Fitness check of EU rules

Humane Society International / Europe

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.


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 Don’t know
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 No opinion
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
Don’t know

Question 8. In your opinion, are there factors that may have hindered the effective implementation of the
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)?
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
Don’t know

Question 12. In your opinion, has the legislation had any other impacts (including unexpected or unintended)?
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?
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?
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
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
Don’t know

Question 17. To your knowledge, do other (non-EU) countries regulate trade in seal products?
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
Don’t know

Question 19. In your opinion, are the legislation’s objectives still relevant?
Yes, fully
Yes, partly
Don’t know

Question 20. In your opinion, is there added value for EU level action compared to national or regional action?
Don’t know

Humane Society International / Europe

Help change the law and making this Iceland’s last whaling license

Humane Society International / Europe

Didier BAUWERAERTS/©European Union 2015 EP Paul Henri

The protection of animals is an issue close to the hearts of millions of EU citizens. This is also reflected in the Treaty on the Functioning of the European Union, which explicitly recognises that animals are sentient beings and that the EU and Member States must pay full regard to their welfare requirements in their policymaking.

Humane Society International/Europe is calling on the 720 Members of the European Parliament to become advocates for farmed, wild and laboratory animals to advance their welfare and improve their protection in the EU and beyond during the upcoming Tenth Parliamentary Term (2024-2029).

You can find detailed information about our asks for the next term of the European Parliament in our Manifesto.

Below are a few of our key priorities:

Improving farm animal welfare

The existing body of EU animal welfare legislation must be revised to fully reflect current scientific understandings of animal welfare and its scope expanded to cover all animals kept for economic purposes. It is imperative that this legislative revision includes the phasing-out of all caged confinement for farm animals, such as laying hens and pigs.

Making fur farming history

A full ban on the keeping, breeding and killing of animals for the sole purpose of fur production must be introduced. The cruel and unnecessary practice of fur farming must be relegated to the annals of history everywhere in Europe.

Restricting hunting trophy imports

EU Member States are currently only required to issue import permits for hunting trophies from species listed on Annex A and just twelve species on Annex B of the EU Wildlife Trade Regulations. For as long as the import of hunting trophies remains legal, this import requirement must be extended to ALL species listed in Annex B to ensure that these hunting trophies are of legal and ‘sustainable’ origin.

Closing the loopholes in the EU wildlife trade Regulations

A loophole in EU legislation allows nationally protected wild animal species, trafficked into international trade flows, to be sold legally in Europe as exotic pets. The EU must commit to adopting supplementary legislation that prohibits the importation, transhipment, purchase, and sale of wildlife taken illegally in the country of harvest/origin.

Ensuring animal-free science

The EU chemicals legislation (REACH) must be revised to close loopholes that allow testing of cosmetic ingredients. Both REACH and the regulation for chemicals classification, labelling, and packaging (CLP) must be updated to maximise adoption non-animal methods for safety assessment and it is crucial that no new or expanded animal testing requirements are introduced via revisions or delegated acts. In research, where the largest number of animals are used in experiments, the EU should commit to a scientific and technological shift towards non-animal approaches.

Promoting sustainable food systems

EU policymaking, including any future Sustainable Food Systems Framework Law, should actively promote the transition to a more plant-based diet and a decrease in the production and consumption of animal products, as well as introducing measures to reduce the number of farmed animals in production and their stocking densities, to mitigate the environmental and climate impacts of intensive animal agriculture.

Learn more and help

  • Read our Manifesto for detailed information about our priorities for the next term of the European Parliament.
  • Are you willing to support our key priorities? Please, get in touch with us:

Humane Society International / Europe

Simon Eeman/Alamy Stock photo

BERLIN—In an interview published yesterday evening, former Botswana President Ian Khama called on the German government to ban the import of hunting trophies, countering a recent political push to squash commitments made by Minister Steffi Lemke to protect species already threatened by trade. As the EU’s largest importer of such species as hunting trophies, Germany has the opportunity to enhance national regulation to safeguard against the illogical trade protection exemptions for hunting trophies currently permitted under the Convention on Threatened and Endangered Species of Wild Fauna and Flora.

“Many species that are now endangered were not at risk before; some have already become extinct,” said Ian Khama in the interview. “Animals whose populations are relatively stable today could one day face the same danger. We all bear responsibility for this world. I urge the German people and government to take this courageous step. Ban the import of hunting trophies.”

