Trade in seal products

The EU ban on trade in seal products has saved hundreds of thousands of seals since it was adopted in 2009. But now, as part of a periodic review of legislation to ensure it is “fit for purpose,” the European Commission has launched a re-evaluation of the ban, potentially putting it at risk. EU citizens are invited to participate in a public consultation on the matter until 7th August 2024.

Background

The EU adopted Regulation (EC) No. 1007/2009 to address public moral concerns about the welfare of seals killed during commercial seal hunts. The trade ban applies to seal products (i.e. fur, leather, oil and meat) produced in the EU and to imported seal products, aside from those that qualify under an “Inuit and other Indigenous communities” exception and those imported occasionally for personal use.

There was never anything in the legislation to prevent EU Member States from killing seals in the context
of fisheries management, at least if done so in accordance with EU Habitats Directive rules. Nonetheless, a few EU Member States have continued to complain that it is a hindrance to seal hunting for marine resource management purposes. This is one of the main reasons why a public consultation is happening.

Below are our responses to the consultation, for your reference.

Please speak out for seals! You can make your own comments here.

Our responses

Question 1. Are you aware of the EU legislation on trade in seal products?
Not aware
Partly aware
Very aware

Question 2. Your understanding of the EU seal regime is that:

	True	False
There is a complete ban on the placing of seal products on the EU market.		X
EU Member States can continue hunting seals, in line with the Habitats Directive, for the sustainable management of their marine resources, but they can no longer place the products from these hunts on the EU market.	X
Products from seals hunted by Inuit and other indigenous communities who hunt seals for their subsistence can be placed on the EU market only if they are accompanied by an attesting document issued by an official body recognised for that purpose by the European Commission.	X
Occasional imports of seal products into the EU are allowed when these goods are exclusively for the personal use of travellers or their families.	X
There is a ban on the commercial imports into the EU of products from pups from all seal species.		X

Question 3. If seal products (such as meat, oil, omega-3 capsules, fur skins, garments or leather goods) were available on the EU market, would you buy them?

	True	False	Don’t know
Irrespective of their origin		X
If they are from Inuit or other indigenous community origin		X
If they are from hunts to protect fishery activities		X
To support the local communities in the coastal areas of the EU Member States around the Baltic Sea		X
If they are made from seal pups		X

Question 4. To what extent do you agree that:

	Strongly disagree	Disagree	Neutral	Agree	Fully agree
Seal hunting raises animal welfare concerns, regardless of the hunting method used.					X
Seal hunting does not raise significant moral concerns if it is conducted with due regard to animal welfare, e.g. by using hunting methods which guarantee instantaneous death.	X
Seal pup hunting raises more moral concerns than adult seal hunting	X
All seal products should be allowed for sale on the EU market, provided these products originate, for the EU, from hunts conducted in line with the Habitats Directive.	X
Products from seals hunted by Inuit and other indigenous communities should be allowed on the EU market, because seal hunting is an integral part of their culture and identity, and contributes to their subsistence.				X
Products from seals hunted by Inuit and other indigenous communities should be accompanied by an attesting document to allow them to be placed on the EU market.				X
Occasional imports into the EU of seal products for the personal use of travellers or their families should be allowed.			X
A small-scale sale of seal product handicraft by local communities from the coastal areas of the EU Member States around the Baltic Sea should be allowed, to contribute as a source of income and showcase their creativity and traditions, provided hunting is carried out in line with applicable legislation, such as the Habitats Directive.	X
Products from seal hunts to protect fishery activities should be allowed for sale on the EU market, as long as these hunts are in line with the Habitats Directive.	X
The import and placing on the EU market of seal pup skins and derived products from whitecoat pups of harp seals and blue-back pups of hooded seals should be allowed if they come from Inuit and other indigenous communities.			X
The import of seal pup skins and derived products should be forbidden for all seal species, unless they come from Inuit and other indigenous communities.				X
The import and placing on the EU market of seal pup skins and derived products should be forbidden for all seal species, even if they come from Inuit and other indigenous communities.		X
No seal products at all should be allowed for import and placing on the EU market.		X

Question 5. In your opinion, how successful has the legislation been in regulating the import and placing on the EU market of seal products?
Very successful
Partly successful
Not successful
Don’t know

Question 6. In your opinion, how successful has the legislation been in allowing the import and placing on the EU market of seal products from Inuit and other indigenous communities?
Very successful
Partly successful
Not successful
Don’t know

Question 7. In your opinion, has the legislation addressed the public moral concerns related to seal hunt?
Yes, fully
Yes, partly
No
Don’t know

Question 8. In your opinion, are there factors that may have hindered the effective implementation of the
legislation?
Yes
No
Don’t know

Question 9. In your opinion, has the legislation had an impact on the socio-economic interests of the relevant stakeholder groups (e.g. Inuit and other indigenous communities, fishers and seal hunters)?
Yes
No
Don’t know

Question 10. In your opinion, has the legislation had an impact on seal populations within or outside the EU?
Positive impact
Negative impact
No impact
Don’t know

Question 11. In your opinion, has the legislation changed seal hunting practices in terms of their animal welfare
impacts?
Yes
No
Don’t know

Question 12. In your opinion, has the legislation had any other impacts (including unexpected or unintended)?
Yes
No
Don’t know

Question 13. In your opinion, are the direct and indirect costs of the legislation justified, given the results it has
achieved, within and outside the EU?
Justified
Not justified
Don’t know

Question 14. In your opinion, is there any simplification and/or cost reduction potential for the legislation, within
or outside the EU?
Yes
No
Don’t know

Question 15. In your opinion, are the Regulation on Trade in Seal Products and the Seal Pups Directive and their
requirements coherent with one another?
Yes, fully
Yes, partly
No
Don’t know

Question 16. In your opinion, is the legislation coherent with other EU policies and priorities, such as the EU
Habitats Directive or the EU Marine Strategy Framework Directive?
Yes, fully
Yes, partly
No
Don’t know

Question 17. To your knowledge, do other (non-EU) countries regulate trade in seal products?
Yes
No
Don’t know

Question 18. In your opinion, is the legislation coherent with the work of international organisations such as the North Atlantic Marine Mammal Commission (NAMMCO) or the Baltic Marine Environment Protection Commission (HELCOM)?
Yes, fully
Yes, partly
No
Don’t know

Question 19. In your opinion, are the legislation’s objectives still relevant?
Yes, fully
Yes, partly
No
Don’t know

Question 20. In your opinion, is there added value for EU level action compared to national or regional action?
Yes
No
Don’t know

Public Consultation