Fur Europe
Fur Europe
Fur Europe is an umbrella organisation covering the entire value chain of the European fur sector with activities in 28 European countries.
ID: 819965911378-79
Lobbying Activity
Response to Sustainable Products Initiative
16 Nov 2020
Fur Europe welcomes the inception impact assessment on the Sustainable Product Initiative (SPI). The European fur industry sees the SPI as a major opportunity to foster the shift of European businesses towards full circularity by removing present obstacles and fostering best practices and features of the industry.
Policy coherence
Fur Europe welcome the Commission’s decision to assess “which combinations of measures will best achieve the objectives”: businesses need legal certainty and policy coherence is paramount to avoid duplicate or contradictory rules and tools on products and value chain sustainability. Moreover, as the European Commission is working in parallel on a separate proposal on due diligence covering social and environmental aspects of value chains, the Commission should avoid creating parallel policy instruments addressing the same objectives but multiplying requirements and obligations. The actual added value of “overarching product sustainability principles” should be thoroughly evaluated as well: in fact, each product category requires specific solutions depending on product characteristics such as materials, production process, use, etc.
Ecodesign framework
Concerning the extension of the Ecodesign framework to textiles, Fur Europe stresses that as ecodesign requirements are designed around products and their function, the right level of granularity should be identified in order to develop actionable ecodesign requirements addressing specific product categories. This process should involve a close dialogue with value chains actors. Moreover, Fur Europe suggests that the ecodesign framework be expanded to “textile and clothing” – intended as including partner value chains in the clothing ecosystem, such as fur. Finally, ecodesign criteria should be defined in a clear and scientifically sound way and cover relevant sustainability aspects of several phases of the life cycle (raw material selection and use, manufacturing, packaging, transport, distribution, use, end of life) as well as aspects such as durability, reparability, reusability and biodegradability of products, in order to maximise the lifespan of products on the one hand, and minimise the generation of harmful waste on the other.
Product passport and consumer information
The product passport can be a B2B one-stop-shop where companies or third-party auditors can add, collect and consult products’ information, including existing sustainability certifications obtained by companies. With regard to consumer information, consumers should be able to rely on clear information that is material to their main concerns, striking the right balance between avoiding overly technical details and misleading oversimplifications or information devoid of context. Therefore, the introduction of any new requirements on mandatory sustainability labelling – e.g. under the Green Claims initiative – should be subject to a comprehensive impact assessment taking into account different options as well as implementation costs for business against expected benefits. Finally, Fur Europe stresses that for a product passport and labelling system to deliver effectively, a strong traceability environment facilitating the seamless flow of information along value chains should be promoted and supported by public institutions.
Proportionality and market surveillance.
New ecodesign requirements will bear compliance costs as well as costs related to innovation along value chains. Since this could prove particularly challenging for SMEs, who may often have less expertise and resources, new requirements have to be designed keeping in mind their specific needs. Moreover – if not paired with effective, risk-based market surveillance enforcement ensuring a true level playing field – virtuous businesses will suffer from free-riders in the Internal Market and won’t be able to reap the benefit of their investments in sustainable practices.
Read full responseResponse to Environmental claims based on environmental footprint methods
27 Aug 2020
Fur Europe welcomes the legislative proposal on substantiating green claims and supports in principle the use of product environmental footprint. But some issues need to be considered to make the PEF scheme truly functional and inclusive, which is a prerequisite to ensure the success of the legislation.
Many terms may be used to describe products as having reduced environmental impacts. For the sake of legal certainty, it will be necessary to define the assertions in the green claims category. Beyond the definition of what green claims entail, we encourage the European Commission to specify who can make them, and whether the scope of the legislation extends to accusatory claims.
The development of the PEF method was a dynamic process, and this approach should be sustained. Comparability and effectiveness will be improved by ensuring that the PEF requirements keep up with the latest scientific research, by providing more extensive allocation rules, and by capturing environmental impacts that are not currently included (e.g. plastic leakage).
