OpenLobby.EU
Explore

The Born Free Foundation

BFF

The Born Free Foundation is a wildlife charity dedicated to animal welfare and conservation.

Lobbying Activity

Response to Supplementing Regulation (EU) 2016/429 on non-commercial movement of pet animals

9 Dec 2025

Born Free welcomes the opportunity to provide feedback on the draft delegated regulation. We support the adoption of such a delegated act to clarify the definition of non-commercial movements and to set out the conditions governing these movements. However, we are concerned that: 1. the delegated act applies to all pet animals of the species listed in Part A of Annex I of the Animal Health Law (pet dogs, pet cats and pet ferrets), yet applies only to pet birds from among the pet animals listed in Part B of Annex I of that Law. 2. The delegated regulation does not clearly define the term pet animals. Although the Animal Health Law provides a definition, it is too vague to determine with sufficient clarity which species should be considered pet animals in the EU. This delegated act presents an important opportunity to address and remedy this gap. 3. The conditions set out in the proposed delegated act differ between animal categories. All animals should be afforded the same level of protection. For example, a maximum number of individual animals should be established for non-commercial movements across all categories. Such a provision would help safeguard animal health and welfare during transport, mitigate risks to human health and safety, and reduce the likelihood of trafficking activities being disguised as non-commercial movements. We thank you again for this opportunity to share our feedback and we are available to provide further information if required.
Read full response

Born Free urges exclusion of offsetting from nature credit scheme

30 Sept 2025
Topic — EU initiative to create an innovative funding tool for nature conservation.
Message — The foundation requests that credits only fund positive actions and explicitly exclude offsetting. They also demand a mandatory regulatory framework that integrates animal welfare into biodiversity assessments.12
Why — This would provide animal welfare NGOs with new funding and policy influence.34
Impact — Businesses that rely on offsetting to justify environmental damage would be effectively excluded.56
Read full response

Born Free urges EU to integrate wildlife into climate framework

4 Sept 2025
Topic — The initiative aims to create an integrated framework for managing accelerating European climate risks.
Message — The foundation demands that climate and biodiversity crises be addressed together through synergistic measures. They advocate for integrating animal welfare and population restoration into all national climate strategies and policies.12
Why — Implementing these measures would protect the specific habitats and animal populations that form the charity's core mission.3
Impact — Human societies and economies face greater danger if environmental policies are deregulated for short-term competitiveness.4
Read full response

Response to Proposal for a new Regulation on the European Union Agency for Law Enforcement Cooperation (Europol)

15 Jul 2025

Born Free welcomes the opportunity to provide feedback on the evaluation and impact assessment of the new Europol Regulation. Our comments reflect our areas of focus and longstanding expertise in environmental crime, in particular wildlife trafficking. Please find them in the attached PDF.
Read full response

Born Free urges EU to tackle organized wildlife crime

15 Jul 2025
Topic — The Commission plans to revise current rules on organized crime to dismantle criminal networks.
Message — Born Free requests the full implementation of the Environmental Crime Directive and a new EU-wide list of permitted exotic pets. They also advocate for criminalizing the trade of species illegally exported from their home countries and expanding the EPPO's mandate.123
Why — These measures would protect threatened species by making illegal wildlife trafficking significantly more difficult and risky.4
Impact — Organized criminal networks would lose the low-risk opportunities currently provided by legal loopholes in the wildlife trade.5
Read full response

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 Alignment of EU rules to recent decisions taken under CITES, the international convention on wildlife trade

12 Jul 2024

The undersigned organisations welcome the opportunity to provide feedback on the draft Commission Regulation amending Regulation (EC) No 865/2006 as regards developments in the framework of the Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES) and the possibility to issue retrospective permits. Following the recommendations emerging from the 77th CITES Standing Committee meeting in November 2023 on the application of Article XIII in the European Union, we are pleased to see the EU recognising the significant gaps in its implementation of CITES, and taking steps to ensure that its legislation better aligns with its commitments under the Convention. We broadly endorse the proposed Regulation. However, we have some reservations regarding the draft text and would like to share some recommendations to address these aspects, which are available in the attached file. We thank you again for this opportunity to share our feedback and we are available to provide further information if required. Born Free Foundation Center for Biological Diversity David Shepherd Wildlife Foundation Defenders of Wildlife Elephant Reintegration Trust Environmental Investigation Agency (EIA) Eurogroup for Animals Fondation Franz Weber Four Paws Humane Society International Europe (HSI) International Fund for Animal Welfare (IFAW) Pro Wildlife Robin des Bois Species Survival Network (SSN) World Parrot Trust
Read full response

