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Federation of Associations for Hunting & Conservation of the EU

FACE

The Federation of Associations for Hunting and Conservation of the EU (FACE) represents 7 million European hunters to promote sustainable hunting and biodiversity conservation.

Lobbying Activity

Meeting with Jérémy Decerle (Member of the European Parliament)

9 Dec 2025 · grands prédateurs

Meeting with Daniel Buda (Member of the European Parliament)

8 Dec 2025 · Large Carnivores

Meeting with Andrea Vettori (Head of Unit Environment) and European farmers and

19 Nov 2025 · Guidance document on the species protection requirements of the Birds Directive

Meeting with Eero Heinäluoma (Member of the European Parliament)

18 Nov 2025 · Firearms policies

Meeting with Cristina De Avila (Head of Unit Environment)

16 May 2025 · Wildlife Trade Regulations

Meeting with Florika Fink-Hooijer (Director-General Environment)

11 Mar 2025 · Exchange on nature protection

Meeting with Valérie Hayer (Member of the European Parliament)

19 Feb 2025 · Wolf status

Meeting with Andrea Vettori (Head of Unit Environment)

28 Jan 2025 · Transposition of the future change of protection of the wolf under the Bern Convention into the EU legislation

Meeting with Jessika Van Leeuwen (Member of the European Parliament)

19 Nov 2024 · Animal Transport

Meeting with Marion Maréchal (Member of the European Parliament)

5 Nov 2024 · Chasse et biodiversité

Meeting with Valérie Deloge (Member of the European Parliament, Shadow rapporteur)

5 Nov 2024 · Transport et bien-être des chiens et des chats

Meeting with Norbert Lins (Member of the European Parliament)

15 Oct 2024 · Animal welfare and animal transport

Meeting with Valérie Hayer (Member of the European Parliament)

24 Sept 2024 · Wolves

FACE demands clearer rules for non-commercial animal transport

12 Apr 2024
Topic — The EU is updating regulations regarding the welfare of animals during transport.
Message — FACE calls for precise wording to distinguish commercial transport from non-commercial activities. They seek clear definitions for animal fitness and transport requirements to ensure legal certainty.12
Why — Clearer rules would exempt hunters from complex standards intended for commercial animal transport.34
Impact — Regulatory authorities may struggle to monitor animal welfare in non-commercial settings due to loopholes.5
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Meeting with Engin Eroglu (Member of the European Parliament)

10 Jan 2024 · Recent developments in the EU regarding large carnivores

Meeting with Patricia Chagnon (Member of the European Parliament) and European Association of European Manufacturers of sporting firearms

5 Dec 2023 · The revision of the EU Firearms regulation

Meeting with Anna-Michelle Asimakopoulou (Member of the European Parliament, Shadow rapporteur)

20 Sept 2023 · Exchange of Views

Response to Mid-term evaluation of the LIFE programme 2021-2027

15 Sept 2023

Separate application forms for LIFE Action and NGO operating grants We are writing to propose the development of separate application forms for LIFE Action grants and NGO operating grants. By simplifying the application process and aligning it with the unique requirements of each grant, applicants will experience reduced burden when writing the grant. It seems that for the 2023 call, there are separate application forms which we appreciate. More personal contact We understand the administrative, coordinative and technical burden of overseeing so many applications and connected procedures on the SyGma portal. While we feel that the response time is very quick via the communication channel of the portal, we anticipate that personalized communication via a phone call would help in addressing any specific or complex questions in a more efficient way. Competitiveness with professional grant writing consultants Small NGOs often have a deep understanding of their work field and community needs. They have firsthand knowledge of the issues they aim to address in a LIFE project, which can be an asset when crafting grant proposals. However, we feel that their success might be decreased when competing against big and wealthy applicants that can effort professional grant writing consultants. Maybe specific training courses can be offered to small scale NGOs.
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Meeting with Alexander Bernhuber (Member of the European Parliament)

