REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL On the implementation of Regulation (EC) No 1007/2009, as amended by Regulation (EU) 2015/1775, on the Trade in Seal Products
Date: 2020-01-10
Institutions: Directorate-General for Environment, European Commission
Subjects: animal product, application of EU law, hunting regulations, indigenous population, market approval, protected species, protection of animals, report, seal, trade restriction

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 10.1.2020  COM(2020) 4 final  REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL On the implementation of Regulation (EC) No 1007/2009, as amended by Regulation (EU) 2015/1775, on the Trade in Seal Products  
 
 
1.  Introduction 

The EU seal regime 

Regulation  (EC)  No  1007/20091  of  the  European Parliament  and  of  the  Council  on trade  in 
seal products (the Basic Regulation) prohibits the placing on the EU market of seal products. 

The trade ban applies to seal products produced in the EU and to imported seal products. The 
Basic  Regulation  was  amended  by  Regulation  (EU)  2015/17752  in  order  to  reflect  the 
outcomes  of  World  Trade  Organization  (WTO)  rulings  in  the  EC-Seal  products  case3.  As  a 
result, the current EU seal regime provides for two exceptions to the ban: 

1)  It allows the placing on the market of seal products where those products come from hunts 
conducted by Inuit or other indigenous communities, provided the specific conditions set 
out in Article 3(1) of the Basic Regulation, as amended, are fulfilled. 

Article  3(1a)  of  the  same  Regulation,  as  amended,  also  provides  that,  at  the  time  of  its 
placing on the EU market, a seal product shall be accompanied by a document attesting 
compliance with the conditions set out for benefiting from the "Inuit or other indigenous 
communities exception". The attesting document should be issued by a body recognised 
for  that  purpose  by  the  European  Commission,  in  accordance  with  Article  3  of 
Commission Implementing Regulation (EU) 2015/18504 (the Implementing Regulation). 

2)  It also allows the import of seal products where it is of an occasional nature and consists 
exclusively of goods for the personal use of travellers or their families (Article 3(2) of the 
Basic Regulation, as amended). 

Reporting obligations under Regulation (EC) No 1007/2009, as amended 

Article 7 of the Basic Regulation, as amended, stipulates that Member States shall submit to 
the Commission, by 31 December 2018 and every four years thereafter, a report outlining the 
actions taken to implement this Regulation. 

The Commission shall then submit to the European Parliament and to the Council a report on 
the implementation of the Regulation within 12 months of the end of each reporting period. 
The first report shall therefore be submitted by 31 December 2019. 

The above reports and the Commission report should assess the functioning and effectiveness 
of the Regulation in achieving its objective. The reports should also assess the impact on the 
socioeconomic  development  of  the  Inuit  or  other  indigenous  communities.  For  the  sake  of 
completeness, the reports also address the impact on the seal population. 

2.  Background 

In 1983, in response to widespread concerns about the annual killing of certain seal pups, the 
EU adopted Council Directive 83/129/EEC5 to prohibit the import of products from two seal 

1 https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32009R1007 
2 https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=uriserv:OJ.L_.2015.262.01.0001.01.ENG 
3 http://trade.ec.europa.eu/wtodispute/show.cfm?id=475&code=2  
4 https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32015R1850 
5 https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:31983L0129 

1 

 
                                                            
pup species, harp seals (‘whitecoats’) and hooded seals (‘blue-backs’), into the EU. It initially 
applied  until  1  October  1985.  Directive  85/444/EEC6  extended  the  validity  of  Directive 
83/129/EEC  until  1  October  1989.  In  1989,  the  indefinite  extension  of  the  Directive  was 
adopted through Council Directive 89/370/EEC7. 

Seals  are  hunted  within  and  outside  the  EU  and  used  for  obtaining  products  as  diverse  as 
Omega-3 capsules and garments incorporating processed sealskins and fur. Given the nature 
of  those  products,  which  are  sold  commercially  on  different  markets,  including  the  EU 
market, it is difficult or impossible for consumers to distinguish them from similar products 
not derived from seals. 

Citizens  and  consumers  expressed  concerns  as  to  the  possible  presence  on  the  market  of 
products obtained from animals killed and skinned in a way that causes suffering. In response, 
several Member States adopted legislation regulating trade in seal products by prohibiting the 
import  and  production of  such  products,  while  no  restrictions  were  placed  on  trade  in  these 
products in other Member States. 

Those  differences  between  national  provisions  governing  the  trade,  import,  production  and 
marketing  of  seal  products  adversely  affected  the  operation  of  the  internal  market  and 
constituted barriers to trade in such products. Therefore, the EU adopted Regulation (EC) No 
1007/20098 of the European Parliament and of the Council (the Basic Regulation), taking into 
account the principles of subsidiarity and proportionality. The Basic Regulation introduced a 
prohibition on the placing on the market of seal products. 

At  the  same  time,  the  EU  recognised  that  seal  hunting  was  an  integral  part  of  the  socio-
economy, nutrition, culture and identity of the Inuit or other indigenous communities, making 
a  major  contribution  to  their  subsistence  and  development,  providing  food  and  income  to 
support  the  life  and  sustainable  livelihood  of  the  community,  preserving  and  continuing  the 
traditional  existence  of  the  community.  The  EU  also  noticed  that  seal  hunts  traditionally 
conducted  by  Inuit  or  other  indigenous  communities  did  not  raise  the  same  public  moral 
concerns as seal hunts conducted primarily for commercial reasons. Moreover, it was broadly 
recognised  that  the  fundamental,  economic  and  social  interests  of  Inuit  or  other  indigenous 
communities  should  not  be  adversely  affected,  in  accordance  with  the  United  Nations 
Declaration on the Rights of Indigenous Peoples of 2007. 

Therefore,  by  way  of  exception,  the  Basic  Regulation  allowed  the  placing  on  the  market  of 
seal products which resulted from hunts traditionally conducted by Inuit or other indigenous 
communities, as long as due regard was paid to animal welfare and suffering was reduced to 
the extent possible. The exception was limited to  hunts  that contribute to  the subsistence of 
those communities. 

The  Basic  Regulation  also  allowed,  by  way  of  exception,  the  placing  on  the  market  of  seal 
products where the hunt was conducted for the sole purpose of the sustainable management of 
marine resources. 

In  2010,  Canada  and  Norway  launched  dispute  settlement  proceedings  at  the  World  Trade 
Organization  against  the  Basic  Regulation  and  its  initial  Implementing  Regulation  (EU) 
737/2010. In 2013, the WTO concluded that, by allowing certain seal products to enter the EU 

6 https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:31985L0444 
7 https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:31989L0370 
8 https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32009R1007 

2 

 
                                                            
market through the Inuit and the marine resource management exceptions, the EU seal regime 
was  producing  a  detrimental  impact  on  the  competitive  opportunities  of  Canadian  and 
Norwegian products vis-à-vis Greenlandic imported and EU domestic like products. Indeed, 
at the time, only Greenland had officially applied for the recognition of an attesting body. 

In order to bring its regime in line with the rulings of the WTO, the EU adopted Regulation 
(EU) 2015/1775, which modified the EU seal regime by removing the exception for marine 
resource management. 