Response to Environmental Implementation Review 2025

2 Jul 2024

Born Free is a UK-based international charity committed to promoting compassionate conservation to enhance the survival of threatened species in the wild and protect natural habitats, while respecting the needs and safeguarding the welfare of individual animals. We welcome the opportunity to provide feedback on the EU Environmental Implementation Review. Our comments, available in the attached PDF, reflect our areas of focus and our expertise in wildlife conservation, wildlife trade and trafficking, environmental crime, and animal welfare.
Read full response

Born Free Urges EU To Protect All Transported Wild Animals

12 Apr 2024
Topic — EU consultation on revising animal welfare standards during transport for better protection and competition.
Message — Born Free calls for new rules to cover all live animal species regardless of the transport's purpose. They request the inclusion of protected wild animals and those moved between zoos to close legal loopholes.12
Why — Broadening the scope would simplify legal enforcement and advance the charity's animal protection mission.34
Impact — Commercial transporters and circuses would face higher costs if current species exemptions are removed.56
Read full response

Born Free urges stricter wildlife trade rules to prevent pandemics

3 Apr 2024
Topic — Evaluation of EU rules on transmissible animal diseases and their effectiveness.
Message — The organization calls for a shift from containing outbreaks to primary prevention of pathogen emergence. They demand stricter regulation or prohibition of trade in high-risk species like primates and bats. Additionally, they advocate for integrating animal welfare and aligning rules with transport regulations.123
Why — Investing in primary prevention would offer significant cost savings compared to pandemic fallout.4
Impact — Commercial wildlife traders and markets would face severe restrictions or bans on their operations.5
Read full response

Response to 8th Environment Action Programme – Mid-term Review

26 Jan 2024

Born Free welcomes the opportunity to provide feedback to support the Commissions mid-term review of the 8th Environment action programme (8EAP). Please find it in the attached document. We thank you again for this opportunity to share our feedback and we are available to provide further information. About the Born Free Foundation Born Free is a UK-based international wildlife protection charity. We promote compassionate conservation to enhance the survival of threatened species in the wild and protect natural habitats while respecting the needs and safeguarding the welfare of individual animals. As a leading wildlife charity, we oppose the exploitation of wild animals in captivity and campaign to keep them where they belong in the wild.
Read full response

Response to Interim evaluation of the EU4Health Programme 2021-2027

20 Dec 2023

Born Free is a conservation and animal protection Charity. We appreciate this opportunity to provide feedback on the EU4Health programme which was adopted in the wake of the COVID-19 pandemic. The pandemic has clearly demonstrated the need to effectively address the risks associated with the human-animal-environment interface, to prevent, mitigate, and respond to the emergence of zoonotic disease spill overs. In its public consultation on the new EU Global Health Strategy from 2023, the European Commission recognised that climate change and the destruction of natural habitats have increased the risk of emergence and proliferation of animal viruses, some of which may have the potential to cross over to people and cause pandemics. This brings the close links between the environment, animal and plant health, and human health sharply into focus, and confirms the need for the operationalization and implementation of One Health and health in all policies approaches, where the many related factors influencing and affecting health are addressed in a comprehensive, joined-up way, especially in a world where health has inevitably acquired a geopolitical dimension, linking with other policies such as food production, trade and security. A highly precautionary approach is needed to the risks associated with wildlife trade. Please find more detailed recommendations in the attached PDF. We thank you again for this opportunity to share our feedback and we are available to provide further information.
Read full response

