1.   INTRODUCTION: THE CITIZENS’ INITIATIVE

EU citizens can ask the European Commission to submit a proposal for legislation on a matter they consider requires legal action for the purpose of implementing the EU Treaties. To do so, they must submit a European citizens’ initiative (ECI) under Article 11(4) of the Treaty on European Union, which requires collecting the signatures of at least one million nationals of a significant number of Member States. Regulation (EU) 2019/788 (1) (the ‘ECI Regulation’) sets out detailed rules on the ECI.

‘Fur Free Europe’  (2) is the tenth ECI to be submitted to the Commission for examination after reaching the thresholds required by the Treaty on European Union and the ECI Regulation. It is also the sixth successful initiative dealing with animals and the fourth successful initiative examined by the Commission in 2023.

The initiative calls on the Commission to take action to prohibit: (i) the keeping and killing of animals for the sole or main purpose of fur production and (ii) the placement of farmed animal fur, and products containing such fur, on the EU market. The organisers list their reasons for an EU-wide ban on fur farming as follows:

(1) Fur farming contravenes even the most basic concept of animal welfare. Behavioural needs of animals farmed for fur cannot be met in fur farms. Neither the five freedoms, nor the five domains, can be met whilst undertaking this activity. (2) The vast majority of animals kept for fur production are still essentially wild animals. They are unsuitable to be intensively kept in caged confinement. When it comes to other animal species, like rabbits and chinchillas, the purpose of keeping animals in small cages and killing them solely or mainly because of the value of their fur cannot be legitimised either. (3) The Commission has announced its intention to phase out caged confinement for species that are farmed for food. Continuing to cage animals for fur production can no longer be justified. (4) A clear majority of EU citizens want to see fur farming banned and, increasingly, more Member States are taking action to eliminate fur production at national level. (5) The co-legislators have expressed their concerns about fur farming. (6) Fur farms pose a risk to animal and human health, as illustrated during the Covid-19 pandemic when hundreds of mink farms were affected by coronavirus outbreaks and new virus variants of SARS-CoV-2 were found to have been transmitted to humans. (7) Fur farming has a significant environmental impact and it poses a serious threat to native biodiversity. (8) A marked divergence between national laws with respect to the fur production sector has led to a distortion in the Union’s internal market, and the only justifiable solution is now to impose an outright ban. (9) The marketing of farmed fur and products containing such fur should not be allowed in the EU.

Following the organisers’ request on 25 January 2022, the Commission registered the initiative (3) on 16 March 2022. On 14 June 2023, after verification of the statements of support by the Member State authorities, the organisers submitted the initiative to the Commission.

The organisers detailed the objectives of the initiative in a meeting with the Commission on 20 July 2023, as well as during the hearing organised in the European Parliament on 12 October 2023  (4). In those meetings, the organisers’ presentations focused on mink, foxes, racoon dogs and chinchillas and highlighted that rabbits are covered by the ‘End the Cage Age’  (5) ECI. Currently no other animal species is bred for the sole or main purpose of fur production in the Union. Concerning the discussion on risks for animal and human health, the organisers also referred to recent Avian influenza cases in fur farms in the EU.

Furthermore, the European Economic and Social Committee (EESC) hosted a debate on the initiative on 20 September 2023  (6) and the European Parliament held a plenary debate on 19 October 2023  (7).

This Communication sets out the Commission’s legal and political conclusions on the initiative and any action it intends to take in response to the initiative and the envisaged timelines in accordance with Article 15(2) of the ECI Regulation.

2.   CONTEXT

Under Article 13 of the Treaty on the Functioning of the European Union (TFEU) (8) and because animals are sentient beings, in formulating and implementing the EU’s policies in agriculture, fisheries, transport, internal market, research and technological development, the EU and its Member States must pay full regard to the welfare requirements of animals while respecting the legislative or administrative provisions and customs of the Member States relating in particular to religious rites, cultural traditions and regional heritage. The Treaty also provides in Article 114 that the Union’s policy on the internal market must ensure a high level of human health and environmental protection.

Articles 168 and 191 TFEU provide the legal basis for the Union’s policies in matters of protection of health and the environment and also require a high level of protection, which in relation to the environment and under Article 11 TFEU must be integrated into the definition and implementation of the Union’s policies and activities.

Regulation (EU) 2022/2371 (9) includes provisions for ensuring prevention, preparedness and response to epidemics and pandemics, including those caused by zoonotic diseases affecting the EU via strengthening surveillance and early warning and incorporating ‘One health’ into health policies.

2.1.   Historical background

2.1.1.   Council of Europe recommendations on the welfare of fur animals

In March 1976, the Member States of the Council of Europe adopted the European Convention for the Protection of Animals kept for Farming Purposes (10).

In June 1999, the Standing Committee of the European Convention for the Protection of Animals kept for Farming Purposes (Council of Europe) adopted recommendations (11) concerning fur animals. The EU ratified the Council of Europe Convention on the protection of animals kept for farming purposes, based on Council Decision 78/923/EEC (12), therefore both the Convention and any recommendations adopted under it are part of the Union legal order.

