Trade in seal products – evaluation of EU regulations underway

Seals are marine mammals that have been hunted for years in some parts of the world for commercial purposes, in some for subsistence, and in others for cultural reasons. The trade in seal products can affect animal welfare, and that’s why the European Union developed regulations in 1983: it banned the import of certain seal pup pelts.

Subsequently, by Regulation (EC) No. 1007/2009 of the European Parliament and of the Council of September 16, 2009. on trade in seal products, a ban on trade in seal-derived goods (except in the two situations indicated in this regulation) has been introduced in the EU. The EC now points out that the 1983 effective. The seal pup directive and those in effect since 2009. The regulation on trade in seal products has never been evaluated, which, given the changes that have taken place since it came into effect, should have been done.

Therefore, the initiative now being consulted will assess whether the current regulations remain adequate for their intended purposes, with particular attention to their socioeconomic effects and impact on the seal population. The European Commission invites all interested parties to submit opinions, comments, proposals by August 7, 2024. The results of the consultation will be published 8 weeks after its completion. They will be a valuable source of information and opinions for the EC on existing regulations relating to the trade in seal products.

Increase in seal population in the Baltic Sea

Some countries in the Baltic Sea catchment area point to an increase in the seal population, leading to increased damage to fish stocks and fishing gear. However, according to the WWF organization: Neither seals nor other species, whose existence depends on the abundance of fish that are their primary food, decimate fish in the sea. This would be against their biological interest. Seal foraging is not a significant factor in the ecosystem responsible for low fish abundance. This is evidenced, for example, when the reduction of seal numbers through hunting has not had the desired results of restoring fish stocks.

It is pointed out that the bans under Regulation 1007/2009 have negative socio-economic effects. The removal in 2015 is cited as the reason. exception, which allowed the sale of seal products resulting from hunts conducted solely for the sustainable management of marine resources.

EU regulations governing trade in seal products

EU seal legislation includes, among others:

1. The Seal Pups Directive, which bans the commercial import into the EU of pelts from Greenland seal pups (known as whitecoats) and hooded seals (known as bluebacks) and products derived from them. The validity of this directive was extended indefinitely by Council Directive 89/370/EEC;
2. Regulation 1007/2009 on trade in seal products, which banned the sale of seal products on the EU market, with two exceptions:
3. when the products come from hunts conducted by Inuit or other indigenous communities;
4. when imports are occasional and consist exclusively of goods for the personal use of travelers or their families.

The European Commission’s (EC) report COM(2023)633 on the implementation of the aforementioned regulation in 2019-2022, published in 2023, indicates that it does a good job of preventing the sale of seal products not covered by the first exception. The report also records that in Canada, some circles believe that the regulation in question is perceived in the EU as a total ban on trade in seal products, and that knowledge of the exception for Inuit and other indigenous communities is not sufficiently disseminated.

EC consults on timeliness of seal product trade regulations

The task of the EC-led consultation is to gather the opinions of all stakeholder groups in order to obtain information on perceptions of the current regulations on trade in seal products, to assist the EC in deciding whether Regulation 1007/2009 and the Seal Pups Directive are still fit for purpose and whether there is room for simplification. It is also an opportunity to assess the impact of the regulation and directive on socio-economic issues and on seal populations.

Scope of evaluation of regulations on trade in seal products

As part of the adequacy assessment, the EC wants answers to the questions asked under the following five evaluation criteria:

• Effectiveness
  • What have been the effects of the legislation? Have there been any unexpected or unintended consequences? How does the legislation affect stakeholders, including vulnerable groups?
  • What are the differences in impact between EU countries and what are the reasons for this?How effectively were the goals of the legislation achieved?
• Effectiveness
  • To what extent are administrative and regulatory compliance costs justified given the changes achieved?Have inefficiencies been identified?
  • Is there potential for simplification and cost reduction, including with regard to the administrative process (e.g., for reporting and monitoring)?
• Adequacy
  • Are the regulations and their objectives, given the EU’s new policy priorities and goals, still relevant? Do the goals of the interventions still meet the needs in the EU?
  • To what extent do the needs/problems addressed by the regulations still require action at the EU level?
• Consistency
  • To what extent are the Seal Trade Regulation and the Seal Puppy Directive and their requirements consistent with each other? To what extent are the regulations in question consistent with other EU policies and priorities (e.g., EC policy priorities)?
  • To what extent is the legislation consistent with international commitments, including the UN Sustainable Development Goals?
• EU added value
  • What is the added value of the legislation in question compared to what Member States could reasonably achieve by taking action at the national or regional level?
  • What would be the consequences of reducing, withholding or withdrawing regulations at the EU level?

Based on the results of the assessment, the European Commission will consider whether further action is needed, such as amending existing regulations.