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

14 Sept 2023

Born Free welcomes the opportunity to respond to the Call for Evidence for the mid-term evaluation of the EU LIFE programme 2021-2027. Our input relates specifically to the LIFE Nature and Biodiversity and LIFE Climate Change Mitigation and Adaptation sub-programmes, recognising the clear link between nature and biodiversity protection and climate change mitigation. According to the World Economic Forum, illegal wildlife trafficking is the fourth most lucrative global crime. It threatens biodiversity conservation, human and animal health and welfare, local and national economies, and national security (thanks to the involvement of organised crime). The EU continues to be a major importer, transit hub and exporter of trafficked wildlife. According to the European Commission, the reported value of the illegal wildlife trade in the EU was a minimum of 4.7 million in 2019 but is likely to be much larger, and since 2017 there have been on average over 6 000 annual seizures involving CITES-listed wildlife in the EU. Tackling wildlife trafficking must therefore be a key priority in efforts to protect and restore nature and biodiversity, and the EUs Action Plan Against Wildlife Trafficking, first published in 2016 and revised in 2022, is designed to achieve this. The LIFE Nature and Biodiversity was a key identified source of funding for the first EU Action Plan against Wildlife Trafficking. However, many key goals and targets in the Action Plan were not met. We note that the European Parliaments Resolution of 9th June 2021 on the EU Biodiversity Strategy for 2030: Bringing nature back into our lives, inter alia explicitly calls on the Commission to jointly address legal commercial trade and illegal trade in the review of the EU Wildlife Action Plan against Wildlife Trafficking, which should be fully in line with the Biodiversity Strategy for 2030 and receive adequate funding, including assistance to non-EU countries and to wildlife rescue centres and sanctuaries. In its communication COM (2022) 581 on the Revision of the EU Action Plan in November 2022, the Commission acknowledged that No real progress can be made in the fight against wildlife crime if no sufficient funding is available to support the accompanying actions, both at the EU level and in EU Member States. It is crucial that funds dedicated to monitoring the wildlife trade and addressing wildlife crime are: (i) identified in advance; (ii) made accessible to the relevant implementing actors; and (iii) used in the most effective and coherent way.. The Commission proposed that The wildlife trade should be fully integrated in the relevant EU funds addressing: (i) security and organised crime; (ii) the environment; and (iii) international cooperation/partnerships. In particular, it should be a priority under: EMPACT; the Internal Security Fund; the LIFE programme; and the Neighbourhood, Development and International Cooperation Instrument. It is therefore critical that the current and future LIFE funding programmes, alongside the other funding mechanisms identified by the Commission, prioritise coordinated financing to effectively resource the full implementation of the objectives and actions identified in the revised EU Action Plan Against Wildlife Trafficking. This should include the establishment of a specific unit within the Commission with a remit to assist Member States with the implementation of the Action Plan, and capacity building and training in Member States. In addition, funding for the development and implementation of a comprehensive monitoring and evaluation mechanism in collaboration with Member States, and for the appropriate management and care of seized and confiscated wild live animals, should be prioritised.
Read full response

Response to Revision of the Union Customs Code

9 Jun 2023

Born Free welcomes the opportunity to provide feedback on the revised Union Customs Code. Our organisation has a long history working on wildlife trade and trafficking and we believe Member States Customs authorities play a central role in the regulation and control of wild animals and wildlife products that enter, circulate within and are exported from the EU. This role needs to be clearly recognised and its importance raised in the revised Union Customs Code in order to effectively address the threats wildlife trade and trafficking present to human health, biodiversity, the environment, national security, and animal welfare. Please find our key recommendations in the attached PDF. We thank you again for this opportunity to share our feedback and we are available to provide further information.
Read full response

Born Free Demands Animal Welfare Standards in Green Finance Rules

2 May 2023
Topic — The EU is defining which economic activities qualify as environmentally sustainable investments.
Message — The foundation proposes that green investments must respect animal welfare and avoid wildlife exploitation. They advocate for prioritizing activities that actively restore biodiversity and maintain habitat connectivity.123
Why — Stricter criteria would channel more capital toward the organization's mission of compassionate conservation.4
Impact — Companies profiting from unsustainable wildlife tourism or habitat-destroying infrastructure would lose investment.5
Read full response

Born Free calls for wildlife trafficking priority in customs

16 Sept 2022
Topic — The EU is revising customs rules to address e-commerce and security challenges.
Message — Born Free wants customs to prioritize wildlife trafficking through harmonized rules and better resources. They request specialized training and improved management of confiscated animals to ensure humane treatment. The foundation also supports stricter monitoring of illegal trade on e-commerce platforms.123
Why — The proposals would strengthen international efforts to protect endangered species and prevent animal exploitation.4
Impact — Organized criminal networks would lose the low-risk environment they currently exploit for high profits.5
Read full response

Meeting with Caroline Roose (Member of the European Parliament, Rapporteur for opinion) and European Environmental Bureau and

