To Executive Vice-President Frans Timmermans€¦ · We commend the European Commission for developing an EU Action Plan against Wildlife Trafficking, which we believe sets out a

To President Ursula von der Leyen

To Executive Vice-President Frans Timmermans European Green Deal

To Commissioner Virginijus Sinkevičius Environment, Oceans and Fisheries European Commission Rue de la Loi 200 1049 Brussels

Brussels, 12th May 2020 Subject: Closure of domestic ivory markets in the European Union (EU) Dear President von der Leyen, Dear Executive Vice-President Timmermans, Dear Commissioner Sinkevičius, We, the undersigned organisations, urge the European Commission to close the EU domestic ivory market and implement a ban on all ivory imports and (re)exports, without further delays. We are currently living through a difficult period with the COVID-19 pandemic severely impacting our health, wellbeing, and economies. The emergence of infectious diseases like COVID-19, that spread from wildlife to humans, provides a stark demonstration of the dramatic societal and economic costs that can result from the destruction of nature and unchecked commercial trade in wildlife. We welcome announcements that recovery from this crisis will require a rethinking of the EU economic system and a new green transition. Such a transition needs to include a comprehensive EU-wide ban on the import, (re)export, and internal trade in ivory. Elephant populations continue to decline significantly in Africa. Each year, at least 20,000 African elephants are killed illegally for their ivory and only bold action can save this iconic species from becoming extinct in many parts of its range.

The EU Commission has been considering further steps to take with regard to the ivory trade within, to and from the EU for the past few years, but with little progress and no clearly defined process or timeframe. It is now almost three years since DG Environment conducted a public consultation on the issue, which closed in December 2017, resulting in almost 90,000 responses. This was the third highest number of responses ever to an EU public consultation showing the high level of interest EU citizens have in this issue, with 92% of respondents favouring the closure of EU ivory markets. There has been growing political pressure from a wide range of stakeholders on the European Commission to address this issue in recent years. They include: African government members of the Elephant Protection Initiative and the African Elephant Coalition; Members of the European Parliament; several EU Member States; a concerned group of 165 scientists in 33 countries worldwide (including from within 13 EU countries); leading environmental NGOs; companies such as eBay; and religious and faith leaders (see the Annex). All have urged the EU to implement a total ban on the commercial ivory trade, including closure of its domestic market, without further delay. The poaching of African elephants continues at high levels. If the EU does not act now, it may be too late. We very much welcome the European Green Deal, described by President von der Leyen as Europe's ‘man on the moon’ moment when published in December 2019 and which we hope will herald the start of a new era of European decision-making, in which protection of the environment, safeguarding global biodiversity and comprehensively tackling the over-exploitation of wildlife are mainstreamed into political decision-making. As the Commission prepares to adopt the EU Biodiversity Strategy to 2030, so critical to achieving the objectives of the Green Deal, you have an opportunity to demonstrate global leadership by closing the EU ivory market and urging other countries to do the same. Your global leadership on this issue is essential. Yours sincerely, Dr. Janice Weatherley-Singh Director, EU Strategic Relations, WCS EU Mary Rice Executive Director, Environmental Investigation Agency, UK (EIA) Staci McLennan EU Office Director, International Fund for Animal Welfare (IFAW) Dr. Joanna Swabe Senior Director of Public Affairs, Humane Society International/Europe (HSI)

Dr. Mark Jones Head of Policy, Born Free Foundation (BFF) Andrea Hoeppner Chair of the Board, Pro Wildlife Reineke Hameleers CEO, Eurogroup for Animals Georgina Lamb Chief Executive, David Shepherd Wildlife Foundation (DSWF) Vera Weber President and CEO, Fondation Franz Weber (FFW) Herbert Lust Vice-President and Managing Director, Conservation International Europe (CI) Elly Pepper Deputy Director, International Wildlife Conservation, Natural Resources Defense Council (NRDC) Dominic Jermey Director General, Zoological Society of London (ZSL) Copy to: Ms. Margrethe Vestager, Executive Vice-President, [email protected] Ms. Ilze Juhansone, Secretary-General, [email protected] Mr. Daniel Calleja Crespo, Director-General DG Environment, [email protected]

[email protected]

ToPresidentJean-ClaudeJuncker

ToFirstVice-PresidentFransTimmermansBetterRegulation,InterinstitutionalRelations,theRuleofLawandtheCharterofFundamentalRights

ToVice-PresidentJyrkiKatainenJobs,Growth,InvestmentandCompetitivenessEuropeanCommissionRuedelaLoi,2001049,BrusselsBE

6thDecember2018

Ref:TheEUandTheElephantProtectionInitiative

DearPresidentJuncker,DearFirstVice-PresidentTimmermans,DearVice-PresidentKatainen,

OnbehalfoftheElephantProtectionInitiative(EPI)MemberStates,IwritetoregisterourdeepconcernthatthepoachingofelephantsandtheillegaltradeinivorycontinuestothreatenAfricanelephantpopulations.Aswellasthreateningthelong-termsurvivalofanimportantandiconicspecies,thisactivityunderminestheintegrityofecosystems,weakensnationalsecurityandgovernanceanddamagessustainableeconomicdevelopmentinmanyplaces.

Asyouknow,oneofthefourcommitmentsoftheEPI,establishedattheLondonConferenceonIllegalWildlifeTradein2014,istoclosedomesticivorymarkets.Thecontinuedexistenceoflegalivorymarketsaroundtheworldcreatesopportunitiestolaunderillegalivory,includingintheEU,andunderminesinternationalattemptstoendthescourgeofpoachingbyreducingthedemandforivory.

WeverymuchappreciatethepersonalattentionyouhavegiventoaddressingtheissueofwildlifetraffickingandforspearheadingthepublicationoftheEUActionPlanagainstWildlifeTraffickingin2016.WealsoappreciatetheEU’sglobalcommitmentstowildlifeconservationanddeliveryofthesustainabledevelopmentgoals.Wethereforeaskyoutotakestrongactiontoensurethelong-termsurvivalofAfricanelephantsbyintroducingacompletebanonallivoryimportsandexportsto/fromtheEUandbyclosingdowntheEU’sdomesticivorymarket.DecisiveactionbytheEUonthisissuewouldserveasawelcomeresponsetotherecentEUivoryconsultationthatshowedoverwhelmingsupportfromEUcitizenstoclosetheivorymarket,sendastrongsignaltoothercountrieswithivorymarkets,andmakeasignificantdifferencetoglobaleffortstosavethisspecies.