The recommendations provide minimum requirements regarding stockmanship and inspection of fur animals, including enclosures, housing and equipment, management, changes of phenotype and/or genotype, killing, research and other supplementary provisions.

The special provisions for the most farmed species include recommendations on the minimum space but also the recommendation to further improve the housing system to minimise the risk of diseases and injuries and provide a stimulating environment enabling animals to fulfil their biological needs, as deduced from studies of the animals in nature and in farm conditions.

The recommendation also acknowledged that, at the time, there was insufficient scientific evidence available on the welfare requirements of fur animals, for detailed provisions for the implementation of all principles set out in Chapter I of the Convention for the protection of animals kept for farming purposes.

2.1.2.   Industry voluntary certification scheme – WelFur

To assess the welfare of fur animals under the existing rearing conditions, a voluntary set of welfare standards for fur farmed animals (WelFur), has been developed by the industry based on the Welfare Quality research project financed by the European Commission. The Welfare Quality project is using science to create a system to assess the level of animal welfare on farms. Based on this, the industry developed a system which does not assess welfare in absolute terms, it provides a methodology to rank farms within the current practice.

The WelFur programme (13) serves as a private certification scheme, for farms breeding mink, silver and blue foxes, and Finnracoon. The latest one, for the Finnracoon, was published in 2019. Farms that are not WelFur certified are unable to sell their skins through the international fur auction houses. The farm level certification scheme (14) incorporates 22 measurements, 4 principles (housing, feeding, health and appropriate behaviour) and is further divided into 12 welfare criteria (15) and 1 overall assessment.

According to industry, from 2017 to the 1st period in 2023, there have been 14 913 farm assessments, with the associated relevant data collected.

The industry indicates that WelFur also serves as a voluntary labelling scheme for consumers allowing them to know if the fur comes from certified European fur farms (16).

Animal welfare NGOs do not consider WelFur as an efficient system to assess the welfare of each individual animal and presented their views in the report ‘Certified cruel. Why WelFur fails to stop the suffering of animals on fur farms’  (17). They highlight in particular that WelFur is designed around the current cage-systems and does not require access to water for mink, or sides for digging for foxes, thus not addressing the natural behavioural needs of those animals.

2.1.3.   2001 Scientific opinion on the welfare of animals kept for fur production

In 2001, the European Commission Scientific Committee on Animal Health and Welfare adopted a report on ‘The welfare of animals kept for fur production’  (18), dealing with the welfare of certain species used for fur production.

The report focused on the scientific assessment of the welfare of animals kept for fur production and states that the husbandry systems, used at the time of the assessment, caused serious problems for all species of animals reared for fur and encouraged corrective measures and efforts to redesign housing systems which fulfil the needs of these animals.

The report states that cages and management practices and methods used for farming mink and foxes should be greatly improved to provide sufficient environmental complexity, to stimulate normal behaviours, such as play and exploration.

2.2.   Current EU policy context

2.2.1.   Current EU legal framework for fur animals

There is currently no specific EU animal welfare legislation covering animals kept for fur production. General minimum requirements for the protection of animals kept for farming purposes are laid down in Council Directive 98/58/EC (19) of 20 July 1998 concerning the protection of animals kept for farming purposes, which includes animals kept for fur production. It provides protection through general principles.

In accordance with the provisions of that Directive, animals have to be adequately cared for, their freedom of movement must not be restricted in such a way as to cause unnecessary suffering or injury and confined animals must be given the space appropriate to their physiological and ethological needs, in accordance with established experience and scientific knowledge. The Directive also provides general requirements on the feeding and watering, housing conditions, inspections, veterinarian, and other treatment when necessary, and breeding procedures. Those rules are based on the European Convention for the Protection of Animals kept for Farming Purposes (20).

2.2.2.   Current EU policy context: Green Deal and Farm to Fork Strategy

On 20 May 2020, the European Commission adopted the Farm to Fork Strategy as part of the European Green Deal, addressing comprehensively the challenges of sustainable food systems and recognising the inextricable links between healthy people, healthy societies, and a healthy planet. The Strategy highlighted that ensuring better animal welfare improves animal health and food quality, can help preserve biodiversity, contributes to the fight against antimicrobial resistance and prevent zoonoses from spreading or emerging.

The Strategy announced the Commission’s intention to revise the EU animal welfare legislation to align it with the latest scientific evidence, broaden its scope, make it easier to enforce, and ultimately increase the level of animal welfare. The Commission also announced that it would explore options on regulating animal welfare labelling.

As a first step of this revision, an evaluation of the existing animal welfare legislation (‘Fitness Check’) was published in October 2022 (21). The results of the fitness check of the animal welfare legislation, show that, despite the progress made, there is a need to address in the future rules the increasing societal expectations, ethical concerns, scientific and technological developments, and future sustainability challenges.