1 Sept 2022 · Environmental Crime Directive (Protection of the environment through criminal law )

Born Free urges more ambitious EU nature restoration targets

22 Aug 2022
Topic — A consultation on legally binding targets to restore Europe's degraded ecosystems.
Message — The foundation calls for moving up achievement deadlines and covering all listed habitat types rather than just some. They also advocate for restricted lists for exotic pet trading and including a ban on harmful subsidies in the main law.123
Why — The stricter rules would help secure the survival of threatened wildlife species.45
Impact — The exotic pet industry and businesses receiving harmful subsidies would face tougher restrictions.67
Read full response

Response to Freezing and confiscation of the proceeds of crime

27 Jul 2022

The Born Free Foundation (Born Free) welcomes the opportunity to provide feedback. Our comments and recommendations are available in the attached PDF.
Read full response

Response to Evaluation of UCPM

1 Jun 2022

The EU Civil Protection Mechanism was established to strengthen cooperation and coordination among the 27 EU countries and 6 non-EU participating countries to improve the systems for preventing, preparing for and responding to natural and human-made disasters of all kinds within and outside the EU. As a conservation and animal protection NGO with longstanding experience of working on wildlife trade-related issues, we regret that the prevention actions undertaken as part of the UCMP haven’t included more effective measures to prevent emerging zoonotic diseases and pandemics in the EU, prior to and since the emergence of the Covid-19 pandemic. According to the Intergovernmental science-policy platform on Biodiversity and Ecosystem Services (IPBES) the majority (70%) of emerging diseases (e.g. Ebola, Zika, Nipah encephalitis), and almost all known pandemics (e.g. influenza, HIV/AIDS, COVID-19), are zoonoses – i.e. are caused by microbes of animal origin, many of which originate from wild animals. Wildlife exploitation, including for trade and consumption, has been identified as an important risk factor for zoonotic diseases . We welcome the decision of the World Health Assembly to develop an international pandemics agreement, with a mandate that will include a focus on preventive action against zoonotic disease emergence. We also support the EU’s efforts to promote the adoption of the much needed One Health approach in international discussions and negotiations, including in the framework of the Convention on Biological Diversity. However, such negotiations can be lengthy, at a time when urgency is paramount if we are to prevent further pandemics with all the associated consequences for human health and economic stability. The EU must adopt a precautionary approach to risk, as is already embedded in the constituting treaties, and ensure that activities occurring within its territory or carried out by its residents do not present any regional or international threats. Indeed, since the emergence of the COVID pandemic, the regulations governing trade in wild animals and wildlife products haven’t changed in the EU, and as a result high-risk practices continue. The EU must urgently show responsibility and leadership, and undertake more effective actions to tackle illegal wildlife trade, as well as adopting a highly precautionary approach to legal trade. This could be achieved through the adoption and implementation of a more ambitious and effective EU Action Plan against Wildlife Trafficking, the mainstreaming of a comprehensive One Health approach (including the ‘One Welfare’ principle) across all relevant EU laws and policies, and a change of perspective regarding wildlife trade, which should only be permitted when strict criteria designed to ensure human and animal health and welfare are met.
Read full response

Meeting with Anja Hazekamp (Member of the European Parliament) and Eurogroup for Animals and Humane World for Animals Europe

20 Apr 2022 · Animal Welfare

Response to Improving environmental protection through criminal law

12 Apr 2022

The Born Free Foundation welcomes the proposed revision of the Environmental Crime Directive and the opportunity to provide feedback. Please find our feedback in the document attached.
Read full response