Theworld’slargestivorymarkets,includingtheUnitedStates,China,(includingHongKong),andmostrecently,theUnitedKingdomalreadyhaveorareintheprocessofclosingtheirdomesticivorymarkets,allrecognisingthatlegaldomesticmarketscontributetotheillegaltrade.WethereforeurgetheEUtofollowsuitandsupportthisglobalefforttotackleivorytraffickingandtheelephantpoachingcrisis.

Yourssincerely,

KumaraWakjiraChairoftheEPIImplementationBoardDirectorGeneralofEthiopianWildlifeConservationAuthority

Benedek JÁVOR

Member of the European Parliament

B-1047 rue Wiertz 60 Brussels

[email protected]

ASP 06E258 www.javorbenedek.eu

Commissioner Vella

Environment, Maritime Affairs and Fisheries

European Commission

Berlaymont

Rue de la Loi 200

1000 - Brussels

Brussels, 3 May 2018

On a Proposal for an Ivory Ban

Dear Commissioner Vella,

We are turning to you to draw your attention to the growing concern related to ivory

trading. Since the implementation in EU law of CITES in 2015, the trade in ivory has

somewhat diminished. However, elephant and rhino species continue to be in serious danger,

as the level of poaching remains high. This situation is exacerbated by the fact that

international criminal organisations have found in wildlife trafficking a lucrative business, as

the risk of getting caught and the consequent penalties are relatively low and the economical

return is significantly higher. The shared feeling is that, despite the actions taken in the past,

this still represents a huge concern and that only a tough measure would help eradicating this

practice.

Given these considerations, we feel that the time is ripe for the next step from the

Commission: a proposal on total ban on ivory import/trade. The Parliament has been

advocating for such a ban for a long time, most recently in the resolution on „EU action plan

against wildlife trafficking” voted with a large majority on 24 November 2016. Moreover, the

issue was raised during the last informal ENVI council on the 5th March 2018 and the report

on the outcome of the discussions seems to suggest an a priori openness from the Council

also.

The EU should pave the way for other countries to follow as it did so many times before

and we count on your leadership on this issue.

We are looking forward to working with you on this matter and to promptly ensure the

welfare and conservation of the affected species.

Yours sincerely,

Benedek Jávor and Catherine Bearder

MEPs for Wildlife

http://ec.europa.eu/oib/pdf/34-loi.pdf

Benedek JÁVOR



[email protected]


Co-signatures:

ADINOLFI Isabella (EFDD)

AFFRONTE Marco (Greens/EFA)

ALBIOL GUZMAN Marina (GUE/NGL)

ANDERSON Martina (GUE/NGL)

ANDERSSON Max (Greens/EFA)

ARIMONT Pascal (EPP)

AUSTREVICIUS Petras (ALDE)

BACH Georges (EPP)

BILBAO BARANDICA Izaskun (ALDE)

BOYLAN Lynn (GUE/NGL)

BRANNEN Paul (S&D)

CARTHY Matt (GUE/NGL)

CASA David (EPP)

CASTALDO Fabio Massimo (EFDD)

CHRYSOGONOS Kostas (GUE/NGL)

COUSO PERMUY Javier (GUE/NGL)

CRAMER Michael (Greens/EFA)

CSÁKY Pál (EPP)

DATI Rachida (EPP)

DE MONTE Isabella (S&D)

DURAND Pascal (Greens/EFA)

FLACK John (ECR)

EICKHOUT Bas (Greens/EFA)

ECK Stefan (GUE/NGL)

EPITIDEIOS Georgios (NI)

EVANS Jill (Greens/EFA)

EVI Eleonora (EFDD)

FARIA Jose Inacio (EPP)

FLANAGAN Luke Ming (GUE/NGL)

FOSTER Jacqueline (ECR)

Benedek JÁVOR



[email protected]


FRUNZULICA Doru (S&D)

GERBRANDY Gerben-Jan (ALDE)

GERINGER DE OEDENBERG Lidia Joanna (S&D)

GILL CBE Neena (S&D)

GODDYN Sylvie (ENF)

GRIESBECK Nathalie (ALDE)

GRIFFIN Theresa (S&D)

HÄUSLING Martin (Greens/EFA)

HAZEKAMP Anja (GUE/NGL)

HOWARTH John (S&D)

JAAKONSAARI Liisa (S&D)

JAMES Diane (NI)

JOLY Gro Eva (Greens/EFA)

KADENBACH Karin (S&D)

KONEČNÁ Kateřina (GUE/NGL)

KYENGE Cécile Kashetu (S&D)

KYLLÖNEN Merja (GUE/NGL)

KYRKOS Miltiadis (S&D)

LALONDE Patricia (ALDE)

LEINEN Jo (S&D)

MARCELLESI Florent (Greens/EFA)

MARTIN David (S&D)

MAYER Alex (S&D)

MCCLARKIN Emma (ECR)

MCINTYRE Anthea (ECR)

MICHEL Louis (ALDE)

MIRANDA Ana (Greens/EFA)

MITROFANOVS Miroslavs (Greens/EFA)

MIZZI Marlene (S&D)

MONTEL Sophie (EFDD)

NAGY József (EPP)

NI RIADA Liadh (GUE/NGL)

Benedek JÁVOR



[email protected]


OMARJEE Younous (GUE/NGL)

POC Pavel (S&D)

POSPÍŠIL Jiří (EPP)

POST Soraya (S&D)

PIETIKÄINEN Sirpa (EPP)

PUNSET Carolina (ALDE)

RADEV Emil (EPP)

REIMON Michel (Greens/EFA)

RIES Frédérique (ALDE)

ROCHEFORT Robert (ALDE)

RODRIGUES Liliana (S&D)

RODRÍGUEZ-PIÑERO Inmaculada (S&D)

ROPÉ Bronis (Greens/EFA)

SOLTES Igor (Greens/EFA)

SZANYI Tibor (S&D)

TAMBURRANO Dario (EFDD)

TAYLOR Keith (Greens/EFA)

TRÜPEL Helga (Greens/EFA)

UJHELYI István (S&D)

URTASUN Ernest (Greens/EFA)

VAIDERE Inese (EPP)

VAJGL Ivo (ALDE)

VAN BREMPT Kathleen (S&D)

VANA Monika (Greens/EFA)

VAUTMANS Hilde (ALDE)

WARD Julie (S&D)

WISNIEWSKA Jadwiga (ECR)

ZOANĂ Maria Gabriela (S&D)

Benedek JÁVOR



[email protected]


1

Mr Karmenu Vella

EU Commissioner for Environment, Maritime Affairs and Fisheries

European Commission

Rue de la Loi, 200

1049, Brussels

December 7, 2017

Subject: European Commission’s public consultation on ivory trade in the European Union (EU)

Dear Commissioner Vella,

We are writing as a concerned group of scientists in response to the current EU consultation on ivory

regulations, to urge you to close down the EU’s domestic ivory market.