Nevertheless,  the  removal  of  that  exception  was  without  prejudice  to  the  right  of  Member 
States to continue regulating hunts conducted for the purpose of the sustainable management 
of marine resources. It, however, prevented Member States from allowing the placing on the 
market  of  the  products  derived  from  such  hunts,  unless  they  would  fall  under  the  “Inuit  or 
other indigenous communities” exception, which remained in force. The amended Regulation 
also strengthened  coherence  with the objective of the Basic Regulation by explicitly adding 
animal welfare considerations as a condition for the use of the exception. 

Article  3(3)  of  Regulation  (EC)  No  1007/2009  required  the  Commission  to  issue  technical 
guidance  notes9,  setting  out  an  indicative  list  of  the  codes  of  the  Combined  Nomenclature, 
which may cover seal products, to facilitate enforcement operations by the relevant national 
authorities. 

In  order  to  ensure  a  uniform  implementation  of  the  Basic  Regulation,  Commission 
Implementing  Regulation  (EU)  2015/1850  was  adopted  to  specify  the  requirements  for  the 
import of seal products for the personal use of travellers or their families. It lists the criteria 
for  the  recognition  of  bodies  responsible  for  issuing  documents  attesting  to  the  compliance 
with  the “Inuit or other indigenous communities” exception. It also specifies the role of the 
Member  States’  Competent  Authorities  for  the  control  of  the  attesting  documents  and  the 
recording of data included therein. 

3.  EU Member States’ reports 

For  the  current  exercise,  the  EU  Member  States  were  given  until  30  June  2019  to  provide 
their national reports to the Commission, through answering an online questionnaire. For the 
28 EU Member States, the reporting period was from 18 October 2015 (date of application of 
Regulation (EU) 2015/1775) to 31 December 2018. 

All  but  four  EU  Member  States  (France,  Greece,  Luxembourg  and  Malta)  provided  their 
national  report.  The  present  report  is  based  on  the  inputs  received.  The  mention  “all  the 
Member States” should  therefore be understood as  “all  but  the four Member States that  did 
not provide their report”.  

a) Competent Authority 

According  to  Article  6  of  Commission  Implementing  Regulation  (EU)  2015/1850,  each 
Member  State  shall  designate  one  or  several  competent  authorities  responsible  for  the 
verification, upon request of the customs authorities, of attesting documents for imported seal 
products; control of the issuing of attesting documents by recognised bodies established and 
active in that Member State, and preservation of a copy of attesting documents issued for seal 
products  originating  from  seal  hunts  in  that  Member  State.  Member  States  shall  notify  the 

9 https://eur-lex.europa.eu/legal-content/EN/TXT/?qid=1560955112627&uri=CELEX:52010XC1229(04) 

3 

 
                                                            
Commission of the designated competent authorities, and the Commission shall make the list 
of  designated  competent  authorities10  available  on  its  website11  and  update  it  on  a  regular 
basis. Member States were asked to update their details in the published list if needed. 

The national legislation of the Member States officially designates a competent authority and 
defines  its  role:  inspection,  verification  of  the  attesting  documents  issued  by  the  recognised 
bodies, cooperation with other public administrations (such as the  Ministry of Finance or of 
Agriculture)  and  the  customs  authorities,  including  the  provision  of  guidance  for  border 
control. In Portugal, the import of seal products is covered through the licenses issued by the 
Management Authority under the Convention on  International Trade in Endangered Species 
(CITES). 

In the margins of their reply to the questionnaire, Denmark questioned the need for Article 6.1 
(b)  and  (c)  in  Implementing  Regulation  (EU)  2015/1850  and  for  the  fourth  copy  of  the 
attesting document in its Annex as, in their understanding, the Member States cannot appoint 
recognised bodies. The Commission replied that some Member States have peoples who meet 
the definition of “Inuit or other indigenous communities” and would therefore be allowed to 
hunt  seals  for  their  subsistence  and  to  put  seal  products  on  the  EU  market.  Those  Member 
States  could  apply  for  one  of  their  bodies  to  be  officially  recognised  for  issuing  attesting 
documents. In that case, Articles 6.1 (b) and (c) would be relevant, as well as the fourth copy 
of the attesting document which should be submitted to the competent authority according to 
Article 6.1 (c). 

b) "Inuit or other indigenous communities" exception 

Denmark was the only Member State to report that seal products were placed on its market 
based  on  the  conditions  set  out  in  the  “Inuit  or  other  indigenous  communities”  exception 
provided for in Article 3(1) of the Basic Regulation, as amended. During the reporting period, 
the  Danish  Customs  recorded  seal  product  imports  from  Greenland  for  a  total  value  of 
2,626,128 Danish Krone and a total volume of 10,502 kg. 

None of the Member States were contacted by the customs authorities or other enforcement 
bodies to decide on the measures to be taken in case of doubts relating to the authenticity or 
correctness  of  an  attesting  document,  or  for  further  advice.  None  of  them  had  to  refuse  the 
placing  on  their  market  of  seal  products  covered  by  the  “Inuit  or  other  indigenous 
communities”  exception.  Only  Portugal  required,  once,  the  translation  of  an  attesting 
document (covered by Article 4 of the Implementing Regulation) into its national language. In 
Croatia,  national  legislation  requires  attesting  documents  to  be  translated  into  the  national 
language. 

c) Personal use of travellers or their families 

Four  Member  States  (Czech  Republic,  Germany,  Poland  and  Spain)  reported  cases  where 
customs  authorities  notified  the  competent  authority  of  a  problem  with  the  import  of  seal 
products for personal use by travellers or their families, as provided for under Article 3(2) of 
the Basic Regulation, as amended. 

10 https://ec.europa.eu/environment/biodiversity/animal_welfare/seals/pdf/comp_authorities.pdf 
11 https://ec.europa.eu/environment/biodiversity/animal_welfare/seals/seal_hunting.htm 

4 

 
 
 
                                                            
d) Placing on the market on another basis 

The  placing  of  seal  products  on  the  EU  market  on  another  basis  than  the  two  above-
mentioned exceptions is not allowed. Only Estonia and Portugal were notified of a request for 
placing  seal  products  on  the  market  for  reasons  other  than  the  “Inuit  or  other  indigenous 
communities” exception or the personal use of travellers and their families. In Estonia, tanned 
sealskins (1,700 pieces in 2016; 1,988 in 2017 and 2,418 in 2018) were imported for inward 
processing  by  a  shoe  manufacturer  who  then  re-exports  all  the  processed  goods.  Portugal 
refused an application for the import of seal products for trade. 

e) Penalties 

In accordance with Article 6 of the Basic Regulation, Member States are required to lay down 
rules  on  effective,  proportionate  and  dissuasive  penalties  applicable  to  infringements  of  the 
provisions of the Regulation, and to ensure that these rules are implemented. 

