Pro Wildlife
Pro Wildlife is a non-profit organisation committed to conserving wild animals and their habitat.
ID: 285805825014-46
Lobbying Activity
Meeting with Gerben-Jan Gerbrandy (Member of the European Parliament) and Humane World for Animals Europe
14 Oct 2025 · MEPs for Wildlife
Meeting with Manuela Ripa (Member of the European Parliament, Rapporteur)
30 Apr 2025 · CITES
Response to The European Oceans Pact
14 Feb 2025
10 REQUIREMENTS FOR A EUROPEAN OCEAN PACT The EU's maritime policy is a patchwork of individual measures that has grown over time. However, the alarming situation regarding poor ocean health and the complexity of interests require an overarching and stringent policy that takes all current and cumulative threats to marine ecosystems into account, that follows the precautionary principle and that aims to preserve and recover healthy oceans, including for future generations. We consider the following 10 key issues to be indispensable: 1. ECOSYSTEM-BASED AND PRECAUTIONARY APPROACH This must be the overarching guideline for all individual policies in fisheries and other marine-related regulations and directives. 2. SUSTAINABLE FISHING PRACTICES So far non-binding recommendations on preventive, ecosystem-based approaches must become obligatory and selective fishing methods need further promotion while destructive methods, such as bottom trawling must be prohibited. 3. REDUCTION OF BYCATCH Cetacean and other protected species bycatch should be minimised and where possible eliminated under EU law. 4. MARINE PROTECTED AREAS The 30x30 target for protected areas must be implemented without delay and consequently, destructive fishing practices and other damaging extractive uses (including oil drilling, mining, geo-engineering) must be completely banned and any further economic utilisation should only be allowed at levels that will not cause harm. 5. RESTORATION OF MARINE ECOSYSTEMS... ...is essential to implement the objectives of the EU Nature Restoration Law (Regulation (EU) 2024/1991) and aim at restoring at least 20 % of Europes marine ecosystems to a near-natural and pristine state by 2030. 6. PROTECTION OF MARINE MEGAFAUNA Top predators such as cetaceans and sharks occupy key roles in marine ecosystems and need strict and comprehensive protection. 7. REDUCTION OF UNDERWATER NOISE POLLUTION Measures have to be taken to reduce underwater noise in context of all anthropogenic activities. 8. REDUCTION OF MARINE POLLUTION AND DEBRIS... ...is needed to achieve the objectives of the Marine Strategy Framework Directive (MSFD, 2008/56/EC) requiring a good environmental status until 2030. 9. CLIMATE PROTECTION Sustainable ocean conservation is only achievable in conjunction with effective climate protection, with policies consistent with a 1.5 pathway. 10. SECURE FUNDING All these measures require a sufficient continuously provided budget, including the adoption of an EU Ocean Recovery Fund.