Over the past 30 years, Africa’s elephant population has fallen from about 1.2 million1 to around

415,400, as reported by the IUCN/SSC African Elephant Specialist Group.2 Scientists overwhelmingly

agree that a primary cause of these worrying declines is the illegal killing of elephants for their ivory.

In September 2016, the IUCN confirmed that “Africa’s overall elephant population has seen the worst

declines in 25 years, mainly due to poaching over the past ten years”. Elephants are iconic, awe-

inspiring animals and perform critical ecological roles in the forests and savannahs they inhabit.3

However, current poaching levels pose a risk to their survival: their numbers are dropping by 8-9%

annually both in the forest and the savannah.4 Unless this poaching trend is halted, African elephants

will continue to disappear across large areas of their range within our lifetime.

We commend the European Commission for developing an EU Action Plan against Wildlife

Trafficking, which we believe sets out a comprehensive blueprint for joined-up efforts to fight wildlife

crime including through further limits on ivory. However in the case of elephant ivory, we consider that

the only solution is for the EU to close its market. Studies of trade in elephant ivory indicate that legal

markets provide a cover for trade in illegal products and undermine enforcement efforts.5 The United

Nations Office on Drugs and Crime (UNODC), for instance, concluded: “the trade in illicit ivory is only

lucrative because there is a parallel licit supply, and ivory can be sold and used openly. Ivory would

lose much of its marketability if buying it were unequivocally an illegal act, or if ownership of these status goods had to be concealed”.6

This link between the legal and illegal trade also exists in the EU – the world's largest exporter of legal

ivory – where traffickers exploit regulatory loopholes in order to misrepresent illegal ivory as legal

ivory.7 Furthermore, most of the ivory seized in the EU in 2016, amounting to more than 2.5 tonnes

and representing the biggest volume seized in recent years, was on its way to Asia – the world’s largest

market for illegal ivory – demonstrating a link between the EU’s illegal ivory trade and international

ivory trafficking.8 The illegal ivory trade is more than a conservation issue: it exacerbates conflict,

corruption, and poverty in countries that are already struggling to defend their economic and national

security. 9 Given the scale of the current elephant poaching crisis across Africa, and the modus

operandi of the trade, the EU must eliminate its parallel legal and illegal markets and the resulting

opportunities for laundering illegal ivory.10

Closing the EU’s domestic ivory market will also send important signals to other consumer countries

and give the EU added credibility when asking other countries to close their own domestic markets.

Thank you for the high level of attention and ambition you have given to tackling wildlife trafficking

and we look forward to further global leadership from the EU on this critical issue.

2

Sincerely,

Katharine Abernethy, Ph.D.

University of Stirling

Stirling, UK

Mark Abrahams, Ph.D.

Bristol Zoological Society

Bristol, UK

Ricardo Antunes, Ph.D.

Wildlife Conservation Society

Glasgow, UK

Mark Auliya, Ph.D.

Helmholtz Centre for Environmental Research

- UFZ

Leipzig, Germany

Lis Bach, Ph.D.

Aarhus University

Aarhus, Danemark

Andrew Balmford, Ph.D.

University Cambridge

Cambridge, UK

Jean-Francois Bastin, Ph.D.

ETH-Zurich

Zurich, Switzerland

Elke Bellefroid, M.Sc.

Botanic Garden Meise

Meise, Belgium

Maíra Benchimol, Ph.D.

Universidade Estadual de Santa Cruz

Ilhéus, Brazil

Elizabeth L. Bennett, Ph.D.


Bronx, NY, USA

Roseline C. Beudels-Jamar de Bolsée, Ph.D.

Royal Belgian Institute of Natural Sciences

Brussels, Belgium

Stephen Blake, Ph.D.

Saint Louis University

St. Louis, MO, USA

Luigi Boitani, Ph.D.

Sapienza University of Rome

Rome, Italy

Iosif Botetzagias, Ph.D.

University of the Aegean

Mytilini, Greece

Robin Brabant, M.Sc.


Brussels, Belgium

Nils Bunnefeld, Ph.D.


Stirling, UK

Colin Chapman, Ph.D.

McGill University

Montreal, Canada

Tara Chapman, Ph.D.


Brussels, Belgium

Nicolas Cichocki, Ph.D. Candidate


- UFZ

Leipzig, Germany

Esther Clarke, Ph.D.

Trunks & Leaves

Newton, MA, USA

Tom Clements, Ph.D.


Cambridge, UK

Lauren Coad, Ph.D.

Center for International Forestry Research

Cambridge, UK

3

Peter Coppolillo, Ph.D.

Working Dogs for Conservation

Bozeman, MT, USA

Mona Court-Picon, Ph.D.


Brussels, Belgium

Andrew A. Cunningham, Ph.D.

Zoological Society of London

London, UK

Joshua H. Daskin, Ph.D.

Yale University

New Haven, CT, USA

Sarah Dawson, Ph.D.

Franklin and Marshall College

Lancaster, PA, USA

Anisha Dayaram, Ph.D.

Leibniz Institute for Zoo and Wildlife Research

Berlin, Germany

Petra De Block, Ph.D.


Meise, Belgium

Charles De Cannière, Ph.D.

Université Libre de Bruxelles

Brussels, Belgium

Shermin de Silva, Ph.D.

Trunks & Leaves Inc

San Diego, CA, USA

Maria del Carmen Fleytas, M.Sc.


Asunción, Paraguay

Pierre Devillers, Ph.D.


Brussels, Belgium

Ilaria Di Silvestre, M.Sc.

Eurogroup for Animals

Brussels, Belgium

Alex Diment, Ph.D.


Yangon, Myanmar

Sarah Durant, Ph.D.

Zoological Society of London; Wildlife

Conservation Society

London, UK

Derek Elsby, Ph.D. Candidate

University of the Highlands and Islands

Thurso, UK

Johan Espunyes, M.Sc.