Moreover, the EF initiative’s ability to offer a level playing field between sectors and companies of all sizes may be questionable: while small companies may benefit from the harmonization, the high costs of conducting a PEF study should be given due consideration, especially as costs are increased when the PEF study is not done on the basis of a PEFCR. A situation where a company (especially SMEs) cannot use category rules as they are non-existent for its product group, does not have the resources to conduct a stand-alone PEF study, and is therefore unable to make a green claim on its products should be avoided at all costs.
As the impact assessment considers “the need to introduce a way to prioritise the development of product and sector-specific approaches”, it ought to recognize that the need for inclusivity is paramount. Special attention should be given to smaller companies and niche market segments/technologies in defining the priority sectors.
The inclusiveness of the initiative may be increased by the following measures (see attached technical paper):
- A flexibilisation of the application procedure for new PEFCRs development, i.e. a continuously open call for applicants.
- Widespread non-financial support for unofficial yet methodologically sound PEFCRs.
- A better strategy on secondary data, to improve availability of datasets and reduce dependence on third-party datasets owners.
- More modularity in the approach taken by the Commission: focus on upstream processes to generate data for the downstream processes.
- An easy-to-use SME tool.
The “green claims” legislation should guarantee a level playing field between EU and non-EU companies, and between companies whose supply chain processes take place within and outside of Europe.
Futhermore, as the ultimate results of a PEF study are communicated to consumers, information should be conveyed in a meaningful way, while avoiding over-simplifications.
The communication vehicle should be reasonably flexible: although a common logo could be adopted as easily recognizable proof of credible information, the ultimate choice of presentation (label, QR code, etc) must be free. We also believe that due to the complexity and depth of the supply chains, rather than primarily being a “B2C” tool to inform consumers, the EF initiative has a much bigger potential to drive a real and not only declared environmental improvement as an internal “B2B” tool.
Finally, there should be a determination to rationalise the EU framework and avoid overlapping or competing instruments – e.g. Ecolabel, Product Environmental Footprint (PEF), Ecodesign.
As Fur Europe is involved in the EF initiative as a member of the TAB, the EF subgroup, the A&F PEFCRs Technical Secretariat and is developing its own “shadow” category rules simultaneously, we would like to point out the practical issues we encountered. Please find our technical comments attached.
Read full responseResponse to Empowering the consumer for the green transition
5 Aug 2020
Fur Europe welcomes initiatives aiming at steering more sustainable consumption patterns and giving consumers an active role in the green transition.
Fur Europe agrees to the need for a common set of consumer information requirements. It should cover information on products’ environmental characteristics, lifespan, biodegradability, and repairability as to inform consumers both on lifespan and after-life product information. We would like to point out that any future framework in this regard should be science-based and take into account specific aspects of products such as their function, quality and average use.
Policy-makers should also consider providing harmonised definitions to key concepts which are closely linked and as a consequence tend to be used interchangeably, such as “product durability” and “product lifetime”, or “reparability”, “reusability”, and “recyclability”.
Although free riders take advantage of greenwashing, the proliferation of many effective and transparent sustainability labels over the last years is also the sign of a complex and vibrant industrial landscape whereby many actors invested in the development of credible and robust assessment systems. The new framework should take this aspect into consideration by not penalising the past investment of responsible business operators. In this perspective, a clear definition of ‘greenwashing’ should be developed, as well as criteria to ensure the transparency and reliability of labels/logos – in any case linked to a solid scientific basis – in order to protect labels and certification programs which do not focus specifically on environmental performance but still provide valuable information about sustainable business practices.
The link between the consumer law initiative and other CEAP initiatives is also paramount. A coherent environmental framework is needed for the sake of legal certainty for both producers and consumers. Policy-makers should take this under advisement as they consider different options. Interactions of different instruments should be taken into account, in particular PEF, Ecodesign and Ecolabel: risks and conflicts should be carefully evaluated, as well as future options for coexistence or integration of these frameworks. In this perspective, the interaction between this and the ‘green claims’ initiative should be analysed in order to ensure legislative coherence. The substantiation of environmental claims using product and organisation environmental footprint (PEF/OEF) methods could be instrumental in forestalling “greenwashing”. However, it should be noted that in order to be functional and beneficial, the PEF/OEF methods should create a level playing field between all interested industries (in particular relating to non-financial support and secondary datasets); furthermore, effective communication tools for PEF/OEF information should be devised.