All  the  Member  States  but  Finland  have  rules  in  place  on  penalties  applicable  to 
infringements  of  the  Basic  Regulation.  Finland  is  in  the  process  of  amending  relevant 
legislation  to  incorporate  such  rules.  These  penalties  range  from  fines,  confiscation  and 
destruction of the goods (in place in all the Member States but Finland), up to imprisonment 
(in some of them only). The amount of the fine usually differs if the offence was committed 
by a natural person or by a legal person. The table below shows the maximum amount of the 
fines  (in  Euro)  in  the  Member  States  that  communicated  this  information  in  their  national 
report. The table is not exhaustive but it nonetheless shows significant differences in the fines 
imposed by the various Member States. 

FINES IMPOSED IN EURO 

Maximum fines on natural persons

Maximum fines on legal persons

0
0
0
0
0
1

0
0
0
0
0
1

0
0
0
2

0
0
0
2

0
0
5

0
0
5

0
0
0
0
1

0
0
0
5

0
2
5
3
1

8
2
0
2

0
7
3
9
1

0
7
3
9
1

0
0
4
6

3
0
3

3
0
3

9
2
2
4
1

1
1
7

0
0
1

0
0
1

None of the Member States that provided a report imposed such penalties during the period of 
reference,  and  the  customs  did  not  confiscate  seal  products  in  any  of  those  Member  States 
because these did not comply with the Regulation. 

f) Processing of data 

Only Croatia, Finland, the Netherlands, Portugal and Spain are using an electronic system for 
the exchange and recording of data contained in the attesting documents, in accordance with 
Article 7 of the Implementing Regulation. None of the Member States had anything to report 

5 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
with regard to the protection of personal data when processing attesting documents, covered 
under Article 8 of the Implementing Regulation. 

g) Information through a QR code label 

To  ensure  the  proper  functioning  of  the  “Inuit  or  other  indigenous  communities”  exception 
and to  improve the information  on the EU seal  regime, the recognised bodies referred to  in 
Article 3 (4) of the Regulation, as amended, may  place a QR code label on the seal products 
that  they  certified  .  This  QR  code  is  linking  to  a  EUROPA  webpage12  providing  relevant 
information on the seal regime. 

Only nine Member States (Denmark, Estonia, Finland, Ireland, Italy, Latvia, Poland, Portugal 
and Slovenia) are aware of the existence of this QR code, and none of the Member States has 
been contacted by the customs authorities or other enforcement bodies for advice in relation 
to this QR code. 

h) Seal hunt 

During  the  reporting  period,  seal  hunt  took  place  on  the  territory  of  Denmark,  Estonia, 
Finland and Sweden. 

In  their  report,  these  four  Member  States  briefly  described  the  purpose  of  the  hunt,  the 
conditions  in  which  it  was  conducted,  the  killing  method  applied,  how  animal  welfare  was 
given due regard,  and the impact of this hunt on the seal population,  on ecosystems and on 
human activities. The text below illustrates the views expressed in the four national reports. 

In Denmark, seals may not be hunted freely, but a derogation may be asked for shooting seals 
within a radius of 100 meters from the fishing gear when the purpose is to avoid damages to 
it,  and  this  exclusively  outside  the  breeding  and  moulting  periods.  From  2018,  derogations 
have also been granted for shooting seals in streams, with a positive impact on brood stocks 
of fish populations under pressure. Derogation shooting is subject to using a rifle of approved 
calibre, passing a specific rifle test and having a Danish hunting license. In Bornholm, grey 
seals  may  be  shot  throughout  the  year,  as  there  are  no  breeding  grounds  in  that  area,  but 
hunters  need  to  follow  a  specific  seal-hunting  course.  Seal  populations  are  monitored  in 
Denmark  with  yearly  counting.  It  appears  that  the  small  number  of  seals  that  have  been 
hunted during the reporting period (78 harbour seals and 1 grey seal) has had no impact on the 
size of the population, on the behaviour of seals in general, on the marine eco-system or on 
seal watching opportunities. 

In Estonia, seals may be hunted to ensure a sustainable management of marine resources and 
the  subsistence  of  the  hunters  and  families  from  the  local  communities  of  Estonia’s  small 
islands, to keep their cultural heritage and traditions alive. The seal hunt is strictly regulated, 
according  to  the  "Hunting  Rules",  and  animal  welfare  is  fully  considered.  It  may  only  take 
place in designated hunting areas, during the hunting season (from 15 April to 31 December), 
and after having passed a shooting test. There are special requirements for the type of weapon 
and  ammunitions  used,  and  hunting  from  watercrafts  with  engine  is  prohibited.  The  annual 
hunting quota is limited to 1% of the seal population, and the impact on the seal population 
and on the ecosystems is marginal. In 2015, 10 seals were hunted for a hunting quota of 53. It 
was 10 for 42 in 2016, 9 for 45 in 2017 and 19 for 37 in 2018. Since 2015, the hunt of grey 

12 https://ec.europa.eu/environment/biodiversity/animal_welfare/seals/eu_seal_regime.htm 

6 

 
                                                            
seals is again permitted in Estonia, reviving an old tradition, as their population has increased 
over the years. Estonia reported that this small-scale hunt is necessary to reduce damages to 
fishery, but it is not permitted in areas where the grey seal is protected. 

In Finland, seal hunt is governed by national and relevant EU legislation through sustainable 
hunting quotas, a time-limited hunting season, and specific technical characteristics for guns 
and  ammunitions.  Licence-based  seal  hunt  is  carried  out,  both  on  island  and  islets,  for 
sustainable  management  of  marine  resources,  but  also  to  prevent  damage  to  commercial 
fisheries.  In  recent  years,  hunting  on  ice  has  been  possible only  in  the Northern  Baltic  Sea. 
Many hunters have special modern rifles for the seal hunt, and they must pass an examination, 
with a prior course on hunting ethics, before hunting is allowed. For a number of years, the 
Finnish Wildlife Agency has also been training hunters in the coastal areas to apply a lethal 
killing  method.  The  Ministry  of  Agriculture  and  Forestry  is  responsible  for  setting  the 
maximum number of grey seals and ringed seals that can be sustainably hunted, based on the 
best scientific data collected by the Natural Resource Institute. No hunting is allowed on weak 
seal populations (e.g. ringed seal in the Gulf of Finland). As there are only a few hundreds of 
seal hunters - because hunting is expensive and suitable days for hunting are limited -, only a 
few hundreds of seals are shot annually. The estimated yearly increase of the seal population 
is higher than the number of hunted seals. Seals are opportunistic feeders. There is evidence 
from Finland and Sweden that seals eat fish from fishing gears unless gears are seal proof. In 
reality, only traps, fykes (long bag-shaped fishing nets held open by hoops) or similar gear 
can be partly made seal proof while maintaining viable commercial fishing. Studies suggest 
that seals take a vast number of fish from gear without leaving evidence, whereby the impact 
of seals to fish populations is difficult to quantify. Seals eat 3 to 5 kilos fish per day, which 
may  jeopardise  fish  species  or  populations  protected  by  EU  or  national  legislation. 
Recreational and commercial fishing with gill nets decreased by 30-40% over the last decades 
in the outer archipelago and even completely stopped in certain areas due to seal predation. 
Seal  hunt  is  conducted  mainly  in  sea  areas  in  the  outer  archipelago  where  interaction  with 
other  human  activities  is  negligible.  Finland’s  report  highlights  that  the  ban  on  the  trade  in 
seal  products  reduces  the  possibilities  to  develop  seal-based  sustainable  activities  such  as 
tourism.  The  positive  effect  of  a  hunt  close  to  fishing  gear  is  only  temporary  as  new  seals 
emerge within a few days or even hours. In general, seal hunt cannot be considered the only 
way to mitigate the problems caused by seals. 

