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 Trade in Seal Products
Date: 2023-10-19
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, 19.10.2023  COM(2023) 633 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 Trade in Seal Products  
 
 
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 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 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 
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 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 
Regulation, as amended). 

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

Article  7  of  the  Regulation,  as  amended,  sets  out  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.  In  its  report,  the  Commission  shall 
assess the functioning, effectiveness and impact of the Regulation in achieving its objective. 

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 

1 

 
 
 
The Commission report should also assess the impact on the socioeconomic development of 
the Inuit or other indigenous communities5. 

The  first  Commission  Report  on  the  implementation  of  the  Regulation,  covering  the  period 
from  18  October  2015  (date  of  application  of  Regulation  (EU)  2015/1775)  to  31  December 
2018, was adopted on 10 January 20206. 

This report covers the period from 1 January 2019 to 31 December 2022. It  is based on the 
contributions  received  from  the  EU  Member  States,  the  United  Kingdom,  and  the  three 
recognised bodies in Canada and Greenland. 

2.  Background 

In 1983, in response to widespread concerns about the annual killing of certain seal pups, the 
EU adopted Council Directive 83/129/EEC7 to prohibit the import of products from two seal 
pup species,  Harp seal  (‘whitecoat’)  and  Hooded seal  (‘blue-back’), into  the EU.  It initially 
applied until 1  October  1985. Its  validity  was first  extended until  1 October 1989, and then 
indefinitely through Council Directive 89/370/EEC8. 

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.  Citizens  and 
consumers  expressed  concerns  as  to  the  possible  presence  on  the  market  of  seal  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  adversely  affected  the  operation  of  the  internal 
market  and  constituted  barriers  to  trade.  Therefore,  the  EU  adopted  Regulation  (EC)  No 
1007/2009 of the European Parliament and of the Council (the Regulation), which introduced 
a prohibition on the placing on the EU market of seal products. 

At  the  same  time,  the  EU  was  prompted  by  governments  and  organisations  outside  the  EU 
who represent Inuit and indigenous peoples, to recognise that seal hunting was an integral part 
of  the  socio-economy,  nutrition,  culture  and  identity  of  these  communities,  contributing  to 
their  subsistence  and  development,  which  should  not  be  adversely  affected,  in  accordance 
with  the  United  Nations  Declaration  on  the  Rights  of  Indigenous  Peoples  of  2007.  They 
claimed that seal hunts traditionally conducted by Inuit or other indigenous communities did 
not  raise  the  same  public  moral  concerns  as  those  conducted  primarily  for  commercial 
reasons. Therefore, by way of exception, the 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  2009  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.  It  also  allowed  the  import  of  seal  products  of  an  occasional  nature  and 
consisting exclusively of goods for the personal use of travellers or their families. 

5 See Recital 8 of Regulation (EU) 2015/1775 
6 https://eur-lex.europa.eu/legal-content/EN/TXT/?qid=1578667308224&uri=COM%3A2020%3A4%3AFIN 
7 https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:31983L0129 
8 https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:31989L0370 

2 

 
 
In  2010,  Canada  and  Norway  launched  dispute  settlement  proceedings  at  the  World  Trade 
Organization  (WTO)  against  the  Regulation  and  its  initial  Implementing  Regulation  (EU) 
737/2010. In 2013, the WTO concluded that, by allowing certain seal products to enter the EU 
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 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.  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  their  marine  resources.  It,  however,  prevented  these  Member  States  from 
allowing the placing on the EU market of the products derived from such hunts, unless these 
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 
Regulation by explicitly adding animal welfare considerations as a condition for the use of the 
“Inuit or other indigenous communities” exception. 

To  ensure  a  uniform  implementation  of  the  Regulation,  the  Commission  adopted  the 
Implementing Regulation, which i) specifes the requirements for the import of seal products 
for the personal  use of travellers or their families;  ii) lists the criteria  for the recognition  of 
bodies  responsible  for  issuing  documents  attesting  compliance  with  the  “Inuit  or  other 
indigenous  communities”  exception;  and  iii)  specifies  the  role  of  the  Member  States’ 
competent  authorities  for  the  control  of  the  attesting  documents  and  the  recording  of  data 
included therein. 