Sylvie Kremerskothen Gleason, country director for HSI/Europe in Germany, stated: “Attempts to politicize the issue of trophy hunting imports won’t change the facts that there are real biological, ecological and social detrimental impacts from trophy hunting. Germany must take responsibility at the national level to promote alternative sustainable solutions to protect wildlife where Germany has a direct influence, such as through their own international trade in hunting trophies. Commitments to reduce hunting trophy imports, made by Minister Lemke, are in line with public opinion in Germany, and must be progressed.”

Through the #NotInMyWorld campaign, Humane Society International/Europe is advocating for national and EU-wide bans on the import of wildlife species threatened by trade, a policy that several EU member states have already partially or fully implemented, including Belgium, France, Finland and the Netherlands. According to a survey, 89% of German citizens support such a ban, which would represent a significant step toward wildlife conservation. HSI/Europe is working with champions across Europe to support countries in moving from extractive, harmful industries such as trophy hunting, into sustainable, humane industries that could provide a much wider suite of benefits for both animals and humans alike.


Media contact: Eva-Maria Heinen, communications senior manager at HSI/Europe:; 3338608589

Humane Society International / Europe

Mark Von Holden/AP Images for the HSUS

BRUSSELS— Today, the European Parliament approved the revised Environment Crime Directive, strengthening the EU’s approach to addressing environmental crime. This decision, endorsing the compromise agreement reached between the Council of the European Union and the European Commission in November 2023, marks a significant step towards better protecting wildlife and habitats. The updated legislation equips authorities with enhanced tools to tackle serious environmental offenses and deter criminals, including wildlife traffickers. Humane Society International/Europe welcomes the European Parliament’s adoption of the revised Environment Crime Directive as a positive step to ensure better protection of wildlife and the environment.

Environmental crime stands as the third most lucrative organised criminal activities in the world, growing at a rate of  . It contributes significantly to biodiversity loss, increases the risk of zoonotic diseases, and has serious negative socio-economic impacts, particularly in countries where animals and wildlife products are sourced. Despite its considerable profitability, detecting, prosecuting and penalizing environmental crime offenses has proven to be  challenging.

A 2019-2020 evaluation revealed that the effectiveness of the initial EU Directive (2008) addressing environmental protection via criminal law was limited. Few cases resulted in sentences, imposed sanctions were too low to deter criminals, and cross-border cooperation was not consistently occurring. Recognising these shortcomings, the European Commission presented in 2021 a proposal aimed at enhancing the effectiveness of the Directive.

Dr Joanna Swabe, senior director of public affairs for Humane Society International/Europe, said:

“The revised Environmental Crime Directive, although not perfect, does respond to societal demands for environmental crime to be taken more seriously. The legislation will now allow more stringent penalties to be imposed on those who commit the most serious criminal offences against the environment, and will hopefully serve as a deterrent to all those considering partaking in crimes against animals, such as wildlife trafficking. We also warmly welcome the fact that underwater noise pollution has been included in the list of criminal offences. This poses a significant threat to the welfare of marine mammals, especially cetaceans, since it disrupts their ability to communicate and navigate properly. We are glad that this threat to marine wildlife has been recognised.”

Over the past few years, HSI/Europe has worked closely with other animal and environmental protection organisations to ensure that the EU legislation on environmental crime, which was originally passed in 2008, was significantly strengthened. Amongst other things, the revised Environmental Crime Directive now:

  • Introduces common sanction levels for both natural and legal persons.
  • Provides a far more comprehensive list of environmental offences to be criminalised in Member States than in the original legislation, although fails to include one the most lucrative environmental crimes, namely illegal, unreported and unregulated fishing.
  • Includes Annex C species of the EU Wildlife Trade Regulations, thereby broadening the scope of the Directive to cover, for example, threatened endemic species.
  • Offers additional tools for national prosecutors through legal guidance and national strategies.
  • While stopping short of using the term ecocide, it introduces a “qualified offence” for the most serious environmental crimes, which cause widespread and substantial damage to the environment that could be irreversible or long-lasting.
  • Enables the involvement of civil society organisations and ordinary citizens to help combat environmental offenses, effectively asserting their legitimacy in exposing environmental crimes and marking a first step toward protecting them from intimidation or litigation when reporting such crimes or assisting investigations.
  • Strengthens data collection provisions to assist Member States’ reporting practices.
  • Recognises the need for enhanced specialisation, training and resources for competent enforcement and judicial authorities.

