September 2012

EUARK Summit Notes

"If a ban was implemented on the importation of live reptiles and amphibians, both wild caught and captive bred, on a scale of 1 - 10 how much impact would this have on you or your business?"

- Opening statement - EUARK summit meeting. September 2012

For most herpers and herp business owners in Europe this might seem a rather alarmist question, but for us here in Britain it resonates strongly. The British reptile industry has been fighting unfair legislation and refuting the claims of animal rights extremists for over fifteen years. During that time we have come to understand our vulnerability and we have come to appreciate how close we have come at times to losing the right to pursue our hobby completely. After much work, the fight in the UK is largely won and our right to keep reptiles is essentially safe from internally generated legislative oppression.

However, since the inception of the European Commission our opponents in the UK have found a new means to attack. Knowing that legislation generated in Brussels will, by default, affect the UK, animal rights groups across Europe are campaigning and lobbying the EU in their endeavour to implement changes. These changes will affect every reptile hobbyist, retailer, trader, importer manufacturer and enthusiast across the whole of Europe. This document aims to communicate the work that has been done n the UK to protect our hobby and to explain the risks now facing reptile keepers and traders in the EU. Finally, it offers a means to protect our interests by using the same model of success that has worked in the UK to address the political issues in Europe.

Much of the content herein is taken from the presentations and comments delivered at the summit meeting called by the European Union Association of Reptile Keepers at Hamm, Germany on September 8th 2012. Extra information and context has been added at the approval of the EUARK board.

British History

The opponents and issues we face today in Europe are largely the same as those we have faced in Britain for the last 15 years. The RSPCA deserves to be mentioned here first as the world's oldest animal welfare organisation, and also one of the wealthiest and largest. Its annual income exceeds £100 million a year and it has resources of over £200 million. Until quite recently the RSPCA had an open declaration for Animal Rights which was removed from their policy document after the Charity Commission threatened to remove their charitable status. The RSPCA openly oppose the sale of animals from pet shops, oppose the trade in wild caught animals and oppose the breeding of captive bred wild animals. The RSPCA also oppose confinement of animals in captivity. In essence, the RSPCA policy opposes all keeping pet, companion and farm animals by means of one or more of their policies. As a business model this broad opposition policy base generates a vast income for the organisation.

But the RSPCA's influence does not end there. The RSPCA acts as the secretariat to a parliamentary group that directly influences and informs British politicians and peers about animal welfare issues. Formed in 1997, the Associate Parliamentary Group for Animal Welfare holds regular meetings and events to provide an opportunity for those with a common interest in animal welfare to meet once each month to debate specific issues. Presentations are made from all stakeholders in the debate before recommendations are given to parliament. Engaging with this group (APGAW) is one of the primary routes used by lobbyist and campaigning groups to directly influence politicians, legislators and law makers. This is where the future of our hobby is debated and decided and so it is no doubt obvious that if our interests are not represented at APGAW, then the views and recommendations of our opponents go unchallenged.

Sometime around 2002, shortly before the commencement of the new British Animal Welfare Bill the RSPCA and other Animal Rights orientated organisations produced several publications calling for a ban on the trade and keeping of reptiles and amphibians. The documents1 appeared very professional and scientific and were seemingly backed by statistics and scientific research. These were circulated to all political parties and stakeholders and were produced for reference and as evidence in several APGAW meetings.

Without representation from our hobby it is highly likely that the RSPCA's recommendations to AGPAW would have been adopted and used to create the backbone of the legislation that would become the Animal Welfare Act. It should be noted that these recommendations sought to ban several species or taxa of animals from private ownership in the UK Thankfully the interests of the reptile hobbyist and pet trade were defended by the Reptile and Exotic Pet Trade Association. Utilising letters and papers produced by advocated, scientists and veterinarians from across Europe, REPTA was able to refute the poorly formulated aspersions cast in the documents produced by the RSPCA. In a statement produced by the EU's own Scientific Review Group, the 'scientific reports' produced by the RSPCA were discredited and subsequently disregarded. The SRG statement read "The outcome of these discussions was that the Scientific Review Group felt unable to accept the conclusions of the RSPCA/Pro-Wildlife report. The SRG felt that the report was based on an incomplete review of the literature, contained inaccuracies and gaps in knowledge.