Universitat Autònoma de Barcelona

Barcelona, Spain

Matthew Evans, Ph.D.

University of Hong Kong

Hong Kong, China

Kate Farr, Ph.D.

University of Wolverhampton

Wolverhampton, UK

Aluane Ferreira, M.Sc.

Universidade Estadual de Santa Cruz

Ilhéus, Brazil

Vicki Fishlock, Ph.D.

Amboseli Trust for Elephants; University of

Stirling

Nairobi, Kenya

German Forero, Ph.D.


Cali, Colombia

Johannes Förster, Ph.D. Candidate


- UFZ

Leipzig, Germany

Martin C. Funes, M.Sc.


Junin de los Andes, Argentina

Louise Gibson, M.Sc.


London, UK

4

Peter Gilbert, Ph.D.


Thurso, UK

Michale Glennon, Ph.D.


Saranac Lake, NY, USA

Kathleen S. Gobush, Ph.D.

University of Washington; Paul G. Allen

Philanthropies

Seattle, WA, USA

Arnaud Goessens, M.Sc.


Brussels, Belgium

Quentin Goffette, M.Sc.


Brussels, Belgium

Elizabeth Greengrass, Ph.D.

Born Free Foundation

Horsham, UK

Oliver Griffin, M.Sc.


Phnom Penh, Cambodia

Kim Gruetzmacher, Ph.D. Candidate

Free University Berlin; Wildlife Conservation

Society

Berlin, Germany

Amy Haigh, Ph.D.

University College Dublin

Dublin, Ireland

Katharina Halbach, M.Sc.


- UFZ

Leipzig, Germany

Rebecca Harris, Ph.D.


- UFZ

Leipzig, Germany

Stephen Harris, D.Sc.

Retired

Bristol, UK

Heidi C. Hauffe, Ph.D.

Fondazione Edmund Mach

Mezzocorona, Italy

Nancy C. Hawkes, Ph.D.

Woodland Park Zoo

Seattle, WA, USA

Klaus Henle, Ph.D.


- UFZ

Leipzig, Germany

Heribert Hofer, Ph.D.


Berlin, Germany

Ilse E. Hoffmann, Ph.D.

University of Vienna

Vienna, Austria

Oliver Höner, Ph.D.


Berlin, Germany

Graziella Iossa, Ph.D.

University of Lincoln

Lincoln, UK

Natalija Ivdra, M.Sc.


- UFZ

Leipzig, Germany

Seth Jackson, M.Sc.


London, UK

Anne Jähkel, M.Sc.


- UFZ

Leipzig, Germany

Devcharan Jathanna, Ph.D.


Bengaluru, India

Kathryn Jeffery, Ph.D.


Stirling, UK

5

Trevor Jones, Ph.D.

Southern Tanzania Elephant Program (STEP)

Iringa, Tanzania

Mark Jones, M.Sc.

Born Free Foundation

Horsham, UK

Alistair S. Jump, Ph.D.


Stirling, UK

Sabine Kleinsteuber, Ph.D.


- UFZ

Leipzig, Germany

David Kneis, Ph.D.

Technische Universitaet Dresden

Dresden, Germany

Marc Kochzius, Ph.D.

Vrije Universiteit Brussel

Brussels, Belgium

Danielle LaBruna, M.A.


Bronx, NY, USA

Chase LaDue, M.Sc.

George Mason University

Fairfax, VA, USA

René-Marie Lafontaine, M.Sc.


Brussels, Belgium

Nicola Largey, Ph.D. Candidate


Thurso, UK

William F. Laurance, Ph.D.

James Cook University

Cairns, Australia

Phyllis C. Lee, Ph.D.

Amboseli Trust for Elephants; University of

Stirling

Stirling, UK

Luc Lens, Ph.D.

Ghent University

Ghent, Belgium

Susan Lieberman, Ph.D.


Washington, D.C. and Bronx, NY, USA

Elizabeth V. Lonsdorf, Ph.D.

Franklin and Marshall College

Lancaster, PA, USA

Jose R. G. López, M.Sc.

Environmental and Water Agency - Regional

Government of Andalucía

Seville, Spain

Oliver Machate, M.Sc.


- UFZ

Leipzig, Germany

Fiona Maisels, Ph.D.


Edinburgh, UK

Ignasi Marco, Ph.D.

Universitat Autònoma de Barcelona

Barcelona, Spain

Jana McPherson, Ph.D.

Calgary Zoological Society

Calgary, Canada

Amelia Meier, Ph.D. Candidate

Duke University

Durham, NC, USA

Dale Miquelle, Ph.D.


Vladivostok, Russia

Antonia Monteiro, Ph.D.

National University of Singapore,

Singapore

Kelle Moreau, M.Sc.


Brussels, Belgium

6

Bethan Morgan, Ph.D.

Zoological Society of San Diego

Edinburgh, UK

Cynthia Moss, Ph.D.

Amboseli Trust for Elephants

Nairobi, Kenya

Elena Motivans, M.Sc.

German Centre for Integrative Biodiversity

Research

Leipzig, Germany

Jochen Mueller, Ph.D.


- UFZ

Leipzig, Germany

Kristin Mühldorfer, Ph.D.


Berlin, Germany

Elizabeth N. Muthiani, Ph.D.

Kenya Agricultural and Livestock Research

Organization

Nairobi, Kenya

Tarun Nair, M.Sc.

Ashoka Trust for Research in Ecology and the

Environment

Bangalore, India

Aaron Nicholas, M.Sc.


Iringa, Tanzania

Ken Norris, Ph.D.


London, UK

Katarzyna Nowak, Ph.D.

University of the Free State

Qwaqwa, South Africa

Matthew Nuttall, M.Sc.


Stirling, UK

Darcy Ogada, Ph.D.

The Peregrine Fund

Nairobi, Kenya

Sébastien Olive, Ph.D.


Brussels, Belgium

Sarah Olson, Ph.D.


Bronx, NY, USA

Lilian Painter, Ph.D.


La Paz, Bolivia

Suzanne Palminteri, Ph.D.

Mongabay

Washington, D.C., USA

Olivier S. G. Pauwels, M.Sc.


Brussels, Belgium

Carlos Peres, Ph.D.

University of East Anglia

Norwich, UK

Guillaume Péron, Ph.D.

Laboratoire de biométrie et biologie

évolutive/CNRS

Villeurbanne, France

Nathalie Pettorelli, Ph.D.


London, UK

Camille Pisani, Ph.D.