Meeting 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

Response to EU police cooperation

7 Jan 2022

Born Free welcomes the opportunity to provide feedback on this initiative that provides an opportunity to improve the effectiveness of EU efforts against wildlife trafficking. Illegal wildlife trade poses serious threats to wildlife conservation and biosecurity, and often involves organised criminal networks which operate across international borders. Recent estimates by the United Nations Environment Programme assign a value of US$7-23 billion to the illegal wildlife trade, which rises to US$69-199 billion when illegal logging and fishing are included. In its Roadmap for an updated EU Strategy on Customs Risks Management the Commission recognised that “Wildlife trafficking is often carried out in the context of transnational organised crime and as such creates additional problems for governance and security in the countries involved.” However, wildlife trafficking continues to expand globally, including in Europe, suggesting that the tools to tackle it at EU and Member State level, and their implementation, are currently inadequate or insufficient. There is increasing international recognition that wildlife trafficking needs to be treated as serious, organised and predicate crime, most recently through the adoption of Resolution 75/311* by the United Nations General Assembly in July 2021. This should translate into increased priority given to illegal wildlife trade activities by enforcement authorities as well as increased intra and inter-State cooperation, which was included among the priorities of the current EU Action Plan Against Wildlife Trafficking (EU WTAP)**, and a recommendation of the Synopsis report of the public consultation - SWD(2021)375. The effective and consistent implementation of Actions 22 and 23 of the EU WTAP would have ensured significant progress; these actions need to be prioritised in a new / revised Action Plan. We also support the Proposal for a COUNCIL RECOMMENDATION on operational police cooperation - SWD(2021)375 that identifies the need to treat “Environmental crime, including illicit trafficking in endangered animal species and in endangered plant species and varieties” as serious offences. Experience and research since the adoption of the EU WTAP has taught us there is a need for increased resources as well as skilled and experienced staff with expertise in wildlife trafficking within law enforcement services, in order to combat wildlife trafficking more effectively and consistently. User-friendly tools to enhance information sharing, training (including on these tools, on protected species and relevant legislation), guidance and mentoring networks must be provided at EU level to facilitate cooperation and increase enforcement capacity, while ensuring consistency across Member States. Finally, a new legal framework for cross-border police cooperation on wildlife trafficking will need to address two key difficulties currently restricting the effectiveness of national law enforcement services: 1. Effective solutions for the management of confiscated live specimens: the costs of sending confiscated animals back to their country of origin is very high, and shelter options for confiscated live animals are limited. This, and the associated administrative burden, can sometimes disincentivise the seizure of illegal shipments and the initiation of associated legal processes. 2. National legislation related to exchange of information with other countries: International cooperation on wildlife trafficking-issues can sometime be hampered by national restrictions that prevent the exchange of information, including between EU Member States. We thank you in advance for your consideration and remain available to provide further information if required. *Resolution 75/311: https://undocs.org/en/A/RES/75/311 **EU Action Plan Against Wildlife Trafficking: https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:52016DC0087&from=EN
Read full response

Response to 2022 EU Justice Scoreboard

10 Dec 2021

Born Free believes the efficiency and quality of Member States’ justice systems need to be improved when it comes to environmental crimes. The Environmental Crime Directive, which is due for review by the end of 2021, suffers from inconsistent implementation across Member States. There are also disparities in national legislation, including different levels of sanctions, that criminals can take advantage of to reduce the risks associated with their activities, which are criminalised under EU law. This is why the judiciary and prosecutorial services in Member States urgently require appropriate training, guidance and access to mentoring networks to help ensure the Directive is consistently and adequately translated into national legislation, and applied consistently and effectively in all Member States. We thank you for considering our recommendations for the development of the 2022 EU Justice Scoreboard. We will be providing more detailed feedback in the framework of the Environmental Crime Directive review. About the Born Free Foundation: Born Free is a UK-based international wildlife protection charity. We promote compassionate conservation to enhance the survival of threatened species in the wild and protect natural habitats while respecting the needs and safeguarding the welfare of individual animals. As a leading wildlife charity, we oppose the exploitation of wild animals in captivity and campaign to keep them where they belong – in the wild.
Read full response

Response to EU strategy for Customs risk management

2 Nov 2021

The Born Free Foundation has noted the consultation on the EU Customs Risk Management Strategy is primarily addressed to Member States’ customs authorities. We would nevertheless appreciate an opportunity to share our thoughts and ideas, particularly related to the risks associated with the trade in wildlife, to help the Commission and Member States develop a comprehensive Risk Management Strategy / Framework for the EU. Please find our comments enclosed as a PDF document.
Read full response

Response to Preventing illegal trade in wildlife

2 Nov 2021

The Born Free Foundation welcomes the opportunity to comment on the European Commission's Roadmap for preventing illegal trade in wildlife - revision of EU Action Plan. Please find our feedback attached as a PDF document.
Read full response