The economic impacts assessment should also bear in mind that one of the key purchasing driver is the price of products. Additional compliance costs for operators could result in a significant economic burden for smaller companies that would on the one hand create a competitive disadvantage, and on the other be cascaded down on the shelf price of products. Therefore, as eco-friendly products are often more expensive than their traditional counterparts, the European Commission should take into account the reasons behind this increased price (cost of environmental certification, higher production cost of sustainable materials, etc.) and subsequently tackle this issue through financial and non-financial incentives.
Read full responseResponse to Fitness Check of the EU legislation on animal welfare
9 Jul 2020
Fur Europe welcomes the fitness check on the EU animal welfare legislation and the Commission’s decision to put animal welfare among the objectives of the Farm to Fork strategy. We take the opportunity of this roadmap to provide our inputs on how the future EU legislation should be shaped. Please find our comments in the attached document.
Read full responseResponse to Farm to Fork Strategy
12 Mar 2020
Fur Europe, the association representing the European fur value chain, welcomes the European Green Deal and the Farm to Fork strategy. Although not directly involved in food production, Fur Europe represents thousands of farmers in Europe and developed state-of-the-art animal welfare tools over the years.
The F2F strategy opens the opportunity to implement a science-based approach to develop coherent and future-proof animal welfare and environmental sustainability policies in the agri-business.
Animal welfare-related aspects
Fur Europe takes into serious consideration consumers’ concerns and the growing attention to animal welfare in production systems. That is why we developed the animal welfare assessment and consumer information tool WelFur. In the context of the F2F strategy, the current review of the Animal Welfare Strategy 2012-15 should be the starting point of a reflection on the future of animal welfare policies at EU level. Fur Europe highlights the following consideration:
- Decision-making related to animal welfare should be based on peer-reviewed scientific evidence and facts;
- A new EU Animal Welfare Strategy should be adopted, including an Animal Welfare Framework Law covering all farmed animals (food and non-food producing animals) at all life stages, to update and replace current legislation;
- Fostering the work on animal welfare indicators should be a priority in this policy area, with a paritcular focus on animal-based indicators: such work should be also carried out through the work of the EU Reference Centre on the welfare of poultry and other small animals;
- Investments already made by the industry should be taken into consideration by the European Commission, who should also acknowledge the industry-led best practices already developed – such as WelFur – as a valuable source of data and information and inspiration in future policy-making;
- Representation of the fur industry in the Platform on Animal Welfare should be ensured or, in alternative, ad-hoc invitations and regular reporting and consultation about the platform activities with non-members should be guaranteed to interested stakeholders.
Environmental sustainability
The Farm to Fork strategy should also be developed bearing in mind the following aspects:
- Adopt fair and comparable calculation methods for the environmental footprint; such methods should take possible credits from industrial symbiosis and the use of by-products into due consideration – e.g. in the production of feed for fur animals;
- Adopt a nutrient management optimisation strategy that supports research and innovation and combines the need to reduce environmental pollution – e.g. eutrophication – and recover scarce raw materials - such as phosphorus from mink manure;
- Avoid the depopulation of rural areas and the relocation of production outside of the EU with lower environmental, animal welfare, and social standards.
The European fur value chain looks forward to cooperate with the European Commission and to discuss further in detail in order to develop a modern, truly sustainable Farm to Fork Strategy.
Read full responseResponse to A new Circular Economy Action Plan
17 Jan 2020
Fur Europe welcomes the initiative of the European Commission to adopt a new Circular Economy Action Plan. With regard to the statements and proposals made in the roadmap, Fur Europe suggests the following comments.
