively limited (in some cases, less than one full 
time  equivalent),  or  are  difficult  to  quantify  as  zoo  inspectors  are  usually  also  responsible  for  the 
enforcement  of  other  legislative  acts  concerning  biodiversity  protection  and  animal  welfare,  as 
explained above. While there is agreement among MSCAs on the increase in costs directly related to 
the performance of the inspections, only half of the Member States that provided an answer reported 
an  increase  in  training  costs.  This  data  is  in  line  with  the  issues  raised  by  stakeholders,  including 
MSCAs, about the lack of appropriate knowledge of zoo inspectors, and the need for better promoting 
targeted  training  activities.  Finally,  no MSCA  was  able  to  quantify  the  costs  occurred  following  the 
closure of a zoo and, according to Article 6 of the Zoos Directive, the relocation and accommodation 
of animals. 

Regarding zoos, the information collected through the targeted consultation is extremely fragmented. 
A  significant  number  of  zoos  in  the  sample  (between  20  and  31  zoos  of  70)  report  an  increase  in 
recurrent  expenditures  related  to  Article  3  conservation  measures  and  investment  across  different 
fields: renovation of the enclosures, provision of information on exhibited animals, improved standard 
of  animal  husbandry  and  enclosures,  systems  to  prevent  escape  and  record  keeping/animal 
identification systems. Where zoos have reported investing money, these costs are usually not seen as 
a direct consequence of the Directive. For example, out of the 31 zoos that reported investments for 
enclosure  renovation,  only  12  attributed  part  of  these  costs  to  the  Zoos  Directive.  Similarly,  for  the 
other types of expenditures, the majority of responding zoos did not consider their expenditure a direct 
consequence  of  the  Directive.  The  same  pattern  appears  to  hold  for  recurrent  expenditures,  where 
some zoos report a wide range of expenditures, but do not see these as attributable to the Directive. In 
general  terms,  it  has  been  difficult  for  zoos  involved  in  the  targeted  consultation,  to  disentangle  the 
costs borne as a direct consequence of the Directive from expenses that would have occurred anyway, 
i.e.  in  absence  of  the  Directive,  and  as  part  of  the  evolution  of  their  role  towards  one  of  “modern 
zoos”.  

Different  considerations  are  valid  in  relation  to  the  administrative  burden,  which  has  also  been 
introduced  along  with  the  licensing  and  inspection  system.  In  this  case,  efforts  of  zoos  related  to 
licensing  and  inspection  procedures  have  increased  (i.e.  preparing  an  application  for  the  license, 
preparatory  work  for 
to  authorities,  fill-in  pre-inspection 
questionnaires,  taking  part  in  the  visit  of  the  MSCAs,  providing  answer  to  the  inspection  report). 
However,  administrative  costs  appear  to  be  strictly  related  to  the  requirements  for  obtaining  the 
license,  and  in  very  few  cases  are  considered  by  zoos  as  not  proportionate  to  the  overall  benefits 
achieved or unnecessary.  

inspection,  send  documents 

the 

Overall,  costs  have  been  considered  as  proportionate  for  competent  authorities  and  zoos  in  the 
wide majority of cases, despite the uncertainty about the extent of costs and the benefits that can be 
attributed to the Directive.  

According to all categories of stakeholders (consulted through  the public and targeted consultation), 
the Zoos Directive has brought benefits across different areas, particularly by contributing to: public 
education  and  knowledge  on  biodiversity,  improved  accommodation  of  animals  and  standards  for 
animal  husbandry,  efforts  for  ex  situ  conservation,  and  higher  engagement  of  the  public  and 
stakeholders  in  biodiversity  protection.  Still,  it  remains  difficult  to  establish  to  what  extent  these 
benefits  can  be  attributed  directly  to  the  implementation  of  the  Zoos  Directive,  and  to  what  extent 
other  factors  (the  evolution  of  zoos  as  institutions,  and  the  change  in  expectations  of  the  general 
public) have played a role. Moreover, benefits in terms of increased numbers of visitors and income 

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for zoos as economic operators, and on the local economy, have generally been considered limited. 

Despite this lack of clarity, as previously mentioned, costs were generally considered proportionate to 
the  benefits  by  the  large  majority  of  zoos.  Moreover,  no  significant  difference  emerged  between 
zoos  of  different  sizes,  with  no  strong  evidence  that  smaller  zoos  have  faced  higher  difficulties  in 
adapting to the legislation. 

Results of the analysis of unnecessary burden and of the factors contributing to efficiency 

No major issues have been raised in terms of unnecessary burdens by zoos or MSCAs. In parallel, it 
has  not  been  possible  to  clearly  identify  how  the  different  licensing  and  inspection  systems, 
implemented in the 14 Member States, affect the level of costs and benefits achieved.  

The  information  collected  on  the  costs,  the  achievements  and  benefits  associated  with  the  Zoos 
Directive  does  not  enable  a  systematic  comparison  between  the  Member  States  and  the  drawing  of 
conclusions about casual links between the level of costs and achievements/benefits on the one hand, 
and  the  key  features  of  the  national  implementation  system  on  the  other.  However,  the  qualitative 
information  gathered  suggests  that  the  issues  hindering  the  proper  and  efficient  functioning  of  the 
licensing  and  inspection  system  are  mainly  associated  with  the  resources  and  capacity  of  national 
inspectorates, rather than with specific requirements of the national implementing legislation (such as 
the frequency of inspections). 

In  this  view,  possibilities  for  enhancing  the  efficiency  of  the  Zoos  Directive  are  mainly  related  to 
improved guidance and involvement of external experts in the inspection process (in order to provide 
specialised expertise during the inspections), and elimination of possible duplications due to controls 
carried out under different legislative acts (i.e. under Regulation (EC) No 338/97 on the protection of 
species of wild fauna and flora by regulating trade therein, and Directive 92/65/EEC on animal health 
requirements for trade in and imports into the EU).  

Relevance 

The relevance analysis relies on a comparison of the current needs and objectives with those defined at 
the time of adoption of the Directive. The Zoos Directive was adopted in 1999, and has been in force 
since  2002  without  further  amendments.  The  purpose  of  the  analysis  was  to  identify  any  disparity 
between the objectives of the Directive and the current (legal, policy and scientific) situation.  

The analysis is mainly based on relevant scientific literature and policy documents. Information was 
also  drawn  from  the  targeted  surveys529  and  public  consultation530.  The  evidence  gathered  in  the 
context  of  the  analysis  of  relevance  is  therefore  based  both  on  documented  evidence  and  on  the 
stakeholders’ perception.  

Overall, the evidence indicates that the Directive  is still relevant, as its objectives still correspond to 
the current needs and objectives and scientific knowledge. This observation is however to be nuanced 
on specific aspects, where relevance could be further enhanced.  

Current needs and objectives at EU and global level 

Scientific  evidence  shows  that  the  status  of  conservation  (both  in terms  of  species  and  habitats)  has 
deteriorated over the last two decades. At the same time, our understanding of the importance of the 
protection  of  threatened  species  and  of  public  awareness  on  biodiversity  conservation  issues  has 
improved. These observations are backed up by scientific literature, and the overwhelming majority of 
stakeholders  who  participated  to  our  targeted  survey  and  public  consultation  (over  88%  of 
stakeholders)  agree  on  the  current  need  to  protect  threatened  species  and  make  the  public  aware  of 
conservation issues.   

529 Stakeholders were asked about the relevance of the needs that justified the adoption of the Directive and whether the Directive was 
adapted to technical and scientific progress. 
530 The consultation sought the opinion of the public on the importance of EU-wide rules on zoos for different aspects of biodiversity conser-
vation and zoo management. 