Read full responseMeeting with Sebastian Everding (Member of the European Parliament)
6 Feb 2025 · Introduction meeting
Meeting with Cristina De Avila (Head of Unit Environment) and Eurogroup for Animals and
14 Jan 2025 · CITES: Transparency; the future Multi-Annual Financial Framework; EU Live Animal Transport Regulation; and Registration of Captive Breeding Facilities for Appendix-I Species
Response to Endangered animal and plant species – suspension of imports from specific countries
7 Oct 2024
Pro Wildlife thanks the European Commission for the opportunity to comment on the update of the EU Suspensions Regulation. We would like to express our concerns about the suggested lifting import suspensions for Mantella cowanii, Mantella crocea, Mantella viridis and Scaphiophryne gottlebei from Madagascar and Varanus dumerilii, Varanus jobiensis and Varanus salvadorii from Indonesia. We are concerned, that no explanation and no evidence have been made available that would justify the removal of long-standing import suspensions for these species, other than that these are said to have been based on the most recent information. It is therefore unclear how it was established that imports would meet the criteria relating to the assessment of non-detriment and other factors relating to the conservation of the species, as set out in Council Regulation 338/97. Mantella viridis, M.cowanii and Scaphiophryne gottlebei are categorized as Endangered in the IUCN Red List and M.crocea as Vulnerable, and all are reported to have declining population trends (due to the impact of over-collection for the pet trade for S.gotlebei). It is therefore highly questionable on what basis the removal of the trade suspensions for these species has been decided. A recent publication by Carpenter and Andreone (2023) https://www.mdpi.com/2076-2615/13/14/2324 on amphibians in Madagascar questions the reliability of NDFs for Mantella species: One area for future study is the appropriateness and robustness of the datasets provided by Madagascars government representatives to CITES that are used to calculate CITES Non-Detrimental Findings (NDFs) and serve as their basis. Upon viewing the quota values available, there seems to be a great deal of commonality in the values used despite the highly variable factors influencing each species. Thus, much greater attention needs to be paid toward increasing the robustness of the datasets that are used to calculate NDFs. The study also highlights the problems in enforcing trade regulations for this genus: Furthermore, with the increase in the number of recognised species, the potential for incorrect species labelling on the CITES permits increases and requires greater attention. We note that Madagascar has neither published NDFs nor export quotas for these species. For the three monitor lizard species, Indonesia has not published NDFs and there is no information on population status or trends and very limited knowledge on distribution. The species are facing various threats including habitat loss, infrastructure development, hunting for bushmeat and trade for the pet market. Again, it is unclear on what basis the decision to lift the long-standing import suspensions. Generally we are concerned, that these and previous recommendations by the SRG to lift import suspensions many of which have been in existence for more than 20 years lack scientific justification as well as transparency, fail to consider the precautionary principle and are not in the best interest of conservation of the affected species.
Read full responseResponse to Better protecting sharks through sustainable fishing and trade
14 May 2024
Please find our more detailed feedback regarding ecological, economic and social impact of shark conservation measures in the pdf attached. The EU is a key player in both shark fisheries and in shark conservation and both interests are in conflict with each other, which repeatedly leads to the EU only half-heartedly implementing specific protection measures for sharks. For example, the EU played a key role in the listing of all Carcharinidae in CITES Appendix II in 2022 (which requires exporting countries to issue a Non-Detriment Finding); however, under ICCAT and other regional fisheries agreements, the commercial interests by EU fleets continue to prevail and manifest a practice that ignores the precautionary principle and risks the further decline of shark populations. While the EUs Shark Finning Regulation of 2013 with its `fins naturally attached´ obligation was a milestone to combat the cruel practice of shark finning, it does not prevent the ongoing EUs export of shark fins as the most valuable product. Moreover, as long as the EU continues to import shark fins and allows transit, it has little opportunity to check whether the fishing requirements (no finning, caught sustainably and legally) are actually being met in the country of origin. Recent studies found that anti-finning regulations did not reduce mortality: they neither prevented sharks from being killed nor prevented fins from being removed and sold (Hammerschlag & Sims 2024; Worm et al. 2024). The EU citizen initiative Stop Finning Stop the Trade is aiming to close existing loopholes in the present EU legislation: Firstly, despite its shark finning regulation, the EU is still one of the largest suppliers of shark fins and secondly, the EU is a hub for shark fins from other regions where lack of legislation or weak enforcement still allow shark finning to continue on a large scale. For decades the EU has been a major supplier for the East Asian shark fin market (Slee & Collis 2023; Okes & Sant 2019; Dockerty 1992) and, based on that business, a new market for shark meat has developed in Latin America (Shea et al. 2022; Souza-Araujo et al. 2021), which further increases the economic incentives for the continuation or even expansion of current unsustainable shark fisheries. A stricter implementation of the EUs Shark Finning Regulation alone would only prevent finning itself by the EU fleet, but not necessarily reduce the numbers of targeted and landed sharks or their bycatch in other fisheries (e.g. longline, purse seine or bottom trawling). A regulation is urgently needed that minimises the economic incentive to continue exploitation of shark populations.