Fur Europe welcomes the decision to focus on “high-impact sectors such as textiles” and invites the Commission to consider expanding such actions to the wider clothing sector. The term “textile” as intended in the EU legislation (art. 3(1)(a) of Regulation (EU) No. 1007/2001) excludes several streams of materials used in the manufacturing of clothing. Narrowing the action plan’s scope solely to textile products would significantly reduce the action plan’s impact on the market.
Fur Europe fully shares the concern about the “unsustainable and sub-optimal use of resources” listed amongst the problems that the action plan will tackle. With this regards, Fur Europe’s suggestions follow in the next four paragraphs.
The roadmap envisages a “sustainable products policy”, which should include a clear objective to increase the longevity of products and “identify options to prioritise reuse and repair before recycling.” Longer-lasting materials, such as fur, increase the longevity of final products and reduce post-consumer-generated waste. Fur Europe encourages and will support initiatives aimed to make an efficient use of materials during design, and favour a longer active lifespan of products by promoting services like repairing and remodelling. In this perspective, Fur Europe suggests to set clear definitions that could facilitate the achievement of this objective, such as “repair” and “remanufacturing.”
As part of the “sustainable products, policy”, existing initiatives should be duly taken into account. For instance, the Environmental Footprint initiative, in particular, has the potential to effectively address the objective to boost “design, production and marketing” of sustainable products by proposing a voluntary harmonised methodology which will help companies to mitigate their environmental impacts.
Fur Europe agrees that consumers have to play a key role in the transition towards a circular economy. Raising consumer’s awareness about the sustainability features of products and their repairability and reuse options is a fundamental step in this direction. Moreover, how the EF initiative could become a good basis for informing consumers on the environmental performance of products should be also evaluated.
Again in view of the sustainable products policy, and in order to “reduce waste generation”, an “integrated market for secondary raw-materials” is envisaged in the roadmap to facilitate the use of recycled materials. Trade in secondary raw-materials should not be restricted to actors within the same sector, but should be in the form of an industrial symbiosis of sectors, ones which may produce very different products: for examples, food by-products being acquired and used to produce feed, or farm by-products to produce biofuels.
The action plan shall also consider that especially SMEs will need support in the transition to a circular economic model. Financial instruments shall be envisaged to help them in the process, while the burden of the transition shall not be pushed on them. With regard to SMEs, Fur Europe also encourages to keep the DG GROW Report – Mapping Sustainable Fashion Opportunities for SMEs in consideration as part of the evidence base and data collection of the action plan.
Finally, a level playing field shall also be ensured in the European market, especially through better market surveillance designed on risk-based approach.
Read full responseResponse to EU 2030 Biodiversity Strategy
17 Jan 2020
Fur Europe welcomes the European Commission decision to adopt a new Biodiversity Strategy to 2030 and in particular the suggestion to include quantified objectives and measures in it.
The roadmap mentions, among others, invasive alien species as a driver of biodiversity loss. With this regard, Fur Europe encourages the European Commission to:
- continue the work done on this subject by preserving Target 5 of the Biodiversity Strategy to 2020 and update it to 2030;
- focus on the strengthening the implementation by the Member States and other stakeholders involved.
Preserving Target 5 and updating it to 2030
Target 5 is a direct reference to the Aichi Target 9 of the Convention on Biological Diversity. It is spelled out in a result-oriented fashion as it is specific in defining clear actions (identification and prioritisation, control, eradication, management, prevention) to achieve the target. Moreover, Fur Europe believes that Target 5 is also fit for purpose when it comes to pursuing SDG 15 “Life on Land” and in particular Indicator 15.8.1 “Proportion of countries adopting relevant national legislation and adequately resourcing the prevention or control of invasive alien species.”
Therefore, Fur Europe encourages the European Commission to preserve it as it is and update it to 2030.