"The SRG concluded that they had difficulties with the RSPCA's approach and the basis on which they formed conclusions".

Note that many organisations continue to use this document as reference, circulating information from it to legislators and media organisations across Europe. Eurogroup for Animals quoted cited this discredited report as recently as summer 2012.

REPTA now participates in several of the governmental working groups, notably sitting on the group which worked to defines Animal Welfare. In addition to this REPTA has representation in several governmental advisory groups2 meeting to discuss pet vending and also chaired the working group that looked at pet fairs.

The political learning curve has been steep and long and our opponents have extensive experience in campaigning and lobbying for change. Our experience highlights the need to be involved in the political discussions from the very start and to support your argument with credible documentation from respected sources. Communicating with reptile keepers and hobbyists to recruit support and to demonstrate a 'constituency' is important, but, given our limited resources, the opportunity to debate and to influence those who make decisions is absolutely vital. In short, direct stakeholder participation is absolutely the most important tool available to us.

Britain's latest challenge

The fashionably popular legislative issue of recent years has been the focus on non-native species of animals and plants. As we know the migration of plants and animals across the world has been happening for centuries and there are relatively few cases where these species have become invasive and troublesome. Nevertheless, this is now a primary focus for governments and legislators around the world. A popular default position for anti reptile hobbyists is an outright ban on ownership, import, transportation and trade. Many stakeholders and legislators are partial to this solution for several different reasons. In addition to providing a sensationalist platform from which to canvass for votes, the issue also provides the potential for investigative funding by organisations that are often far from impartial. In addition to this there the concern that legislators might opt for a solution that creates the least amount of administration and work by introducing a 'white-list' of species that are legal. Producing a black-list of species that are known to be an issue may be a fairer method, but is a far more labour intensive process.

Formed in 2001, the Non-native Species Secretariat was responsible for coordinating the approach to invasive non-native species in Great Britain and its findings were received by the relevant governments and agencies of England, Scotland and Wales. At the time the UK was the only EU Member State that had a dedicated governmental agency dedicated to Invasive Alien Species and its recommendations included the prohibition in trade and ownership of several herp species including Xenopus and Crested Newts amongst others.

By 2004 the EU had begun investigation into invasive species, whereupon all work in the UK on this subject was shelved. It was clear to all concerned that legislation produced in Europe would supersede any produced in the UK and so our opponents began to shift their focus from London to Brussels.

The New European Threats

Conscious of the legislative shift to the continent, the RSPCA instigated and formed a new organisation called Eurogroup for Animals. Based in Brussels, EGA is a coalition of animal welfare organisations from 40 European countries3 and has represented its members for over 30 years. Its broad goal is to improve the treatment of animals throughout the European Union; from farming, animal testing, skin trade and wildlife stakeholders to all aspects of the pet trade and companion animal interaction. Eurogroup for animals is successful because as a federation they can mobilise millions of citizens who support their affiliate organisation. With so many voices of support their influence is substantial and acts to ensure European, national and local decision makers take note and respond. As one might expect, the apparently laudable public image presented by the EGA's mission statement belies a more radical animal rights policy.

The organisation meets once every month and enables a voice to a small but dedicated minority of animal rights fanatics from across the continent. Indeed, many of the prominent adversaries from Britain are vocal within the EGA. In 2010 the EGA had a budget of 1.5 Million Euros and employed the services of professional lobbyists, scientists and campaigners to present and enhance their case. Currently our hobby has no representation within Europe by which to counter the views of EGA.

For those who have been involved in the political and legislative issues that have occurred in Britain over the last 15 years, this is akin to a bad feeling of déjà-vu.

The EGA currently represents the biggest direct threat to our hobby and their potential for harm should not be underestimated. The group debates and produces recommendations that directly influence decision makers and legislators across Europe - topics such as invasive species, welfare, zoonotic disease and CITES specific issues are debated without any specialist representation, opinion or data from the reptile keeping community being heard. This lack of representation says two things to the legislators of Europe - either that we don't exist or that we don't care.