Brussels, Belgium

Joyce H. Poole, Ph.D.

ElephantVoices

Sandefjord, Norway

George Powell, Ph.D.

World Wildlife Fund

Washington, D.C., USA

Jennifer B. Pramuk, Ph.D.

Woodland Park Zoo

Seattle, WA, USA

7

Sebastien Puechmaille, Ph.D.

University of Greifswald

Greifswald, Germany

Kristina Raab, Ph.D.


- UFZ

Leipzig, Germany

Marc Reynders, Ph.D.


Meise, Belgium

Vanessa Richardson, Ph.D.

University of East Anglia

Norwich, UK

William J. Ripple, Ph.D.

Oregon State University

Corvallis, OR, USA

Henri Robert, M.Sc.


Brussels, Belgium

Anne-Julie Rochette, M.Sc.


Brussels, Belgium

Dagmar Rosenow, Ph.D.


- UFZ

Leipzig, Germany

Marcus Rowcliffe, Ph.D.


London, UK

Renato Russo, Ph.D. Candidate


- UFZ

Leipzig, Germany

Urmas Saarma, Ph.D.

University of Tartu

Tartu, Estonia

Fernanda Santos, Ph.D. Candidate

Universidade Federal do Pará

Belém, Brazil

Isa Schön, Ph.D.


Brussels, Belgium

Bruce A. Schulte, Ph.D.

Western Kentucky University

Bowling Green, KY, USA

Claudio Sillero, Ph.D.

University of Oxford

Oxford, UK

Scott C. Silver, Ph.D.

Wildlife Conservation Society; Columbia

University

Queens and Manhattan, NY, USA

Eleonore Slabbert, Ph.D. Candidate


- UFZ

Leipzig, Germany

Gontran Sonet, M.Sc.


Brussels, Belgium

Merel B. Soons, Ph.D.

Utrecht University

Utrecht, The Netherlands

Henk P. Sterk, M.Sc.

Environmental Research Institute

Thurso, UK

Mark Taggart, Ph.D.


Thurso, UK

Egle Tammeleht, Ph.D.

University of Tartu

Tartu, Estonia

8

Georg Teutsch, Ph.D.


- UFZ

Leipzig, Germany

Valentine Thiry, Ph.D. Candidate


Brussels, Belgium

Stephanie Thomas, Ph.D.

University of Bayreuth

Bayreuth, Germany

Macarena Toll Riera, Ph.D.

University of Zurich

Zurich, Switzerland

Hendrik Trekels, Ph.D.

Vrije Universiteit Brussel

Brussels, Belgium

Jenny Tschörtner, M.Sc.


- UFZ

Leipzig, Germany

Stefano Vaglio, Ph.D.

University of Wolverhampton; Durham

University

Wolverhampton, UK

Yoo R. Van Bourgonie, M.Sc.


Brussels, Belgium

Josh Van Buskirk, Ph.D.

University of Zurich

Zurich, Switzerland

Marijke van Kuijk, Ph.D.

Utrecht University


Maarten P. M. Vanhove, Ph.D.

Finnish Museum of Natural History, University

of Helsinki

Helsinki, Finland

Erik Verheyen, Ph.D.


Brussels, Belgium

Robert Wallace, Ph.D.


La Paz, Bolivia

Eva Warns-Petit, Ph.D.

Direction Départementale de la Protection des

Populations (DDPP)

Ploufragan, France

Samuel K. Wasser, Ph.D.

University of Washington

Seattle, WA, USA

James Watson, Ph.D.

University of Queensland; Wildlife

Conservation Society

Brisbane, Australia

Janice Weatherley-Singh, Ph.D. Candidate

Wildlife Conservation Society; Wageningen

University & Research

Brussels, Belgium

Renate Wesselingh, Ph.D.

Université catholique de Louvain

Louvain-la-Neuve, Belgium

Nathan Whitmore, M.Sc.


Goroka, Papua New Guinea

Rosie William, Ph.D. Candidate


London, UK

Leslie Wilmet, Ph.D. Candidate


Brussels, Belgium

Steffen Zacharias, Ph.D.


- UFZ

Leipzig, Germany

9

Mashaalah Zarejousheghani, M.Sc.


- UFZ

Leipzig, Germany

Barbara Zennaro, Ph.D. Candidate

University of Bayreuth

Bayreuth, Germany

Joeri Zwerts, Ph.D. Candidate

Utrecht University


1 Douglas-Hamilton, I. (1979). African elephant ivory trade study. Final Report. Unpublished Report, US Fish & Wildlife Service. 2 Thouless, C. R., Dublin, H. T., Blanc, J. J., Skinner, D. P., Daniel, T. E., Taylor, R. D., Maisels, F., Frederick, H. L., and Bouché, P. (2016). African Elephant Status Report 2016. An update from the African Elephant Database. Occasional paper of the IUCN Species Survival Commission No. 60. Gland, Switzerland, IUCN/ SSC African Elephant Specialist group. 3 Poole, J. H., Kahumbu, P., and Whyte, I. (2013). Loxodonta africana Savanna elephant (African bush elephant). The Mammals of Africa Vol I: Introductory Chapters and Afrotheria. Jonathan Kingdon, David Happold, Michael Hoffman et al. London, New Delhi, New York, Sydney, Bloomsbury Publishing, (2013) 351 pp. ISBN 1: 181-194; Turkalo, A., and Barnes, R. (2013). Loxodonta cyclotis Forest elephant. The Mammals of Africa Vol I: Introductory Chapters and Afrotheria. Jonathan Kingdon, David Happold, Michael Hoffman et al. London, New Delhi, New York, Sydney, Bloomsbury Publishing, (2013) 351 pp. ISBN 1: 195-200. 4 CITES (2017). Report on the conservation status of African and Asian elephants, trade in elephant specimens, the African Elephant Action Plan, and MIKE and ETIS, available at https://cites.org/sites/default/files/eng/com/sc/69/E-SC69-51-01.pdf; Maisels, F., et al. (2013). Devastating decline of forest elephants in Central Africa. PloS one, 8(3), e59469., available at http://www.plosone.org/article/info%3Adoi%2F10.1371%2Fjournal.pone.0059469; Strindberg, S., and F. Maisels (2013, March 16). Slaughter of the African Elephants, The New York Times, retrieved from http://www.nytimes.com/2013/03/17/opinion/sunday/slaughter-of-the-african-elephants.html?_r=0. ; Chase, M. J., Schlossberg, S., Griffin, C. R., Bouché, P. J. C., Djene, S. W., Elkan, P. W., Ferreira, S., Grossman, F., Kohi, E. M., Landen, K., Omondi, P., Peltier, A., Selier, S. A. J., and Sutcliffe, R. (2016). Continent-wide survey reveals massive decline in African savannah elephants. PeerJ 4: e2354. 5 Harvey, R. (2015). Preserving the African elephant for future generations. South African Institute of International Affairs, July, available at http://www.saiia.org.za/occasional-papers/862-preserving-the-african-elephant-for-future-generations/file. Lemieux, A. M., and Clarke, R. V. (2009). The international ban on ivory sales and its effects on elephant poaching in Africa. The British Journal of Criminology, 49(4), 451-471, available at http://bjc.oxfordjournals.org/content/49/4/451.full.pdf+html?sid=e62953ae-e11d-468f-b909-c3d818429660. 6 UNODC (2010). The Globalization of Crime: A Transnational Organized Crime Threat Assessment, available at http://www.unodc.org/unodc/en/data-and-analysis/tocta-2010.html. 7 According to WWF’s UK chief adviser on wildlife, Heather Sohl “We have evidence that ivory, which dates from after 1947 is being sold in the UK as antique ivory. It is not always easy to identify modern, post 1947 ivory, and ivory that has been poached on elephants before 1947. Some pieces of ivory are tea-stained to make it look older. They are literally dipped in tea to stain the piece”. A report by the UK House of Commons published on January 30, 2017, states that “illegal ivory items seized by police and the Border Force in the UK have been falsely antiqued, using artificial stains or ageing techniques, clearly destined for the legal antique market”, available at http://researchbriefings.files.parliament.uk/documents/CDP-2017-0034/CDP-2017-0034.pdf (page 18) 8 European Commission (2017). Commission introduces new measures to fight poaching and to end trade in raw ivory, available at http://europa.eu/rapid/press-release_MEMO-17-1307_en.htm.