Under  Article  3(1)a  of  the  Regulation,  as  amended,  seal  products  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). 

So far, the European Commission has recognised three bodies: 

-  Greenland Department of Fisheries, Hunting and Agriculture9 (now called Department of 

Fisheries and Hunting) 

-  Government of Nunavut (Canada)10 
-  Government of the Northwest Territories of Canada11 

3.  EU Member States’ reports 

The 27 EU Member States were requested to provide their national reports to the Commission 
through answering a questionnaire. All but three Member States (France, Greece and Malta) 
provided their national report. The further mention “all the Member States” should therefore 
be  understood  as  “all  but  the  three  Member  States  that  did  not  provide  their  report”.  This 
section summarises the inputs received. 

9 https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32015D1027(02) 
10 https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=uriserv:OJ.L_.2020.426.01.0056.01.ENG 
11 https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32017D0265 

3 

 
 
a) Competent authorities 

In  accordance  with  Article  6(1)  of  the  Implementing  Regulation,  each  Member  State  shall 
designate  one  or  several  competent  authorities  responsible  for  (a)  the  verification,  upon 
request of the customs authorities, of attesting documents for imported seal products; (b) the 
control  of the issuing of attesting documents by recognised bodies established and active in 
that Member State, and (c) the preservation of a copy of attesting documents issued for seal 
products originating from seal hunts in that Member State. The Commission has made the list 
of designated competent authorities available on its website12. 

Even though no bodies, established and active in the EU, have been officially recognised so 
far  for  issuing  attesting  documents,  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 place 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, Article 6(1) (b) and (c) of the Implementing Regulation would be relevant. 

b) "Inuit or other indigenous communities" exception 

Denmark and Estonia were the only Member States to report that seal products were placed 
on  their  market,  based  on  the  conditions  set  out  in  the  “Inuit  or  other  indigenous 
communities” exception. The Danish customs recorded seal product imports from Greenland 
for a total value of DDK 8 347 944 (= EUR 1 122 337 with the exchange rate of 17.01.2023) 
and a total volume of 32 109 kg, in comparison with the 10 502 kg reported for the previous 
period,  which  covered  three  years  instead  of  four.  For  the  first  time,  Estonia  reported  seal 
product  imports  from  Greenland  for  a  total  value  of  EUR  1  555.67  and  a  total  volume  of 
34.16  kg.  The  products  imported  by  Denmark  and  Estonia  mainly  included  unassembled 
tanned or dressed sealskins, but also articles of apparel, clothing accessories and other articles 
of sealskin, such as shoes and boots from seal leather. 

c) Exception for the personal use of travellers or their families 

None of the Member States’ competent authorities was notified by its customs authorities of a 
possible issue with the occasional import of seal products for the personal use by travellers or 
their families. 

d) Inward processing 

The import of seal products for processing and re-export of the processed goods is not banned 
under the Regulation. In Estonia, tanned sealskins (2 405 pieces in 2019; 1 682 in 2020; 2 030 
in 2021 and 1 875 in 2022) were imported from Canada and Norway for inward processing by 
a shoe manufacturer which then re-exported all the processed goods. 

e) Penalties and enforcement 

All the Member States reported having rules in place on penalties applicable to infringements 
of the provisions of the Regulation. They range from fines, confiscation and destruction of the 
goods  (in  all  the  Member  States),  to  imprisonment  (in  Cyprus,  Denmark,  Latvia  and  the 
Netherlands). No Member State imposed such penalties during the period of reference. 

12 https://environment.ec.europa.eu/topics/nature-and-biodiversity/trade-seal-products_en 

4 

 
 
The chart below shows the maximum amounts established for fines in the 18 Member States 
that communicated this information. In eight of them, the amounts for fines differ according 
to whether the offence is committed by a natural person or by a legal person. In Denmark and 
Finland, the maximum amount for fines is not stipulated in the national legislation. It would 
have to be estimated by the competent authorities in case of violation of the Regulation.  