Strengthening the implementation of Target 5
The new strategy should be rather focused on better implementation of Target 5. The mid-term evaluation of the Biodiversity Strategy to 2020 considered in a positive fashion that Target 5 was “currently on track with implementation [and that] the next critical step for achieving the target will be implementation by the Member States.” Similarly, the Council conclusions of 16 December 2015 “urges the Member States and the Commission to follow up on the list of invasive alien species of Union concern with concrete measures and comprehensive and coherent implementation actions.” The implementation of the Regulation (EU) 1143/2014 on the EU list of invasive alien species by the member states is particularly relevant in this sense. In this field, the new strategy shall envisage continuous and coordinated action between the European Commission, the member states and civil society stakeholders.
Moreover, the strategy shall insist on making good use of all means provided by the legislation on a case by case basis, such as the enhanced regional cooperation mechanism, and bear in mind environmental, social and economic considerations as required by the regulation.
Finally, the new strategy shall provide for additional funding resources – e.g. through LIFE+ – to finance actions aimed to
tackling invasive alien species such as engaging stakeholders, improve knowledge, identify and quantify threats,
manage pathways of introduction.
Read full responseMeeting with Risto Artjoki (Cabinet of Vice-President Jyrki Katainen)
25 Jun 2019 · Animal welfare
Response to Evaluation of the EU Animal Welfare Strategy (2012-2015)
13 Jun 2019
Fur Europe represents the European value chain of the fur sector from farm to retail. Fur Europe welcomes the opportunity to participate in the consultation on the evaluation of the EU Strategy for the protection and welfare of animals 2012-15.
We would like to comment in particular on the actions and evaluation criteria envisaged in the roadmap.
Concerning the actions, as the only actor representing fur farming in Europe, Fur Europe looks forward to being contacted and participate in targeted consultations, surveys, interviews and focus groups.
Moreover, in the roadmap, it appears that the stakeholder conference/workshop/seminar will be further considered and is not confirmed yet. Fur Europe strongly advises the European Commission to hold such an event as it represents an occasion to receive further first-hand inputs and have a multilateral debate.
The roadmap also lists among the actions ‘regular reporting and consultation via the EU Platform on Animal Welfare.’ The European Commission shall make sure that such reporting and consultation are not limited to the members of the platform because this would leave several actors – representing sectors encompassing thousands of jobs and billions of business value – with no chance to participate in the evaluation of the strategy to an equal level as the members of the platform.
Finally, Fur Europe also shares the evaluation criteria listed in the roadmap: relevance, coherence, effectiveness, efficiency and EU added value. While Fur Europe deems all of these criteria equally important, Coherence and EU added value have a specific significance: the former reflects the fact that all animal husbandry is treated equally by the EU law and EU-sponsored initiatives; the latter because it will allow appreciating how the EU action harmonised and streamlined concepts and tools related to animal welfare across the EU.
Read full responseMeeting with Marco Valletta (Cabinet of Commissioner Vytenis Andriukaitis)
6 Feb 2019 · Welfare of fur animals
Meeting with Marco Valletta (Cabinet of Commissioner Vytenis Andriukaitis)
2 Oct 2018 · DG SANTE mission to China
Response to Evaluation of the EU agricultural promotion policy
15 Aug 2018
Fur Europe considers agricultural promotion policy an important tool in supporting EU agriculture. Therefore, it regrets that the eligibility criteria in Article 5 of Reg. 1144/2014 do not cover fur.
While the fur sector in the EU maintains its profitability without any direct public support, EU remains a global leader (over 50%) in fur production. Majority of this fur is exported outside of EU, wanted for its superior quality and production standards and methods.
At times, however, the market faces specific challenges, putting in risk tens of thousands EU citizens whose subsistence depends on it. In such cases, EU agricultural promotion policy should be able to help the sector to restore normal market conditions.
Annex I of TFEU includes fur animals but does not include fur as the product. Reg. 1144/2014 correctly anticipates such exclusions and in its Art. 5 allows, especially via Annex I of this regulation, for some sectors or products excluded by TFEU to be part of the EU agricultural promotion policy. These are, among others, cotton (raw material for textile and clothing) or alcoholic beverages.