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The  need  to  protect  biodiversity  conservation  is  significantly  greater  now  than  at  the  time  of  the 
adoption  of  the  Directive,  and  this  evolution is  reflected  in  the  changes  in  policy  objectives  at  EU 
and  international  level.  In  particular,  global  biodiversity  policy  has  drastically  changed  since 
adoption  of  the  Directive.  The  objectives  set  by  the  Parties  to  the  CBD,  which  provided  the  initial 
international  context  of  the  Zoos  Directive,  have  evolved  markedly  since  the  Directive  came  into 
force,  with  the  adoption  in  2010  of  20  targets  (Aichi  targets)  with  a  specific  focus  on  biodiversity 
conservation,  and  direct  references  to  the  protection  of  species  and  to  education  and  awareness. 
Similarly, some of UN Sustainable Development Goals (SDG) adopted in 2015, set up targets for the 
protection  of  biodiversity  by  2020.  These  international  instruments  provide  a  stronger  legal 
framework surrounding the Directive than what was in place at the time of its adoption.    

In  light  of  these  new  objectives,  the  Directive’s  objectives  are  still  relevant.  Its  main  general 
objective,  the  protection  of  biodiversity,  and  its  specific  objectives  of  ensuring  the  participation  of 
zoos  in  conservation  activities  and  the  conservation  promotion  and  awareness  activities  of  zoos,  are 
more  needed  than  ever.  This  view  is  supported  by  all  types  of  stakeholders  (authorities,  zoos  and 
federations/NGOs)  surveyed  for  the  study,  who  consider  the  Directive  as  an  appropriate  way  for  ex 
situ management to meet the current needs (on average over 74% of respondents to the survey find the 
Directive still relevant).  

The evolution of international instruments from general aspirations  to focused targets has resulted in 
more specific objectives in relation to the conservation of biodiversity, to which  ex situ management 
can contribute. These more specific objectives and indicators facilitate the implementation of the Zoos 
Directive's framework provisions. However, there is a general need to be more explicit about where ex 
situ  management  is  most  needed  and  could  have  the  biggest  impact  in  achieving  conservation 
objectives.  This  criticism  is  supported  by  previous  reports531and  stakeholders  in  our  survey  (zoo 
operators, federations) pointed to the need for a more targeted approach to ex situ conservation to meet 
the new, more specific objectives set at EU and international level.   

Scientific and technical developments 

There  has  been  a  wide  range  of  scientific  and  technical  developments  in  the  field  of  biodiversity 
conservation since 1999, in particular in terms of:  

population management, 

identification of species in need of conservation action,  

identification of the actions needed for threatened species. 

More  specifically,  in  relation  to  scientific  and  technical  developments  in  the  field  of  ex  situ 
management,  a  lot  of  progress  has  been  made  since  the  adoption  of  the  Directive  in  relation  to  the 
interaction between in situ and ex situ conservation.  

Due to its broad scope and formulation, the Directive does not contain any outdated requirements in 
relation to these developments. The results of stakeholders’ consultations support this conclusion. The 
majority of stakeholders responding to the targeted surveys (82%) consider that the Directive remains 
appropriate in light of subsequent technical and scientific developments. There is a strong sense that 
it  is  in  particular  well  adapted  given  scientific  and  technical  progress  in  the  field  of  biodiversity 
generally.  

Stakeholders nevertheless also indicated that the interaction between  in situ and ex situ conservation 
could be significantly enhanced.  

Coherence 

Evaluating  the  coherence  of  an  EU  act  involves  looking  at  the  wider  policy  and  legal  framework  in 

531 LIFE preventing species extinction, Safeguarding endangered flora and fauna through ex-situ conservation, European Commission 2011 
at 
http://ec.europa.eu/environment/life/publications/lifepublications/lifefocus/documents/reintroduction.pdf  

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relation to a policy field. It evaluates how well the different interventions work together, by providing 
evidence  of  synergies  and  complementarities  that  could  reinforce  the  achievement  of  common 
objectives,  but  also  analyses  inconsistencies  and  overlapping  obligations  that  could  lead  to 
inefficiencies.  The  evaluation  on  coherence  also  seeks  to  examine  the  extent  to  which  the  Directive 
has supported the EU internal market and the creation of a level playing field for zoos across the EU. 
The  primary  objective  of  the  Directive  is  the  conservation  of  biodiversity  through  establishing  a 
conservation role of zoos. The Zoos Directive hence fits within a wide net of laws and policies at EU 
and  national  level  aimed  at  the  conservation  of  biodiversity,  including  in  relation  to  conditions  for 
accommodation of animals.  

The  coherence  analysis  is  primarily  based  on  the  legal  examination  of  the  strategic  objectives  and 
specific  provisions  of  relevant  legal  acts,  with  a  view  to  assessing  their  consistency  with  the  Zoos 
Directive.  The  results  of  the  targeted  consultations  and  public  consultation  were  also  taken  into 
account.  

The evaluation study reached the conclusion that there are no major inconsistencies and that, by the 
creation of a coherent legal framework, the Directive contributed to establishing a level-playing-field 
between all EU zoos. However, it also noted that this has not yet been achieved fully, and would be 
strengthened by better and more coordinated implementation.  

A comprehensive and consistent framework for biodiversity conservation 

The legal analysis has not revealed any inconsistencies between the Zoos Directive and the legislation 
examined532.  On  the  contrary,  there  are  examples  of  positive  interactions  that  strengthen  the 
achievement  of  the  objective  of  biodiversity  conservation.  Biodiversity  conservation  is  not  only  the 
primary objective of the Zoos Directive, but also of the Birds and Habitats Directives, the EU Wildlife 
Regulation  and  the  IAS  Regulation.  Taken  together,  these  instruments  establish  a  comprehensive 
system for biodiversity conservation in the EU, and contribute to the compliance of the Union with its 
obligations under the CBD.  

At the same time, there is scope for further synergies in order to reinforce the effectiveness of the legal 
framework  applicable  to  zoos  and  their  contribution  to  biodiversity  conservation.  For  instance, 
reintroduction programmes for native species are foreseen under both the Zoos Directive and the 
Habitats  Directive,  and  zoos  should  be  encouraged  and  provided  with  funding  to  participate  and 
develop  such  programmes.  Further  synergies  can  also  be  enhanced  with  regard  to  the  inspections 
carried out by the competent authorities in each Member State to check the compliance of zoos with 
their  obligations,  notably  under  the  Zoos  Directive,  the  EU  Wildlife  Regulation  and  Directive 
92/65/EEC on animal health requirements. Instead of making zoos subject to several inspections, the 
organisation  of  joint  inspection  procedures  to  ensure  compliance  with  the  different  pieces  of 
legislation  applicable  to  zoos  was  observed  as  a  good  practice  to  prevent  inefficiencies  and  the 
duplication  of  the  work  required  from  zoos  and  competent  authorities  to  prepare  and  carry  out  the 
inspections. 

Certain  stakeholders  and  members  of  the  wider  public  participating  in  the  public  consultation 
considered  that  there  are  some  inconsistencies  between  the  Zoos  Directive  and  Regulation  No. 
1739/2005  on  the  movement  of  circus  animals  (‘Circus  Regulation’),  as  well  as  with  the  IAS 
Regulation. However, the legal analysis concludes that there are no coherence issues. With regard to 
the Circus Regulation, it should be noted that given the clear exclusion of circuses from the scope of 
the Zoos Directive, there is no interaction between the two acts. Concerning the IAS Regulation, even 
though  zoos  are  required  to  ban  the  keeping  and  breeding  of  IAS,  this  is  fully  in  line  with  the 
biodiversity conservation objectives embodied in the Zoos Directive and the IAS Regulation, in view 

532 The legislation examined included: Council Directive 79/409/EEC of 2 April 1979 on the conservation of wild birds, Directive 
2009/147/EC of the European Parliament and of the Council of 30 November 2009 on the conservation of wild birds (Birds Directive), 
Council Directive 92/43/EEC of 21 May 1992 on the conservation of natural habitats and of wild fauna and flora (Habitats Directive), Regu-
lation (EC) No 338/07 on the protection of species of wild fauna and flora by regulating trade therein (CITES Regulation), Regulation (EU) 
1143/2014 on invasive alien species (IAS Regulation), Directive 92/65/EEC laying down animal health requirements for trade in and imports 
into the EU of animals, semen, ova and embryos not subject to other specific rules, and Regulation (EC) 1739/2005 laying down animal 
health requirements for the movement of circus animals between Member States. 