In  Sweden,  seal  hunt  is  allowed  and  strictly  regulated  by  the  Swedish  Environmental 
Protection Agency in areas where the growing seal population is causing serious damages to 
fishing gear and eating the catches. The hunting quota and ammunitions to be used are strictly 
regulated  too.  Decisions  by  the  Swedish  Environmental  Protection  Agency  imply  that  the 
killing  method  used  must  cause  immediate  death,  avoiding  unnecessary  suffering,  and  that 
hunting  seals  from  a  boat  requires  the  hunter  to  have  followed  a  course  with  a  hunters’ 
association  in  Sweden  or  Finland,  and  the  boat to  stand  still.  The  Swedish  Hunting  Act  too 
stipulates that the hunt cannot cause unnecessary suffering. Research is ongoing in Sweden to 
develop  seal  proof  fishing  equipment.  The  number  of  seals  hunted  to  protect  the  fishing 
sector,  the  only  type  of  hunt  allowed,  only  represents  a  very  small  share  of  the  seal 
population.  Therefore,  Sweden  reported  that  the  impact  on  the  seal  population  and  on  the 
ecosystems is minimal. 

i) Overall assessment 

Member States were asked to provide an overall assessment of three aspects of the Regulation 
on  their  territory:  its  functioning  (ability  to  perform  its  regular  function),  effectiveness 

7 

 
(capacity  to  produce  a  desired  result)  and  impact  (for  example,  changed  market  for  seal 
products). 

Some  Member  States  (Belgium,  Bulgaria,  Czech  Republic,  Ireland,  Italy,  Lithuania  and 
Slovakia) mentioned that there is no trade in seal products on their territory and that they are 
therefore unable to assess the functioning, effectiveness and impact of the Regulation. Others 
(Cyprus, Germany, the Netherlands, Romania and Slovenia) did not provide any assessment, 
supposedly for the same reason. 

Others  (Austria,  Croatia,  Denmark,  Estonia,  Finland,  Hungary,  Latvia,  Poland,  Portugal, 
Spain, Sweden and the United Kingdom) consider that the Regulation is fit for purpose and 
they have not experienced any problem so far with it. Procedures are in place at their customs 
authorities  to  implement  the  Regulation  properly.  Denmark,  Estonia,  Finland  and  Sweden 
made some concrete comments which are reflected below. 

Denmark  raised  the  fact  that  seal  hunting  is  of  great  importance  in  Greenland  and  that  the 
Danish Government sees the need to promote the understanding of Greenland's seal hunting 
as  a  sustainable  legitimate  profession  and  to  strengthen  the  export  of  seal  products  from 
Greenland,  including  to  the  EU.  However,  Denmark  and  Greenland  claimed  that,  although 
products from seals hunted by Inuit or other communities are not covered by the import ban, 
the  ban  has  led  to  a  large  drop  in  the  sales  of  Greenlandic  sealskins  to  the  EU  market. 
Denmark  would  like  the  EU  to  better  inform  the  public  on  Greenland's  right  to  export 
sealskins (under certain conditions). 

Estonia is of the opinion that seals hunted for marine resource management purposes should 
be  fully  utilised  and  that  small-scale  sale  as  handicraft  by  local  communities  should  be 
allowed, in order to compensate for the expenses of the hunt and to showcase the creativity 
and  traditions  of  these  communities.  For  Estonia,  the  legal  inability  to  sell  even  a  minor 
amount of seal products affects the tourism, the development of the local communities and the 
preservation of traditions in certain areas. 

According to Finland, the impact of the Regulation has gone beyond its intended purpose. The 
ban has contributed to the present poor state of coastal fishing and significantly downgraded 
the  value  of  seals  as  a  game  species.  With  the  ban,  hunted  seals  can  be  used  solely  by  the 
hunters,  reducing  the  willingness  to  hunt  seals  close  to  fishing  gears,  and  forcing  seals  and 
resigned fishermen to cohabit. Seal populations are on a growing curve in the Baltic Sea and 
are  found  everywhere  at  the  Finnish  coast.  Finland  reported  that  a  seal  hunt  carried  out  to 
sustainably manage marine resources, with full respect of animal welfare and with all parts of 
the caught animal being used instead of wasted, should not raise public moral concerns. Seals 
can  be  killed  rapidly,  without  causing  avoidable  suffering,  using  methods  that  destroy  the 
sensory  brain  functions.  For  Finland,  considering  seals  as  a  valuable  resource,  through 
allowing  a  well-framed  trade  in  seal  products,  would  enhance  the  sense  of  ownership  and 
commitment  to  sustainably  using  these  resources.  Trade  in  seal  products  has  never  been  a 
large sector with significant economic turnover. However, in the coastal areas, trade has the 
potential  to  contribute  as  a  source  of  income  and  nurture  cultural  values.  An  enquiry 
conducted in 2018 shows that 50% of Finnish citizens have a positive attitude towards small-
scale trade in seal products. According to Baltic Sea counts, the total grey seal population is 
of 40,000-54,000 individuals, with an annual population growth of 2,300 to 3,000 seals. 254 
grey  seals  were  caught  in  the  Baltic  Sea  between  1  October  2018  and  31  July  2019.  The 
ringed  seal  population  is  of  at  least  20,000  individuals,  with  an  annual  increase  of  1,000 
individuals. The grey seal used to occupy only the northern Baltic Sea areas but its growing 

8 

 
population  is  now  expanding  to  the  whole  Baltic  Sea,  infesting  the  eastern  cod  stock  with 
parasites,  thereby  increasing  cod  mortality.  For  Finland,  the  EU  should  seriously  consider 
amending the Regulation banning the trade in seal products to reduce the significant negative 
socioeconomic effects of the ban on fisheries and on the hunting culture. 