In the UK our voice is heard and our input is considered through organisations such as the Reptile and Exotic Pet Trade Association (REPTA) and the Federation of British Herpetologists (FBH). REPTA and the FBH are considered to be useful parliamentary tools by providing specialist assistance to stakeholders and decision makers who are otherwise naïve of the issues surrounding reptile keeping and herpetology. In the EU, we currently have no voice and our lack of representation and presence in Europe was summarily highlighted to us just a few weeks ago.

Right Here. Right Now.

Over the last year we have become aware of several documents that have been produced and circulated by animal rights organisations. Funded by the EU commission and usually compiled at the behest of Eurogroup for Animals, these documents have been compiled and written by organisations such as Animal Protection Agency, International Animal Rescue, Eurogroup for Animals and other European animal protection groups. The aim and intent of them is to ban many aspects of reptile keeping entirely and these documents have been circulated to politicians and other stakeholder organisations and individuals across Europe. Many of the personalities involved in authoring these documents are well known to us in the UK and have been active in political lobbying there for decades. Whilst these documents have the appearance of credible scientific studies, much of the content is in fact ridiculous and unsubstantiated.

In addition to the reports written and circulated to the EU, there has also been a significant increase in animal rights media exposure. Reputable publications such as The Biologist and The Veterinary Times have run features written by the same animal rights activists who authored the EU focused reports. Whilst this increase in output had been noted, we were unaware of their primary purpose until now.

Instigated by the EGA, the intergroup for welfare and conservation is currently engaged in collecting data and opinion on several issues that could directly affect our hobby and trade. Bans on import of captive bred and wild caught animals are proposed, using invasive species as reasoning. Reptile shows are also under fire. Other issues such as the risks to public health and conservation are also used to instigate legislation to the detriment of our hobby, despite extensive evidence to the contrary.

Headed by the Federation of European Veterinarians (FVE), sponsored by the Cypriot Government and financially funded by the EU commission, a debate4 is to be held in Brussels to look at these issues. Numerous organisations, experts and prominent players in this field have been invited to speak. However, having viewed the list of speakers invited to present at the meeting we were disturbed to note that the only names that we recognize belong to organisations that are known to oppose us.

More disturbing still was the fact that despite the fact that REPTA and FBH are established stakeholders in this field of study, we had not been invited to be present or even informed of the debate. To all intents and purposes it appears that representation from the reptile hobby had been excluded, perhaps purposefully so. The meeting only came to our attention via an advocate in the USA - a disturbing indictment of our position within Europe. Thankfully, within 12 hours of becoming aware of the meeting EUARK was able to secure a place at the table. We are currently compiling our case based on our experiences of engagement in the UK.

Given the time frame, we realize that we are poorly prepared for this meeting compared with our adversaries. Whilst the documents and media coverage they have produced is deeply flawed, it has the potential to be very damaging when presented to the Eurogroup for Animals. We have just enough time to produce our own document to refute these claims, but we have very limited resources. The volunteers who undertake this work for free on behalf of EUARK have sacrificed months of their time to dedicate to this issue. In addition to this REPTA has incurred substantial expenses in its work to address these European issues. This situation is unsustainable in the long term.

Yet more

Three months ago we became aware of a three year study researching zoonotic disease transmission. The study is funded by the EU commission and is being conducted by the Federation of Veterinarians of Europe (FVE). Entitled CALLISTO5, the study has already reached some conclusions, despite the research being incomplete. It surmises that 60-75% of all human disease comes from contact with an animal. What the study fails to point out is that the animal mostly responsible for transmitting these diseases is in fact the mosquito. However, the study is likely to be used as ammunition in the debate against exotic pets and companion animals. Indeed, the CALLISTO brochure that is available for reference online already paints reptile keeping in a very bad light.

The CALLISTO study is typical of the lobbyist tactics employed by animal right groups and bears many of the hallmarks of the type of hidden agenda politics we are familiar with in the UK. Whilst appearing to be legitimate and impartial, the study is loaded to produce the results that are desired by the organisations behind it and has the added benefit of generating the need for more research funding.