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of  the  particularly  negative  impact  that  a  spread  of  invasive  alien  species  may  have  on  local 
biodiversity. While it is acknowledged that zoos are not the main pathways for invasive alien species, 
there is evidence that they can still function as pathways, which justifies the strict approach taken. 

Creation of a level-playing-field 

The coherence analysis examined the extent to which the Zoos Directive has supported the EU internal 
market  and the creation of a level-playing  field for zoos across the EU. Prior  to the adoption  of the 
Directive, not all Member States had legislation in place to regulate the activities of zoos. Therefore, 
by making zoos in the EU subject to certain minimum requirements, such as the obligation to hold a 
license,  to  be  subject  to  inspections  and  adopt  the  conservation  measures  provided  in  Article  3,  the 
Zoos  Directive  constitutes  an  important  step  towards  the  establishment  of  a  coherent  legal 
framework for all EU zoos.  

However,  the  establishment  of  a  real  level-playing  field  requires  consistent  and  coordinated 
implementation of the Directive by the Member States. In practice, the analysis of the implementation 
of the Directive indicates that there are discrepancies in the legal obligations imposed on zoos in the 
different Member States533, as well as in the level of control and enforcement mechanisms put in place 
presented under the analysis of effectiveness above. These discrepancies prevent the full achievement 
of a level-playing field.  

This partial completion of the level-playing field is well reflected in the nuanced results of the targeted 
consultation,  where  53%  of  stakeholders  who  expressed  an  opinion  on  this  matter  believe  that  the 
Directive has brought no benefits or minor benefits through establishing a level-playing field between 
zoos in different Member States.  

EU Added Value 

The criterion of EU Added Value aims at examining, from a qualitative perspective, to what extent the 
Zoos  Directive  has  contributed  to  strengthening  the  role  of  zoos  and  to  promote  the  adoption  of 
conservation  measures  in  a  way  that  could  not  have  been  achieved  by  Member  States  on  their  own 
and/or by other stakeholders, and whether there is a need for continued EU action.  

The analysis of the added value of the Directive was impaired by two critical limitations in the data 
available. Firstly, due to the absence of an impact assessment prior to the adoption of the Directive, 
only  limited  information  was  available  to  understand  the  situation  in  the  Member  States  before  the 
regulation of this issue at EU level. To overcome this lack of information, we defined the baseline by 
analysing the legislative frameworks applicable in countries member of the European Communities in 
1992, by reviewing the 1988 European Survey of Zoological Collections and by interviewing experts 
in biodiversity conservation involved in the adoption of the Zoos Directive. The second data limitation 
concerns the lack of monitoring and reporting requirements under the Directive. Such data would have 
helped  us  fully  grasp  the  evolution  in  the  implementation  of  the  Directive  across  Member  States. 
Information to understand this evolution was instead gathered through the targeted surveys, in-depth 
interviews and the public consultation.  

The results of our analysis indicate that the Zoos Directive has, to  some  extent,  achieved more than 
what  would  have  been  achieved  by  Member  States  on  their  own,  and  is  perceived  as  a  needed 
instrument for continued EU action in the field of ex situ conservation. 

EU wide results achieved by the Directive 

The Zoos Directive has played a crucial role in setting a legal framework for the implementation of 
conservation  measures  by  zoos.  It  is  the  main  achievement  and  added  value  of  this  EU  legislative 
instrument:  the  Directive  has  set  binding  rules  on  all  European  zoos  and,  as  such,  prompted  the 

533 The framework wording of the Directive has given Member States a big margin of discretion in the transposition and implementation of 
the Directive’s requirements. This resulted in a situation where Member States have adopted legislation which varies significantly in terms of 
the obligations with which zoos must comply, e.g. different definitions of ‘zoo’, varied use of the exemption clause, use of cumulative in-
stead of alternative wording in transposing Article 3, 1st indent, adoption of different standards, etc. 

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in 

legislation, 

through  participation 

international  agreements  or 

adoption  of  conservation  measures  among  them  through  the  compulsory  requirements  of  licensing. 
Without  an  EU  Directive,  this  overall  result  would  probably  not  have  been  achieved  under 
national 
the  membership 
requirements  of  zoos  federations.  Before  the  adoption  of  the  Zoos  Directive,  national  legislation 
regulating the matter was absent in most Member States. Where national rules were in place - in five 
out  of  the  twelve  then  Member  States  (i.e.  Belgium,  Denmark,  France,  Spain,  and  the  United 
Kingdom) - (European Parliament 1993) they included requirements for licensing and inspection, but 
mainly  in  relation  to  conditions  for  animal  accommodation  and  animal  welfare,  while  missing 
objectives  on  biodiversity  conservation.  Standards  and  guidelines  were  provided  by  zoo  federations 
such as EAZA prior to the adoption of the Directive. These nevertheless had a limited impact due to 
their coverage (17% of licensed zoos are part of EAZA), scope (before the adoption of the Directive, 
EAZA standards covered exclusively accommodation and care of animals) and non-binding nature. 

Regarding  the  implementation  of  conservation  measures,  the  results  of  the  targeted  consultation, 
especially  from  zoo  operators,  highlighted  that  the  Zoos  Directive  has  partly  contributed  to  the 
implementation  of  conservation  measures  and  to  a  strengthened  role  of  zoos.  While  EU  action  has 
certainly prompted the setting-up of a common framework, it is less obvious to what extent it has led 
to  increased  conservation  activities  among  zoos.  As  outlined  under  the  section  on  effectiveness, 
external factors also led zoos to implement conservation measures. The work done by zoo federations 
(i.e. definition of guidance and standards) as well as individual ambitions of zoo owners are important 
elements  behind  the  increased  efforts  conservation  activities  of  zoos.  In  that  regard,  it  should  be 
mentioned that 50% of the zoos belonging to a zoo federation that responded to our survey considered 
that the Zoos Directive did not contribute to implementing new conservation measures or improving 
the existing ones. These zoos expressed the view that, regardless of legal obligations, they would have 
implemented  conservation  measures  as  a  consequence  of  broader  changes  at  a  global  scale,  the 
evolution  of  the  role  of  zoos  as  conservation  centres,  and  to  meet  visitors’  expectations  on  animal 
welfare, education and biodiversity conservation. It can be stated that the Zoos Directive and external 
factors exerted a mutually reinforcing effect on strengthening the role of all zoos in the conservation of 
biodiversity.  According  to  a  majority  of  MSCAs,  NGOs  and  zoos,  the  Directive  has  caused  a  more 
efficient and faster implementation of conservation measures, especially in zoos that are not part of a 
zoo federation.   

The  results  achieved  with  the  implementation  of  the  Zoos  Directive  were  limited  by  several  key 
factors,  as  discussed  in  the  previous  sections.  Besides  the  external  factors  mentioned  above,  some 
factors are also related to the design and practical implementation of the Directive itself. According to 
both literature534 and stakeholders535, the alternative wording of Article 3, first indent, diminished the 
potential of the Directive  to make all zoos evolve from entertainment  to more conservation-oriented 
entities.  On  this  note,  it  is  important  to  bear  in  mind  that  the  choice  between  several  conservation 
options  accommodates  the  wide  differences  in  zoos'  capacities  to  implement  these  measures.  The 
absence  of  requirements  on  the  prioritization  by  zoos  of  ex-situ  conservation  of  protected  and 
threatened  species  hinders  the  contribution  of  the  Directive  to  wider  conservation  objectives, 
especially in the absence of complementary and targeted strategies on this aspect. Limitations on the 
implementation  of  the  Directive  also  had  a  critical  impact,  with  its  lack  of  monitoring  or  reporting 
requirements, absence of coordinated action at EU level, and late issuance of the Guidance Document. 