Therefore, Fur Europe considers it necessary to expand the Annex I of Reg. 1144/2014 to include fur and calls for European Commission to initiate such procedure.
Read full responseResponse to Multiannual Financial Framework - CAP Strategic Plans
2 Aug 2018
Fur Europe’s vision of post-2020 agriculture is that of the European Union with a globally competitive agriculture that sustains itself with as little taxpayers’ money as possible and thus the public support can be focused on generating added value. This is in line with the reality of the fur sector in Europe, which assures its profitability with no direct public support, while remaining a leader in global competition in terms of quality and standards.
Below is a summary of Fur Europe's feedback on this initiative and post-2020 CAP as such; more detailed position is provided as an attachment.
• As non-food agricultural production sectors also play a role in attaining the objectives of the EAGF and EAFRD support, it needs to be covered by the Common Agricultural Policy in a way that leaves no room for interpretation allowing its exclusion (e.g. proposed Art. 4(1a) or Art. 6(1i)).
• Pillar II is more efficient in generating added value to European agriculture and rural areas, therefore it should not be the main target of the crucial cut in CAP spending.
• Special efforts should be made to avoid delays in rural development implementation, learning from the current period delays and especially considering burden on Member States created by the new delivery model.
• Fur Europe is concerned about the topic of animal welfare losing prominence compared to the current period where it had its dedicated measure. The wording of rural development interventions should be reconsidered (proposed Art. 65) so that animal welfare gets a better visibility; otherwise there is a threat of this topic being overlooked by the Member States when drafting CAP Strategic Plans.
• Focus on networking and information sharing with various stakeholders should continue (as defined in proposed Art. 65) but it should be assured that underperformance of certain National Rural Networks is targeted and avoided post-2020.
Read full responseResponse to Commission Delegated Regulation on the methodology for risk assessments of invasive alien species
19 Dec 2017
Fur Europe wishes to provide a feedback concerning the consultation in subject, focusing in particular on: the evaluation of the socio-economic value of species in risk assessments (RA); the assessment of the cost-effectiveness of including a species in the EU list; the composition of the scientific forum.
Evaluating the socio-economic value of species under discussion
Article 4(6) of Reg (EU) 1143/2014 states that special attention should be given to species that provide significant social and economic benefits to Member States. However, the current draft risk assessment does not reflect this required element. Whenever the socio-economic benefits of a species are not already available, and also following the discussion of the management committee on December 5, the Scientific Forum should seek information related to these aspects to an extent which reflects the reality of the known uses of a species in a comprehensive and satisfactory manner. As long as socio-economic aspects are not properly assessed by special experts, a RA should not be agreed upon by the Scientific Forum.
Evaluation of the cost-effectiveness of including a species in the EU list
Fur Europe has for long advocated for a proper analysis of the cost-effectiveness of including a species on the EU list, but nonetheless we hardly see a comprehensive and satisfactory analysis in the risk assessment e.g. on the American mink. In order for the management committee to make an informed decision, the RA should provide sufficient information on the costs associated with the eradication and conservation/control activities of a species; and their comparison with the reasonably foreseeable outcome of those activities in order to evaluate their cost-effectiveness.
Composition of the Scientific Forum
The Scientific Forum has the responsibility to provide a scientific opinion upon which the management committee can further discuss and decided about the inclusion of a species in the EU list. For this reason, the members of the Scientific Forum shall be independent and have relevant scientific and technical knowledge related to each species to which each risk assessment refers to, in order to provide the highest level of scientific excellence when taking the decision to (not) include a new species in the EU list.
ABOUT FUR EUROPE
Fur Europe represents the entire value chain of the European fur sector including farmers, feed kitchens, auction houses, fur brokers, manufacturing, marketing and fur retailers. A Brussels-based umbrella organisation we represent national associations in 28 European countries. We exist by the values of openness, transparency and reliability and from this fundament we develop our policies under six sustainability pillars: animal welfare, biodiversity, by-products, environmental footprint, skills and transparency. Fur Europe was founded in 2014, as a result of a merger between the European Fur Breeders’ Association and the European members of the International Fur Federation.