28 Mar 2023 · Nature Restauration

Meeting with Olivér Várhelyi (Commissioner) and

19 Sept 2022 · Protection of biodiversity and nature

European hunting federation supports binding EU nature restoration targets

22 Aug 2022
Topic — This consultation proposes legally binding targets to restore biodiversity and degraded ecosystems.
Message — FACE urges the inclusion of hunters and local authorities in planning. They request incentives for private landowners to ensure restoration projects succeed locally.12
Why — Restoring habitats would increase populations of huntable species and recognize hunters' contributions.34
Impact — Sectors responsible for land degradation will face stricter requirements to restore ecosystems.5
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Response to Preventing illegal trade in wildlife

29 Oct 2021

FACE’s comments We acknowledge that good progress has been made on most of the actions set in the Action Plan as EC’s mid-term progress report has concluded. The EU already has a strong policy and legal framework for preventing and raising awareness for wildlife trafficking. Increasing enforcement and effectiveness of existing policies against wildlife trafficking should be a primary goal of the new Action Plan. Funding is also key for the successful implementation of the Action Plan. FACE welcomes that the EC recognises in its roadmap that wildlife trafficking also has serious negative impacts on those who depend on legal and sustainable trade for their livelihoods, in source countries but also further along the supply chain. This is important because legal and sustainable wildlife trade is well-regulated and brings benefits especially to poorer communities around the world. Unfair and unjustified restrictions on wildlife trade impact the benefits that the latter brings for nature conservation and local communities. Further, it is important to acknowledge that restrictions or complete bans on legal wildlife use and trade do not offer solutions to the current wildlife trafficking issues. Unfortunately, some groups advocate for this based on ideological anti-use/trade biases, which are not supported by science and go against successful community-based conservation measures. In this context, it should be noted that revenue generated by hunters plays a significant role in funding wildlife conservation and anti-poaching activities. Expenditure by hunters for licenses, services, or other special fees provides important revenue to wildlife management authorities in developing countries for conservation and anti-poaching programmes. Additionally, there are incidents where cases of wildlife trafficking have been brought to the attention of hunters or hunting providers who have reported or attended to them. We believe it is important that hunting providers' and hunters' efforts against wildlife trafficking as well as the difference between hunting, on the one hand, and illegal killing and trade in wildlife (or poaching), should be clearly defined and communicated in the EC’s work on preventing illegal trade in the revised EU Action Plan. Furthermore, it is important to acknowledge the importance of sustainable wildlife use, including international hunting in combatting wildlife trafficking. The IUCN , amongst others, has provided ample scientific evidence of the value of international hunting to the conservation of threatened species and habitats across the world. International hunting acts as an incentive for local communities to support wildlife conservation, including combatting illegal activities. This could be seen as a ‘preventative measure’, in conserving wildlife and eliminating the need for enforcement. Finally, we believe that the future Action Plan should focus on coordination and awareness-raising to maximise the impact of existing structures.
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Response to Review of rules of export authorisation, and import and transit measures for firearms

1 Jul 2021

We thank the Commission for giving us the opportunity to comment on the inception impact assessment regarding Regulation (EU) No 258/2012. At this stage, we have the following concerns. 1. With regards to the list of items requiring legislative clarification, specifically the identification of “objective criteria making it easier to differentiate between civilian and military firearms”, we believe that such an identification could be problematic as we do not know yet what criteria the Commission has in mind. 2. As to legislative proposal concerning “better controls of ‘semi-finished' unmarked components, by import prohibitions, or authorising imports only to arms dealers”. This implies that firearms parts not defined as essential components under the Firearms Directive can be included in the revision of Regulation (EU) No 258/2012. This could effectively prevent the importation of ordinary spare parts for firearms. Finally, it is important that the upcoming revision leaves untouched art. 9 of Regulation (EU) No 258/2012, which lays down simplified procedures for hunters and sport shooters who temporarily (=no longer than 24 months) bring their firearms and ammunition to a third country. Such a simplified procedure has been a key tool to ease the administrative burdens for hunters and shooters travelling with their weapons outside the EU
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Response to Wildlife trade – alignment of EU rules with recent decisions taken under the CITES convention and changes to EU ivory trade rules