Need for continued EU intervention 

Several  elements  suggest  that  there  is  still  a  need  for  EU  intervention.  Firstly,  as  explained  under 
effectiveness,  the  objectives  of  the  Directives  have  not  yet  been  fully  achieved.  As  a  consequence, 
differences exist across Member States in terms of implementation and enforcement, which has led to 
discrepancies  in  the  obligations  applying  to  zoos.  As  explained  above,  this  affects  the  level-playing 
field between zoos operators in the different Member States. This also impairs the proper protection of 
biodiversity sought by the Directive. These difficulties can only be overcome with full implementation 

534 See for instance Rees, 2005.  
535 In interviews with MSCAs and NGOs, see also Born Free Inquiry.  

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of the Directive.      

In  parallel,  existing  international  (i.e.  Conventions  such  as  CBD  and  CITES)  and  non-legislative 
instruments  (standards  and  guidelines  of  zoo  federations)  enhance  the  role  of  zoos  in  conservation. 
However, these instruments do not enable the full achievement of the objectives of the Zoos Directive. 
Firstly, the Zoos Directive is instrumental to the practical implementation of the principles enshrined 
in  international  agreements  such  as  the  CBD  and  CITES,  in  order  to  fulfil  the  EU’s  obligation  as  a 
party  to  the  CBD.  Secondly,  as  already  mentioned,  standards  and  guidelines  defined  by  zoo 
federations can contribute only to a limited extent. These instruments, compared to the Zoos Directive, 
miss a key feature: a legally binding value that enables enforcement across all EU zoos. As such, the 
Directive remains important for ensuring the implementation of conservation measures by zoos.   

The need for continued EU action in the field of ex situ management is recognised by all stakeholder 
groups  surveyed  for  the  evaluation  study.  EU-wide  rules  in  relation  to  different  aspects  of  ex  situ 
conservation  (e.g.  keeping  animals  under  appropriate  conditions,  promoting  education,  protecting 
threatened species), are deemed important by the large majority of all stakeholder groups responding 
to the public consultation (on average, by more than 80% of the respondents). Moreover, while zoos 
and public authorities tend to agree on the fact that most of the activities currently promoted by zoos 
would  be  continued  also  in  absence  of  the  Directive,  other  stakeholder  categories,  including 
individuals and NGOs, are less affirmative (on average, less than half of the respondents believe that 
all activities would be continued). Concerns were raised by NGOS regarding the political message of 
not having an EU legislation on zoos. One of the key concerns was that an absence of EU legislation 
on zoos would trigger repeals of national legislation or cuts in the budgets for enforcement. 

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ANNEX III – PRESENTATIONS 

METHODOLOGY  

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Effectiveness 

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Efficiency 

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Coherence 

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Relevance 

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EU Added Value 

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ANNEX X – SYNOPSIS REPORT 

1  OVERALL APPROACH 

In line with the Better Regulation Guidelines on Stakeholders Consultation, this report aims at summa-
rizing  the  methodology  and  results  of  all  the  stakeholders’  consultation  activities  undertaken  for  the 
study to support the evaluation of the Zoos Directive. It is the result of the Consultation Strategy that 
was developed for DG ENV and approved by the Steering Group. 

It  draws  from  information  provided  in  the  Targeted  Surveys  Report,  the  Interviews  Report  and  the 
Public Consultation Report in which each activity is more extensively described. Key issues raised in 
each  of  the  separate  stakeholder  consultations  will  be  presented.  The  overview  of  quantitative  and 
qualitative results of the consultation activities is contained in the relevant specific reports. 

Based on the intervention logic of the Directive, the evaluation framework and specific needs for in-
formation, stakeholders were selected on the basis of: (i) their involvement in the implementation of 
the Zoos Directive, (ii) the way that they are impacted by the EU legislation, and (iii) their knowledge 
and/or interest in the topics concerned. The following stakeholder groups were directly targeted by the 
consultation process: 

  CAs including enforcement authorities, responsible of the implementation and enforcement of the 

Zoos Directive in the 14 Member States selected as case studies.  

  Zoos (including public, private, charity supported and mixed entities), in the 14 Member States 
selected  as  case  studies.  As  far  as  possible,  and  based  on  the  information  provided  by  the  CAs 
and other stakeholders (such as zoos federations and NGOs), a mix of different types of zoos was 
involved:  membership/non-membership  to  the  European  Association  of  Zoos  and  Aquaria 
(EAZA), large and small operators, single/multiple operator, aquaria, animal parks, safari parks, 
collections of birds, reptiles, etc.). 

  Zoos  associations/representative  organisations,  acting  at  international,  EU  and  (for  the  14 
Member  States  selected  as  case  studies)  national  level,  including  federations  and  unions  of  zoo 
operators and, when relevant, of zoo and wild animals’ veterinarians, keepers and/or trainers.  
  NGOs,  focused  on  biodiversity  conservation  in  general  and/or  on  ex  situ  conservation,  and  on 

animal welfare, at international, EU and (for the 14 Member States) national level.  

  Experts/academics  with  expertise  on  the  topics  of  biodiversity  conservation,  ex  situ 

conservation, wild fauna, etc. 

Moreover, a broad range of stakeholders (including national stakeholders of the 14 Member States 
not involved in  the case  studies) and  the  civil society at large,  including  individual citizens, were 
informed and reached through the public consultation and the evaluation dedicated webpage536.  

More  in  detail,  the  collection  and  analysis  of  stakeholders’  inputs  were  core  tasks  of  the  supporting 
study, as demonstrated by the overall methodology of the project. The consultation strategy comprised 
four forms of consultation: (i) Targeted surveys for competent authorities (CAs) and zoo operators, 
zoos federations, non-governmental organisations (NGOs) and experts from the 14 selected Member 
States  as  well  as  at  EU  and  international  level  (17  August  –  28  November  2016);  (ii)  Open  public 
consultation (15  September  –  8  December  2016); (iii)  In-depth  interviews  with  CAs,  zoos  federa-
tions,  NGOs  and  zoo  operators  from  the  14  selected  Member  States,  and  with  EU  and  international 
stakeholders  (18  October  –  12  December  2016);  and  (iv)  validation  workshop  with  stakeholders 
(CAs, zoo operators, zoo federations, NGOs and experts) from all EU Member States.  

536 http://ec.europa.eu/environment/nature/legislation/refitzoosdirective/index_en.htm  

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The evaluation framework guided the data collection and formed the basis for the detailed review of 
evidence and analysis of each evaluation question. The evaluation framework maps the links between 
the evaluation questions and the questions posed by the different surveys (targeted and public) in the 
study.  
The  main  analytical  method  used  was  content  analysis,  based  on  the  aggregation  and  analysis  of 
information collected through the interviews, targeted questionnaires (open-ended answers) and public 
consultation.  Replies  to  closed  questions  were  analysed  using  descriptive  statistics.  It  was  the  main 
method of analysis of the results of the public consultation. The replies to the targeted questionnaires 
were  organised  according  to  the  relevant  evaluation  questions  (on  the  basis  of  the  correspondence 
matrix) and, for each survey, replies were analysed in order to establish and compare the opinions of 
different types of stakeholder. Zoo replies were investigated according to sub-groups, i.e. membership 
of  a  national,  European  or  international  federation,  and  number  of  employees.  Replies  to  the 
questionnaire  addressed  to  federations,  NGOs  and  experts  were  disaggregated  according  to  the 
category  of  stakeholder,  and  to  level  of  action  (EU,  national,  international  or  mixed).  Open-ended 
replies were also screened and represented an important means of gaining deeper insights and better 
understanding of the reasons behind the answers provided, with examples integrated into the analysis 
for illustrative purposes.  