The results of numerous public consultations, Eurobarometers and other surveys, and the number of successful ECIs in this field, show that citizens expect a better protection of farmed animals. According to the Eurobarometer survey (22) published on 19 October by the European Commission, a large majority of Europeans (84 %) believe that the welfare of farmed animals should be better protected in their country than it is now. On fur farming, over half of those surveyed (57 %) consider that it should be strictly banned in the EU, while close to a third (32 %) think it should only be maintained under improved welfare conditions.

The Commission is currently working on the revision of the existing animal welfare rules. As a first step, the Commission publishes, at the same time as this Communication, a proposal to revise the EU rules on the welfare of animals during transport and a proposal for new rules on the welfare of cats and dogs. In addition, the Commission is planning a strategic dialogue on the future of agriculture to stimulate a discussion on food systems as such, and to inform future work on animal welfare and sustainability at large.

2.2.3.   One Health dimension and policy response

As cornerstone of the preventive measures, biosecurity is a key factor for fur animal farms to prevent diseases, including infections with Covid-19 (SARS-CoV-2) and highly pathogenic avian influenza (HPAI) viruses. The risk for spill-over of zoonotic pathogens at the animal-human interface is always present, in the nature, in a household, or in the farming system. Farmed animals are kept under supervision, control and biosecurity conditions minimising such risk.

The EU Member States, the European Commission, together with key agencies like the European Centre for Disease Prevention and Control (ECDC) and the European Food Safety Authority (EFSA), are ensuring constant surveillance, fostering early warning, preparedness, and response for zoonotic threats. EU legislation in public health and in animal health has well established structures, mechanisms and response capacities, including upgrading the rapid availability of medical countermeasures, to react to any major outbreak.

For the risk represented by SARS-CoV-2 virus in fur farms, several assessments by EFSA and ECDC were carried out (23). The latest EFSA/ECDC assessment (24) concludes that the introduction of the virus into fur farms is usually via infected humans and this can be controlled by systematically testing people entering farms and applying adequate biosecurity, for example appropriate use of non-pharmaceutical interventions (e.g. personal protective equipment) by humans accessing mink farms.

The genomic analysis of SARS-CoV-2 showed mink-specific clusters with a potential to spill back into the human population. In the current epidemiological situation in the EU, where a substantial decrease of outbreaks in mink farms has been reported and where the majority of the human population has acquired some level of immunity to SARS-CoV-2, the risk for the general population represented by infected mink is considered very low to low.

Also, over the last year, due to a wide geographical area where highly pathogenic avian influenza (HPAI) virus has been circulating in wild birds, infections in wild and kept mammals were more frequently reported, including in several fur farms (25). Protection (26) of farmed mammals from wild birds (especially seabirds and migrating waterfowl) should be prioritised.

Reports (27), with the results of the joint assessments by EFSA, ECDC and Reference Laboratory of the European Union (EURL), of the epidemiological situation with Avian Influenza in Europe and worldwide, including in mammals, are published at least every three months. According to these joint assessments, the risk of infection of humans with avian influenza viruses of the currently circulating clade 2.3.4.4b A(H5) virus in Europe for the general public in EU/EEA countries remains low and low to moderate for occupationally or otherwise exposed groups to avian influenza infected animals (e.g. farm workers in contact with infected animals). The sequencing analyses of avian influenza viruses isolated from some of the fur farms suggest a possible transmission between mammals in the affected fur farms. Fur animal farms where these viruses can circulate could represent a setting for virus reassortment, in particular during autumn and winter seasons when also human influenza viruses circulate in parallel.

This makes it necessary to address the situation, through a One Health approach. The European Commission services have thus convened several meetings of the Health Security Committee (HSC) and joint meetings with the EU Chief Veterinary Officers (CVO), to ensure constant monitoring and readiness for rapid response.

The HSC is working on a position statement on HPAI with suggested actions to be considered by Member States to foster collaboration between Public Health and Veterinary authorities under the One Health umbrella.

2.2.4.   EU policies on invasive alien species

Invasive alien species (IAS) are animals (and plants) that are introduced accidentally or deliberately by human action into a natural environment where they are not normally found. They are a major threat to native animals (and plants) in Europe and one of the major causes of biodiversity loss. The Invasive Alien Species Regulation (Regulation (EU) 1143/201423) (28) (IAS Regulation) includes a set of measures to be taken across the EU in relation to invasive alien species and a list of IAS of Union concern. Species listed are considered to have a negative impact on biodiversity, are selected based on a risk-assessment process and are subject to restrictions on keeping, importing, selling, breeding, growing and releasing into the environment.

For two species commonly used in fur farming, risk assessments were undertaken under the IAS Regulation. These are the Raccoon dog (Nyctereutes procyonoides) and the American mink (Neovison vison). Both species have a negative impact on biodiversity. The Raccoon dog has been listed and this species is subject to the restrictions mentioned above, including a ban on trade in live specimens, although authorisations to continue fur farming for this species have been granted to Finland and Poland. This means that a limited number of facilities are allowed to continue farming it, provided they respect measures that limit the risks for the environment.