MA XI MUM  A MO UNT S ESTA BLI SHE D FO R  FI NES (I N   E UR)

On natural persons

On legal persons

0
0
0
0
0
1

0
0
0
0
0
1

0
0
0
0
0
1

0
0
0
0
0
1

0
0
0
0
9

0
0
0
0
3

0
0
0
0
3

0
0
5
2
2

0
0
0
6
6

0
0
0
6
3

6
1
9
9
1

0
0
4
6

0
0
2
1

4
5
2

4
5
2

0
0
0
7

0
0
4
1

0
0
3

0
0
3

0
0
0
4

0
2
7

0
2
7

0
0
4

0
0
4

0
0
0
5
2

0
0
0
5
2

0
0
0
2

0
0
0
2

0
0
0
0
1

0
0
0
5

2
7
2
3
1

0
9
9
1

0
0
0
1
2

0
0
0
1
2

0
0
0
7
1

0
0
0
7
1

Note:  For  the  Netherlands,  the  above  maximum  amounts  concern  offences  that  have  not  been 
committed deliberately. In case of intent, the fine can rise to EUR 90 000 for natural persons and EUR 
900 000 for legal persons. 

Two  imports  of  seal  products  were  stopped  by  the  Belgian  customs.  The  first  case  was  a 
package  coming  by  post  from  the  United  States  with  a  dietary  supplement  containing  an 
extract  of  seal  thyroid  (omega-3  capsules).  The  second  case  was  a  seal  skull  for  which  the 
necessary  documents  were  not  provided.  The  Swedish  customs  carried  out  almost  4  000 
documentary  checks  of  import  declarations.  Seven  of  them  were  supposedly  covering  seal 
products  but  wrong  combined  nomenclature  codes13  had  actually  been  used.  These 
declarations were corrected by the Swedish customs. 

f) Information through a QR code 

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 may place a QR 
code label on the seal products that they certify. This QR code links to a webpage14 providing 
information on the EU seal regime. 

Fifteen  Member  States  (Belgium,  Croatia,  the  Czech  Republic,  Denmark,  Estonia,  Finland, 
Ireland, Latvia, Lithuania, Poland, Portugal, Romania, Slovakia, Slovenia and Sweden) have 

13 https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=OJ:L:2022:282:FULL&from=EN 
14 https://environment.ec.europa.eu/topics/nature-and-biodiversity/trade-seal-products_en 

5 

 
 
 
reported  being  aware  of  the  existence  of  this  QR  code,  and  none  of  the  Member  States  has 
been contacted by its customs authorities or other enforcement bodies for advice in relation to 
the QR code. 

g) Seal hunt in the EU 

Seal populations in the EU are mainly concentrated in the Baltic Sea. According to a holistic 
assessment  of  the  state  of  the  Baltic  Sea15  by  the  Baltic  Marine  Environment  Protection 
Commission, also known as HELCOM, three seal species are resident in the Baltic Sea. The 
Grey seal occurs in the whole region, whereas the Baltic ringed seal is restricted to the eastern 
and northern Baltic Sea, and the Harbour seal to the southwestern Baltic Sea and the Kattegat. 

The  Habitats  Directive16  aims  to  contribute  towards  ensuring  biodiversity  through  the 
conservation of natural habitats and of wild fauna and flora in the EU. Its Annex II, listing the 
species requiring the designation and management of special areas of conservation, includes: 

-  Halichoerus grypus (Grey seal) 
-  Monachus monachus (Mediterranean monk seal) 
-  Phoca/Pusa hispida botnica (Baltic ringed seal) 
-  Phoca/Pusa hispida saimensis (Saimaa ringed seal) 
-  Phoca vitulina (Harbour seal) 

The  Mediterranean  monk  seal  and  the  Saimaa  ringed  seal  are  priority  species  and  therefore 
also listed in Annex IV of the Habitats Directive, which means that Member States must take 
the  requisite  measures  to  establish  a  system  of  strict  protection  for  these  species.  The  three 
other  species  (Grey  seal,  Baltic  ringed  seal  and  Harbour  seal)  are  also  listed  in  Annex  V, 
meaning  that Member States should  take measures to  ensure that their taking in  the wild  as 
well  as  their  exploitation  is  compatible  with  their  being  maintained  at  a  favourable 
conservation status. 