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2  CONSULTATION METHODS 

2.1 

TARGETED SURVEYS 

The targeted surveys were aimed at all stakeholder categories with a high and medium interest accord-
ing to the stakeholder analysis matrix. It covered (i) Member States Competent Authorities (MSCAs) 
in the 14 selected Member States; (ii) NGOs, zoos federations, and experts in the 14 selected Member 
States, at EU and international level; and (iii) zoo operators in the 14 selected Member States.  

In total, the study team contacted: 19 MSCAs; 53 NGOs, federations and experts; 19 EU and interna-
tional stakeholders; and 514 zoos. 

The  questionnaires  were  structured  to  meet  the  needs  of  the  evaluation  questions  according  to  the 
evaluation framework. A major focus was placed on those evaluation  questions for which the infor-
mation was particularly scarce (such as state of play, effectiveness, efficiency and EU added value). 
The  questionnaire  for  the  targeted  survey  included  closed  questions,  to  facilitate  comparability  and 
quantification,  and  open  questions  for  explanations  and  qualitative  information.  The  questionnaires 
were also tailored to each different type of respondents.   

The CAs of the 14 selected Member States responded to the survey. Regarding the survey addressed to 
zoos federations, NGOs and experts, 27 stakeholders replied (13 federations of zoos, 13 NGOs and 1 
expert). Organisations active in the field of biodiversity conservation (IUCN, CITES, CBD) were non-
responsive to repeated invitations to contribute to the study. 70 zoos (i.e. 16% of contacted zoos) from 
the  14  selected  Member  States  have  replied  to  the  survey.  12  additional  zoos  responded  only  by 
emails. The results of the survey targeting zoos display an overrepresentation of EAZA zoos: in the 14 
selected Member States only 20% of zoos are members of EAZA, yet 52% of zoos responding to the 
survey are members of EAZA.   

More information about the targeted surveys is available on the website of the European Commission 
in the report dedicated to this consultation537. 

2.2  PUBLIC CONSULTATION 

The public consultation had the objective to get the views and perceptions of a wide set of stakehold-
ers on the contribution of the Directive to strengthen the role of zoos and enhance biodiversity conser-
vation.  The  public  consultation  intended  to  enlarge  the  scope  of  the  consultation  beyond  the  stake-
holders consulted in the 14 selected Member States for the targeted surveys and in-depth interviews. It 
gave  stakeholders  from  all  EU  countries  and  citizens  the  opportunity  to  express  their  opinion  on  all 
evaluation points. The questions were aimed at collecting opinions and input on the different evalua-
tion questions, in order to easily evaluate the outcome of the public consultation per evaluation ques-
tion  and  strengthen  the  evidence  base.  The  public  consultation  focused  on  ten  key  questions538.  The 
questionnaire is available on the website539 of the European Commission in the national languages of 
the 28 Member States. 

The public consultation was open for 12 weeks: between 15 September 2016 and 8 December 2016, 
and received 2297 answers. The main  categories of respondents were individuals (zoo visitors) with 
1944 answers, and zoos operators with 148 answers. 105 respondents chose the category ‘other’ types 
of respondents. The involvement of interest groups was visible in the results of the public consultation. 
At least two NGOs involved in animal welfare (Born Free540  and Eurogroup for Animals541) provided 

537 http://ec.europa.eu/environment/nature/legislation/refitzoosdirective/pdf/Responses.pdf 
538 Additional introductory questions were included to understand the respondent’s profiles (questions 1-19). The core questions were ques-
tions 20-29. 
539 http://ec.europa.eu/environment/nature/legislation/refitzoosdirective/index_en.htm  
540 http://www.bornfree.org.uk/fileadmin/user_upload/files/zoo_check/EU_Zoo_Inquiry/Public_consultation_on_Zoo_Directive_REFIT.pdf 

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suggested  replies.  Such  guidance  was  also  disseminated  through  other  EU/international  associations 
(such as Animal Defender International, ADI542), and other associations at national level (such as An-
imal Public543, which is active in Germany). It is expected that additional examples may be found on 
other websites. A very limited number of respondents followed all indications for the closed questions 
(40  of  the  2,297  respondents)  544.  Responses  to  semi-open  fields  revealed  the  presence  of  additional 
campaigns by other interest groups, including zoos associations at both EU and Member State level. In 
these cases, overall, only a limited number of stakeholders provided input in semi-open fields, most of 
which appear to be influenced by interest groups545. These campaigns were followed by various stake-
holder categories: individuals, NGOs, other associations and zoo operators.  

It  is  not  possible  to  precisely  assess  the  impact  of  these  campaigns  on  the  overall  results  (some  re-
spondents may have followed the guidance only partly, or might have answered closed questions simi-
larly  by  coincidence).  However,  the  overall  impact  of  replies  that  followed  all  indications  for  the 
closed questions is very limited (40 of the 2,297 respondents or 1.74%). These identical reply patterns 
were  not,  therefore,  analysed  separately.  For  semi-open  questions,  repeated  comments  were  consid-
ered in the overall analysis. 

A full report on the online consultation is available on the webpage of DG ENV546.  

2.3 

IN-DEPTH INTERVIEWS 

The aim of the interviews was to obtain an in-depth view of the issues covered by the study in each of 
the  selected  countries,  and  an  overview  of  the  situation  at  the  EU  and  international  levels.  Where 
appropriate,  the  interviewees  were  asked  to  provide written  supporting  evidence  (e.g.  for  issues  that 
require quantitative assessments, such as on costs). The interviews outline ensured a full coverage of 
the  evaluation  questions  and  tailored  the  questions  to  the  different  types  of  stakeholder  groups 
identified.  The  links  between  the  evaluation  questions  and  interview  questions  were  added  to  the 
evaluation  framework.  A  semi-flexible  approach  was  adopted,  meaning  that:  on  the  one  hand,  each 
interview  took  into  account  the  specific  context  and  issues  raised  by  the  stakeholder  in  the  targeted 
survey; on the other hand, the same topics were covered in all interviews and information remained 
comparable to a certain degree. The interviews were organised with: (i) National stakeholders: within 
each  of  the  14  Member  States,  (ii).  EU  and  international  stakeholders  (EAZA,  the  European 
Association  for  Aquatic  Mammals  (EAAM),  Eurogroup  for  Animals  and  Born  Free  (Daniel  Turner; 
Will  Travers)).  Regarding  national  stakeholders,  depending  on  the  number  of  relevant  stakeholders 
acting at national level, at least two and up to four interviews were held. 

In  total,  44  stakeholders  were  interviewed:  13  MSCAs,  8  zoo  federations,  6  NGOs,  9  zoo  operators 
and  8  EU  and  international  stakeholders.  The  Interviews  Report  provides  the  overview  of  the  44 
stakeholders interviewed. 

More information about the interviews is available on the website of the European Commission in the 
report dedicated to this consultation547. 