Read full responseMeeting with Timo Pesonen (Director-General Communication)
16 Nov 2017 · Circular economy, priorities of Juncker Commission and Communication challenges
Meeting with Andrew Bianco (Cabinet of Vice-President Karmenu Vella) and EU Consult International
29 Sept 2017 · Invasive Alien Species
Response to Commission Implementing Act updating the List of invasive alien species (IAS) of Union concern
29 Mar 2017
Fur Europe is concerned about the inclusion of the Finnraccoon (Nyctereutes procyonoides) in the list.
As a general remark, the Regulation underlines that priority should be on those invasive alien species that are not yet present in the Union or are at an early stage of invasion, which is not the case of the finnraccoon.
Moreover, further scientific evidence is needed before including the finnraccoon in the list. The scientific literature suggests that its impact can be very different from region to region, and the risk assessment itself suggests that there is not yet sufficient science to get to unequivocal conclusions. Additionally, the risk assessment does not take into account important scientific evidence:
- there is no reason to believe that it will inflict serious and lasting damage to nature, given its ability to find its niche in the ecosystem;
- Some studies highlights that further research is needed to establish the extent of the disease spreading and sicknesses in finnraccoon;
- While it seems that the finnraccoon fits very well into the local communities and successfully coexist with the native medium-sized carnivores, there are scarce robust scientific studies clearly demonstrating that this species causes damage to bird population.
Furthermore, the direct and indirect socio-economic value of finnraccoon farming was completely disregarded, while the cost-effectiveness of adding this species to the list was mostly overlooked. Indeed, there is not enough existing research to make a cost/effective analysis of the impact of the finnraccoon on nature (the risk assessment acknowledges that information is scarce about the economic impact of finnraccoon.)
On top of that, research studies and several eradication attempts performed in Europe proved ineffective and extremely resource consuming for Member States, bearing no evidence that they would systematically work with non-congregatory species at low population densities as the racoon dog. Therefore, adding the animal on the list would oblige member States to invest huge sums of tax-payers’ money into activities which would most likely bring little to no results.
(Please see the attached document for more details about the economic and scientific arguments mentioned above).
Fur Europe would also like to stress at least three elements at procedural level.
First of all, in contradiction with article 5(3) of the regulation (EU) 1143/2014, the European Commission proceeded to approve the list before a method to carry out a risk assessment for potentially invasive species was defined, including the methodology to be applied in the risk assessment.
Secondly, Article 9(1) establishes that the Commission can allow Member States to issue permits allowing to carry out activities involving listed species for reasons of compelling public interest, including of social and economic nature. Moreover, article 9(2) states that the Commission shall set up and operate an electronic authorisation system to handle authorisation requests for Member States. However, no implementing act was adopted to define the format of the document serving as evidence for the permit; nor the electronic authorisation system has been put in place, with the overall likely risk to end up in a situation where a species is listed, but Member States have no means to issue a permit in accordance with the regulation.
Finally, the discussion about the update of the list started soon after the adoption of the first list in July 2016, and Fur Europe is worried that the Commission and Member States proceeded too rapidly to discuss the update of the first list, without taking into considerations possible shortcomings and learnings flagged by the different stakeholders involved.
Fur Europe is the European federation representing the full supply chain of the European fur sector, including fur farmers, fur auction houses, brokers, dressers and dyers, manufacturers, wholesalers, and retailers.
Read full responseMeeting with Astrid Ladefoged (Cabinet of Vice-President Karmenu Vella)
25 Jan 2017 · Seal product labelling
Meeting with Aurore Maillet (Cabinet of Vice-President Karmenu Vella)
28 Jun 2016 · The EU seal regime
Meeting with Jyrki Katainen (Vice-President)
13 Jul 2015 · Fur sector
Meeting with Marco Valletta (Cabinet of Commissioner Vytenis Andriukaitis)
8 Apr 2015 · Animal Welfare