Read full responseResponse to Revision of EU rules on textile labelling
22 Sept 2023
Please find attached our reply.
Read full response25 Aug 2023
Pro Wildlife is seriously concerned about the proposed removal of import prohibitions for a large number of species-country combinations. These fail to consider the precautionary principle, embedded in the TFEU, are not based on latest available information and not in the best interest of conservation of the affected species. We are also concerned about the lack of transparency and stakeholder engagement in the process: While EU Treaties require that all decisions are taken as openly and closely as possible to the citizen and the COM in its Action Plan against Wildlife Trafficking committed to increasing transparency and engagement, civil society is only informed and consulted months after the relevant decisions have been discussed and agreed by the EU's Scientific Review Group, without any prior information or publication of relevant reports and thus no opportunity for timely stakeholder input. We are concerned consultation at this late stage may render this a purely formal exercise. We also note a recent consultation by the EU Ombudsman on "Transparency and participation in decision-making related to the environment" highlighted similar concerns. We are also concerned, that no explanation or evidence is provided to justify the proposed lifting of import prohibitions. Only in five out of 15 cases a very brief rationale is given, e.g. mentioning most recent available information, without providing any documentation or data, or that decisions had been based on CITES processes. However, the proposal fails to consider recent CITES discussions such as at the 32nd Animals Committee and CITES processes raising concerns on compliance with and implementation of CITES requirements of certain Parties (e.g. Lao PDR, Madagascar, Togo, Benin, Indonesia) including on making of non-detriments findings and control of captive production. For some concerned species the decisions seem to fignore recent publications on the threats posed by trade and IUCN assessments of the conservation status of species (e.g. Macaca fascicularis: Endangered (as of 2022); Indotestudo forstenii: Critically Endangered; Kynionga fischeri: very limited distribution; K. tavetana: likely declining population; Profelis aurata: Vulnerable; Ranitomeya variabilis: Data Deficient, small range in Peru). It appears several decisions are based on the publication of new export quotas. However, this in itself does not mean that all requirements of EU Regulation 338/97 with regard to non-detriment and legality have been fully met, specifically as for the majority of species no reliable data are available (e.g. on population size, overall offtakes) on which NDFs could be based. Also, zero export quotas (established e.g. for Kinyongia fischeri, K. tavetana; Brookesia decaryi) may not be maintained in the future and should not form the basis for removal of (long-standing) import prohibitions. Continued EU trade prohibitions should support such zero quotas (or bans on offtake). We lwould ike to highlight two examples illustrating the need to maintain all import prohibitions until the above-mentioned concerns have been adressed: For Longtailed Macaques (Macaca fascicularis) the CITES AC in June 2023 requested the CITES Secretariat to investigate the issue of legal acquisition of founder stock for captive-breeding facilities in Lao PDR in its ongoing compliance discussions with the country. Several recent reports highlight illegal offtakes and cross-border trade between range states of the species, including Lao PDR. For Brown Beras (Ursus arctos) from British Columbia trade suspensions have been in place for more than 18 years, due to concerns on the validity of non-detriment findings. While British Columbia is currently banning trophy hunting of the species, such decisions may be subject to change. Last but not least, removal of import suspensions would ignore opposition to trophy hunting by indigenous peoples in BC, by the general public in Canada and in the EU.