Media contact: Yavor Gechev, communications director for HSI/Europe, ; +359889468098 ; +393515266629

Humane Society International / Europe

Ukrainian Red Cross

BRUSSELS―Animal protection charity Humane Society International and humanitarian agency the Ukrainian Red Cross will reach their goal of having helped 100,000 dogs, cats and other pets and 40,000 pet guardians in war-torn Ukraine by the end of 2024 since their collaboration first began two years ago. The organizations have been working together to provide lifesaving aid such as pet food, veterinary care and supplies for pets and support for their owners internally displaced or otherwise affected by conflict in Ukraine.

So far, the partnership has provided emergency relief in 14 regions across Ukraine, reaching over 19,000 pet guardians and 40,000 pets and delivering over 205 tonnes of pet food. In addition, 48 tonnes of cat litter, 3,530 litter boxes, 2,500 pet carriers and 9,000 packages of flea and tick prevention have been distributed to help dogs and cats in need. To reach their goal, the HSI/URC program will expand its outreach to three more regions, Zakarpattia,  Kharkiv and Sumy, to ensure that aid reaches those in need across Ukraine.

Ruud Tombrock, executive director of Humane Society International/Europe, said: “As the conflict in Ukraine persists, both people and animals are enduring unimaginable hardships side by side. Pets are family, and in such dire circumstances they provide comfort and a sense of normality. We are grateful for the recognition by the Ukrainian Red Cross that the welfare of animals during times of war is intricately linked with the well-being of the people who cherish and depend on them. We are committed to keeping people and pets together.”

In the two years since Russia invaded Ukraine, the war has displaced over 11 million people, including 5 million inside the country, many of whom refuse to evacuate without their pets. To help these people and their animals, the joint efforts of HSI and the URC have provided vital supplies in Kyiv, Khmelnytskyi, Donetsk, Rivne, Zaporizhzhia, Chernihiv, Volyn, Poltava, Zhytomyr, Ternopil, Cherkasy, Chernivtsi, Mykolaiv and Kryvyi Rih. In regions such as Donetsk where congregating in centralized locations poses risks, volunteers from the Red Cross facilitate door-to-door deliveries to ensure the safety of recipients. In select districts, such as the Podil district in Kyiv, additional partnerships enable internally displaced Ukrainians to access complimentary veterinary care.

Maksym Dotsenko, director general of the Ukrainian Red Cross, said: “The Ukrainian Red Cross highly appreciates the support of Humane Society International in providing aid for pets during this difficult time. Being able to stay together with pets is so important for the well-being of our citizens, and this program is helping to make that possible.”

Humane Society International has been helping Ukrainian refugees and their pets since March 2022, providing emergency funding and supplies such as pet food, pet carriers, blankets and veterinary care.

Download Photos


Media contact: Wendy Higgins:

Landmark decision will increase protection of elephants, lions, rhinos and other iconic species

Humane Society International / Europe

Britta Jaschinski, co-founder of Photographers Against Wildlife Crime

BRUSSELS—In a momentous triumph for wildlife conservation and animal welfare, Belgium’s Parliament sealed a landmark decision today by voting unanimously in favour of the Minister of Climate, the Environment, Sustainable Development and Green Deal, Zakia Khattabi’s bill prohibiting the import of hunting trophies from endangered species into the country. This historic move, following nearly two years since the Parliament’s initial call for such a ban, will protect revered species such as lions and rhinos.

The vote, endorsed in the Belgian Chamber of Representatives unanimously, echoes the 91% of Belgians standing against trophy hunting and the 88% supporting a ban on the importation of any hunting trophy, according to a 2020 Ipsos survey commissioned by Humane Society International/Europe.