2.4  WORKSHOP  

The purpose of the workshop was to present the main findings of the Draft Final Report and to provide 

541 http://www.eurogroupforanimals.org/wp-content/uploads/2016/10/Suggested-Replies.pdf 
542 Suggested replies are the same as those provided by Eurogroup for animals (http://www.ad-
international.org/animals_in_entertainment/go.php?id=4264&ssi=12). 
543 Suggested replies provided by Eurogroup for animals are the same as those provided by BornFree (http://www.animal-public.de/europas-
zootiere-brauchen-ihre-hilfe/). 
544 36 respondents followed the indications of Born Free (1.5% of the total number of respondents); four respondents followed the indications 
of Eurogroup for Animals (0.17% of the total number of respondents). 
545 Depending on the question, from 56% to 84% of the respondents provided replies affected by campaigns.  
546 http://ec.europa.eu/environment/nature/legislation/refitzoosdirective/pdf/public_consultation_report_april_2017_clean.pdf 
547 http://ec.europa.eu/environment/nature/legislation/refitzoosdirective/pdf/interviews_report_2017_03.pdf  

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an opportunity for important stakeholders to input on the conclusions on the effectiveness, efficiency, 
relevance  and  coherence  of  the  Directive,  through  a  robust  debate  and  an  informative  exchange  of 
opinions. At the workshop, the study team presented the main findings of the Report as a basis for the 
discussion. Stakeholders were asked to focus and provide input in particular on any existing gaps or 
misrepresentations that they identified in the study’s findings. 

The notes of the workshop are published on the corresponding website548. 

More information about the workshop is available on the website of the European Commission in the 
report dedicated to this consultation549. 

2.5  AD-HOC CONTRIBUTIONS 
Through the functional mailbox set-up by the European Commission in the context of this study550 or 
direct contacts with the contractor, ad-hoc contributions were received from the following stakehold-
ers: 

  EAZA:  contact  details  of  MSCAs;  contact  details  of  EAZA  zoos;  history  of  EAZA  standards, 

scientific studies, 

  BornFree: European Survey of Zoological Collection551; Captive Polar Bears in UK and Ireland552; 

Identifying the Training Needs of EU MSCAs553; early findings from 2016 Zoo Inquiry554. 

  University of Birmingham, S. Thorpe (Reader in Zoology, School of Biosciences): study on En-

closure Design Tool for great apes555. 

  Sergiel, A.: The welfare of bears in zoos: a case study of Poland  556; The Welfare of Animals in 

Zoos and EU Legal Standards 557.  

  KMDA (BE zoo and research institute): complementary documents to targeted surveys. 
  NL MSCAs: complementary documents to targeted surveys. 
  Tiergarten Heidelberg GmbH: complementary documents to targeted surveys. 
 

Individual and zoo who wished to conserve anonymity: position statements through emails on the 
uselessness of a Zoos Directive (breach of subsidiarity principle, inappropriate intervention logic). 

548 http://ec.europa.eu/environment/nature/legislation/refitzoosdirective/workshop_en.htm  
549 http://ec.europa.eu/environment/nature/legislation/refitzoosdirective/pdf/Workshop_report.pdf  
550 ENV-REFIT-ZOOS-DIRECTIVE@ec.europa.eu  
551 Travis, W, et R Straton. 1988. European Survey of Zoological Collections. Zoo Check contract for EEC (contract 6681 (87) 07). 
552 Horsman, P., Captive Polar Bears in UK and Ireland, 1988. 
553 BornFree, Identifying the training needs of EU Member State competent authorities - Survey to assess implementation of legislation and 
need for training: wild animals kept in captivity, July 2016, available at: http://endcap.eu/wp-
content/uploads/2016/11/EU_Member_State_Training_Needs_report_0716_FINAL.pdf. 
554 Not yet published. 
555 University of Birmingham, Apeing the Apes: New Enclosure Design Tool created for UK Zoos, 11.05.2016, 
http://www.birmingham.ac.uk/news/latest/2016/05/new-enclosure-design-tool-created-for-uk-zoos.aspx  
556 Maślak, R., Sergiel, A., Bowles, D., Paśko, Ł. 2016. The welfare of bears in zoos: a case study of Poland. Journal of Applied Animal 
Welfare Science 19(1): 24-36. 
http://www.tandfonline.com/doi/abs/10.1080/10888705.2015.1071671?journalCode=haaw20  
557 Gardocka, T., Gruszczyńska, A., Maślak, R., Sergiel, A.  (eds.) 2014. The Welfare of Animals in Zoos and EU Legal Standards. ELIPSA, 
Warsaw. 
https://www.academia.edu/30092738/The_Welfare_of_Animals_in_Zoos_and_EU_Legal_Standards  

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3  RESULTS OF CONSULTATION 

3.1  EFFECTIVENESS 

The assessment of the “effectiveness” of the Zoos Directive covered a range of issues: the key features 
and the adequacy of the  licensing and inspection systems set up in the 14 selected Member States; 
the actual implementation of conservation measures by zoos; the broader contribution of the Zoos 
Directive to the protection of wild fauna and conservation of biodiversity; and other positive or nega-
tive changes going beyond the objectives of the Zoos Directive. Both the targeted and public consulta-
tions covered these issues. The results of the consultation activities are outlined in the paragraphs be-
low.  

All  Member  States  have  transposed  the  Directive  into  national  law  and  established  a  licencing  and 
inspection system. The targeted consultations, but also the workshop and in-depth interviews, allowed 
us  to  understand  the  functioning  of  the  licencing  and  inspection  systems  in  the  selected  Member 
States,  and  to  gather,  especially  from  the  MSCAs,  information  on  specific  features  of  these  systems 
(i.e. the use of inspection protocols; the involvement of external experts, advisory boards, zoos associ-
ations; the use of guidance documents; training for inspectors; centralised zoo database).  

All stakeholder groups taking part in the targeted surveys and interviews highlighted that the Directive 
has represented an important instrument, as far as it introduced a legally binding framework that did 
not exist in most of the Member States before the entering into force of the Zoos Directive. During the 
interviews, MSCAs, zoo federations and NGOs also recognised that the national licensing and inspec-
tion systems have gradually improved (e.g. through the setting up of operational procedures, improved 
coordination,  training  of  the  staff  for  inspections)  and  that  progress  has  been  made  towards  the 
achievement of the objectives of strengthening the role of zoos and preserving biodiversity. On a simi-
lar note, most of the respondents to the public consultation think that the Zoos Directive has produced 
significant benefits regarding the improvement of systems for licensing and inspections. 

Regarding  the  actual  implementation  of  conservation  measures  among  EU  zoos,  evidence  and 
opinions collected through the consultations shed a light on the progress made, but also point to im-
plementation and enforcement issues. The results of the targeted survey addressed to zoos is affected 
by the high participation of EAZA zoos in the consultation (37 out of 70, or 53%) and are, therefore, 
not representative. Despite these limitations, the targeted survey highlighted that many zoos are under-
taking conservation activities, as required by the Directive. Not all conservation measures receive the 
same attention; for example, not all zoos take part in research that benefits conservation, and less than 
half of the zoos surveyed are not involved in training activities in conservation skills. Nevertheless, the 
survey  shows  that  many  zoos  are  engaged  in  population  management  programmes  (EEP  and  ESB), 
education  and  awareness-raising  activities,  and  many  measures  are  in  place  for  animal  husbandry, 
prevention of escapes and record-keeping. 

The overall positive picture emerging from the targeted survey is confirmed in the public consultation, 
which shows that the public considers that the implementation of conservation measures is, generally, 
sufficiently promoted by EU zoos. This is especially the case for activities related to the provision of 
information on exhibited species, wild animals and their natural habitats, and for activities related to 
education and awareness  raising. Benefits of the Directive  were  also underlined  by all stakeholders’ 
groups in the various consultations in relation to better knowledge on biodiversity among the public, 
the ability of the Directive to promote harmonization at EU level, enhance the role and public percep-
tion of zoos as entities contributing to biodiversity conservation, increased standards for animal keep-
ing, public information, improved measures relating to the prevention of escape of animals. The level 
of negative perception among stakeholders is however higher in relation to animal conditions and care 
and animal shows. In the public consultation, 53% of the respondents disagreed with the fact that ani-
mals live in conditions that satisfy their needs and 54% of the respondents did not adhere to the obser-
vation that animal shows were adapted to the animals’ natural behaviours.  