https://cites.org/sites/default/files/eng/com/sc/69/E-SC69-51-01.pdf

https://cites.org/sites/default/files/eng/com/sc/69/E-SC69-51-01.pdf

http://www.plosone.org/article/info%3Adoi%2F10.1371%2Fjournal.pone.0059469

http://www.nytimes.com/2013/03/17/opinion/sunday/slaughter-of-the-african-elephants.html?_r=0

http://www.saiia.org.za/occasional-papers/862-preserving-the-african-elephant-for-future-generations/file

http://www.saiia.org.za/occasional-papers/862-preserving-the-african-elephant-for-future-generations/file

http://bjc.oxfordjournals.org/content/49/4/451.full.pdf+html?sid=e62953ae-e11d-468f-b909-c3d818429660

http://www.unodc.org/unodc/en/data-and-analysis/tocta-2010.html

http://researchbriefings.files.parliament.uk/documents/CDP-2017-0034/CDP-2017-0034.pdf

http://europa.eu/rapid/press-release_MEMO-17-1307_en.htm

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9 Wyatt, T., Johnson, K., Hunter, L., George, R., & Gunter, R. (2017). Corruption and Wildlife Trafficking: Three Case Studies Involving Asia. Asian Journal of Criminology, 1-21, available at https://link.springer.com/article/10.1007/s11417-017-9255-8; Maguire, T., & Haenlein, C. (2015). An illusion of complicity: terrorism and the illegal ivory trade in East Africa. In London: Royal United Services Institute. Environmental Humanities South, Seminar “Saving the Saviours. Hickey, V. (2013, November 3). The Fight to End Wildlife Crime Is a Fight for Humanity, The World Bank, retrieved from http://blogs.worldbank.org/voices/Fight-to-End-Wildlife-Crime-Is-Fight-for-Humanity. 10 Bennett, E. L. (2015). Legal ivory trade in a corrupt world and its impact on African elephant populations. Conservation Biology, 29(1), 54-60, available at http://onlinelibrary.wiley.com/doi/10.1111/cobi.12377/full.

https://link.springer.com/article/10.1007/s11417-017-9255-8

http://blogs.worldbank.org/voices/Fight-to-End-Wildlife-Crime-Is-Fight-for-Humanity

http://blogs.worldbank.org/voices/Fight-to-End-Wildlife-Crime-Is-Fight-for-Humanity

http://onlinelibrary.wiley.com/doi/10.1111/cobi.12377/full

Hugo-Maria Schally Directorate-General for Environment European Commission 1049 Brussel Belgium

Brussels, 6th February 2019

Subject: European Commission non-paper on elephant ivory trade in the EU and possible additional measures Dear Mr Schally, We, the undersigned organisations, are writing to provide input to the European Commission non-paper on elephant ivory trade in the European Union (EU) and possible additional measures. We thank you for the organisation of a second EU stakeholder meeting on ivory trade in the EU, on Monday 28th January 2019 and for presenting a draft proposal on EU ivory trade. However, we are concerned that the EU response to restricting such trade is inadequate and does not go far enough to address key concerns presented to the Commission as part of the 2017 public consultation. Allowing the sale of ivory reinforces its social acceptability and makes it a desirable product to own or even invest in, further fuelling demand (including in Asia), the illegal market, trafficking, and poaching, and stimulating transnational wildlife crime. Ivory trafficking exacerbates conflict, corruption, and poverty, and thus also weakens local, national and transnational security and governance. We note that most elephant range States have implemented domestic ivory bans and have encouraged all countries to close their ivory markets as well, and that consumer states such as the US, China, France, Luxembourg and the UK have taken strong steps to close their commercial domestic ivory markets. Several other key jurisdictions (including Hong Kong SAR of China, Singapore, Taiwan, and Australia) are in the process of considering or implementing restrictions on domestic ivory trade, highlighting the global shift away from ivory as a commodity. We greatly appreciate the commitment and contributions of the EU and its Member States to the conservation of elephants in the wild, and to ending elephant poaching and ivory trafficking. We welcome the efforts from the European Commission to present a proposal to further restrict ivory markets in the EU. Unfortunately, the new proposals from the European Commission outlined in the non-paper presented at the stakeholder meeting are overly complex, will be difficult to understand and enforce, are inconsistent with stricter domestic measures taken by several Member States, undermine international commitments made by the EU to close its domestic ivory market, and fall well short of the action required by the EU and its Member States to seriously tackle elephant poaching and ivory trafficking. We urge the EU to act in two phases, first, by amending the guidance as soon as possible, second, by making changes to the EU legislation ((EC) No 865/2006).