Response to Environmental Implementation Review 2022

12 Oct 2021

The EU has committed to “lead by example” to help address the Biodiversity and Environmental crisis, and EU environmental legislation is one of the most protective in the world, but it’s not consistently enforced and implemented. This not only undermines the EU’s capacity to meet its environmental goals, it also affects its credibility both internationally and at home. More ambitious EU environmental regulations, needed to face the global challenges of biodiversity loss, climate change and zoonotic risk, will not be effective without robust implementation. The EU must effectively address the implementation gaps in existing EU rules, and ensure future legislation is comprehensively implemented in all Member States. There are several reasons why EU Member States fail to implement EU environmental legislation: • Several key aspects of EU Environmental policy, including the EU Action Plan against Wildlife Trafficking and the EU Biodiversity Strategy, are not binding. It is understandable that Member States with restricted resources do not prioritise actions if they are not compelled to. • Key aspects of EU Environmental Policy are insufficiently funded. • Binding EU environmental legislation also suffers from enforcement issues: - National prosecutorial services lack the guidance and training to effectively implement and enforce the EU Environmental Crime Directive. The Directive text also fails to provide clear guidance, leading to inadequate and heterogeneous transpositions into national law. - Penalties for failure to enforce binding environmental rules are too weak. Some Member States intentionally opt to infringe the rules to serve economic, political or other interests. For instance, some allow the hunting and trade in trophies from native species that are strictly protected under the Habitats Directive and the EU Wildlife Trade Regulations, such as brown bears in Romania and Sweden. • The EU itself doesn’t apply EU environmental legislation effectively, setting a poor example for Member States. The EU doesn’t follow the precautionary principle embedded within the treaties when it comes to wildlife trade and gives a green light to trade quotas for ANNEX B species for which data is unavailable or unreliable, undermining the credibility of non-detriment findings. It also continues to approve hunting quotas for leopards while CITES Decision 18.169 has not yet been completed and amidst concerns that quota levels are too high. The underlying issue is the lack of political will to take biodiversity loss seriously. The EU must send a strong signal to its Member States, beginning with the robust implementation of its own rules and investing in the EU services dedicated to their enforcement and implementation. Examples include the Scientific Review Group which has been without a chair and hasn’t met since 2020, and the CITES Unit at the Commission which is constantly under-resourced; such issues should be addressed as priorities. The EU must also support Member States with the implementation of EU rules, with guidance and training, as well as appropriate funding. Environmental crimes must be regarded as serious and predicate crimes, and effectively treated as such in the EU, particularly wildlife crimes which are too often disregarded, or for which associated sanctions are insufficient and inconsistently applied. A change of mentality is necessary for this. The EU should begin by actively advocating for the development and adoption of a global agreement on wildlife crime in the form of an UNTOC protocol, which is referred to in the EU Strategy to Tackle Organised Crime 2021-2025. Finally, given the urgency and cross-border nature of the crises we face, we cannot wait for voluntary individual action and need more ambitious and binding EU rules with robust enforcement and implementation, alongside a continuous and transparent monitoring system and truly dissuasive penalties for infringement.
Read full response