In this case the CALLISTO study has input from several animal rights organisations including Eurogroup for Animals and Pro Wildlife. The FVE is by default geared to look at reptile keeping unfavourably given the experience and professional involvement that most vets are subjected to with regards to reptiles. It is interesting to note here that vets are a surprising choice for a study which is investigating HUMAN health, and one cannot fail to be suspicious of the reasoning behind this. However, as a professional body, the European Commission is likely to accept the findings of the FVE, despite the lack of objectivity and expertise in this field.

Mobilising for Europe

While our hobby and business interests are unrepresented in Europe we risk being subjected to major disruption caused by unfair over-legislation. The political influence of animal rights organisations has already caused damage in Europe and we know that there are several campaigns underway that would have much more significant effects.

It is vital that the legitimate interests of reptile keepers and the pet reptile trade are represented during all debates that could influence legislation in the EU. It would be a grave mistake indeed to gamble and hope that legislators and decision makers are informed enough or considerate enough to produce proportionate and pragmatic regulations. There are sufficient lessons from history where reptile keepers have been subject to unfair, prejudiced and disproportionate legislation. We must act.

EUARK aims to counter the aspersions made by Eurogroup for Animals and other animal rights organisations. The most effective means of achieving this is to be involved in the discussion and debating process from the earliest possible time.

Early intervention in the political process has proven to be enormously beneficial. The RANA project is a three year study, commissioned and funded by the EU commission to study an amphibian virus originating in Rana species. The study purports to investigate Rana virus, to assess its potential for transmission to other amphibian species and highlight conservation concerns. A primary proposition of the RANA project was to ban the importation of amphibians into Europe. By pure chance REPTA and the FBH were alerted to this issue and so managed to commandeer a thirty minute presentation slot at the RANA conference. The result of this intervention was for the chairman of the conference to declare that the animal rights groups should not press the RANA committee for a ban. "You have no evidence to support this!" he stated.

The numbers

As mentioned previously, in the UK, the trade interests of the reptile keeping hobby are secured largely through the work of the Reptile and Exotic Pet Trade Association. REPTA receives funding totaling around £85,000 per year from just four of the large UK reptile trade businesses. This funding is not sufficient to stretch the resources REPTA has to cover the issues that are gathering momentum in Europe.

In order to address the issues in Brussels REPTA estimates that a further £60,000 is required. REPTA cannot and should not seek to influence how the funds are raised.

Footnote

For those who have been involved in the political and legislative issues in the UK it is obvious and likely that without representation in Europe, a ban on reptile keeping will be implemented in Europe. The severity and scope of a ban is debatable, but it is widely accepted that it will have significant economic consequences.

A ban on reptile keeping is far more likely than most people realise. Norway and Sweden both suffered a legislative ban on reptile keeping, with Sweden only becoming exempt following its accession into the EU. Reptile keeping is still illegal in Norway.

Similarly, it is worth remembering that the ban on importation of both wild and captive bred birds was implemented in the UK in a matter of weeks with very little lead up to the event. Although this ban was initially stated as a temporary measure it is widely accepted that a revocation will not occur at any time in the foreseeable future. Campaigning around the topics of human and animal health was the primary focus for legislators and it is this exact rationale that is being used by animal rights groups in their fight to ban reptile imports.

UK is safe, or at least it was until the issue moved to Brussels. Eurogroup for animals is hugely powerful and we need to make our views heard.

"One of the penalties for refusing to participate in politics is that you end up being governed by your inferiors" - Plato

More information can be found on the European Union Association of Reptile Keepers website.

Click here to see the EUARK brochure 2012 »
References
  1. Documents produced by animal rights organisations included:
    • Far From Home
    • Morbidity and Mortality in Private Husbandry in Reptiles
    • Reptiles as Pets
  2. REPTA and/or FBH are represented on these governmental and advisory bodies:
    • Associate Parliamentary Group for Animal Welfare (APGAW)
    • Partnership for Action Against Wildlife Crime (PAW)
    • [CITES] Joint Liaison Group (JLG)
    • Pet Advertising Advisory Group (PAAG)
    • Companion Animal Sector Council (CASC)
    • Sustainable Users Network (SUN)
    • Pet Advisory Committee (PAC)
  3. Humane Society International is a non EU biased member
  4. See attached PDF entitled Import &keeping of exotic animals in Europe - Existing concerns and risks - Current challenges to meet
  5. Read the CALLISTO brochure »
 

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