Before the ban, Belgium imported trophies of species vulnerable to extinction such as hippopotamus, cheetahs and polar bears. The new law will stop the import of hunting trophies from many species currently at risk of extinction due to trade or that could be threatened unless trade is limited. All species listed in Annex A of the European Regulation 338/97 on the protection of species of wild fauna and flora, such as jaguars, cheetahs, leopards, some brown bears, Cape mountain zebra and chimpanzees, and African elephants will be protected by the new bill, along with certain species in Annex B of the same regulation, including African lions, Southern white rhinos, hippos and argali sheep, also listed in Annex XIII to Regulation (EC) No 865/2006 regulating the trade of protected wild flora and fauna. The new law surpasses the 2022 Parliament resolution, by extending protection to more species from Annex B than the initial six initially covered by the resolution.

Minister of Climate, the Environment, Sustainable Development and Green Deal, Zakia Khattabi says: “With the approval of my legislative project this Thursday in plenary, the Parliament is providing a legal basis to the resolution it unanimously adopted on 24 March 2022. It was urgent and necessary to protect these threatened and endangered species!”

Member of Parliament Kris Verduyckt (Vooruit, Flemish Socialists), who initiated the legislative proposal to ban hunting trophy imports, said: “Our country is finally banning the import of hunting trophies of endangered animals. The protection of these species is incompatible with trophy hunting imports. I am delighted that my legislative proposal is now enshrined in our legislation and I hope that it will serve as a source of inspiration for many other countries.”

Having championed this cause for years and collaborated closely with Belgian MPs to garner parliamentary support, Humane Society International/Europe applauds the adoption of this crucial legislation, which brings to a successful outcome a complicated legislative process. The animal protection charity has worked with MPs to secure an import ban for over two years, resulting at first in a unanimously supported parliamentary resolution in 2022 that became a legislative proposal approved by the Federal government’s Council of Ministers in July 2023.

“The Belgian Parliament made history today for animals and is illustrating its continued and principled stand against the senseless killing of endangered wildlife,” said Ruud Tombrock, executive director of HSI/Europe. “With this decision, Belgium positions itself as a leader in protecting biodiversity and endangered species. We believe other European countries are also ready to follow suit and take a strong stance against trophy hunting by banning imports of such souvenirs. The time is now for an EU-wide ban on the import of hunting trophies from endangered and protected species, reflecting the views of citizens across Member States in the European Union who share a commitment to being cautious and protective of animals and biodiversity, as well as preventing the fragmentation of the EU Single Market.”

The ban in Belgium sends a positive signal in support of the adoption of a similar ban in neighbouring France, where a cross-party Assembly bill proposal to ban the import of hunting trophies of protected species is currently under parliamentary session. That ban was proposed by Ecologist MP Sandra Regol with the support of Renaissance MP Corinne Vignon, chair of the Assembly’s Study Group on the Condition and Welfare of Animals.

Before its implementation, the adopted Belgian legislation needs to receive royal sanction and promulgation. The text will then be published in the ‘Moniteur Belge,’ coming into force on the day specified within the text, or if unspecified, 10 days after publication.

Download pictures of hunting trophies and campaign materials against trophy hunting here.


  • Trophy hunting of endangered species poses a severe threat to conservation and the world’s natural heritage. Trophy hunters prefer to kill the largest, most physically impressive animals, whose loss can cause cascade declines in populations. Many of the targeted species, such as African elephants, rhinoceros and leopards, are facing the risk of extinction and play crucial roles in maintaining healthy ecosystems and biodiversity.
  • According to an HSI/EU report, the EU is the second largest importer of hunting trophies after the United States, with an average of 3.000 trophies imported in the period between 2014 and 2018. The EU was also the largest importer of cheetah trophies with 297 cheetah trophies imported into the EU between 2014 and 2018. The top five species imported into the EU as trophies: Hartmann’s mountain zebra (3.119), Chacma baboon (1.751), American black bear (1.415), brown bear (1.056) and the African elephant (952),
  • Belgium is the 13th largest hunting trophy importer of internationally protected species in Europe.
  • In May 2016, the Netherlands instituted a ban on the import of hunting trophies for more than 200 species listed under Annex A of European Regulation 338/97 on the protection of species of wild fauna and flora by regulating trade therein and of species in danger of extinction. The import ban also applies to the following Annex B species: white rhinoceros, hippopotamus, mouflon (wild sheep from the Caucasus), lion and polar bear. A total of 200 animal species are affected by the import licenses ban.
  • France implemented a ban on the import of lion-hunting trophies in 2015. In 2023, a Bill proposal for registration, aimed at “stopping the issuance of import permits for hunting trophies of certain endangered species” was tabled.
  • The import of hunting trophies into Finland was restricted in June 2023. The new Nature Conservation Act includes a provision that prohibits the import of individual animals or their parts from the most endangered species worldwide which are threatened by international trade as trophies from countries outside the EU.
  • In Germany, the Minister of the Environment, Steffi Lemke (The Greens), announced that she intends to restrict the import of hunting trophies from protected animal species. Germany terminated the Country’s membership in the International Council for Game and Wildlife Conservation, a pro-trophy hunting lobby, in 2022.
  • In Italy in 2022, a bill aimed at banning the import, export and re-export to and from Italy of hunting trophies obtained from animals that are protected by CITES (the Convention on International Trade in Endangered Species) was presented. After the fall of the government and the elections in 2022, the same bill was tabled again in Parliament.


