Preventing illegal trade in wildlife – revision of EU action plan

Beastly Business team responds to the European Commission’s public consultation to revise the EU Action Plan against Wildlife Trafficking

The European Commission has recently closed a round of public consultation for revising the EU Action Plan against Wildlife Trafficking. In the EU Biodiversity Strategy for 2030, the Commission committed to revising the Action Plan adopted in 2016, as a contribution to achieving the objectives of the European Green Deal.

Wildlife trafficking is a key threat to biodiversity, yet it is not a priority issue on the political agenda of most EU Member States, despite being among the most lucrative illegal activities worldwide. The European Union is a major player in the illegal wildlife trade as a source, consumer and transit area, however the challenges faced by species native to Europe which are illegally traded have been largely overlooked.

Dr George Iordachescu has collated our responses to the present stage of the public consultation. We welcome the European Commission call for input in the process of revising the EU Action Plan against Wildlife Trafficking and used insights from our research to provide feedback by focusing on the five most pressing, interconnected challenges:

1. Reassess the role of the EU in the global wildlife trafficking

As the role of the EU as source region is reassessed in the future Action Plan, the Commission should also dedicate increased scrutiny to new methods and trafficking routes as these have most probably changed under the recent impact of the COVID-19 pandemic.

2. Acknowledge the green collar crime

In the revised Action Plan, the Commission should aim to widen the focus on organised criminal networks and raise political and societal awareness of the role of legally registered businesses in facilitating wildlife trafficking. In addition, we recommend a precautionary approach to legal trade, as this can also impact biodiversity, notably if scientific data on the conservation status of certain species is missing.

3. Close the loopholes in the legislation

Exemptions from the EU legislation could create porous lines between legal and illegal activities, thus enabling wildlife trafficking, for example, by facilitating the laundering of illegally caught specimens into the legal trade. Because these legal loopholes exist, wildlife crime remains a low risk-high profit activity.  Moreover, as in the case of the Environmental Crime Directive, also under revision, vague definitions create opportunities for the development of grey markets that green-collar offenders can exploit.

4. Enhance cooperation

The revised Action Plan should strengthen the consistent and transparent reporting on prosecution and seizures data to perform adequate monitoring and evaluation. The Commission should particularly complement the efforts of third-party actors (such as NGOs) to facilitate training and capacity-building across the Member States.

5. Dedicate resources and introduce implementation mechanisms

The failure to dedicate appropriate financial resources coupled with the lack of implementation mechanisms were significant shortcomings of the 2016 Action Plan. The Roadmap document places the revision of the Action Plan within the larger frames constituted by the EU Green Deal and the European Biodiversity Strategy 2030. In this context, the Commission should dedicate financial and human resources at the EU level for its implementation, providing at the same time measurable targets doubled by monitoring and evaluation standards.

You can read our complete response to the public consultation here.