2.2.5.   EU textile policies in relation to fur products

While real fur is almost entirely employed in apparel and clothing accessories products, current EU legislation on labelling of fur in apparel (and related) products is largely limited to a single provision of the Textile Labelling Regulation (29). Crucially, this provision requires a mere reference to the presence of ‘non-textile parts of animal products’ (which can, of course, be either real fur or any other non-textile animal product such as leather, feathers, bone, etc.) and it does not apply to products containing 20 % or more of fur by weight.

In view of this, alongside other policy concerns such as the wider environmental impact of textile and related products beyond animal welfare, proper consumer information and the integrity of the internal market, in August 2023 the Commission launched a review of the Textile Labelling Regulation (30). Among other objectives, the review aims to explore the possibility of an accurate and more detailed labelling of the presence of real fur in all apparel and certain related products, notably clothing accessories. Several industry and environmental protection stakeholders alike have already called for and supported such a label, even if with different views concerning its details. In the context of the Call for Evidence (31) to revise EU rules on textile labelling, almost one quarter (32) of all feedback supported detailed, harmonised and at times even mandatory labelling of real fur, with no feedback voicing opposition to labelling real fur in textile and related products.

2.2.6.   EU trade policy context

In its ‘Trade policy review – an open, sustainable and assertive trade policy’  (33), adopted on 18 February 2021, the Commission stressed that imports must comply with relevant EU regulation and standards, and that, under certain circumstances determined by World Trade Organization (WTO) rules, it is appropriate for the EU to require that imported products comply with certain production requirements. The legitimacy of applying production requirements to imports may be based on the need to protect the environment or to respond to ethical concerns. Where this approach is taken, it must be done in full respect of WTO rules, notably the principle of non-discrimination and proportionality, aiming at avoiding unnecessary disruption of trade. It is also possible to promote higher animal welfare standards in the framework of bilateral trade agreements.

The Report from the Commission of June 2022 on the ‘Application of EU health and environmental standards to imported agricultural and agri-food products’  (34) recognised that there is indeed policy space for the EU to pursue the application of health and environmental and ethical concerns (including animal welfare) requirements on process and production methods to imported products in a WTO compatible manner. At the same time, the Report showed that before applying such production standards to imports, it is always essential to make a case-by-case assessment and carefully analyse each case on its own merits.

2.3.   Analysis of current situation in relation to internal market and trade

2.3.1.   Farm production in EU Member States and national measures and positions

In 2023, according to data from the European fur industry, there were approximately 1 088 active fur farms in the EU for mink, fox and Finnracoon, with approximately 7,7 million animals distributed as follows:

Table 1

Number of farms in the EU by Member State and by species

Country	Mink farms 2023	Mink prod. 2022	Fox farms 2023	Fox prod. 2022	Finnracoon farms 2023	Finnracoons prod. 2022
Bulgaria	1	90 000
Denmark	4	—
Spain	28	450 000
Finland	157	500 000	365	700 000	60	70 000
Greece	91	1 400 000
Lithuania	88	1 160 000
Latvia	4	360 000
Poland	234	3 400 000	35	30 000
Romania	2	207 601
Sweden	19	200 000
	628	7 767 601	400	730 000	60	70 000
Farms in total	1 088
Source: Fur Europe and Member States’ data.

The figures indicated in Table 1 for mink production currently located in Latvia and Lithuania will be adjusted as of 2027/2028, as production will cease due to the national bans. As regards chinchillas, the EU produces around 220 000 skins yearly (35). There is no accurate data for all Member States. In 2023, in Estonia, there were 231 chinchillas in 4 farms however, the production of fur will be prohibited in that Member State from 1 January 2025. In Romania, there were in 2023 7 chinchilla farms, with 7 514 animals. Spain has 3 chinchilla farms. Other countries keeping chinchillas are Denmark, Hungary, Lithuania, Poland.

17 Member States have adopted bans or partial bans on fur farming (with different scopes and date of application):

Table 2

National bans in EU Member States

	EU Member State	Adoption of the ban	Scope of the ban	Entry into force of the ban
1	Austria	2005	All fur farms	2005
2	Belgium (Flanders) Belgium (Wallonia) Belgium (Brussels)	2019 2015 2016	All fur farms	2023 2015 2016
3	Czechia	2017	All fur farms	2019
4	Croatia	2007	All fur farms	2017
5	Denmark	2009	Foxes	2009 with a transitional period until 2023
6	Estonia	2021	All fur farms	2025
7	France	2021	American mink and of other non-domestic species exclusively for fur production. It does not cover chinchillas and rabbits	2021
8	Ireland	2022	All fur farms	2022
9	Italy	2021	All fur farms	2022
10	Latvia	2022	All fur farms	2028
11	Lithuania	2023	All fur farms	2027
12	Luxembourg	2016	All fur farms	2018
13	Hungary	2020	Mink, foxes, polecat and coypu, but not chinchilla or angora rabbits	2020
14	Malta	2022	All fur farms	2022
15	Netherlands	2013	All fur farms	2021 (date of entry into force brought forward from 2024 to 8 January 2021 at the end of 2020)
16	Slovenia	2013	All fur farms	2015
17	Slovakia	2021	All fur farms	2025