Swedish  authorities  and  non-governmental  organisations  raised  the  following  comments 
regarding the impact of the Regulation. Seal hunt has always been part of the Swedish culture 
and  history,  and  a  way for  the  small-scale coastal  fisheries  to  get  an  extra  income  from  the 
sale of the meat, skin and bones used for tools, jewellery and weapons. With the ban, fewer 
people hunt for seals, while the increasing seal population reaches beyond the Safe Biological 
Level  and  is  causing  parasite  infections  of  fish  stocks,  competition  for  the  fish  and  the 
destruction  of  fishing  gear.  A  key  concern  highlighted  by  the  Swedish  Environmental 
Protection Agency is that the trade ban of the current seal regime prevents the use of the seal 
as a resource, as well as the effective management of the increasing seal population causing 
serious  damages  to  catch  and  equipment.  Sweden  has  committed  to  ensure  a  favourable 
conservation  status  for  the  grey  seal.  For  the  Swedish  Agency  for  Marine  and  Water 
Management,  the  public  may  therefore  accept  the  measures  necessary  to  implement  the 
required  management  of  the  increasing  seal  population  if  trade  in  seal  products  was 
authorised again for the above reasons. For Sweden, in order to justify the reimbursement for 
damage  caused  by  seals,  allocated  to  fishermen  under  national  legislation,  the  grey  seal 
should be valued as a resource. The economic value of hunting tourism and the sale of seal 
products should be analysed in comparison with the cost of reimbursing damages caused by 
seals.  The  Swedish  Board  of  Agriculture  considers  as  a  guiding  principle  that  all  species 
naturally occurring in Sweden should be managed in a long-term sustainable manner that does 
not  negatively  impact  on  their  conservation  status.  The  amended  EU  Seal  Regime  made  it 
illegal  to  make  commercial  use  of  seals  hunted  for  the  sustainable  management  of  marine 
resources. Thus, while seals are being legally hunted in the Baltic Sea, the catch can only be 
used in the hunter’s own household or it ends up as waste in landfills, which could be seen as 
non-sustainable  from  an  environmental  as  well  as  ethical  perspective.  That  is  why  Sweden 
reports that small-scale trade in seal products should be allowed. The National Board of Trade 
reminded  that  Sweden  had  asked  for  an  exception  to  the  trade  ban  on  seal  products  in 
previous negotiations. The Swedish fishers’ associations raise the fact that seals are causing 
more and more damages to the small-scale coastal fishery sector and that they will continue 
hunting  them  for  resource  management  reasons  in  the  Baltic  Sea.  They  deplore  that  such  a 
valuable resource is turned into waste, since most of the catches end up on dump sites, where 
the  hunters  must  even  pay  in  order  to  dispose  of  their  catch.  According  to  the  Hunters’ 
Association,  seal  hunting  is  part  of  the  cultural heritage  and  a  way  to  protect  the  biological 
diversity of fish stocks. The currently practised protective hunt is governed by strict rules but 
the real issue is that the legally caught seals cannot be used or sold because of the trade ban. 
For  the  Swedish  Hunters’  Association,  protective  hunt  requires  important  investments  in 
knowledge  and  equipment  and  becomes  the  domain  of  a  few  specialised  experts  whose 
interest in hunting decreases when their own personal needs for meat and skin are met. 

4.  Reports by the recognised bodies 

Under Article 3.1a of the Basic Regulation, as amended, seal products that can be placed on 
the  EU  market  under  the  "Inuit  or  other  indigenous  communities”  exception  must  be 
accompanied by an attesting document issued by a body recognised  for that  purpose by the 
European  Commission,  in  accordance  with  Article  3  of  Commission  Implementing 
Regulation (EU) 2015/1850 (the Implementing Regulation). 

9 

 
So far, the European Commission has recognised three bodies: 

-  Greenland Department of Fisheries, Hunting and Agriculture13 
-  Department of Environment, Government of Nunavut (Canada)14 
-  Government of the Northwest Territories of Canada15 

For the current exercise, the recognised bodies were  given until  30 June 2019 to  answer an 
online questionnaire. The reporting period for Greenland and Nunavut was from 26 October 
2015 to 31 December 2018, and for the Northwest Territories of Canada, from 14 February 
2017 to 31 December 2018. 

a) Attesting documents 

The  recognised  bodies  of  Greenland  and  Nunavut  issued  an  important  number  of  attesting 
documents over the reporting period, to accompany their seal products so that these could be 
placed  on  the  EU  market.  These  seals  products  consisted  in  dressed/tanned  sealskin  pelt  or 
leather,  of  products  made  from  commercially  tanned  sealskin  pelt,  but  also  of  accessories 
made using seal pelt, such as headbands, hats, slippers, hairpins or purses. 

The Greenland Department of Fisheries, Hunting and Agriculture issued attesting documents 
to accompany products originating from ringed, harp and hooded seals, which were put on the 
EU market in Denmark, Sweden and the United Kingdom. The table below shows the number 
of units of seal products from a given seal species, imported by these three EU Member States 
during the three years covered by the reporting period. 

25000

22828 

20000

15000

10000

5000

0

14765 

11360 

320 

50 

1 

Denmark

Sweden

2016

2016

5 

UK

2016

1946 

12 

6 

28 

1020 

Denmark

2017

UK

2017

Denmark

2018

Ringed seal

Harp seal

Hooded seal

The  Department  of  Environment  of  the  Government  of  Nunavut  (Canada)  issued  attesting 
documents to accompany products originating from ringed seals only, which were put on the 
EU  market  in  France,  the  United  Kingdom,  Poland,  Sweden  and  Estonia.  The  table  below 
shows  the  number  of  units  of  ringed  seal  products  imported  by  these  EU  Member  States 
during the three years covered by the reporting period. 

13 https://eur-lex.europa.eu/legal-content/EN/TXT/?qid=1571662742841&uri=CELEX:32015D1027(02) 
14 https://eur-lex.europa.eu/legal-content/EN/TXT/?qid=1571662612122&uri=CELEX:32015D1027(01) 
15 https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32017D0265 

10 

 
 
                                                            
80

70

60

50

40

30

20

10

0

71 

59 

5 

France

2016

15 

15 

6 

UK

2016

Poland

Sweden

Estonia

Sweden

2017

2017

2018

2018

The  table  does  not  show  that  Estonia  also  imported  one  harp  seal  product  in  2018.  For 
information only, as Norway is not covered in this Report, the Department of Environment of 
the  Government  of  Nunavut  issued  attesting  documents  to  accompany  377  ringed  seal 
products and 23 harp seal products to be put on the Norwegian market in 2018. 

The  Government  of  the  Northwest  Territories  of  Canada  has  not  issued  any  attesting 
documents during their two-year reporting period, as raw seal pelt sales through auctions have 
been  limited  to  the  domestic  Canadian  market  that  does  not  require  verification  of  origin. 
According to the recognised body, the lack of EU market/demand is due to the EU seal ban. 

The three recognised bodies reported some issues in relation to the attesting documents. 

For  the  recognised  body  of  Greenland,  customs  clearance  at  the  border  for  tanned  sealskin 
packages  from  Great  Greenland  Furhouse/Kopenhagen  Fur  to  the  UK  has  taken  a 
disproportionately long time at the border. This has meant that some customers do not want to 
buy sealskin anymore, as they cannot be sure of getting the goods quickly. 

The  recognised  body  of  Nunavut  identified  several  issues  with  the  attesting  documents  and 
asked the EU whether it would be acceptable for them to: 

- 

- 

Issue one single certificate for multiple pelts, as the Nunavut’s recognised body system is 
currently  set  up  to  issue  certificates  for  individual  pelts  only.  Once  this  issue  is  solved, 
Nunavut would like to fully automate the issuing of certificates. 

Issue  a  certificate  to  Nunavut  handicraft  workers  who  attest  to  only  using  seal  pelts 
resulting  from  hunts  by  Inuit  in  their  work.  One  seal  product  can  indeed  be  made  of 
several  pelts,  or  one  pelt  can  be  processed  into  several  seal  products.  Some  handicraft 
workers  purchase  pelts  from  other  recognised  bodies  and  combine  these  with  Nunavut 
pelts to make their final products. The Government of Nunavut would commit to tracking 
these individuals and requiring a traceability element to ensure compliance. 

