COMMISSION STAFF WORKING DOCUMENT EXECUTIVE SUMMARY OF THE EVALUATION of the EU action plan against wildlife trafficking Accompanying the document COMMUNICATION FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT, THE COUNCIL, THE EUROPEAN ECONOMIC AND SOCIAL COMMITTEE AND THE COMMITTEE OF THE REGIONS Revision of the EU action plan against wildlife trafficking
Date: 2022-11-09
Institutions: Directorate-General for Environment, European Commission
Subjects: EU action, biodiversity, environmental cooperation, illicit trade, organised crime, protection of animals, protection of plant life, wildlife

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  EN 

   EUROPEAN COMMISSION  Brussels, 9.11.2022  SWD(2022) 355 final  COMMISSION STAFF WORKING DOCUMENT  EXECUTIVE SUMMARY OF THE EVALUATION  of the EU action plan against wildlife trafficking Accompanying the document COMMUNICATION FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT, THE  COUNCIL, THE EUROPEAN ECONOMIC AND SOCIAL COMMITTEE AND THE COMMITTEE OF THE REGIONS Revision of the EU action plan against wildlife trafficking {COM(2022) 581 final} - {SWD(2022) 354 final}  
 
 
The EU action plan against wildlife trafficking (“2016 action plan”) was adopted in 2016, for 
the period 2016 to 2020. An initial review of implementation was undertaken in 20181. The 
evaluation  was  undertaken  in  the  course  of  2021-2022.  More  detail  can  be  found  in  the 
support study. 

The  current  evaluation  covers  action  to  combat  illegal  wildlife  trade  undertaken  by  the 
European Union and its Member States since the adoption of the 2016 action plan. It seeks to 
assess  the  2016  action  plan  through  evaluation  of  its  effectiveness,  efficiency,  relevance, 
coherence and EU added value.  

to  compare  current  action  against  wildlife 

Due  to  the  illegal  nature  of  the  activities,  data  on  wildlife  trafficking  is  neither  widely 
available nor robust and complete. There is therefore a notable absence of a baseline against 
which 
trafficking  as  well  as  key 
measurable/performance indicators.  Moreover, the  action  plan is  broad  and ambitious by its 
very  design,  encompassing  a  wide  variety  of  actors  and  actions.  Therefore,  assessing 
achievements  is  challenging  –  especially  due  to  the  lack  of  a  monitoring  and  evaluation 
framework. In addition, the 2016 action plan was adopted in the context of existing EU and 
Member State action against wildlife trafficking, seeking to raise ambitions and coordinate the 
existing efforts within the EU. Where new actions have been undertaken, it is impossible to 
prove that they would not have occurred without the Action Plan.  

these 

limitations 

into  account, 

Taking 
literature  reviews, 
implementation reports, and a series of stakeholder consultations undertaken in 2021- 2022, to 
assess  the  coherence  of  efforts  taken  to  address  the  illegal  wildlife  trade  since  2016.  The 
evaluation was used to inform the elaboration of the revised EU action plan against wildlife 
trafficking.  

the  evaluation  drew  on 

The  evaluation  found  that  there  has  been  progress  towards  the  implementation  of  the 
objectives  of  the  action  plan,  leading  to  raising  the  profile  and  a  strengthened  response  to 
illegal wildlife trade, as well as increased cooperation and coherence between Member States.  

Due to the difficulties mentioned above, it was difficult to measure the cost efficiency of the 
action  plan.  Most  of  the  actions,  including  projects,  policy  and  legal  initiatives,  as  well  as 
outreach  at  the  international  level,  did  not  come  with  dedicated  funding  and  their  results 
cannot be translated in economic terms. Even in case of EU funded projects, the actions listed 
in  the  action  plan  have  often  been  implemented  through  contracts  supporting  wider 
environmental  (e.g.  biodiversity),  enforcement  (e.g.  organized  crime)  and  other  goals. 
Moreover,  in  terms  of  measuring  benefits,  while  the  link  between  providing  alternative, 
sustainable  income  to  local  populations  and  reducing  poaching  is  well-established,  there  is 
little way to measure this impact directly. Many of the projects in third countries take a wide, 
community-based, approach within which action against wildlife trafficking is a constituting 
part rather than being the primary aim. Therefore, only general estimates are available. 

The  benefits  generated  by  the  action  plan  are  also  difficult  to  determine  precisely.  It  is 
possible,  however,  to  outline  the  potential  benefits.  Fighting  the  illegal  wildlife  trade 
contributes  to  preserving  global  biodiversity,  which  underpins  all  economic  activity,  and  is 
presently  worth  an  estimated  127  trillion  EUR2.  In  addition,  the  fight  against  the  illegal 

1 European Commission, Directorate-General for Environment, Study to support the Evaluation and Revision of 

the EU Action Plan against Wildlife Trafficking, Publications Office, 2022.  

2 WWF, Living planet report 2020: Bending the curve of biodiversity loss, 2020. 

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wildlife  trade  contributes  to  strengthening  rule  of  law,  reducing  threats  to  security,  and  is  a 
key  part  of  the  fight  against  organized  crime.  The  benefits  of  these  issues  are  not  easily 
quantifiable, and go beyond economics. 

The analysis of the actions taken under each objective did not identify any contradiction, and 
it was possible to conclude that the action plan was internally consistent and coherent. While 
many actions against the illegal wildlife trade were occurring in the EU and Member States, 
and  internationally,  before  its  adoption,  the  action  plan  has  proven  to  be  a  well-suited 
response to a need for an organized and coordinated response at an EU level. Coordination, 
funding and political prioritisation were key aspects where strong EU added value was noted.  

Wildlife  trafficking  takes  different  forms  in  different  Member  States  and  requires  adapted 
approaches to tackle the challenges at hand. However, coordination and cooperation between 
Member States is  a key  aspect  as the EU is  a single market,  to  ensure a common and level 
implementation of rules, and avoid loopholes in certain Member States being problematic for 
other Member States. In that sense, the illegal wildlife trade is to be tackled at the EU level, 
with a strong involvement of relevant authorities in the Member States. At the same time, the 
action  plan  was  found  to  be  sufficiently  flexible  to  allow  for  Member  States  to  prioritise 
actions  that  were most relevant  to  them, whether through the definition of a national  action 
plan or through mechanisms that improve coordination and prioritisation of actions. 

The  comprehensive  and  ambitious  nature  of  the  action  plan  presented  its  own  challenges. 
During  consultations,  the  primary  challenges  to  implementation  identified  by  relevant 
stakeholders were the persistent lack of human and financial resources, and the wide-ranging 
scope of the action plan. Member States often lacked the time and staff to implement actions 
and  faced  difficulties  in  coordinating  action  between  different  authorities  and  actors, 
especially at the national level. The problem of lack of resources and coordination was found 
across the entirety of the action plan, but also notably when it came to reporting.  

The  action  plan  has  been  a  crucial  tool  to  coordinate  the  many  aspects  of  the  fight  against 
wildlife trafficking and to raise the profile of this fight at Member State level and within the 
EU.  While  it is  complicated  to  assess  the  extent  to  which  the  progress  is  attributable  to  the 
action  plan itself, it speaks  to  the success  of its approach as  a comprehensive framework to 
tackle  the  fight  against  wildlife  trafficking  in  the  EU  and  its  Member  States.  As  the  illegal 
wildlife trade remains an important threat to biodiversity and security both worldwide and the 
EU, the action plan remains an important and relevant tool to address it.  

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