Trophy Imports to Europe
November 2013, Volume 11-5&6

The World Conservation Monitoring Centre of the United Nations Environmental Program has prepared a study for the Scientific Review Group (SRG) of the European Commission titled “Assessing potential impacts of trade in trophies imported for hunting purposes to the EU-27 on conservation status of Annex B species”. Recommendations from report:

Trophy hunting is often sustainable, as is evident for many of the case studies highlighted in this report, and it generally serves as a useful conservation tool. Against this backdrop, there is a basis for the current derogation for hunting trophies, as it removes unnecessary administrative burden and reduces the risk of over-regulating/banning trade in cases where, overall, trophy hunting is beneficial for wildlife conservation. There are however cases, such as some populations of Lion Panthera leo or Argali Ovis ammon for example, where serious concerns exist about the sustainability of trophy hunting. In these cases, and particularly where hunting trophies represent a substantial proportion of the trade, an assessment of hunting trophy imports may be warranted as part of a strategy to work with range States towards establishing appropriate management and sustainable use programs. The SRG may need the legislative support to identify these cases and subject them to appropriate EU import restrictions (e.g. SRG negative opinions), recognizing that trade in hunting trophies may in some cases merit different EU decisions than trade for other purposes.

It is therefore recommended that an amendment to the current derogation is made applicable only to species/country combinations where SRG concerns have been raised over the sustainability of trophy hunting. This should however not be restricted to a list of species for which concerns have been raised to date, but allow for species to be assessed as soon as concerns arise, without the requirement of an amendment of the Regulations. The SRG may want to explore whether Article 57.1 of Commission Regulation (EC) No 865/2006 could contain an additional condition to this effect, which specifies that the derogation only applies where no current suspension or negative opinion formed by the SRG are in place.

It is further suggested that the potential unintended negative effects of restrictions imposed on the import of hunting trophies are considered and, where possible, measures put in place to mitigate such effects, such as provision of technical and capacity support to range States. Consideration should also be given to extending the amendment to trophies traded for personal purposes to avoid the potential use of the latter purpose code as a regulatory loophole. The present draft Regulations refer to an import permit being required for the first introduction into the EU only, but it may be administratively clearer to refer to any introduction.

Reporting Member States should report hunting trophies in accordance with the Guidelines for the presentation and submission of CITES annual reports (CITES Notification No. 2011/019). In particular, all the parts that reasonably add up to one animal (e.g. horns, skull, cape, backskin, tail and feet) should be reported as one trophy when shipped together. The same rule applies where at least two trophy parts of an animal are shipped together (e.g. skin and skull). When any one of these parts are shipped alone, however, the trade should be recorded individually on permits (e.g. one skin).
Should stricter measures for hunting trophies be introduced, it would be advisable to monitor trade for personal purposes more closely, to identify any potential shifts in trade resulting from this change. Some hunting trophy items were reported as wild-taken from countries outside the known distribution range of the species concerned or relating to introduced populations. The SRG may therefore wish to seek a common approach to the use of source codes for mammal hunting trophies derived from game farms.

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Author: Rolf Baldus