In addition, the situation in the remaining Member States can be summarised as follows:

Table 3

State of play  (36) in Member States without a ban on fur farming

1	Bulgaria	Proposals for banning fur farming are currently under parliamentary debate.
2	Denmark	Denmark had suspended the farming of mink in late 2020 due to the Covid-19 pandemic but decided not to prolong the ban beyond 1 January 2023. Prior to 2020, Denmark was the first world producer of mink fur.
3	Germany	Germany adopted in 2017 new requirements for fur farming aiming at improving animal welfare, which led in practice to the phasing out of activities due to costs outweighing profits.
4	Greece	No ongoing parliamentary debate on a possible ban on fur farming.
5	Spain	American mink is considered as an invasive alien species therefore, since 2013, new farms can only be authorised if preventive measures have been taken. Also, a Strategic Plan of 2022 foresees measures to be taken to close the farms of American vison by 2030, including financial support for reconversion.
6	Cyprus	There is no fur farming in Cyprus.
7	Poland	No ongoing parliamentary debate on a possible ban on fur farming.
8	Portugal	There is no fur farming in Portugal.
9	Romania	Proposals for banning fur farming are under parliamentary debate.
10	Finland	No ongoing parliamentary debate on a possible ban on fur farming. Debates occur in the society.
11	Sweden	The Government has put forward a proposal to financially support mink farmers who voluntarily discontinue their business during 2024-2025, whilst simultaneously initiating a review of the animal welfare legislation to investigate whether fur farming should be banned.

In summary, once the Lithuanian national ban on fur farming enters into force in 2027, Finland, Poland and Greece will be the Member States with the most important production and no debate ongoing or decision on a possible ban on fur farming.

The position of Member States on a possible ban on fur farming was expressed at the occasion of two meetings of the Agriculture and Fisheries Council, on 28 June 2021 and on 26 June 2023. In 2021, 12 Member States (37) supported an EU ban on fur farming. In 2023, 17 Member States (38) supported the idea of a ban on fur farming in the EU, while Greece, Finland, Poland and Denmark spoke against such a ban.

Among those Member States supporting a ban, several highlighted the need for a European approach as national bans can lead to a transfer of production to other Member States. Diverging views were expressed as regards the need to introduce an EU ban on the marketing of fur and fur products into the EU, in order to avoid that an EU ban leads to a transfer of production outside the EU. Diverging views were also expressed on the extent to which fur farming should be banned based on the zoonotic risk associated with this activity. Several Member States were in favour of excluding certain species from a possible EU ban, such as rabbits and chinchillas. Several Member States asked for sufficient transition periods.

Among the four Member States opposing an EU ban, two asked for consideration of the economic impact and argued that fur farming is a key agricultural production in some areas bringing income to rural communities; and the other two Member States considered that a ban would be disproportionate and that the production could be done with science-based animal welfare standards without the need of a ban.

2.3.2.   Economic and social dimensions of fur farming, manufacturing and retail of fur apparel in the EU

Fur production occurs in 11 EU Member States (in a few years, only 8 Member States once Latvian, Lithuanian and Estonian bans enter into force) and impacts the welfare of approximately 8,6 million animals. Fur farms are owned by SMEs, most of them micro and small enterprises. The fur industry is comprised of a wide array of economic operators, including farmers, trappers, dressers, manufacturers, brokers, auction houses, retailers and designers.

The value of EU fur production can be summarised as follows:

Table 4

Value of EU production by fur species

Species	Pre-Covid 19-20	Worst Covid impact 21-22	After Covid 22-23
Mink	357 600 000 EUR	208 250 000 EUR	297 000 000 EUR
Fox	167 700 000 EUR	104 200 000 EUR	43 800 000 EUR
Finnraccoon	7 644 000 EUR	3 744 000 EUR	4 550 000 EUR
Total	532 944 000 EUR	316 194 000 EUR	345 350 000 EUR
Source: Fur Europe, value obtained by multiplying the EU skin production by the average price on the international market in those seasons.

Until Covid-19 and the closure of mink farms by the Netherlands and Denmark, the EU was the largest world producer of fur. Denmark was the largest mink producer in the world, producing around 12,5 million pelts in 2019, i.e. 23 % out of a total of 56 million worldwide (for most of the previous decade, Denmark shared the top spot with China). In 2021, China became the largest producer of mink, foxes and raccoon dogs, producing 6,87 million mink pelts. However, it is difficult to predict how the situation will evolve in the coming years.

The total value of EU market sales, registered by the manufacture of farmed fur apparel, reached EUR 540 million before the Covid-19 crisis, with an export value of around EUR 400 million in 2019. The latest available figure revealed a significant downturn in the EU27 turnover in 2020 (to EUR 260 million in total and almost EUR 230 million in exports) (39) due to the pandemic. Industry estimates a potential recovery of EU production to around Chinese levels in the coming years.