During  the  reporting  period,  as  the  removal  of  the  “sustainable  management  of  marine 
resources” exception from the initial Regulation was without prejudice to the right of Member 
States  to  continue  regulating  hunts  conducted  for  that  purpose,  Ringed,  Harbour  and  Grey 
seals  have  been  hunted  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 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,  there  is  no  hunting  season  or  quota  for  seals.  Shooting  seals  can  only  be 
authorised  through  a  derogation,  within  a  radius  of  100  meters  from  the  fishing  gear  and 
outside  breeding  and  moulting  periods,  to  prevent  serious  damage  to  fisheries.  In  addition, 
derogation shooting of Grey seals is not allowed within Natura 2000 sites designated for that 
species. 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 licence. The hunter is encouraged to aim for the head for an instant kill. In Bornholm, 
Grey  seals  may  be  shot  throughout  the  year,  as  there  are  no  breeding  grounds  in  that  area. 
Seal populations are monitored in Denmark with yearly counting. Denmark reported that the 

15 http://stateofthebalticsea.helcom.fi/biodiversity-and-its-status/marine-mammals/ 
16 https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A01992L0043-20130701 

6 

 
 
number of seals  shot through derogation shooting during the  reporting period (134 Harbour 
seals and 9 Grey seals) has had no significant impact on the population size. 

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 
and  animal  welfare  is  fully  considered.  Seal  hunt  may  only  take  place  in  designated  areas, 
during  the  hunting  season,  and  hunters  must  have  passed  a  shooting  test  and  use  specific 
weapons  and  ammunitions.  Based  on  the  latest  Estonian  monitoring  report,  the  number  of 
Grey seals in Estonian waters is on an upward trend, and the largest number of Grey seals in 
the last 20 years was counted throughout the Baltic Sea in 2021. Estonia reported that a small-
scale  hunt,  limited  to  a  yearly  quota  of  1%  of  the  seal  population,  which  represented  55 
individuals per year  during  the reporting  period,  is  necessary to  reduce damage to  fisheries, 
but it is not allowed in the special protection areas designated for the Grey seal. 

In  Finland,  seal  hunt  is  carried  out  for  sustainable  management  of  marine  resources,  to 
prevent  damage  to  commercial  fisheries.  Hunting  quotas  are  established  for  Grey  seals  and 
Ringed seals. Throughout the reporting period, the hunting quota for Grey seals in mainland 
Finland  was  1  050  individuals  per  year.  The  average  hunting  quota  for  Ringed  seals  in  the 
Bothnian  Bay  area  during  the  same  period  was  335  individuals  per  year,  while  the  average 
hunting quota for Grey seals in the Åland island, an autonomous region of Finland, was 480 
individuals  per  year.  The  seal  hunt  is  also  subject  to  a  hunting  season,  specific  technical 
characteristics for guns and ammunitions, and passing an examination with a prior course on 
hunting ethics to apply a killing method causing immediate death. No hunting is allowed on 
threatened  seal  populations  (e.g.  Ringed  seal  in  the  Gulf  of  Finland  and  Archipelago  Sea). 
Finland  reported  that  the  estimated  yearly  increase  of  the  seal  population  is  higher  than  the 
number of hunted seals, and that there is evidence that seals eat fish from fishing gear unless 
this gear is seal-proof.  However, 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. Seals eat 3 to 5 kilos of 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. The positive effect  of a hunt  close to  fishing 
gear is only temporary as new seals emerge within a few days or even hours. Therefore, seal 
hunt cannot be considered the only way to mitigate the problems caused by seals. 

Sweden’s  wildlife  management  includes  licence  hunting  of  Grey  seals  since  2020  and 
Harbour  seals  since  2022,  and  “protective  hunting”  of  Ringed  seals.  Protective  hunting  is 
allowed and strictly regulated in areas where the growing seal population  is causing serious 
damage to  local  fisheries,  destroying  the  fishing gear and eating the catches.  As opposed to 
protective hunt, licence hunt is not restricted to the areas where seals are causing damage to 
fisheries.  There  is  a  hunting  quota.  The  average  hunting  quota  for  Grey  seals  during  the 
reporting  period  was  1  692  individuals  per  year,  while  it  was  712  individuals  for  Harbour 
seals  and  346  individuals  for  Ringed  seals.  Ammunitions  are  strictly  regulated,  the  killing 
method used must cause immediate death, avoiding unnecessary suffering, and hunting seals 
from a boat requires the boat to stand still. Research is ongoing to develop seal-proof fishing 
equipment. Sweden reported that the number of seals hunted to protect the fishing sector only 
represents a small share of the seal population.  