24 Feb 2021

The European Federation for Hunting and Conservation (FACE) welcomes the European Commission’s efforts to combat illegal trade in ivory that in our view undermines legal trade and the effective conservation and management of elephants. FACE also appreciates the EU’s dedication to the conservation of elephants and its support of sustainable use. In this context, we would like to draw your attention to some issues related to the draft proposal for changes to be made to the two main policy instruments relevant for ivory trade in the EU, i.e. Commission Reg. 865/2006 and an existing Guidance document on ivory trade. Hunting Trophies: FACE understands that proposed measures would not affect an individual who hunts an elephant and imports the tusks as part of a hunting trophy, and this must remain unchanged. These are legally imported into the European Union for non-commercial purposes as personal effects. Further restrictions on ivory trade should not hinder an individual hunter’s ability to bring an elephant trophy home or to move it. We also would like further clarifications on the status of ivory for which the certificates become invalid after 12 months (draft amendments on the Commission Reg. No 865/200 – Art. 11.5). While these products can no longer be commercialized, the owners should remain able to prove the legality of their product if the ivory they possess becomes solely a personal effect. Potential negative effects on indigenous people and local communities in Africa: FACE would like to underline the fact that some Range States that have populations in appendix II (Botswana, Namibia, South Africa and Zimbabwe) will likely be affected. In particular, Namibia and Zimbabwe could be affected by stricter measures in ivory trade as worked ivory is imported into EU market. The European Commission should consider the economic, social and environmental consequences for Range States of elephants and local communities in these range states. At this point, it should be highlighted that wildlife trade offers substantial resources to support the effective conservation of elephants through bringing economic benefits to local communities in Africa. EC’s guidance document: We would like to highlight that the following text in the EC’s guidance document (page 2) should be amended because it is not a one size fits all approach with respect to different regions in Africa with reference to: “Elephant poaching reached unprecedented levels in the recent past, which has led to a widespread decline in African Elephant populations”. Since 2011, the total number of carcasses of elephants illegally killed has decreased in Africa (Monitoring the Illegal Killing of Elephants (MIKE) Report: PIKE trend analysis – Methodology and Results). Additionally, it should be taken in account that declines in African elephant populations are also caused by other reasons like habitat loss, fragmentation and human-elephant conflict.
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Meeting with Virginijus Sinkevičius (Commissioner) and

9 Sept 2020 · To discuss hunting under the Birds Directive

Meeting with Karmenu Vella (Commissioner) and

23 May 2019 · Birds & Habitats Policies

Meeting with Violeta Bulc (Commissioner) and

17 Dec 2018 · Meeting with the Representatives of FACE

Response to Technical specifications for the marking of firearms and their essential components