In theory, a ban on the marketing of farmed fur and fur products would lead to a replacement by artificial fur. However, according to the fur industry, real and artificial fur are two different products, occupying two different markets which do not necessarily compete against each other. While real fur occupies a niche market in the wider apparel ecosystem, it generates a proportionally high return in value. Real fur is mostly used by companies producing high-end fashion products, both global-reaching brands and smaller maisons, a segment in which the EU excels and dominates globally. On the contrary, artificial fur is mostly used for cheap garments and accessories used in fast fashion.

While a number of luxury and non-luxury brands have recently stopped using farmed fur (40), the turnover linked to fur apparel should not be underestimated. One study (41) available on an industry stakeholder website, not peer reviewed, estimates that the European fur retail value (value of fur trade at retail level, i.e. of fur coats, accessories, etc.) was around USD 4,8 billion in 2020, which is below the trend level (estimated at USD 6 billion) due to the impact of the Covid-19 measures (closing mink farms in some Member States).

The number of full-time jobs is estimated to be 10 per farm (42) and in some regions the processing industry is directly linked to the mink farms. No estimate of the number of jobs that are dependent on the production and marketing of fur apparel have been found at this point. Fur production brings tax revenues for States and municipalities. For example, for Finland, according to the Finnish Fur Breeders’ Association, in 2021, taxes and contributions from the fur industry to the Finnish State and municipalities amounted to EUR 87 million. Fur farm jobs are primarily located in rural areas, where job opportunities are more limited.

In many cases, those Member States that have introduced national bans have compensated farmers impacted by these bans.

2.3.3.   Trade in fur and fur products

The EU has a considerable trade surplus in fur and fur products. While most of the surplus comes from the sale of raw skins, the EU also has a surplus in fur apparel.

The EU exports value for fur products (43) in 2022 was around EUR 3,5 billion. The top 10 EU export destinations in 2018 to 2022 were China (17 % of the EU exports), the United States (8 %), Hong Kong (6 %), Viet Nam (6 %), Cambodia (6 %), Thailand (4 %), the United Kingdom (5 %), Tunisia (4 %), Serbia (4 %) and South Korea (4 %).

The EU imports of fur products from third countries were lower than exports in value and corresponded to EUR 2,7 billion in 2022. The 10 largest importers to the EU in 2018 to 2022 were Brazil (13 % of the EU imports), the United States (11 %), China (7 %), the United Kingdom (7 %), Türkiye (5 %), India (5 %), Argentina (4 %), South Africa (3 %), Nigeria (3 %) and New Zealand (3 %).

3.   RESPONSE TO THE EUROPEAN CITIZENS’ INITIATIVE

3.1.   Response to the initiative: actions and timelines

In recent years, a number of studies were published relating to animals kept for fur production, such as studies on the behavioural effects of integration of enrichment objects in mink cages (e.g. Hansen et al (44)., 2007; Meagher and Mason (45), 2012) and in fox cages (Korhonen et al (46)., 2003; Koistinen et al (47)., 2009). However, there is still no broad scientific consensus on important aspects regarding their keeping and the impact on welfare. There is also no consensus yet on whether it is feasible to achieve minimum conditions needed in fur farms to ensure the welfare of those animals, and if so on what those conditions would be.

Opportunities for mimicking natural conditions (fulfil natural behaviour) and the effect on the welfare of these animals are investigated and, at least so far, lead to inconclusive discussions and diverging views. For example, there are divergent views on whether water for swimming should be provided to mink, or the extent to which swimming is an essential behaviour for mink.

Thus, an updated scientific assessment is currently missing to conclude on whether fur animals can be farmed under conditions that ensure a sufficient level of animal welfare.

Therefore, in response to this citizens’ initiative, the European Commission, on 5 December 2023, sent a mandate to EFSA requesting an updated scientific opinion on the welfare of fur animals. The mandate requests EFSA to give an independent view on the protection of animals kept for fur production (mink, foxes, racoon dogs and chinchillas). Under this mandate, EFSA is requested to:

(a)	provide an update of the literature review on the welfare of animals kept for fur production;

(b)	provide a review of the most common husbandry system(s) and current practices or other field-tested systems for keeping animals for fur production for mink, foxes, racoon dogs and chinchillas;

(c)	identify the most relevant welfare consequences and corresponding hazards in relation to common husbandry systems and practices for fur production for mink, foxes, racoon dogs and chinchillas;

(d)	for the most relevant welfare consequences, assess whether these welfare consequences can be prevented or substantially mitigated under current farming conditions or other field-tested farming systems for mink, foxes, raccoon dogs and chinchillas.

EFSA is requested to provide this scientific opinion by March 2025.