Media contact: Cassie Bodin-Duval,  international media relations coordinator at Humane Society International/Europe,; +32 469 149 469

Animal-Free Safety Assessment Collaboration urges European Chemicals Agency to step up compliance with mandates to prevent animal testing

Humane Society International / Europe


BRUSSELS—A new paper published this month in Regulatory Toxicology and Pharmacology by Unilever, Procter & Gamble, Innospec and other members of the Animal-Free Safety Assessment Collaboration has exposed numerous concrete examples of acceptance barriers to companies’ good-faith attempts to honour the requirement under European chemicals law that new animal testing may only be undertaken “as a last resort.”

The peer-reviewed article, “The last resort requirement under REACH: from principle to practice,” also provides recommendations to enhance the governance and enforcement of the legal requirement established in the EU Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH) regulation. If implemented, the AFSA suggestions would significantly advance science and animal welfare by helping to inform upcoming plans to revise REACH and develop an EU roadmap for phasing out animal testing in the chemicals and other regulated product sectors.

Members of AFSA have issued the following statements:

“This paper highlights the challenges and type of barriers that REACH registrants often face when using non-animal methods to try to meet various test requirements,” said Anders Bergqvist, PhD, head of toxicology team for Global Product Compliance Europe. “While we will certainly continue to aptly use non-animal methods, we hope that the recommendations presented in this paper will be adopted by the European Commission and the European Chemicals Agency so that animal testing under REACH, before being phased out, can be reduced to the absolute minimum.”

“All scientists must uphold the legal requirement that animal testing is conducted only ‘as a last resort’ when addressing REACH information requirements,” said Dr Carl Westmoreland for Unilever’s Safety and Environmental Assurance Centre. “To ensure that this principle is transparently applied to all proposed testing, it is essential that new science which offers advanced approaches to adapting standard information requirements is robustly applied, discussed and submitted.”

James Dawick, senior toxicology and risk assessment manager, and Ian Callan, vice president global regulatory compliance and ESG, Innospec, together said: “Innospec is very proud to have collaborated with AFSA colleagues on this important publication. As an organisation we are working hard across multiple forums to eliminate the need for animal testing. This publication provided a great opportunity for us to highlight some of the challenges and opportunities on the subject, specifically in regard to EU REACH. Innospec sincerely hopes the case studies and solutions provided in this AFSA paper serves to stimulate dialogue with key stakeholders and catalyse the necessary changes to ensure animal testing is used as a last resort under EU REACH.”

“As P&G is a founding member of AFSA, we are happy to have contributed to hands-on ingredient examples evidencing how well animal-free methods address safety questions without the need for new animal data,” said Dr Xiaoling Zhang, senior scientist and toxicologist, Central Product Safety, Global Product Stewardship for Procter & Gamble. “We hope this paper will build trust and help accelerate the global adoption of non-animal methods for chemical safety assessments.”

“We are proud to support efforts that will help drive greater acceptance of new approach methodologies to validate the safety of ingredients around the world,” said Ben Carrick, head of global public policy at Kenvue.  “Through the implementation of these recommendations, we hope we can reduce the need for unnecessary testing on animals and only leverage these outdated methods as a last resort for chemicals regulation in the EU.”