-  Not to be obliged to specify the name of the EU Member State where the product will be 
placed on the market. In some circumstances, the product may enter the EU, exit, and then 
re-enter; in others, it may be processed in a given Member State but the recognised body 
does  not  know  where  the  final  product  will  be  placed  on  the  market.  The  current 

11 

 
 
certificate format requires the recognised body to include the name of the Member State 
and this should be changed to a blanket entry into the EU. 

-  Exploring other means of proving the Inuit origin than a physical certificate, for example a 
stamp tattooed only on the pelts that have been tracked and attested by the Government of 
Nunavut, or tags with the QR code and a stamp embossed by the Government of Nunavut, 
which is nearly impossible to imitate. 

The recognised body of Nunavut would also like to know what to do if an individual enters 
the EU with both products for sale and personal items made of seal pelts. 

For  the  recognised  body  of  the  Northwest  Territories,  the  main  issue  is  that  their  current 
system can only verify handwritten certificates  for whole seal pelts (raw or processed). It is 
unable  to  accommodate  for  individual  products  made  from  one  or  more  seal  pelts,  and 
therefore  certificates  need  to  be  created  manually  for  each  item.  The  implementation  of  the 
attesting  document  will  require  modifications  to  their  system,  which  implies  funding.  All 
seals  harvested  by  Inuit/Inuvialuit  in  Nunavut  and  the  Northwest  Territories  should  be 
considered compliant and those pelts should automatically be certified. The mechanisms for 
ensuring  compliance  have  been  well  communicated  through  the  attestation  body  process. 
Penalties  for  non-compliance  do  exist  and  have  not  been  needed  thus  far.  The  recognised 
body of the Northwest Territories deplores the lack of EU commitment to provide financial or 
technical  support  in  order  to  operationalize  the  exemption,  and  urges  the  EU  to  provide 
targeted  project  funding  in  the  field  of  education  and  outreach,  allowing  Inuit/Inuvialuit  to 
advocate  amongst  consumers  and  the  people  of  Europe,  as  they  emerge  in  economic 
activities. 

The  recognised  bodies were  asked to  describe how  they  monitored  compliance  with  Article 
3(1) of the Basic Regulation, as amended, which allows the placing on the market only where 
the  seal  products  result  from  hunts  traditionally  conducted  by  Inuit  or  other  indigenous 
communities, contributing to their subsistence, and with due regard to animal welfare. 

For  Greenland,  the  Department  of  Fisheries,  Hunting  and  Agriculture  referred  the 
Commission to the still valid information provided prior to their recognition as attesting body. 

Nunavut  attests  that  Inuit  have  always  harvested  seals  traditionally  and  historically  in 
Nunavut,  and  that  all  seal  harvests  in  Nunavut  are  subsistence  in  nature.  There  are  no 
commercial licences issued to  Inuit on the territory.  The Nunavut Wildlife Act provides  for 
humane  treatment  of  hunted  seals  and  is  enforced  by  Conservation  Officers.  Sealskins  are 
tracked  through  the  Fur  Tracking  System.  The  Department  of  Environment  of  the 
Government of Nunavut has issued certificates for all certifiable seal pelts and products that 
qualify under the Indigenous Communities exemption. Three main principles of sealing guide 
Inuit  and  the  Government  of  Nunavut:  (1)  sustainable  harvest,  whereby  resources  are 
protected from over-harvesting and managed to maintain the place of seals within the global 
ecosystem; (2) complete use whereby the meat provides food, the pelts are used for clothing 
and the oil is a rich source of omega-3 acids; and (3) humane harvest, whereby seals must be 
treated with respect and hunted only for what is needed, and the kill itself is clean and quick. 

For the Northwest Territories, the Government of the Northwest Territories and the Inuvialuit 
Regional Corporation are the only eligible representatives of Northern cultures/communities. 
A study of the sector and its potential still needs to be undertaken. 

12 

 
None  of  the  recognised  bodies  encountered  any  case  of  non-compliance.  In  Nunavut,  the 
small  group  of  crafters  involved  strictly  follows  the  rules  to  access  the  EU  market.  The 
recognised body of Nunavut has distributed educational materials within the territory and to 
key groups outside of Nunavut, to provide clarity around the process of certification, together 
with their contact details. 

The  three  recognised  bodies  are  being  audited  on  an  annual  basis.  In  Greenland,  this  audit 
does not exclusively address the EU seal regime certification process. In Nunavut, more in-
depth audits can be conducted if specific issues arise. 

The three recognised bodies draw up regular activity reports. In Greenland, on a yearly basis. 
In Nunavut, quarterly briefings are provided to the Minister on the status of all programmes, 
projects, activities and initiatives related to seal pelt use. In the Northwest Territories, regular 
reports are provided to the Minister on initiatives related to the fur industry, thereby covering 
seal  products,  annual  sales  of  raw  material,  and  support  to  traditional  economies.  The 
recognised bodies were not requested to provide any details on the contents of these activity 
reports. 

b) Processing of data 

The three recognised bodies are using an electronic system for the exchange and recording of 
data  contained  in  the  attesting  documents.  Nunavut  is  using  the  Fur  Tracking  System  for 
information on the origin of pelts, and for the issuance of certificates for seal pelts. 

None of the recognised bodies had issues to report as regards the protection of personal data 
at the time of processing the attesting documents. For Nunavut, the Fur Tracking System is in 
part a financial system, and its contents are therefore confidential. 

c) Information through a QR code label 

Upon request from Greenland, the Commission agreed with the placing of a QR code label on 
seal products, with a view to better informing consumers of the existence and legitimacy of 
the Inuit exception. The placing on the EU market is facilitated for a seal product carrying that 
specific  code  and  accompanied  by  its  attesting  document,  issued  by  one  of  the  recognised 
bodies. This QR code links to a webpage providing information on the EU seal regime. 

Greenland and Nunavut are using the QR code. Nunavut is placing it on seal pelts and also on 
product tags, which artisans and craft makers use. The Northwest Territories are not using it 
yet  as  it  would  need  to  be  associated  with  existing  labelling  or  product  branding  and  this 
would require modifying registered trademarks to accommodate the QR code. 

d) Overall assessment 

The recognised bodies provided their assessment of the functioning and effectiveness of the 
"Inuit or other indigenous communities exception" on their territory. 

In  Greenland,  the  Department  of  Fisheries,  Hunting  and  Agriculture  acknowledges  EU’s 
commitment  to  respecting  and  promoting  indigenous  peoples’  rights,  including  the  right  to 
engage  freely  in  their  economic  activities.  However,  in  practice,  they  consider  that  the  EU 
seal  regime  is  having  adverse  effects  on  Inuit  or  other  indigenous  communities.  The 
Department sees a need to raise awareness and improve information to European citizens on 

13 

 
the legality of trade in products from seals hunted by Inuit or other indigenous communities, 
hereby restoring consumer confidence in seal products from Greenland. 