Taking into account the EFSA opinion, in 2025, as a second step, the Commission will evaluate the necessity and justification of the bans requested by the ECI ‘Fur Free Europe’ in pursuing environmental, animal health, public health and animal welfare objectives; in ensuring that consumer concerns can be addressed in practice, in ensuring smooth operation of the internal market. It will also evaluate the proportionality of such bans. The evaluation will include an assessment of the economic and social impacts of such bans in the EU. The assessment should also evaluate the feasibility and suitability of alternative approaches to ensure the welfare of farmed fur animals, including the introduction of stricter farming animal welfare rules, and whether they should also apply to imported products. Furthermore, it will examine ways of futureproofing possible policy initiatives.

Taking into account the EFSA opinion and the outcomes of this evaluation, the Commission will, by March 2026, communicate whether it considers it appropriate to propose a prohibition, after a transition period, on the keeping in farms and killing of farmed mink, foxes, raccoon dogs or chinchilla, and whether it is appropriate to propose a prohibition, after a transition period, of the placing on the Union market of fur and fur products derived from mink, foxes, raccoon dogs or chinchilla originating in fur farms, or alternatively to adopt, through EU legislation, appropriate standards suited to better address the welfare needs of the animals. It will then also provide the related envisaged timelines for any action it may propose to take.

3.2.   Accompanying actions

3.2.1.   One Health accompanying actions

Joint Health Security Committee (HSC) and Chief Veterinary Officers (CVO) meetings will continue to be held to monitor the evolution of the High Patogenic Avian Influenza (HPAI) epidemiology and its potential impact on public health.

The joint assessments by the European Food Safety Authority (EFSA), the European Centre for Disease Prevention and Control (ECDC) and the EU Reference Laboratory (EURL) on avian influenza will continue on a regular basis and will address newly identified risks with an iterative approach.

The ECDC constantly monitors Covid-19 data, including genomic and carries out event-based/epidemic intelligence surveillance for zoonotic flu, including HPAI.

The Commission is also planning to conduct in 2024 three on-site visits to Member States with mink/fur farms, exploring the controls and the One Health mechanisms in place for the prevention, detection and response to zoonotic threats with pandemic potential, such as SARS-CoV-2 and avian influenza, in these farms. These visits may also include some fact-finding elements on animal welfare.

3.2.2.   Invasive alien species

The Commission is currently updating the risk assessment for the American mink (Neovison vison). Depending on the outcome of this assessment, the Commission will consider in 2024 whether to propose the species for listing under the IAS Regulation.

3.2.3.   Labelling of fur in apparel and clothing accessories

The Commission is undertaking an evaluation of the Textile Labelling Regulation exploring the possibility, subject to an impact assessment, of harmonising and even requiring accurate and detailed labelling information to consumers on the presence of real fur in all apparel and related products such as clothing accessories. Consumers could then tailor their fur consumption choices based on accurate, easily accessible and trustworthy information.

Several consultation initiatives are foreseen, including an open public consultation to be launched before the end of 2023.

The Commission will finalise during 2024 the evaluation and impact assessment. Based on the outcome of that evaluation and impact assessment, the Commission will consider whether a revision of the Textile Labelling Regulation is opportune.

4.   CONCLUSION

The European citizens’ initiative ‘Fur Free Europe’ raises important issues that are relevant to the EU’s One Health policy of protecting animals, humans and the environment.

The Commission’s response outlines actions aimed at obtaining a solid scientific evidence-base for the assessment of social, environmental, economic and legal aspects as well as from a One Health perspective.

Therefore:

—	the Commission requested EFSA to provide by March 2025 a scientific opinion in order to take an informed decision;

—

based on the EFSA opinion and the outcomes of this evaluation, the Commission will, by March 2026, communicate whether it considers it appropriate to propose a prohibition, after a transition period, on the keeping in farms and killing of farmed mink, foxes, raccoon dogs or chinchilla, and whether it is appropriate to propose a prohibition, after a transition period, of the placing on the Union market of fur and fur products derived from mink, foxes, raccoon dogs or chinchilla originating in fur farms or alternatively to adopt, through EU legislation, appropriate standards suited to better address the welfare needs of the animals.

—

Pending this assessment, the Commission is taking several steps in relation to animal welfare, one health and environmental impacts of fur farming: — in 2024 the Commission is planning to conduct three on-site visits to Member States with mink/fur farms, exploring the controls and the One Health mechanisms in place. These visits may also include some fact-finding elements on animal welfare; — depending on the outcome of the ongoing assessment, the Commission will consider in 2024 whether to propose to include American mink (Neovison vison) in the list of invasive alien species of Union concern under the IAS Regulation; — the Commission shall finalise during 2024 an evaluation and impact assessment preparing the revision of the Textile Labelling Regulation to provide detailed labelling information to consumers on the presence of real fur in all apparel and related products such as clothing accessories. Based on the outcome of the evaluation and impact assessment, the Commission will consider whether a revision of the Textile Labelling Regulation is opportune.

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(1)  Regulation (EU) 2019/788 of the European Parliament and of the Council of 17 April 2019 on the European citizens’ initiative (OJ L 130, 17.5.2019, p. 55).