“Companies should not be penalised for obeying the law and making best efforts to avoid new animal testing except as a ‘last resort’,” said Jay Ingram, director of chemicals for Humane Society International.Chemicals, chemical regulations, guidance and regulatory compliance reviews by the European Chemicals Agency and EU Member States should facilitate, not impede, compliance with this legal mandate. We hope our publication sparks dialogue and action to ensure regulatory enforcement mechanisms are appropriately leveraged in the pursuit of protecting human and environmental health and animal welfare—a true win, win, win for everyone.”


Media Contact: Emily Ehrhorn:; 202-779-1814


  • Despite efforts from regulatory bodies to increase the use and acceptance of non-animal methods such as read-across, a popular non-animal approach, their use has remained static from 2016 to 2022. Given the predicted increase in the number of chemicals proposed in the EU over the next 30 years, it is vital that companies are adequately supported in the safety assessment process.
  • Co-operative efforts to further support the transition towards an animal-free future of chemical legislation require genuine intentions to execute the last resort requirement. The peer-reviewed article sets out recommendations for the European Commission, ECHA, and companies registering new products:
  • The study has revealed the redundancy of ECHA’s requested animal tests, Companies who adhere to REACH’s last resort requirement and sufficiently establish safety using non-animal methods have been asked by ECHA to reconsider their approach, being left with no option but to test on animals.
  • Some EU-based companies initially use animal tests rather than as a last resort, due to ECHA’s lack of provision, whereby those collecting data to register new chemicals and products face several challenges in satisfying the last resort requirement. For example, data from read-across is often rejected after ECHA reviews.
  • Inflexible administrative processes, non-acceptance of non-animal methods, and redundancy of testing can contribute to a fear of rejection from regulators, creating an environment not conducive to mainstream adherence of REACH’s last resort requirement.
  • In 2021, the European Parliament called for acceleration towards the transition to innovation without the use of animals in regulatory testing. A 2022 European Citizens initiative signed by over 1.4 million people echoed this notion, supporting the phasing out of animal testing in the EU. The European Parliament response to this initiative repeats its commitment to ‘reducing and potentially eliminating animal testing in the context of chemicals legislation’.

Humane Society International / Europe


BRUSSELS—Today the European Commission has announced that it will be taking steps to reduce legal protections for wolves in the EU. To achieve this, they will propose the downgrading of the wolf’s protection status under the Bern Convention. At present, wolves are listed under Appendix II, which means they require special protection. However, if Parties to the Bern Convention agree to this proposal, the species will be downlisted to Appendix III. While still protected, the “exploitation” of the species could still be regulated in accordance with the Convention. This would open the door to more wolves being killed in the EU and the potential amendment of the EU Habitats Directive.

Humane Society International/Europe condemns the Commission’s alarming attempts to downgrade legal protections for wolves in the EU. Despite the remarkable resurgence of this species as a conservation success, the leadership of the Commission, instead of upholding its commitment to biodiversity protection, appears to be yielding to pressure from farming and hunting lobbies advocating for increased wolf killings. HSI/Europe is also concerned about the process that led to the current decision.

Dr Joanna Swabe, senior director of public affairs for HSI/Europe, says: “This decision of the European Commission is deeply troubling, as it is driven more by political convenience than scientific evidence and stems from an opaque and irregular consultation process relying on anecdotal submissions.”

HSI/Europe, in collaborating with other animal and environmental protection organisations, has consistently communicated its profound concerns to President Ursula  von der Leyen regarding the alarming trajectory of large carnivore protection.

Dr Swabe emphasizes: “If President von der Leyen believes that she is currying favour with rural voters with such decisions ahead of the EU elections, she should think twice. A recent survey conducted among rural communities in 10 Member States found that a significant majority are keen to see legal protections for wolves upheld and priority given to their conservation. Rather than trying to destroy legal protections for these large carnivores, the Commission should be working harder to promote the uptake of coexistence measures in Member States, since opportunities to implement mitigation measures are being underutilised despite the fact that farmers can receive 100% remuneration for taking non-lethal action to protect their animals.”