The chart below gives the total number of seals hunted during the reporting period by the four 
EU  Member  States  authorising  this  hunt  for  the  sustainable  management  of  their  marine 

7 

 
resources. In Finland and Sweden, the quotas are set for a hunting season and not by calendar 
year.  The hunting season starts  in  autumn  and ends the following year  in  spring.  Under the 
Habitats Directive, Member States are responsible for ensuring that the taking of specimens of 
these  species,  which  are  listed  in  Annex  V  of  the  Directive,  is  compatible  with  their  being 
maintained at a favourable conservation status. 

4500

4000

3500

3000

2500

2000

1500

1000

500

0

Seal hunt in EU Member States during the whole 
reporting period (in number of seals)

4248

2141

1113

1525

1068

134

9

0

81

0

0

0

Denmark

Estonia

Finland

Sweden

Grey seal

Ringed seal

Harbour seal

In Latvia, seal hunt applications were received during the reporting period, but denied. After 
the recent approval of a seal management plan, the hunting of a small number of adult Grey 
seals is allowed as of 2023, to prevent damage to fisheries when no alternative method can be 
found. 

h) Overall assessment by the EU Members States 

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

Eight  Member  States  (Bulgaria,  Croatia,  Cyprus,  Czech  Republic,  Hungary,  Ireland, 
Lithuania  and  Slovakia)  mentioned  that  there  has  been  no  trade  in  seal  products  on  their 
territory  during  the  reporting  period  and  that  they  were  therefore  unable  to  assess  the 
functioning, effectiveness and impact of the Regulation. Five Member States (Germany, Italy, 
Luxembourg, Romania and Slovenia) did not provide any assessment. 

Seven  Member  States  (Austria,  Belgium,  Denmark,  the  Netherlands,  Poland,  Portugal  and 
Spain) consider that the Regulation is fit for purpose and that procedures are in place at their 
customs  authorities  to  implement  it  properly.  They  have  not  experienced  any  problem  with 

8 

 
 
the Regulation so far. The Netherlands committed to reinforce the cooperation between their 
competent authorities and customs in this regard. 

Estonia, Finland, Latvia and Sweden consider that the Regulation functions well as a means to 
control  the  trade  of  seal  products  but  its  impact  has  gone  beyond  its  intended  purpose. 
According to them, the ban has contributed to the present poor state of coastal fishing and has 
significantly downgraded the value of seals as a game species. In their view, it is important to 
include  the  management  of  seal  populations  in  the  ecosystem-based  management  plans  for 
EU  waters.  They  claim  that  their  seal  populations  are  closely  monitored  and  that  the  small 
number of seals hunted during the reporting period has had an almost insignificant impact on 
their population size and conservation status. These Member States consider 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.  According  to  Swedish  hunting  ethics,  an  animal  must  be  hunted  in  a  humane 
manner  and  the  resulting  resource  should  be  fully  used  for  the  hunt  to  be  considered 
acceptable. As the seal hunters, after collecting what they need for their personal use, have to 
destroy  or  dump  this  valuable  resource,  Sweden  considers  that  the  ban  goes  against  these 
ethics  and  makes  the  seal  hunt  less  attractive.  These  Member  States  highlighted  that, 
meanwhile,  the  increasing  seal  population  is  causing  damage  to  fishing  gear  and  catches, 
infesting all fish species with seal worms, killing harbour porpoises, and catching large adults 
of  cod,  salmon,  sea  trout  and  pike,  with  economic  consequences  for  recreational  fishing 
tourism. To alleviate the situation, Sweden enacted a national decree in 2020, which provides 
that, if a male Grey seal causing damage to fisheries or to aquaculture is legally hunted, the 
prejudiced  party  is  entitled  to  financial  aid  for  the  appropriate  processing  of  the  carcass.  In 
Finland,  around  350-400  fishermen  per  year  are  affected  by  damage  caused  by  seals. 
Compensation can be given for the costs incurred for salvaging and submitting seal carcasses 
of legally hunted seals to an approved facility for destruction. No compensation is given for 
the  hunt  itself.  The  support  is  intended  to  encourage  increased  seal  hunting,  but  Finland 
considers  that  lifting  the  seal  trade  ban  would  be  an  even  stronger  incentive.  It  would  also 
eliminate the need for compensation and the related administrative costs. 