Supporting information Research focusing on the EU undertaken by INTERPOL1 and TRAFFIC,2 as well as NGOs such as the International Fund for Animal Welfare (IFAW),3 Robin des Bois,4 Save the Elephants, Elephant Action League and Avaaz in collaboration with Oxford University,5 supported by evidence from the UK’s Border Force and observations by WWF,6 has uncovered numerous examples of illegal ivory trade in the last 15 years. In the most recent report published by TRAFFIC, (March 2018), it was found that “based on number of records, the EU plays a role as a re-exporter of illegal ivory”, with 15 of the 28 EU Member States reporting significant seizure records involving elephant ivory and expressing their concerns that newly worked ivory items are being presented as antiques, generally in online platforms, and subsequently re-exported.7 In 2016, the highest volume of specimens of elephant ivory carvings and tusks were seized inside the EU. On raw ivory We believe that a 10-year transition period for phasing out intra-EU commercial trade in raw ivory is far too long; it will undermine the intent of the measure, and pose significant enforcement challenges. We urge the EU to adopt a moratorium on the issuance of certificates for trade in raw ivory as soon as possible. We consider that a maximum transition period of 1 year is more than sufficient and in line with swift changes brought about by EU guidance on ivory and rhino horn in the past and by other large consumer countries such as China. We strongly oppose the proposal’s support for processing new ivory products in the EU by allowing use of raw ivory to produce new ivory items or musical instruments. This raises serious enforcement concerns and would continue to stimulate demand for worked ivory items, as well as enabling laundering of illegal ivory through the legal system. This is a potentially very harmful provision. On worked ivory The EU proposal would not only continue to allow a large amount of worked ivory to be traded within the EU but would also allow exports including to markets in Asia, which poses a significant risk of facilitating laundering of illegal ivory and continued poaching and trafficking. The proposal’s complicated rules for four sets of dates would make enforcement impossible. TRAFFIC's latest report highlights concerns from several Member States that new worked ivory items are being presented as antiques, and reports the seizure of such items advertised online.8 During hearings for the 2018 Ivory Act in the UK, the CITES Management Authority stated that “The UK Border Force has seized multiple ivory items which have been subject to artificial stains or ageing techniques, which are clearly destined for the antique market. Studies have shown that where outlets [are] offering legal and illegal ivory side-by-side, revenue and profits become intermingled and difficult to separate”.9

1 INTERPOL, IFAW (2013) Project Web: An investigation into the ivory trade over the internet within the European Union 2 Lau, W., Crook, V., Musing, L., Guan, J. and Xu, L. (2016) A rapid survey of UK ivory markets. TRAFFIC, Cambridge, UK. 3 IFAW (2012) Killing with keystrokes 2.0: IFAW’s investigation into the European online ivory trade. IFAW (2018) Disrupt: Wildlife Cybercrime: uncovering the scale of online wildlife trade. 4 Examples from On the Trail, the quarterly bulletin with information and analysis on animal poaching and smuggling published by French NGO Robin des Bois, include: Chiswick Auctions in West London was sold a carved ivory authenticated by its experts as dating from before 1947. The ivory was seized by a police unit specialized in art trafficking. Scientific analysis revealed that the ivory came from an elephant killed in the 60s (Bulletin n°6 p. 97, 19 August 2014); The carbon-14 dating of worked ivory seized from eBay vendor proved that the objects came from elephants that were alive in the 1970s (n°14 p. 98, 13 September 13 2016). 5 Avaaz, in collaboration with Oxford University and Elephant Action League (2018) Europe’s deadly ivory trade: Radiocarbon testing illegal ivory in Europe’s domestic antique trade. 6 WWF’s chief adviser on wildlife in the UK, Heather Sohl stated: “We have evidence that ivory, which dates from after 1947 is being sold in the UK as antique ivory. It is not always easy to identify modern, post 1947 ivory, and ivory that has been poached on elephants before 1947. Some pieces of ivory are tea-stained to make it look older. They are literally dipped in tea to stain the piece”. 7 TRAFFIC (2018) Examining options for possible restrictions on ivory trade in and from the EU – Summary of EU Member States responses to the European Commission questionnaire. Prepared for the European Commission. March 2018 (revised January 2019) 8 TRAFFIC (2018) Examining options for possible restrictions on ivory trade in and from the EU – Summary of EU Member States responses to the European Commission questionnaire. Prepared for the European Commission. 9 Defra, Ivory Bill Factsheet – overview, 23 May 2018

Coupled with the absence of specific recording, inspection and enforcement procedures to monitor the movement of ivory, the lack of EU requirements for worked ivory to be accompanied by a certificate of authenticity to be sold as “antique” represents a major loophole to EU rules on ivory trade, poses significant challenges to effective enforcement and must be closed. Way forward We recommend that EU rules be harmonised with the stricter domestic measures that have been developed to date. We recognize that some very limited exemptions may be prudent. We call for a prohibition of all ivory imports into and re-exports from the EU and intra-EU trade for commercial purposes, with ONLY the following limited exemptions:

• Musical instruments made prior to 1975, containing less than 20% ivory by volume, and which should

be accompanied by documentation establishing an uninterrupted chain of custody.

• "De minimis" items made prior to 1947, containing less than 5% ivory by volume.

• Sales to and between officially accredited museums.

We note that the above restrictions would not apply to non-commercial inheritance, transfer, bequest, gifting or donations. These rules would make regulations far less complicated for both the public and enforcement officials. It would also ease the burden on management authorities responsible for implementing the new rules. Drawing from the guidance document (2016/c 15/02) on the export, re-export, import and intra-Union trade of rhinoceros horns, a suspension of exports and intra-EU trade in raw ivory and post-1947 worked ivory can be achieved by amending the existing guidance on ivory with limited exemptions as suggested above. This could be a crucial immediate step with an outlined commitment that legislation will subsequently be adopted. As intra-EU trade of pre-1947 worked ivory is currently possible without a certificate, restriction of trade in pre-1947 ivory will require a change of Commission Regulation 865/2006 as a second step. The burden of proof to demonstrate the age of an item must in all cases rest with the seller in accordance with the precautionary principle, and to reduce unnecessary burden on enforcement officials. As regards the requirement for potential sellers of ivory items to demonstrate reliably, using approved scientific evidence, that an ivory item meets any age-related restrictions, we recommend, in order to ensure conformity, that the EU provides details of approved methods for obtaining such evidence. We submit that isotope analysis (Strontium and Thorium) is currently the only established scientific method that provides precise and unambiguous results10. Conclusion We urge the EU to act in two phases, first, by amending the guidance as soon as possible, second, by making changes to the EU legislation ((EC) No 865/2006). Measures aimed at further restricting the ivory trade within, to and from the EU should focus on achieving:

1. Consistency - EU Member States should all operate on the same basis and those who have already

enacted stricter domestic measures, including France, Luxembourg, the Netherlands and the UK,

should not have to weaken their measures. In other words, harmonization should be upwards.