Response to Animal welfare labelling for food

24 Aug 2021

Transportation of live wild animals, particularly but not exclusively for pet trade, poses significant risks to animal welfare and animal and human health. We urge the Commission to adopt a highly precautionary approach when it comes to the shipment of live wild animals for the exotic pet trade or for other captive purposes, given the welfare and potential health implications. A ‘positive list’ system could support this precautionary approach and has the potential to significantly reduce the scale and scope of wild animal mortality during transportation while minimising the risk of new emerging disease outbreaks in the future. Risk to live wild animal welfare during transportation: Council Regulation (EC) No 1/2005 states that animals should not be transported in a way likely to cause injury or undue suffering. However, the natural history and optimal husbandry and welfare needs of many wild animal species are incompletely understood by biological science, and as a result, exact conditions to ensure their welfare during transportation are often difficult to determine. Consequently, it is commonplace for fatalities to occur during transportation [Wyatt, T., Maher, J., Allen, D. et al. The welfare of wildlife: an interdisciplinary analysis of harm in the legal and illegal wildlife trades and possible ways forward. Crime Law Soc Change (2021)]. Transportation of live wild animals and human health: the conditions in which animals are transported have potential consequences for human health and safety. Wild animals present a risk of injury and infection to traders, handlers, and other close contacts. Injuries include scratches, bites, constriction, and associated issues such as wound infection. Furthermore, wild animals may harbour zoonotic pathogens, and stress and poor welfare during transport can provide ideal conditions for pathogens to propagate and spread, increasing the risks of infectious disease affecting both animals and people. We recommend: 1.Considering the development and implementation of a robust ‘positive list’ system, establishing lists of species that are regarded as appropriate for trade (and excluding or restricting the trade in of species that are not or have not been assessed), based on clear and scientifically robust criteria including the identified risks for animal welfare and animal and human health during transportation. 2.Considering using zoonotic disease risk as one of the criteria when determining which species are permitted. Several European countries have introduced positive list legislation that specifies which species are permitted to be kept as pets based on risks to animal welfare, the environment and human health, and several countries (Belgium, Cyprus, the Netherlands (recommended – positive list not yet introduced) and Norway) have used or are considering using zoonotic disease risk as one of the criteria when determining which species are permitted. This kind of precautionary approach can help prevent trade in of high-risk animals, thereby greatly reducing associated zoonotic disease risk. 3.Considering animal welfare and in particular mortality rates during transportation as one of the criteria for a ‘positive listing’. Article 4 Par 6 of Council Regulation (EC) No 338/97 states: “In consultation with the countries of origin concerned, in accordance with the regulatory procedure referred to in Article 18 (2) and taking account of any opinion from the Scientific Review Group, the Commission may establish general restrictions, or restrictions relating to certain countries of origin, on the introduction into the Community: (b) of live specimens of species listed in Annex B which have a high mortality rate during shipment or for which it has been established that they are unlikely to survive in captivity for a considerable proportion of their potential life span.“ All live wild vertebrate animals traded in and within the EU should benefit from such protection.
Read full response

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

On behalf of the Born Free Foundation, I welcome the opportunity to provide feedback on the Commission's latest proposals aimed at restricting EU imports, (re)exports, and internal trade in ivory. Born Free has joined with a number of wildlife protection NGOs to produce a joint statement in relation to the Commission's proposals, which is attached. To summarise, Born Free broadly supports the proposed amendments to the Regulation 865/2006 and the draft revised guidance document, particularly the proposal to suspend imports and re-exports both in raw and worked ivory and the proposal to suspend intra-EU trade in raw and post-1947 worked ivory. In addition, we are in favour of the Commission’s proposal to require certificates for intra-EU trade in worked ivory antiques (pre-1947 worked ivory), although we would urge the Commission to restrict such trade to pre-1947 worked items that meet strict criteria specifying the maximum weight and proportion of ivory in such items as detailed in the attached document, which would bring the EU into broad alignment with other jurisdictions. We urge that the proposed exemption for musical instruments be subject to strict regulation and independent oversight, and restricted to items that contain less than 20% of ivory by volume. We also urge the Commission to ensure that hunting trophies containing elephant ivory are treated as raw ivory, and that the import, (re)export and internal trade in them is regulated accordingly. We remain concerned that, apart from the requirement for certificates for internal trade in pre-1947 items, the proposals are for the restrictions to be contained in guidance, and urge the Commission to commit to transposing such guidance into legally binding regulations at the earliest opportunity. Finally, we strongly maintain that a witness statement/affidavit or signed declaration from an applicant for a certificate to trade antique worked ivory should not be accepted as a satisfactory proof of legal acquisition. Declarations in support of legal acquisition/origin should be provided by independent approved/recognised experts only. In summary, we urge the Commission to further revise and strengthen the proposal currently on the table to deliver on the longstanding request of the European Parliament and EU citizens, and respond to the new EU Council Conclusions, asking for the closure of the EU domestic ivory market, through legally binding regulations. Thank you for your consideration.
Read full response

Response to EU 2030 Biodiversity Strategy

20 Jan 2020

Born Free welcomes the opportunity to provide feedback on the EU’s Biodiversity Strategy to 2030. We call upon the European Commission to consider our recommendations in the attached, and look forward to constructively engaging further with the EU in the process leading to the adoption of the post-2020 global biodiversity framework and beyond.
Read full response

Meeting with Sebastien Paquot (Cabinet of Vice-President Karmenu Vella) and Eurogroup for Animals and

22 Nov 2018 · CITES

Meeting with Marco Valletta (Cabinet of Commissioner Vytenis Andriukaitis)

19 Oct 2015 · Animal welfare