Estonia, Finland, Latvia and Sweden admit that 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.  A  lift  of  the  ban 
would  help  exploit  this  potential,  create  a  national  market  and  export  opportunities  for  seal 
products, and increase the value of seal products and  even the volume of imports to the EU 
from Inuit or other indigenous communities, as the placing on the EU market of seal products 
would not be wrongly perceived as totally banned anymore. These Member States claim that 
small-scale sale as handicraft by local communities in the EU should be allowed, in order to 
compensate for the expenses of the hunt and to showcase the creativity and traditions of these 
communities. If a lift of the ban is not possible, Estonia, Finland, Latvia and Sweden advocate 
for  considering  the  reinstatement  of  the  sustainable  management  of  marine  resources 
exception  for  Member  States  that  include  protective  and  licence  seal  hunt  in  their  wildlife 
management  plans.  In  2019,  the  Swedish  Parliament  called  on  the  government  to  work 
towards a lift of the ban or at least an exception to the ban. 

4.  Report by the United Kingdom 

For the current exercise, the United Kingdom was still requested to provide its national report 
to  the  Commission.  The  reporting  period  for  Great  Britain  was  from  1  January  2019  to 
31 December 2020, which was the end of the transition period jointly agreed by the EU and 

9 

 
the  United  Kingdom    following  the  United  Kingdom  ’s  withdrawal  from  the  EU.  For  the 
United Kingdom  in respect of Northern Ireland, the reporting period was the same as for the 
EU  Member  States  (i.e.  until  end  2022)  by  virtue  of  the  Windsor  Framework17,  which 
includes the Seals Regulation. 

Therefore, the elements  below applied to Great  Britain until the end of the transition period 
and they continue to apply in and to the United Kingdom in respect of Northern Ireland. 

The  United  Kingdom  Seal  Products  Regulations  2010  implement  the  EU  Regulation.  His 
Majesty’s Revenue & Customs, Home Office and Border Force Agency are instructed to act 
in accordance with the EU and domestic legislation and relevant guidance on the seal regime. 
The processes are in place for the EU Regulation to function effectively. 

The rules on penalties are contained in the Seal Products Regulations 2010. Anyone guilty of 
an offence is liable to a fine not exceeding GBP 75 000. The maximum amount is the same 
for fines imposed on legal persons. 

During  the  reporting  period,  no  seal  products  were  placed  on  the  United  Kingdom  market 
under the “Inuit or other indigenous communities” exception. 

The United Kingdom reported that there is no seal hunt on its territory as marine mammals, 
including seals, are protected under legislation that makes it an offence to intentionally kill, 
injure or take any wild marine mammal. 

5.  Reports by the recognised bodies 

For  the  current  exercise,  the  recognised  bodies  of  Canada  and  Greenland  were  asked  to 
answer a questionnaire. The reporting period was the same as for the EU Member States, i.e. 
from 1 January 2019 to 31 December 2022. 

a) Attesting documents 

The  Greenland  Department  of  Fisheries  and  Hunting  issued  attesting  documents  to 
accompany  sealskins  from  Ringed  and  Harp  seals,  which  were  put  on  the  EU  market  in 
Denmark and Estonia. The chart below shows the number of units of sealskins imported from 
Greenland  by  these  two  EU  Member  States  during  the  reporting  period.  The  Greenland 
Department of Fisheries and Hunting also mentioned the export of 281 sealskins to Italy and 
18  sealskins  to  Portugal  in  2019,  but  these  imports  were  not  reported  by  the  relevant  EU 
competent authorities. 

17 Since 24 March 2023, by virtue of Joint Declaration No 1/2023 of the Union and the United Kingdom in the 
Joint Committee established by the Agreement on the Withdrawal of the United Kingdom of Great Britain and 
Northern Ireland from the European Union and the European Atomic Energy Community, the Protocol on 
Ireland/Northern Ireland should be known as the ‘Windsor Framework’.  