2. Simplicity - The more complicated the protocols are the less likely they will be implemented effectively.

Anything complicated will create unnecessary difficulties for EU enforcement agencies.

3. Coherence - The EU should operate on the basis of 'best available evidence' which means we need to

listen to and respect the opinions of other stakeholders including wardens, rangers, field operatives,

10 https://www.sciencedirect.com/science/article/pii/S0379073818303360

and the majority of African nations, as well as scientists and experts, who believe there is increasing

evidence linking EU domestic ivory trade with elephant poaching and smuggling.

4. Leadership - Currently the EU lags behind other jurisdictions in banning domestic ivory trade. The

majority of elephant range States are looking to the EU for closure of its domestic ivory markets and

the EU must respond with meaningful and prompt action in line with CITES Resolution Conf. 10.10 (Rev.

CoP17), and WCC-2016-Res-011 on closure of domestic markets for elephant ivory. If the EU wishes to

continue to be seen as a world leader in the promotion of global biodiversity and protection of our

diminishing wildlife, and not risk to be isolated on this issue at the up-coming CITES CoP18, bold action

on its domestic ivory market is urgently required.

Yours faithfully, Janice Weatherley-Singh Director, EU Strategic Relations, WCS EU

Andrea Hoeppner Chair of the Board, Pro Wildlife

Staci McLennan EU Office Director, International Fund for Animal Welfare (IFAW)

Ruud Tombrock Executive Director, Humane Society International/Europe (HSI)

Mark Jones Head of Policy, Born Free Foundation (BFF)

Reineke Hameleers Director, Eurogroup for Animals

Herbert Lust Vice-President and Managing Director, Conservation International Europe (CI)

Myfanwy Griffith Executive Director, European Association of Zoos and Aquaria (EAZA)

Karen Botha Chief Executive, David Shepherd Wildlife Foundation (DSWF)

Mary Rice Executive Director, Environmental Investigation Agency, UK (EIA)

Vera Weber President and CEO, Fondation Franz Weber (FFW)

Will Travers President, Species Survival Network (SSN)

Charlie Mayhew, MBE Chief Executive, Tusk Trust

John Stephenson Chief Executive Officer, Stop Ivory

Andrew Wetzler Managing Director, Nature Program, Natural Resources Defense Council (NRDC)

Katherine Secoy Interim Director of Conservation and Policy, Zoological Society of London (ZSL)

Commissioner for the Environment, Karmenu Vella European Commission Rue de la Loi/Wetstraat 200 1049 Brussels December 7, 2017 Dear Commissioner Vella, As clergy members, faith leaders, and faith-based organisations representing a diverse range of religious traditions, we urge you to promulgate a strict ban on the import, export and inter-EU trade of elephant ivory. We are submitting this letter in response to the public consultation on ivory trade in the EU.

The duty to care for creation is present in religious teachings and sacred texts that span centuries and, in some cases, millennia. As a result, we consider ourselves the guardians of the wondrous diversity of nature that is a key part of God's plan for creation. Elephants are sentient beings with complex social lives and high intelligence. They are an iconic and beloved species synonymous with Africa’s natural wonders and heritage. Elephants are the keystone species to their ecosystems and the keystone to the ecotourism economy, brining hundreds of thousands of visitors from around the world and generating billions of euros in revenues. As people of faith, we hold dear respect and compassion for all beings including wild animals and the communities who live beside them. We are especially concerned about the poaching cruelty against elephants and ivory trafficking challenging the rule of law and the local communities’ social and economic stabilities. Hundreds of thousands of elephants were killed during the last decade. More than a thousand wildlife rangers lost their lives while on duty. Poaching and wildlife trafficking have affected many faith members in the rural communities from Africa to Southeast Asia.

Wildlife trafficking is not solely an Africa or an Asia problem. Every place where ivory is traded plays a part in fuelling ivory consumption and facilitating ivory trafficking. We were disheartened to learn that the EU is among the world’s largest ivory exporters and that the majority of the ivory re-exports from the EU were sent to Hong Kong and China, known as the global hub of the illegal ivory trade. While some people may say that the re-exports from the EU were old and legal items, conservation experts and enforcement officials have lamented that legal ivory markets provide a convenient cover for illicit ivory because of the difficulty to distinguish the two. Any legal ivory trade will perpetuate the market demand for ivory and fuels poaching. Moreover, every piece of ivory comes from a dead elephant, regardless the animal died five years ago or eighty years ago. We do not support a trade built on slaughters of one of the most sentient beings on earth. The EU’s actions come at a critical juncture as China and Hong Kong are amidst of closing their ivory markets. We must not lag behind in the international effort to end the ivory trade. As people of faith, we respectfully urge that the EU stop our complicity in contributing to the illegal ivory trade, once and for all, with a strict ban on the import, export and inter-EU trades of ivory. Sincerely, Catholic Concerns for Animals Catholic Youth Network for Environmental Sustainability in Africa on behalf of eight national chapters The Alliance of Religions and Conservation (ARC), and on behalf of 34 of ARC's African, Asian and European faith partners who in 2013 signed statements calling on their vast communities to stop the illegal wildlife trade. Animal Interfaith Alliance (AIA) on behalf of themselves and their affiliate organizations: The Anglican Society for the Welfare of Animals Bhagvatinandji Education and Health Trust The Christian Vegetarian Association UK The Christian Vegetarian Association US Dharma Voices for Animals The Institute of Jainology Islamic Concern The Jewish Vegetarian Society The Mahavir Trust The Oshwal Association of the UK Quaker Concern for Animals The Sadhu Vaswani Centre Veeravatan: Compassion in Action The Young Jains

Documents

To Executive Vice-President Frans Timmermans€¦ · We commend the European Commission for developing an EU Action Plan against Wildlife Trafficking, which we believe sets out a