In 2021, at least 3.5 million wild animals were imported into the EU and traded within Member States. This trade covers a wide variety of taxa including reptiles, birds and mammals. Whether captured in the wild or bred in captivity, wild animals that are transported retain their innate instincts and characteristics. Physical restraint and transport conditions are therefore highly likely to induce a stress response that can lead to injury and illness, and even mortality risk. 

The specific needs and behavioural motivations of wild animals make transport particularly challenging, calling for species-specific provisions.

In addition to the risks to the animals themselves, the transport of live wild animals represents a risk for public health and safety. Spatially limited and stressed animals may present abnormal behaviours and are more likely to present a danger to those responsible for their handling. Stress and injury also increase the likelihood of pathogen expression and dissemination, and close contact with people during loading, transportation and unloading provides opportunities for spillover of zoonotic disease.

The proposal contains a welcomed clarification of the scope of the Regulation regarding wild animals, confirming its application when transport is undertaken in connection with an economic activity. However, the proposed application of the Regulation is inappropriate and fails to address important segments of wild animal transports in the EU:

• Circuses are businesses that aim to generate profits in a commercial setting. The Regulation should therefore apply to circuses, beyond general requirements.
• Zoos are commercial enterprises fulfilling the criteria of an economic activity. The exclusion of the transport of animals between zoos cannot be justified.
• CITES listed species are excluded from the proposal. Many species from CITES Appendices are transported in the EU in connection to economic activity, including the exotic pet trade. The welfare of these animals should be guaranteed. The transport of such species carries high risks for public health because of zoonotic diseases, and to public safety, as many of these species are dangerous, poisonous or venomous.

We call for the Regulation to empower the European Commission to adopt further rules specific to wild animals’ transport for each species or taxa based on recommendations to be elaborated by the European Food Safety Authority (EFSA).

The adoption of specific requirements for wild animals is an essential prerequisite to ensure minimum welfare standards, optimal sanitary conditions preventing disease spillover and improved safety of transport operators and the general public.