Read full responseResponse to Sustainable fishing in the EU: state of play and orientations for 2024
27 Jul 2023
This is a joint response from Pro Wildlife and Sharkproject. We congratulate the EU and its Member States on the progress made so far in reducing overfishing. However, we also believe that much more needs to be done and therefore welcome the opportunity to make a submission to this consultation. Please find attached our more detailed response, which covers three areas with a range of concrete examples of where improvements are urgently needed to ensure sustainable fisheries in the EU (but also by EU fleets in other regions): 1. Ecological aspects (such as long-term sustainability of fishing quotas, rebuilding of overfished stocks, destructive fishing gears and dFADs, stricter regulations for shark fisheries, RFMOs - to mention just a few) 2. Monitoring and enforcement (for instance human observer coverage at high-risk vessels, exemptions, fishing under foreign flag) 3. Socio-economic aspects (fossil fuels, social standards, global responsibilities, food security and equal obligations for all) Please do not hesitate to contact us in case of queries. Yours sincerely Dr. Sandra Altherr
Read full responseResponse to Detailed rules on selective devices in the Baltic Sea
22 Jun 2023
Pro Wildlife welcomes any technical improvement to further reduce bycatch of cod in the Baltic Sea (and any related bycatch, such as of harbor porpoise or sea ducks). However, we fear that the contribution of the proposed modifications to the recovery of already collapsed cod stocks is not enough to ensure their recovery and that they may prevent the urgently needed comprehensive turnaround, towards a real reform and transformation of the Baltic Sea cod fishery. Pro Wildlife therefore urges you to seek a more comprehensive change of course and prioritize, among other things, the following: - fully implementing the precautionary principle and the ecosystem management approach, - further expanding marine protected areas as well as temporarily and geographically closing gillnet fisheries, - closing loopholes and - supporting systematic research on interactive entanglement measures for critically endangered species, such as the harbor porpoise. Restrictions and regulations for fisheries in the Baltic Sea have been deliberately circumvented time and again in the past (e.g. Valentinsson et al. 2019) and management plans and regulations have failed. It is feared that even the measures now proposed will not lead to the desired success. Given the already catastrophic stock situation of cod in the Baltic Sea, bolder and more far-reaching measures must be taken that do justice to the precautionary principle and the complexity of the problem. While we are fully aware of the immense economic and social problems and upheavals in the Baltic Sea fishery, we see no alternative to the recommendations in our attechment.
Read full responseMeeting with Anna Deparnay-Grunenberg (Member of the European Parliament)
6 Jul 2022 · internationaler Artenschutz, Bedrohung von Tieren durch internationalen Handel
Response to Improving environmental protection through criminal law
23 Feb 2022
Pro Wildlife welcomes the Commission’s proposal to revise the Directive. We agree with the EU Commission’s analysis of existing problems; however, we recommend several steps for further improvement of the Directive.
As Pro Wildlife’s focus is wildlife trade and wildlife crime our feedback below is limited to this aspect of environmental crime.
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Scope of the Directive:
Specifying the definition of what constitutes environmental crime is an important step to increase efficiency and practicability of the Directive. However, this will not prevent the need for regular updates, by referencing any new EU environmental legislation.
Furthermore, we urgently call on the EU to further expand the scope of the Directive by the two following relevant crime categories:
a) We urge the Commission to expand the scope of the Directive to illegal, unreported, and unregulated fishing. The EU’s fishing fleet is one of the largest in the world and regularly found to be involved in IUU fishing activities. IUU fishing becoming a part of the Environmental Crime Directive, including defined minimal sanctions and prosecutions, would send a strong signal, would further highlight the criminal aspect of IUU fishing, and would help to achieve a deterrent effect.
b) Wildlife trafficking is by far not limited to species protected under EU Regulation 338/97: For many years Pro Wildlife has been documenting systematic wildlife trafficking of threatened species, which are nationally protected in their country of origin. After being stolen from and successfully smuggled out of range states, such wildlife can at present be legally imported and sold within the EU. This special type of wildlife crime is highly profitable, with the EU being a main hub and destination and EU citizens being heavily involved as traffickers and clients. We therefore urge the EU to combat this type of wildlife crime by passing legislation making import, trade and possession of wildlife, taken in violation of national legislation in the country of origin an offence in the EU. This could and should be done in the context of the review of the EU Action Plan against Wildlife Trafficking, as recommended by the EU Parliament, too.
More information: https://bit.ly/3scKWn7, https://bit.ly/3p9MuMH, https://bit.ly/3scK69Z).