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Overall, the feedback on the broader contribution of the Zoos Directive to biodiversity conserva-
tion  is  positive  across  stakeholder  categories.  The  majority  of  stakeholders  involved  in  the  targeted 
surveys (63 on 111, or 56.7%558) and the majority of respondents to the public consultation (1,301 on 
2,297,  or  56.6%559)  considered  that  the  Directive  produced  benefits  in  terms  of  overall  biodiversity 
conservation.  

Together  with  these  achievements,  important  issues  in  terms  of  implementation  and  enforcement  of 
the legislation remain, as reported in the surveys, the interviews and at the workshop. Issues have been 
raised especially by NGOs, zoo federations and zoos. These issues encompass: the lack of cooperation 
between different authorities, the lack of human and financial resources for licensing and inspection 
(also raised as an issue by MSCAs), the lack of knowledge in competent authorities, the lack of inven-
tory of all establishments that should be regulated under the Directive, the rare cases of closure of zoos 
as it requires a lot of resources and coordination. In particular, stakeholders present at the workshop 
reminded  that,  despite  the  progress  made,  there  are  still  many  non-compliant  zoos  across  the  EU, 
which leads to unfair and unacceptable competition for well performing and dedicated zoos.  

Stakeholders also underlined, especially during the workshop, the need to translate and better dissemi-
nate the Good Practices Document, to set up a platform for exchange to identify means of improving 
licensing and inspection, and to adopt a more active approach on enforcement.  

Finally,  the  supporting  study  explored  whether  the  Zoos  Directive  prompted  significant  (positive  or 
negative) changes beyond the objectives of biodiversity conservation and protection of wild fau-
na. Only a few stakeholders (NGOs) pointed out negative effects and these were generally related to 
the legitimisation of the role of zoos, even where their participation in conservation activities and con-
tribution to conservation is very small. Conversely, most of the stakeholders agreed that the Directive 
had additional positive effects in terms of: increased public awareness of the role of zoos in biodiversi-
ty conservation (an opinion shared across all the stakeholder categories and confirmed by the results of 
the public consultation); increasing attention paid to the welfare of wild animals in zoos (according to 
zoos, zoos’ federations and MSCAs). 

3.2  EFFICIENCY 

Given the lack of independent analyses on the issue, the limited information available on the situation 
of zoos prior to the adoption of the Directive and the lack of monitoring and reporting requirements 
under the Directive, the information provided by zoos and MSCAs was crucial for the assessment of 
the efficiency of the Directive. Information relevant for that evaluation criterion was gathered through 
the targeted surveys, which was complemented by in-depth interviews and the validation of findings at 
the workshop. Given the technicity of the issue, the public consultation was not designed to provide 
detailed data on this point.  

Overall, the consultations allowed us to overcome the lack of data only to a limited extent: both zoos 
and MSCAs were, in most of the cases, not able to provide quantitative data and, especially, to disen-
tangle the costs directly due to the Zoos Directive from costs that would have been incurred anyway 
(i.e. also in the absence of the EU legislation).   

Zoos and MSCAs reported in all consultations that the Zoos Directive prompted additional regulatory 
costs. For zoos, those costs include: one-off investments and recurrent expenses to implement Art. 3 
measures;  administrative  costs  to  obtain  and  keep  the  license;  charges;  and  (in  a  limited  number  of 
cases) costs due to delays in obtaining licences. Small zoos find it slightly more difficult to bring their 
installations in line with the Zoos Directive, where costs for enclosure renovation can be significant.  

558 MSCAs, zoos and zoos’ federations, NGOs and experts that, in the targeted questionnaires, rated the benefits as “moderate” or “major”. 
559 Respondents to the public consultation that rated the benefits on overall biodiversity conservation as “significant” or “crucial”.  

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For MSCAs, the costs are mainly enforcement costs: setting up and running the licensing and inspec-
tion system; possible costs for accommodating animals in case of a zoo closure. However, zoos and 
MSCAs  generally  underline  that  costs  stemming  from  the  implementation  of  the  Zoos  Directive  are 
difficult to quantify but appear to be limited. For instance, only 6 out of 70 surveyed zoos reported that 
delays in licensing caused additional costs. The zoos moreover highlighted that part of the investment 
would have happened anyway. They reported the costs either as, not attributable to the Directive, or 
difficult to disentangle from ‘business as usual’ expenses. In comparison with other legislations (ani-
mal welfare laws for instance), stakeholders confirmed during the workshop that the costs induced by 
the Zoos Directive are very low. In that  respect, participants to the workshop assessed  the Zoos Di-
rective as the most efficient instrument possible for MS to implement Article 9 of the CBD. 

The main benefits reported by all stakeholders’ categories in the targeted surveys are increased public 
education, improved accommodation of animals and standards of animal husbandry, stronger ex-situ 
conservation efforts and higher engagement of the public/stakeholders in biodiversity protection and 
other  nature  protection  activities  (Figure  80).  These  benefits  were  likewise  mentioned  in  interviews 
and during the workshop.  

Figure 80: Stakeholders’ opinions on the significance of benefits associated with the Zoos Directive (results from the 
targeted questionnaires addressed to MSCAs, zoos and zoos’ federations, NGOs and experts. Number of replies = 111) 

Source: Present survey of MSCAs, federations, NGOS and experts, and zoos 

Regarding the relation between costs and benefits, costs are generally considered by stakeholders con-
sulted as proportionate to the benefits.  In the targeted  surveys, only one MSCA considered enforce-
ment costs to be disproportionate. Between five and nine targeted zoos (out of 70) considered one-off 
investment, recurrent costs or administrative costs as disproportionate to the benefits. This pattern is 
confirmed among the smaller zoos surveyed. The results of the public consultation confirm this trend 
in perception: the majority of zoos operators declares that the benefits exceed the costs (94 zoos out of 
148 or 63.5% of total). 

Overall,  no  major  issues  related  to  unnecessary  burden  have  been  raised.  Stakeholders,  in  particular 
associations and federations, mentioned in targeted surveys and in interviews that there is nonetheless 
room for improvement of the licensing and inspection process through, inter alia, the involvement of 
zoo federations in the licensing and inspection process, the elimination of overlaps with controls under 

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9171927282930313237442929323326343232322828323425322930273125282320121181245457521192411161417131711110102030405060708090100110j) For zoos as economic operators as Zoos Directive triggers higher visitor numbersh) Local economy (e.g. new jobs, recreational activities, increased tourism, researchand innovation on conservation issues)i) Zoos as economic operators because of an EU wide legal framework (similarconditions among zoo operators in different EU MS)e) Positive changes of behaviour towards biodiversity protectionk) Society (e.g. health, culture, recreation)a) Overall biodiversity conservationb) Protecting species from extinctionf) Higher engagement of the public/stakeholders in biodiversity protection and othernature protection activitiesc) Ex-situ conservation effortsg) Accommodation of animals and standard of animal husbandryd) Public education and better knowledge on biodiversityMajor benefitsModerate benefitsMinor benefitsNo benefitsNo opinion/No answer 
 
 
 
 
other legislations, better cooperation and communication between different authorities and stakehold-
ers, in particular regarding the closure of zoos. 

3.3  RELEVANCE 

The  Directive  remains  relevant  to  the  CBD  Aichi  Targets,  the  EU  Biodiversity  Targets  and  the  UN 
SDGs. Stakeholders across all groups underlined indicate in the targeted surveys that the objectives of 
the Directive are still relevant to the current needs and even more relevant given the increased global 
decline in biodiversity. The impression of the  majority of stakeholders, as reported  under the public 
consultation  and  at  the  workshop,  is  that  EU-wide  rules  are  important  or  very  important  in  order  to 
strengthen the role of zoos in conservation (see  Figure 28), and that without EU-wide rules on zoos, 
the fulfilment of EU’s commitments to the protection of biodiversity would be unlikely (see EU Add-
ed Value). 