  • The Council of Europe’s Convention on the Conservation of European Wildlife and Natural Habitats, known more commonly as the Bern Convention,is a legal instrument in the field of nature conservation, covering most of Europe and extending to some states of Africa.
  • On 4th September 2023, the Commission issued a press release claiming that the concentration of wolf packs in the EU has become a danger for farm animals and potentially for humans. This statement was misleading and not based on science. It also announced the collection of data on “challenges related to the return of wolves” for an 18-day period.
  • HSI/Europe and other NGOs consequently wrote to President von der Leyen raising concerns that this public ‘consultation’ violated the Commission’s own rules with regard to Better Regulation, and challenging its necessity given the data generated by the recent Fitness Check of the Nature Directives, as well as from Member States reporting under the requirements of the Habitats Directive, including in relation to the existing derogations concerning large carnivores.
  • A survey conducted by Savanta in November 2023 among a sample of 10,000 inhabitants of rural areas in 10 Member States (Germany, France, Spain, Netherlands, Italy, Belgium, Poland, Denmark, Sweden and Romania) found that many rural inhabitants are supportive of protecting wolves and other large carnivores, with 68% stating that they should be strictly protected and over two-thirds (72%) agreeing that they have a right to co-exist.
  • The farming and hunting lobby have consistently been pushing for the protection status of wolves to be downgraded. Yet the Savanta survey found that a very low proportion of respondents indicated that they feel well-represented by hunting (12%) and farming (18%) interest groups.
  • Wolves are listed in the Annexes of the EU Habitats Directive as either a strictly protected or protected species, depending on the population in question. Hunting permits to kill them can only be granted under exceptional circumstances.
  • The Habitats Directive authorises Member States to use derogations to allow management control provided there is “no satisfactory alternative and the derogation is not harmful to the maintenance of the populations of the species concerned.” These exceptions are meant to stop “serious damage” to livestock and crops, protect the public’s health and safety or for research and education. However, research indicates that while in theory hunting may be allowed in very narrow circumstances, in reality it would be very difficult to do so in a way that complies with all criteria of the Directive, and questionable whether it could comply with the precondition that no satisfactory alternatives exist.
  • The Commission recently published a detailed Guidance Document to provide clarification to Member States on how this derogation can be applied.
  • The EU’s LIFE programme has already funded numerous projects to help effectively mitigate human-large carnivore conflicts.
  • State Aid provisions compensate farmers with 100% financial remuneration for losses suffered and costs incurred by predator attacks, but also offer 100% reimbursement for the mitigation measures implemented. The primary issue is that farmers are not always aware of their entitlement to such funds, and Member States are slow in compensating them for their losses.


Media contact: Yavor Gechev, communications director for HSI/Europe: ; +359889468098 ; +393515266629

Heavily watered-down animal welfare package also disappoints with weak animal transport proposal

Humane Society International / Europe

Jo-Anne McArthur

BRUSSELS—Animal protection group Humane Society International/Europe has called “inexcusable” the European Commission’s failure today to recommend an EU-wide fur farming ban in response to the 1.5 million signature-strong European Citizens’ Initiative petition. Despite overwhelming evidence that animal suffering is endemic within fur farming, the European Commission failed to urgently end the suffering of 10 million foxes, raccoon dogs, mink and chinchillas killed on EU fur farms each year and instead delayed until 2026 any decision on proposing a ban. HSI/Europe says that the Commission’s failure to deliver a ban condemns millions of sentient animals to lives not worth living on the EU’s remaining fur farms.

The Commission’s Communication states the European Food Safety Authority will provide its scientific opinion on the welfare of animals on fur farms by March 2025, followed by an evaluation which the Commission pledged to present by March 2026 to say whether they will deliver an EU-wide ban on fur farming and on the sale of fur taken from mink, foxes, raccoon dogs, and chinchillas. Given that the mandate of the current Commission is due to end in late 2024, there is no guarantee that their successors will make good on this promise.

Dr Joanna Swabe, senior director of public affairs for Humane Society International/Europe, noted: “The plans announced today show a European Commission that is out of touch with public opinion and expectations for stronger laws to stop animals suffering. Millions of European citizens recognise that keeping huge numbers of wild animals on fur factory farms is grossly inhumane, and leading virologists warn that fur farms present a very real pandemic disease risk. So, it is deeply frustrating and worrying that the Commission is side-stepping its responsibility for decisive action to end the outdated and unnecessary fur trade. Irrespective of fur industry claims about welfare, each and every fur farm investigation in recent times consistently shows chronically stressed animals living under appalling conditions. Stereotypical behaviours, self-mutilation, untreated wounds and even cannibalism are tragically common horrors on European fur farms. The Commission’s failure to deliver a ban today is inexcusable and condemns millions of sentient animals to lives not worth living on the EU’s remaining fur farms.”