For  the  Government  of  Nunavut,  the  “Inuit  or  other  indigenous  communities”  exception 
functions properly. Some practical issues in relation to issuing certificates would need to be 
solved though, in agreement with the EU. Nunavut would like the certificate of a given pelt to 
be allowed to be used for all products derived from that pelt. They would also like to simplify 
the certificate itself to reduce the information a manufacturer needs to provide (e.g. country of 
placing on the market), and perhaps even reduce the certificate to small tags with a QR code. 
The  exemption  could  be  effective  in  providing  a  means  by  which  Inuit  producers  from 
Nunavut  could  access  the  EU  market  if  the  challenges  noted  above  were  addressed. 
Certification requirements have imposed an undue burden and disincentive on Inuit producers 
and  EU  purchasers.  Nunavut  would  welcome  support  from  the  EU  to  undertake  outreach 
activities  with  EU  manufacturers,  museums  and  retailers  as  regards  the  existence  and 
functioning of the exemption. Nunavut wishes to support the EU in ensuring that indigenous 
rights,  food  sovereignty  and  poverty  reduction  are  achievable  and  addressable  by  the 
legislation that has been enacted. 

For the Government of the Northwest Territories, the direct benefit of the exception has been 
very  limited.  The  attestation  costs  would  be  higher  than  the  value  of  the  seal  products  the 
system is intended to monitor and certify under the EU Regulation and, therefore, these costs 
would  have  to  be  passed  on  to  the  Inuvialuit/Inuit  themselves.  The  impact  of  the  Inuit 
exception would be vastly improved if the EU agreed that all seals harvested by Inuvialuit in 
the  Northwest  Territories  be  considered  compliant  and  therefore  automatically  certified.  A 
system  could  be  developed,  in  consultation  with  the  EU,  to  identify  pelts  and  issue  product 
tags.  Otherwise,  external  funding  would  be  required  to  create  and  maintain  a  system  – 
compliant  with  the  requirements  of  the  EU  regulation  –  that  would  allow  the  Inuit  to 
effectively  access  the  EU  market.  The  domestic  and  local market  for  seal  products  and  raw 
materials remains healthy; however, the export market is limited to non-existent. The level of 
subsistence harvesting remained fairly consistent throughout the years but showed a marked 
decline starting in 2000, in line with decreased demand and actual volume sold. In 2009, the 
Government of the Northwest Territories established a programme to mitigate the effects of 
the EU seal ban to stabilize prices in support of the traditional economy. In the past 10 years, 
only  16%  of  the  raw  pelts  have  been  sold  outside  Canada,  with  a  potential  income  loss  of 
140,000 Canadian Dollars. 

The recognised bodies assessed the impact of the Regulation on Trade in Seal Products on the 
socio-economic development of Inuit or other indigenous communities on their territory. 

In  Greenland,  hunting  and  trading  in  seal  products  is  of  fundamental  socio-economic  and 
cultural importance to Inuit communities. The implementation of the EU seal regime has had 
a  huge  impact  on  sealing,  especially  on  the  remote  and  isolated  areas  in  North  and  East 
Greenland. Compared to the period 2005-2008, i.e. before the EU seal regime, the number of 
seals caught in Greenland in the period 2014-2017 shows a decrease of 35%. The number of 
seal skins sold to the Great Greenland A/S tannery in 2015-2018 decreased by 66%, while the 
number of seal skins sold on the international market in the same period decreased by 54% - 
with  the  highest  drop  of  92%  in  2010  -  and  those  sold  on  the  national  market  by  38%. 
However, the number of seal skins kept for private use in the periods 2005-2008 and 2014-
2017  have  stayed  at  the  same  level.  The  Ministry  of  Fisheries,  Hunting  and  Agriculture 
questions the rationale behind the seal regime and notes that sustainable seal hunting with full 
respect of animal welfare would have been possible without it. The Ministry is concerned that 

14 

 
no prior assessment was carried out, including on the perceived concerns of today’s European 
citizens  as  the  basic  justification  for  the  Regulation,  and  on  possible  alternative  less  trade-
restrictive ways of addressing potential concerns. The Ministry is also concerned that the EU 
seal regime, even with the Inuit exception, is not fulfilling the Blue Economy concept that the 
EU supports in all aspects of sustainable use of living resources, except for seal species. 

In Nunavut and in the Northwest Territories, the year-round harvest, consumption, design and 
sale  of  seal  products  has  been  a  long-standing  component  of  the  cultural  expression  and 
economic  livelihood  of  the  Inuit  society.  Inuit  today  depend  on  seals  for  food  security  and 
income  in  a  territory  with  the  highest  prices  on  store  bought  food  and  limited  employment 
opportunities.  Seal harvesting enables Inuit to maintain  their  connections with  the land, and 
pass  on  traditional  knowledge  and  skills  to  younger  generations.  The  Governments  of 
Nunavut and of the Northwest Territories work with artisans and arts and crafts associations 
to promote the sustainable, traditional, and contemporary economy of their territory, towards 
equal economic independence of both men and women. Inuit women largely market their seal 
products  locally,  within  their  community,  and  do  not  export  them  to  the  EU,  despite  being 
fully compliant with the Regulation. Primary reasons include a fear of being in contravention 
of  the  EU  Seal  Regime,  barriers  to  trade  which  have  resulted  from  the  ban  itself  (loss  of 
interest  from  buyers,  lack  of  connections  with  potential  buyers),  no  experience  of 
international trade, and confusion about certification of pelts vs products from certified pelts. 
As  yet,  for  Nunavut,  the  Regulation  has  not  had  a  positive  impact  on  the  socio-economic 
development  of  Inuit.  The  EU  seal  regime  has  opened  a  door,  but  is  seen  as  a  policed 
instrument. The Government of  Nunavut  invites the EU to  meet with  the recognised bodies 
and other implicated stakeholders to discuss ways to better operationalise the requirements of 
the  Regulation  in  order  to  maximize  the  benefit  of  the  exemption  for  Inuit  in  this  changing 
world. 

The  Northwest  Territories  are  still  creating  the  appropriate  administrative  environment  to 
comply  with  the  exception.  The  critical  first  step  of  identifying  local  capacity  and  potential 
markets/products  demand  has  been  postponed  indefinitely.  The  pre-feasibility  work  was 
expected  to  inform  strategic  investment  decisions  within  the  sector  and  to  encourage  the 
sector  development  in  a  relevant  and  sustainable  way,  but  it  still  needs  to  be  carried  out. 
A promotional  event  hosted  in  March  2019  helped  identify  some  new  market  opportunities 
amongst local residents and visiting populations. The Northwest Territories acknowledge the 
fact that the EU recognises the Inuit as a distinct society of cultural importance and the need 
to equally protect the arctic environment and the Inuit existence. However, for them, the EU 
Seal Regime has destroyed the EU market for seal products, and its negative impact on local 
Inuit/Inuvialuit economies is widespread. The Government of the Northwest Territories urges 
the EU to address the seal ban in a public forum and to issue a communique acknowledging 
the  existence  of  the  Inuit  exception,  listing  the  recognised  jurisdictions  to  date.  The  forum 
should promote the Inuit right to sell raw or processed seal products within the EU and also 
the fact that EU citizens can legally possess, wholesale/retail certified merchandise. 