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Use of vague terms:
We support Option 2c and wish to underline the importance of defining terms such as “substantial damage”, considering also potential long-term effects or aggravating circumstances as well as the conservation status of a trafficked species.
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Sanction types and levels:
Although wildlife crime is a serious and highly profitable form of organised crime, it is often neglected and treated by the judiciary as a trivial offence. Pro Wildlife is aware of many cases where wildlife trafficking did not even result in seizures or prosecutions or were just dismissed with a small fine, not at all reflecting the huge profit that can be achieved with the illegally acquired wildlife and therefore having no deterrent effect.
We therefore strongly support Option 3c to not only introduce minimum sanction levels plus aggravating circumstances and accessory sanctions but would also include the obligation to link the level of fines to the financial situation of legal persons and/or illegal profits.
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Cross-border cooperation & practical law enforcement:
While controls and enforcement are still mainly focused on airports and borders, large portions of wildlife trafficking are presently organised via online platforms, open and closed Facebook groups and other online channels.
The EU should encourage its Member States to extend their online investigations, to provide specific training for their enforcement staff, to establish national online task forces and to intensify cross-border cooperation and coordination with their EU counterparts. Moreover, it is important to include wildlife trade into the Digital Service Act.
Read full responseMeeting with Andrea Vettori (Cabinet of Commissioner Virginijus Sinkevičius) and Eurogroup for Animals and
28 Jan 2022 · Trophy hunting in relation to EU biodiversity objectives
Meeting with Helena Braun (Cabinet of Executive Vice-President Frans Timmermans) and Eurogroup for Animals and
28 Jan 2022 · Trophy hunting in relation to EU biodiversity objectives
24 Feb 2021
On behalf of Pro Wildlife and in cooperation with 16 other organisations, we would like to submit the attached joint NGO statement on the EU proposal to tighten further the EU ivory trade regime (see attached statement by 17 NGOs).
Pro Wildlife welcomes the European Commission’s intent to tighten the rules on ivory trade and broadly supports the proposed amendments to Commission Regulation 865/2006 and the draft revised guidance document. However, we are concerned that some important gaps remain, and recommend the following amendments:
● We strongly recommend that the new rules are not only included in non-binding guidance, but that Commission Regulation 865/2006 is amended to ensure consistency and enforceability.
● The requirement that antique ivory can be traded with a certificate is too broad. We suggest a de minimis provision restricting the issuance of certificates for pre-1947 worked ivory .
● Exceptions regarding pre-1975 musical instruments should only apply when the volume of ivory in the instrument is less than 20% of the total volume of the material of which the instrument is made.
● The guidance only refers to a "suspension" of trade. This is creating the expectation that the suspension will someday be lifted, which is counter-productive in efforts to reduce demand and close ivory markets permanently and might lead individuals to retain or stockpile ivory. We recommend the use of the terms ‘prohibition’ or ‘ban’.
● A witness statement/affidavit or signed declaration from an applicant for a certificate to trade antique worked ivory does not provide proof of legal acquisition. Declarations in support of legal acquisition / origin should be provided by independent approved/recognised experts only.
Read full responseMeeting with Camilla Bursi (Cabinet of Commissioner Virginijus Sinkevičius)
21 Oct 2020 · To discuss EU action on wildlife trade
Response to EU 2030 Biodiversity Strategy
20 Jan 2020
Pro Wildlife welcomes the possibility to comment on the draft EU Biodiversity Strategy for 2030. We welcome the EU´s commitment to curtail biodiversity loss and preserve and restore ecosystems. In the attached PDF document, we provide our input on a number of issues that we believe need to be included in the EU´s Biodiversity Strategy to 2030 if the EU wants to lead by example in global negotiations on halting biodiversity loss and safeguarding ecosystems.
Read full responseMeeting with Sebastien Paquot (Cabinet of Vice-President Karmenu Vella) and Eurogroup for Animals and
22 Nov 2018 · CITES