In July this year the European Commission circulated a call for stakeholder input on the topic of a proposed tightening of the European Union controls over the import of trophies from animals hunted outside the EU. The proposed change would establish a requirement for import permits to be issued by EU Member States to allow import of these trophies. While this measure would be likely to enable better monitoring of the sustainability of trade, and the tracking of subsequent use of these items, the increase in administration could also create significant costs for conservation and livelihoods through impeding sustainable hunting programs.
The motivation for the proposed change appears to derive in part from science-based concerns regarding the sustainability of trophy hunting in some contexts and countries, and in part from lobbying by anti-hunting groups within the EU. Anti-hunting sentiment certainly appears to be gaining ground in some quarters and is alarming in its indiscriminate nature. For instance, ending all trophy hunting imports to Germany has been reported as an explicit election commitment for the Green Party in the recent elections in Germany, a move that would handicap the operation of an important tool for conservation and livelihoods.
The EU applies a range of "stricter domestic measures" in its implementation of CITES. In particular, for import of those species listed in the EU Wildlife Trade Regulations Annex B (roughly corresponding to Appendix II), the EU requires the issue of an import permit by the importing EU Member State. Generally, under CITES, hunting trophies fall under the "personal effects" exemption, meaning their movement between countries require the usual CITES documentation. The EU already applies certain stricter domestic measures to import of hunting trophies, requiring an export permit to be issued by the country of origin. However, the aim of this measure is to extend the same independent EU assessment of sustainability and legality that the EU extends to import of other Appendix II listed species to hunting trophies.
SULi consulted internally on this proposal and drafted a response that was then circulated to the Chairs of all other SSC Specialist Groups and to the Chair of CEESP. The final response, submitted by Simon Stuart, SSC Chair, and Luc Bas, Director of the European Union Representative Office, makes the following key points:
- While stricter domestic measures are explicitly provided for by the CITES Convention text, they generate considerable controversy, and a program of work on cooperation and promotion of multilateral measures is underway in CITES.
- The proposed measure would enable the EU to extend an additional oversight role over the sustainability of trade in hunting trophies, and enable them to exercise independent scrutiny of the conservation impacts of the associated hunting and the legality of the acquisition of the permit. This could lead to conservation benefits, if any consequent reductions of trophy imports into the EU from unsustainable trophy hunting programmes lead to reduced levels of hunting in range states.
- However, the rationale for the proposed change does not appear to take into account the important role trophy hunting often plays in conservation and sustainable management. Trophy hunting can justify the retention of areas for wildlife (which otherwise would be likely to be used for more intensive income-generating uses), produce revenue for protected area management or community conservation, offset the costs of living with wildlife for rural communities and generate positive attitudes toward wildlife, and/or be employed as a management tool for wildlife populations. Trophy hunting is viable across large areas where tourism is not viable, including areas with little infrastructure, relatively low wildlife densities, and political instability.
- The IUCN SSC Guiding Principles on Trophy Hunting as a Tool for Creating Conservation Incentives were highlighted.
- The proposed measure could have a significant negative impact on the operation and viability of trophy hunting operations and programmes. The practical impact of the measure would presumably be that individual EU hunters would be required to individually apply for and gain an import permit in order to return with the trophy to their homes. (In effect, the hunter would be treated in the same way as a commercial enterprise seeking to trade Annex B listed species.) This process is likely to involve a considerable administrative burden, delay and uncertainty for both hunters and hunting operators, reducing the incentive for hunters to hunt and the economic viability of hunting programmes, and undermining their effective operation. This could have potentially serious negative conservation impacts in range states.
- In some cases trophy hunting also generates significant benefits for rural communities, in terms of both income and the capacity and institutional development associated with community-based natural resource management. While monetary values are often low in global terms but can be highly significant for very poor rural people.
- Scrutiny of the evidence that trophy imports of Annex B-listed taxa into the EU are associated with negative conservation impacts indicates it is equivocal and suggestive of problems limited to a fairly small number of species-country combinations. (This analysis was based on a UNEP-WCMC document that is currently confidential.)
- The limited nature and specificity of these conservation concerns suggests that more targeted and discriminating approaches may be better suited to achieve improvements in sustainability with fewer negative side-effects.
- Interventions to improve the sustainability of trophy hunting, particularly through improvements in governance, are greatly needed in a range of contexts. However, targeted support for monitoring, institutional development or management in those range states may be a more effective approach than import measures, which risk indiscriminately affecting both good and bad practice programmes.
Rosie Cooney is Chair of SULi: email@example.com