10 

 
 
20000
18000
16000
14000
12000
10000
8000
6000
4000
2000
0

Sealskins imported from Greenland and covered by an 
attesting document (in Units)

17403

10267

6149

8805

799

0

0

0

Denmark

Estonia

2019

2020

2021

2022

The  Government  of  Nunavut  (Canada)  issued  two  attesting  documents,  in  2020  only,  to 
accompany two Ringed seal skulls and two Ringed seal skins exported to Belgium, and one 
complete seal skull with two tusks exported to Italy. These imports were not reported by the 
relevant EU competent authorities. 

The Government  of the  Northwest  Territories of Canada  issued  two  attesting documents,  in 
2022  only,  to  accompany  one  fur  trimmed  coat  for  the  Czech  Republic  and  the  same  for 
France. Here again, these imports were not reported by the relevant EU competent authorities. 

The  recognised  body  of  Nunavut  identified  several  issues  with  the  attesting  documents  and 
urged  the  EU  to  consider  whether  it  would  be  acceptable  for  them  to  (1)  issue  one  single 
certificate for multiple pelts; (2) issue a certificate to Nunavut handicraft workers who attest 
to  only  using  seal  pelts  resulting  from  hunts  by  Inuit  in  their  work;  (3)  not  be  obligated  to 
specify the name of the  EU Member State where the product  will be  placed on the market; 
and (4) explore other means of proving the Inuit origin than a physical certificate, for example 
a  stamp  tattooed  on  the  pelts  or  tags  with  the  QR  code  and  a  stamp  embossed  by  the 
Government of Nunavut, which is nearly impossible to imitate. 

In  2021,  the  Government  of  the  Northwest  Territories  developed  a  Seal  Certification 
Programme  to  identify  seal  products  harvested  by  Inuit/Inuvialuit  hunters  and  crafted  by 
Inuit/Inuvialuit/indigenous  peoples  of  the  Northwest  Territories.  Once  the  seal  product  is 
complete, it is affixed with a Seal Certification tag (see below). 

11 

 
 
The recognised body of the Northwest Territories considers that pelts from seals harvested by 
Inuit/Inuvialuit in the Northwest Territories should be automatically certified and that  the EU 
should  provide  financial  or  technical  support  to  operationalise  the  exemption.  Penalties  for 
non-compliance do exist and have not been needed thus far. 

b) Seal hunt under the “Inuit or other indigenous communities” exception 

Article 3(1) of the Regulation, as amended, 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. 

In  this  respect,  the  recognised  bodies  mentioned  that  three  main  principles  of  sealing  guide 
Inuit  and  Inuvialuit:  (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. 

c) Processing of data and protection of personal data 

The three recognised bodies are using an electronic system for the exchange and recording of 
data  contained  in  the  attesting  documents.  None  of  them  reported  issues  related  to  the 
protection of personal data at the time of processing the attesting documents. 

d) Information through a QR code 

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 or other indigenous communities” exception, and facilitating the placing on the EU 
market. This QR code links to a webpage18 providing information on the EU seal regime. 

Great  Greenland  is  placing  a  QR  code  on  all  its  sealskins.  Local  artisans,  craft  makers  or 
small sewing houses are allowed to add their own logo next to the QR code.  Nunavut has a 
QR  code  that  links to  information  on  the  exception  in  the  EU  seal  regime.  The  QR  code  is 
placed  on  all  attested  items  and  available  as  needed  by  artisans  and  craft  makers.  In  the 

18 https://environment.ec.europa.eu/topics/nature-and-biodiversity/trade-seal-products_en 

12 

 
 
 
Northwest  Territories,  a  QR  code  is  placed  on  the  seal  products  made  from  the 
documented/certified pelts. 

e) Overall assessment by the recognised bodies 

The recognised bodies were asked to provide an assessment of three aspects of the Regulation 
and the “Inuit or other indigenous communities” exception on their terriroty:  the functioning 
and  effectiveness  of  the  exception,  the  impact  of  the  Regulation  on  the  socio-economic 
development of their Inuit or other indigenous communities, and the impact on the Regulation 
on their seal populations. 

Greenland 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  these communities. They 
see a need 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 in seal products. 

Nunavut shares the same opinion and would like to replace the attesting document with small 
tags  with  a  QR  code.  Nunavut  considers  that  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 exception. 