Figure 81: Stakeholders’s opinions on the relevance of the protection of threatened species (results from the targeted 
questionnaires addressed to MSCAs, zoos and zoos’ federations, NGOs and experts. Number of replies = 108) 

Protect species threatened by extinction 

70

60

50

40

30

20

10

0

62 

13 

1 

1 

1 

4 

25 

1 

MSCAs

Zoos

Federations/NGOs/Experts

Yes

No

No opinion

Source: Present survey of MSCAs, federations, NGOS and experts, and zoos 

As pointed by federations, experts and NGOs, both in surveys and in the workshop, the development 
of  more  specific  objectives  and  indicators  in  global  biodiversity  policy  clarifies  what  is  needed  for 
species  and  biodiversity  more  widely.  It,  therefore,  allows  clear  links  to  be  made  between  zoos  and 
these global needs: all of this allows the Zoos Directive to have greater impact. 

The  Directive  remains  appropriate  in  the  light  of  subsequent  technical  and  scientific  developments. 
The fact that the Directive is a framework act and not too prescriptive is considered beneficial in this 
respect: the Directive can adapt to new developments. Some stakeholders, especially federations, high-
lighted in the targeted surveys that the link between ex situ management and in situ conservation could 
however be better emphasized. During the workshop, it was also underlined that ex situ conservation 
has  to  be  better  coordinated  in  the  future  (e.g.  EU  wide  strategy  or  a  centralised  multi-stakeholder 
process identifying which species need conservation measures how, where, by whom). The opinions 
on the value of keeping non-threatened species in zoos varies depending on stakeholders’ groups. For 
some  participants  to  the  workshop  and  interviewees,  especially  federations,  species  that  are  not  yet 
vulnerable should also be prioritised in captive breeding to avoid losing an opportunity to ensure their 
protection, and species of least concern can also have a conservation value for their endangered rela-
tives. For others, in particular NGOs, captive breeding is not the best answer for threatened species, 
and there is a need to carefully review where resources are placed to ensure the best use. 

Given the continuing deterioration in the status of species, and the increasing pressures on biodiversi-

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ty, it is agreed by all stakeholders that the potential for the Zoos Directive to support EU and global 
targets remains, and is greater than in when it was adopted. 

3.4  COHERENCE 

The technical nature of the questions of coherence implied that the input of stakeholders was mainly 
sought to complement the legal analysis, i.e. to identify whether, in practice, inconsistencies were per-
ceived. The views gathered through all consultations are similar: the Directive is considered consistent 
and  mutually  supportive  of  other  EU  legislation  on  biodiversity  and  international  guidelines,  agree-
ments and strategies. Some stakeholders, mainly zoos and competent authorities, are concerned about 
upcoming, potential, inconsistencies between the Zoos Directive and Regulation (EC) No. 1143/2014 
on Invasive Alien Species (IAS Regulation), and overlaps with Directive 92/65/EEC (Animal Health 
Directive).  Some  other  stakeholders,  mainly  NGOs  and,  in  the  case  of  the  public  consultation,  also 
individuals,  refer  to  potential  issues  with  Regulation  1739/2005  on  the  movement  of  circus  animals 
(Circus Regulation). Even though some stakeholders and responses to the public consultation pointed 
to inconsistencies between the Zoos Directive and both the IAS Regulation and the Circus Regulation, 
the legal analysis found no issues of coherence. 

3.5  EU ADDED VALUE 

As for the assessment of the effectiveness of the Directive, answering to the questions on the added 
value of the Directive was challenging given the limited information available on the situation prior to 
the adoption of the Directive and the lack of monitoring and reporting requirements that would illus-
trate the progress made in its implementation. The targeted surveys, public consultation, and discus-
sions during in-depth interviews and the workshop underlined the following points. 

The main added value of an EU instrument lies in the creation of a common EU wide legal framework 
applicable to all zoos, as the targeted surveys underlined. The set-up of such EU wide framework was 
considered by all stakeholders’ groups surveyed as partly contributing to the strengthening of role of 
zoos in conservation, along with other factors (Figure 80). The Directive was also reported in targeted 
surveys  as  having  acted  as  a  catalyser  for  faster  and  more  efficient  implementation  of  conservation 
measures (Figure 82). In that respect, the discussions at the workshop emphasized that, although the 
Directive leaves an important margin of interpretation, a certain level of harmonization through mini-
mum standards was reached. 

Figure 82: Stakeholders’ perceptions that the EU intervention has contributed to make zoos adopt or implement the 
Article 3 conservation measures more efficiently or more quickly as compared to national law or non-legal initiatives 
(results from the targeted questionnaires addressed to MSCAs and zoos’ federations, NGOs and experts. Number of 
replies = 41) 

Source: Present survey of MSCAs, federations, NGOS and experts, and zoos 
The  effects  of  legislation  are  more  striking  for  zoos  not  belonging  to  zoos  associations  that  already 
require from their members to uphold certain standards on animal accommodation, and conservation 
measures.  While  participants  to  the  workshop  agreed  that  there  is  still  a  gap  in  conservation  perfor-
mance between zoos that are members of associations and zoos that are not members, they highlighted 

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that the Directive is key in bridging this gap. 

Other benefits of EU intervention raised by stakeholders in the targeted surveys and in the workshop 
include  the  facilitation  of  cross-border  cooperation  and  cooperation  between  zoos.  According  to  the 
discussion held during the workshop, conservation has clear cross-border implications and should not 
be left to the sole regulation at national levels. In this respect, although the role of the Commission is 
limited  (lack  of  monitoring/reporting  system,  no  committee),  stakeholders  expressed  the  view  that 
further coordination at EU level would be useful. Another added value of the Directive is related to the 
increased  awareness  that  it  triggered  about  zoos  conservation  role  because  of  higher  visibility  and 
political engagement due to the EU intervention. The importance of the political message behind the 
existence of an EU instrument in that field was reiterated during the workshop: according to the partic-
ipants, the Directive has raised political interest and action. From the point of view of MSCAs inter-
viewed, this induced greater resources dedicated to the implementation of zoos regulation; while from 
the point of view of NGOs interviewed it led  to a stronger leverage on authorities to ensure the en-
forcement of the rules. 

For  these  reasons,  nearly  all  stakeholders’  groups  in  the  various  consultations  report  that  there  is  a 
need  for  continued  EU  intervention,  with  more  focus  on  coordinated  implementation  and  common 
understanding of certain requirements. A majority of zoos, NGOs, zoos associations and experts indi-
cated in the targeted survey that they consider that an EU legislation is necessary to ensure that zoos 
implement  conservation  measures.  As  illustrated  by  the  results  of  the  public  consultation,  the  wider 
public shares that view (Figure 83). It is however not fully shared by competent authorities replying to 
the survey (6 out of 11 that replied that they do not deem an EU legislation as necessary), though there 
was a consensus from all stakeholders’ groups present at the workshop, including MSCAs, on the need 
to keep EU wide rules on zoos. 

Figure 83: Answers of the public consultation to ‘‘How important do you think EU-wide rules on zoos are on the 
following matters?’ 

Source: Present public consultation 

The  effects  of  not  having  the  Directive  were  discussed  during  the  workshop.  Participants,  while  ac-
knowledging that the impacts are hard to predict, mentioned most commonly as potential impacts that: 

  Zoos that are part of organisations would maintain their standards; 

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  The gap between “good” and “bad” zoos would increase; 
  Animal welfare would generally collapse; 
 
  Member States that went beyond the requirements of the Directive and effectively implemented it 

Illegal trade would soar; 

would keep the existing legislation; 

  Member  States  that  struggle  with  implementation  are  more  likely  to  get  rid  of  the  Zoos  Di-

rective's requirements. 

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doi:10.2779/901336