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AAP Animal Advocacy and Protection

AAP

Globally recognized for its expertise in caring for primates and other non-domesticated exotic animals, AAP also stimulates public debate and political decision-making, including by giving input to legislative consultations, providing expert advice to policy-makers throughout Europe and educating the broader public.

Lobbying Activity

Response to Fitness Check of the EU legislation on animal welfare

29 Jul 2020

AAP Animal Advocacy and Protection welcomes this opportunity to comment on the Fitness Check Roadmap (Ref. Ares(2020)2653994) concerning EU legislation on animal welfare. As stated in the Roadmap, the Fitness Check will evaluate the EU legislation applicable to the protection of the welfare of farmed animals. It is of course understandable that the Fitness Check reviews the current EU legislation concerning animal welfare on farms, during transport and at the time of killing. However, we urge the Commission to take a comprehensive approach by not only reviewing the existing acquis in the aforementioned areas, but by also assessing the shortcomings, gaps and need for further legislation to protect the welfare of all animals, including wild animals, within the EU. While the EU wildlife trade regulation No 338/97 and the Invasive Alien Species Regulation No 1143/2014 serve to protect biodiversity, there are currently no EU laws to protect the welfare of wild animal species kept in the context of an economic activity within the EU, such as animals within the exotic pet trade and wild animals used in circuses. This legislative gap in our view warrants urgent attention as well and should not be overlooked. We would like to provide the following recommendations with regard to the Transport Regulation, based on our expertise as a rescue center for exotic, non-domesticated mammals: ● The Regulation should ensure that the needs of all wild animals that are transported across the EU, either for the exotic pet trade or for entertainment purposes like performance in circuses (both of which are commercial purposes), are duly taken into account. The current, vaguely worded provision in the Regulation (“due regard shall be paid to the need of certain categories of animals, such as wild animals, to become acclimatised to the mode of transport prior to the proposed journey”) is wholly insufficient in that regard. Wild animals show signs of behavioural and physiological distress during transport[1], which need to be addressed. It also noteworthy that studies have demonstrated a connection between transport and the immediate development of diseases in some wild animal species[2]. Wild animals used in circuses in particular spend most of their lives being transported across the EU on long journeys to serve an economic activity. They should therefore expressly fall within the scope of the Transport Regulation and their specific needs should be taken into account. ● We also strongly urge the Commission to integrate the CITES guidelines on the care and shipment of live wild animals[3] into the Transport Regulation. These guidelines are broadly based upon the IATA Live Animals Regulation[4] and CITES Resolution Conf. 10.21 (Rev. CoP16)[5] recommended that this Regulation is incorporated into Parties' domestic legislation or policies. [1] Montes I., G. McLaren, D. Macdonald and R. Mian, 2004. “The effect of transport stress on neutrophil activation in wild badgers (Meles meles),” Animal Welfare, vol. 13, pp. 355-359. [2] Munson L., J. Koehler, J. Wilkinson and R. Miller, 1998. “Vesicular and ulcerative dermatopathy resembling superficial necrolytic dermatitis in captive black rhinoceroses (Diceros bicornis),” Veterinary Pathology, vol. 35, pp. 31-42. [3] Available at: https://www.cites.org/sites/default/files/eng/resources/transport/transport_guidelines_2013-english.pdf [4] Available at: https://www.iata.org/en/publications/store/live-animals-regulations/ [5] Available at: https://cites.org/eng/res/10/10-21R16.php
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Response to Wildlife trafficking - EU action plan (evaluation)

13 Mar 2020

To Whom it May Concern, Please find the feedback provided by AAP Animal Advocacy and Protection in the attached document. Kind regards, Raquel García Head of Public Policy AAP Animal Advocacy and Protection
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Response to EU 2030 Biodiversity Strategy

17 Jan 2020

AAP Animal Advocacy and Protection is a full member of Eurogroup for Animals and has contributed to this organization's submission, which we strongly support.
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