26 Nov 2018

FACE (www.face.eu) is the European Federation for Hunting and Conservation. Established in 1977, FACE represents the interests of Europe’s 7 million hunters. FACE is made up of its Members: national hunters’ associations from 36 European countries including the EU-28. FACE also has 8 Associate Members. FACE upholds the principle of sustainable use and has been a member of the International Union for Conservation of Nature (IUCN) since 1987. Art. 1 of the Draft (“any firearm and all essential components of a firearm, be they part of an assembled firearm or not”) is different from Art. 4 (1) of the Directive (“any such firearm, or any essential component”). FACE strongly believes that only one or two essential components (barrel and/or receiver) should be marked according the wording of the Directive (…either…or…). The Directive is already providing a binding legal interpretation for the Draft. The Draft is also in contrast with the provisions of the Directive concerning the monitoring system (Art. 5 (2) Directive). When Member States are required to keep their monitoring systems updated and shared, we have to consider that competent authorities register only the serial number on the frame of the firearm for the European Firearms Pass. The markings of all other essential components are not registered. Therefore, this would not contribute to the improvement of traceability and monitoring of the movement of firearms. It is noted that additional national marking requirements do not improve traceability, as all necessary specifications are already ensured by the EU provisions, and that they would disturb competition, since they would introduce further obligations (and costs) for companies that do not apply to competing companies in other Member States. Furthermore, additional marking requirements only introduced in a given Member State could threaten the free movement for hunters with their own firearms. Hunters States could be forced to adopt required national markings, even for a sole temporary introduction like hunting travels in other Member States. It is also important to note that, unfortunately, no reference is made by the Draft to the technical specifications under the Convention for the reciprocal recognition of proof marks on small arms of 1 July 1969 (CIP Convention). In particular, it should be specified that the data provided by the CIP marking replaces those provided by the Directive, as affixed by the manufacturer or the importer. Not including such a clarification or reference could cause unnecessary difficulties for the movement of hunters. For instance, if a hunter wants to travel with a firearm as marked in an EU country, but having a CIP accredited bank, he/she could be obliged to re-mark the barrel. All these conflicting rules result in hindering the free movement of firearms which have alternative components. Furthermore, hunters may have to remark essential parts of the firearms coming from a third country. For instance, a hunter – even though not being a professional importer - could be obliged to remark an essential part of a firearm purchased in the United Kingdom (a third country from March 2019 and part of the C.I.P. Convention). This could happen because no clear hierarchy is established in the Draft between the C.I.P. Convention’s rules on marking and the ones set by the Directive. To sum up, it is very important for hunters in Europe that the marking rules are unique and fully harmonized in all Member States and that these rules are consistent with existing international standards. We fear that if marking rules will be applied differently across Europe this will lead to more expensive firearms and a reduced offer of firearms as their manufacturing processes are taking place in more than just one Member State. The free movement of hunters with their own firearms would be also restricted due to inconsistent marking rules.
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Meeting with Günther Oettinger (Commissioner)

21 Sept 2018 · environment policy + MFF

Meeting with Jerzy Bogdan Plewa (Director-General Agriculture and Rural Development)

29 Jun 2018 · exchange of view - Wolfspopulation in Deutschland

Meeting with Jyrki Katainen (Vice-President) and Suomen Metsästäjäliitto - Finlands Jägarförbund

31 May 2018 · Nature Legislation and Common Agricultural Policy

Meeting with Andrew Bianco (Cabinet of Vice-President Karmenu Vella)

21 Feb 2018 · Nature

Meeting with Phil Hogan (Commissioner)

8 Feb 2018 · Conservation matters

Meeting with Karmenu Vella (Commissioner)

27 Nov 2017 · Hunting of vulnerable species

Meeting with Phil Hogan (Commissioner)

7 Sept 2017 · Address conference

Meeting with Shane Sutherland (Cabinet of Commissioner Phil Hogan)

7 Sept 2017 · Annual Reception

Meeting with Christiane Canenbley (Cabinet of Commissioner Phil Hogan)

18 May 2017 · Position of FACE on the future CAP

Meeting with Karmenu Vella (Commissioner) and

1 Sept 2016 · Spring hunting of Turtle Doves

Meeting with Fabrice Comptour (Cabinet of Commissioner Elżbieta Bieńkowska), Tomasz Husak (Cabinet of Commissioner Elżbieta Bieńkowska)

1 Mar 2016 · Draft legislation of weapons

Meeting with Polykarpos Adamidis (Cabinet of Commissioner Dimitris Avramopoulos)

23 Jun 2015 · EU regulatory developments in the domain of civilian firearms

Meeting with Karmenu Vella (Commissioner) and Stichting BirdLife Europe

17 Mar 2015 · REFIT of Nature Legislation

Meeting with Vytenis Andriukaitis (Commissioner) and

30 Jan 2015 · The Food Chain, Innovation and Challenges, Food Information to Consumers, Nutrition, and Food Waste, Animal Health, Animal Welfare and Plant Health