The announcement about the Fur Free Europe ECI was made alongside the publication of the Commission’s highly watered-down Animal Welfare Package. The only proposals that the Commission has delivered today are to revise Regulation (EC) No 1/2005 on the protection of animals during transport and related operations, and a new Regulation on the welfare of dogs and cats and their traceability. Alone, these proposals fall short of the commitments made in the Farm to Fork Strategy and the Commission’s promise to the 1.4 million European citizens backing the ‘End the Cage Age’ European Citizen’s Initiative

Ruud Tombrock, executive director of HSI/Europe, commented: “While the proposal on animal transport contains some progressive elements, it ignores EFSA’s scientific recommendations about making sure no animal is transported in frigidtemperatures below 5°C and suffocating heat exceeding30°C. Derogations would still allow vulnerable and young animals, such as calves not yet weaned from their mother’s milk to be transported for long durations byroad. Absurdly, when these unweaned animals are transported by sea, as it often happens with calves exported from Ireland to mainland Europe, the time travelled by sea does not count as journey time. There is also no ban on live exports to non-EU countries, which has been long demanded by animal protection NGOs. The failure to address these issues is evidence that industry interests have prevailed over science and ethics, and that despite this legislative revision, it will be business as usual for operators to the detriment of animal welfare. Member States and Members of the European Parliament during the next political term must commit to strengthening this proposal to give animals the protection that they deserve.”

Facts on fur farming
  • The Commission’s communication on the Fur Free Europe ECI acknowledges that fur farming poses a risk to public health and that it is relevant to the EU’s One Health policy of protecting animals, humans and the environment. To these ends, it commits to conducting three on-site visits to fur farms to assess the disease control mechanisms in place, as well as looking into animal welfare on the selected farms.
  • The risk to native biodiversity posed by fur farms is also addressed in the Communication. While raccoon dogs are already listed on the list of invasive alien species of Union concern, the Commission states that in 2024 it will consider whether to propose to include American mink in this list. Previous attempts to do so had been blocked by several Member States despite the responsible scientific committee’s approval of a risk assessment highlighting the threat American mink pose to native biodiversity.
  • Fur farming has already been completely banned in 15 Member States (with phase-outs still ongoing in some), namely Austria, Belgium, Croatia, Czech Republic, Estonia, France, Ireland, Italy, Latvia, Lithuania, Luxembourg, Malta, the Netherlands, Slovenia and Slovakia. Partial bans have also been introduced in other Member States, namely Denmark, Sweden and Hungary. Legislation in Germany has rendered fur farming economically unviable. A proposal to ban fur farming is currently under consideration in Romania.
Facts on improving lives of animals farmed for food:
  • In 2020, the Commission committed to revising and expanding the scope of the existing EU animal welfare legislation in the framework of the EU Farm to Fork Strategy. Following the 1.4 million signatures strong ECI to End the Cage Age, the Commission later pledged to deliver a legislative proposal to end caged confinement for animals farmed for food by the end of 2023. This proposal has not been forthcoming.
  • The Commission’s proposal to revise the existing animal transport legislation includes the following elements:
    • Proposing the lowering of maximum journey times for most species. For example, horses, cows, sheep, goats and pigs should not be transported to slaughter for more than nine hours.
    • Updating space allowances to be aligned with EFSA’s recommendations on animal transport
    • Protecting young unweaned calves, lambs, kids, piglets and foals by banning on-road transportation over eight hours. However, a very concerning loophole exists where if part of the animal transportation occurs at sea, the time spent at sea is not included in the overall journey duration, thereby undermining the protection of unweaned animals.
    • Requiring real-time traceability of live animal consignments for all road journeys, which will help enforce rules designed to protect animals, such as maximum transportation times.
    • Limiting live animal transport to ships flying white or grey flags. Under the performance ratings of the Paris Memorandum of Understanding on Port State Controls, only those ships will be allowed to operate and receive authorisation certificates to transport live animals. This will exclude ships that have shown an excessive number of deficiencies to be responsible for transporting animals.


Media contact: Cassie Bodin-Duval, international media relations coordinator;

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