For  the  Northwest  Territories,  the  direct  benefits  of  the  Inuit  exception  would  be  vastly 
improved  if  the  EU  agreed  that  all  seals  harvested  by  Inuit/Inuvialuit  in  the  Northwest 
Territories  were  considered  compliant  and,  therefore,  automatically  certified.  The  level  of 
subsistence harvesting has remained fairly consistent, and the domestic and local market for 
seal  products  and  raw  materials  has  remained  healthy  throughout  the  last  reporting  cycle. 
However, the export market has been limited to non-existent. 

In  Greenland,  hunting  and  trading  in  seal  products  is  of  fundamental  socio-economic  and 
cultural importance to Inuit communities. In the period 2019-2022, the number of seals sold 
to the Great Greenland A/S tannery increased by almost 6% in comparison with the previous 
reporting period, but is far from the pre-EU ban levels. 

The total numbers of seals caught in Greenland in the period 2019-2021 has decreased by 6% 
in comparison with the previous reporting period. The graph below shows the seal catches in 
Greenland by species in  the four years of the  reporting period. The numbers  do not  include 
the last three months of 2022. 

13 

 
Greenland seal catches

2019

2020

2021

2022

2
1
9
5
4

9
2
6
0
4

9
5
5
4
3

1
1
7
4
2

8
3
8
8
3

4
3
7
3
3

2
3
5
2
3

9
4
6
0
2

1
1
6
7
1

1
1
3
6
1

2
8
5
6
1

7
6
9
8

7
2
6
1

8
7
3
1

4
4
9

9
0
9

4
8
0
1

4
9
9

6
5
0
1

4
2
9

R I N G E D   S E A L

B E D L A M E R

S A D D L E B A C K

H O O D E D   S E A L

B E A R D E D   S E A L

The value of traded skins from ringed, bedlamer and saddleback seals to the Great Greenland 
Tannery in the reporting period has not reached the pre-EU ban levels either. 

The  Greenland  Ministry  of  Fisheries  and  Hunting  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 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  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/Inuvialuit society. Inuit/Inuvialuit today depend on seals for 
food  security  and  income  in  a  territory  with  the  highest  prices  on  store-bought  food  and 
limited  employment  opportunities.  Inuit/Inuvialuit  largely  market  their  seal  products  locally 
and do not export them to the EU. 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,  the 
Regulation  has  not  had  a  positive  impact  on  the  socio-economic  development  of 
Inuit/Inuvialuit. The EU seal regime has opened a door, but is seen as a policed instrument. 

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/Inuvialuit values. 

14 

 
 
 
 
6) Conclusion 

The  Regulation  seems  to  work  well  in  preventing  the  placing  on  the  EU  market  of  seal 
products  not  covered  by  the  “Inuit  or  other  indigenous  communities”  exception.  Member 
States have established penalties in case of infringement, but they have not yet imposed any. 
Only Belgium reported non-compliant imports, which were stopped at its customs. 

As they already expressed in their previous reports, the EU Member States of the Baltic Sea 
would  welcome  a  reinstatement  of  the  “sustainable  management  of  marine  resources” 
exception, which was removed in 2015 to bring the Regulation in compliance with a ruling of 
the  World  Trade  Organization.  They  consider  that  the  ban  has  negative  socio-economic 
impacts in the EU Member States of the Baltic Sea. 

The recognised bodies in Canada consider that the Regulation is perceived in the EU as a total 
ban on trade in seal products, that the “Inuit or other indigenous communities” exception is 
not  sufficiently  well  known  in  the  EU,  and  that  this  has  an  impact  on  the  economic 
development of their Inuit/Inuvialuit communities. The exports of seal products from Canada 
to the EU are insignificant. Greenland continues exporting seal products to the EU, mainly to 
Denmark. A small number of imports from Greenland and Canada were not reported by the 
relevant EU competent authorities. 

The  Commission  will  launch,  in  2024,  an  evaluation  of  the  Regulation  on  Trade  in  Seal 
Products and of the Seal Pups Directive to assess their functioning, effectiveness and impact 
against  their  objectives,  and  whether  they  remain  fit  for  purpose.  This  will  involve  an 
assessment of their socio-economic impact and of their impact on the seal populations. On the 
basis of the evaluation findings, the Commission will consider whether further measures are 
needed. 

15