The recognised bodies were also asked to assess the impact on the Regulation on the seals on 
their  territory.  The  Greenland  Ministry  of  Fisheries,  Hunting  and  Agriculture  wishes  to 
underline that the trade in seal products is a legitimate and sustainable activity that should not 
be hampered or stigmatized, and that animal welfare is a concern to Inuit or other indigenous 
communities. According to Nunavut and the Northwest Territories, there has been no impact 
on  seal  populations  as  a  result  of  the  Regulation,  nor  did  the  exception  increase  harvesting. 
The  harvest  was  and  continues  to  be  conducted  according  to  harvest  regulations  and  Inuit 
values. In the Northwest Territories, subsistence Inuvialuit/Inuit hunters historically harvested 

15 

 
seals  using  traditional  humane  methods.  Seals  are  still  being  harvested  sustainably  as  a 
healthy  and  affordable  source  of  protein  and  of  omega  3  mammalian  oil.  Their  pelts  are 
intended for domestic use or represent a valuable source of income. 

5.  Conclusions 

As  mentioned  above,  this  report  is  based  on  the  contributions  received  by  all  but  four  EU 
Member States (France, Greece, Luxembourg and Malta), and on the reports provided by the 
three recognised bodies in the provider countries. 

a)  Implementation by the EU Member States 

Although,  according  to  the  statistics  provided  by  the  recognised  bodies  of  Greenland  and 
Nunavut,  several  EU  Member  States  imported  seal  products  covered  by  the  “Inuit  or  other 
indigenous communities” exception, only Denmark reported having done so. 

The majority of Member States has no seal populations on their territory. In the Nordic EU 
Member  States  (Denmark,  Finland  and  Sweden)  and  in  Estonia,  the  expanding  seal 
populations  are  becoming  an  issue  for  fishermen.  Seals  are  perceived  as  causing  serious 
damages to local fisheries, eating the catches, destroying the fishing gear and contaminating 
fish stocks with parasites. 

Those  four  Member  States  authorise  seal  hunt  for  marine  resource  management  reasons, 
provided strict rules are respected as regards hunting quotas/season/areas, training of hunters, 
animal  welfare  considerations,  killing  method  used,  type  of  rifles  and  ammunitions.  They 
deplore  that  the  marine  resource  management  exception  was  withdrawn  from  the  EU 
Regulation on Trade in Seal Products, making it illegal for the hunters to put the resulting seal 
products on the EU market. They consider that the fact that only the hunters themselves can 
use  the  seal  products  for  their  own  needs  discourages  the  hunt,  which  turns  out  to  be  more 
expensive than the benefits than can be drawn from it. They also claim that the fact that all 
parts of the caught seals cannot be fully used and that carcasses end up in landfills is against 
the principle of sustainable resource use. According to Sweden, the seal should be valued as a 
resource, and the economic value of hunting tourism and the sale of seal products should be 
analysed in comparison with the cost of reimbursing damages caused by seals to fishermen, 
which is provided for in the national legislation. The four Member States argue that trade in 
seal products has never been a large sector with significant economic turnover but that, in the 
coastal areas, trade has the potential to contribute as a source of income and nurture cultural 
values.  They  plea  for  at  least  small-scale  sale  as  handicraft  by  local  communities  to  be 
allowed, in order to compensate for the expenses of the hunt and to showcase the creativity 
and traditions of these communities.  

Seal populations are closely monitored in these four Member States, and the small number of 
seals  that  have  been  regulated  during  the  reporting  period  has  had  an  almost  insignificant 
impact  on  the  size  and  conservation  status  of  the  growing  populations  of  grey,  ringed  and 
harbour seals. According to these four countries, a seal hunt carried out to sustainably manage 
marine resources, with full respect of animal welfare and with all parts of the caught animal 
being used instead of wasted, should not raise public moral concerns. A recent enquiry shows 
for example that 50% of Finnish citizens have a positive attitude towards small scale trade in 
seal products. 

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b)  Implementation by the recognised bodies 

The  recognised  bodies  acknowledge  EU’s  commitment  to  respecting  and  promoting 
indigenous  peoples’  rights,  including  the  right  to  engage  freely  in  their  economic  activities, 
and they want to support the EU in ensuring that these rights, but also food sovereignty and 
poverty reduction, are achievable and addressable by the legislation that has been enacted. 

However, for them, the EU Seal Regime is having adverse effects on Inuit or other indigenous 
communities, and certification requirements have imposed an undue burden and disincentive 
on Inuit producers and EU purchasers. Greenland underlines that the trade in seal products is 
a  legitimate  and  sustainable  activity  that  should  not  be  hampered  or  stigmatized,  and  that 
animal  welfare  is  a  concern  to  Inuit  or  other  indigenous  communities.  The  Northwest 
Territories  are  still  creating  the  appropriate  administrative  environment  to  comply  with  the 
exception but, for them, the EU Seal Regime has destroyed the EU market for seal products, 
and  it  would  be  vastly  improved  if  the  EU  would  agree  that  all  seals  harvested  by 
Inuit/Inuvialuit be considered compliant and therefore automatically certified. For Greenland, 
less  trade  restrictive  ways  of  addressing  potential  perceived  concerns  of  European  citizens, 
and  sustainable  seal  hunting  with  full  respect  of  animal  welfare,  would  have  been  possible 
without the EU Seal Regime. In Greenland, the number of seals caught and of seal skins sold 
on the domestic or the international markets in the period 2014-2017 shows a huge decrease 
compared to the period before the EU Seal Regime. 

In Nunavut and in the Northwest Territories, there has been no impact on seal populations as 
a  result  of  the  Regulation,  nor  did  the  exception  increase  harvesting,  which  continues  to  be 
conducted  according  to  harvest  regulations  and  Inuit  values.  In  the  Northwest  Territories, 
subsistence  Inuvialuit/Inuit  hunters  are  still  harvesting  seals  sustainably,  using  traditional 
humane methods, as a healthy and affordable source of food and a valuable source of income. 

Greenland urges the EU to raise awareness and improve information to European citizens on 
the legality of trade in products from seals hunted by Inuit or other indigenous communities, 
hereby  restoring  consumer  confidence.  Nunavut  invites  the EU  to  meet  with  the  recognised 
bodies  and  other  implicated  stakeholders  to  discuss  ways  to  better  operationalise  the 
requirements of the Regulation in order to maximize the benefit of the exemption for Inuit in 
this changing world. The Northwest Territories urge the EU to address the seal ban in a public 
forum and to issue a communique acknowledging the existence of the Inuit exception and the 
right of the Inuit to sell seal products to the EU and of EU citizens to legally possess certified 
seal products. 

6.  Next steps 

Further to the questions raised and concerns expressed by the four EU Member States affected 
by  the  increasing  seal  population  and  by  the  three  recognised  bodies,  the  European 
Commission  will  organise  in  2020  a  special  meeting  of  the  “Group  of  Experts  of  the 
Competent  CITES  Management  Authorities”  from  the  EU  Member  States,  especially 
dedicated to trade in seal products, and invite the recognised bodies to join the meeting for the 
agenda items dealing with issues relevant for them. 

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