(2)  https://europa.eu/citizens-initiative/initiatives/details/2021/000006_en

(3)  Commission Implementing Decision (EU) 2022/482 of 16 March 2022 on the request for registration of the European citizens’ initiative entitled ‘Fur Free Europe’ pursuant to Regulation (EU) 2019/788 of the European Parliament and of the Council (OJ L 98, 25.3.2022, p. 82).

(4)  https://www.europarl.europa.eu/committees/en/fur-free-europe/product-details/20231005ECI00161

(5)  https://food.ec.europa.eu/animals/animal-welfare/eci-end-cage-age_en#end-the-cage-age

(6)  https://www.eesc.europa.eu/en/news-media/press-releases/eesc-celebrates-success-fur-free-europe-citizens-initiative

(7)  https://www.europarl.europa.eu/news/en/agenda/briefing/2023-10-16/16/parliament-to-debate-citizens-initiative-on-a-fur-free-europe

(8)  Article 13 of the Treaty http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:12012E/TXT

(9)  Regulation (EU) 2022/2371 of the European Parliament and of the Council of 23 November 2022 on serious cross-border threats to health and repealing Decision No 1082/2013/EU (OJ L 314, 6.12.2022, p. 26).

(10)  https://food.ec.europa.eu/system/files/2016-10/aw_european_convention_protection_animals_en.pdf

(11)  https://www.coe.int/t/e/legal_affairs/legal_co-operation/biological_safety_and_use_of_animals/farming/Rec%20fur%20animals%20E%201999.asp

(12)  Council Decision 78/923/EEC of 19 June 1978 concerning the conclusion of the European Convention for the protection of animals kept for farming purposes (OJ L 323, 17.11.1978, p. 12).

(13)  https://www.sustainablefur.com/animal-welfare/#:~:text=WelFur%20is%20a%20Europe-wide%20programme%20designed%20to%20assess,and%20is%20based%20on%20a%20purely%20scientific%20approach

(14)  https://sustainablefur.com/wp-content/uploads/2018/12/WelFur_Briefing.pdf

(15)  Absence of prolonged hunger and thirst, comfort around nesting, thermal comfort, ease of movement, absence of injuries, absence of disease, absence of pain induced by management procedures, expression of social behaviours, expression of other behaviours, good human-animal relationship, positive emotional state.

(16)  https://www.furmark.com/traceability

(17)  https://www.furfreealliance.com/wp-content/uploads/2020/01/CertifiedCruel_FFA-Research-Report-3.pdf

(18)  https://food.ec.europa.eu/system/files/2020-12/sci-com_scah_out67_en.pdf

(19)   OJ L 221, 8.8.1998, p. 23.

(20)  https://food.ec.europa.eu/system/files/2016-10/aw_european_convention_protection_animals_en.pdf

(21)  https://food.ec.europa.eu/system/files/2022-10/aw_eval_revision_swd_2022-328_en.pdf

(22)  https://ec.europa.eu/commission/presscorner/detail/en/IP_23_4951

(23)  https://www.ecdc.europa.eu/sites/default/files/documents/RRA-SARS-CoV-2-in-mink-12-nov-2020.pdf and https://doi.org/10.2903/j.efsa.2021.6459

(24)  https://efsa.onlinelibrary.wiley.com/doi/epdf/10.2903/j.efsa.2023.7822

(25)  1 farm in ES in 2022 and 26 farms in FI in 2023.

(26)  7 Sims LD, Domenech J, Benigno C, et al. 2005. Origin and evolution of highly pathogenic H5N1 avian influenza in Asia. Veterinary Record 157:159–64.

(27)  https://www.efsa.europa.eu/en/topics/topic/avian-influenza#published-on-this-topic

(28)  Regulation (EU) No 1143/2014 of the European Parliament and of the Council of 22 October 2014 on the prevention and management of the introduction and spread of invasive alien species (OJ L 317, 4.11.2014, p. 35).

(29)  Article 12 of Regulation (EU) 1007/2011.

(30)  https://single-market-economy.ec.europa.eu/sectors/textiles-ecosystem/regulation-eu-10072011_en

(31)  https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/13872-Textile-labelling-rules-revision-_en; see also the petition to the European Parliament 0645/2019, available here https://www.europarl.europa.eu/petitions/en/petition/content/0645%252F2019/html/Petition-No-0645%252F2019-by-Joanna-Swabe-%2528Dutch%2529-on-insufficient-consumer-protection-under-EU-legislation-in-the-labelling-of-fur-products

(32)  26 out of 108 opinions received (i.e. 24 %), among which 10 businesses or business associations (16,4 % of all businesses or business associations submitting comments) and 14 NGOs (53,8 % of NGOs submitting comments), as well as one public authority (the Spanish Ministry on Consumer Affairs) and one European citizen. To be noted that all but one NGO addressing the topic in the feedback to the Call for Evidence are specialised in animal welfare or even in the fight against trade of real fur and its use in products.

(33)  https://ec.europa.eu/commission/presscorner/detail/en/qanda_21_645

(34)  https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:52022DC0226

(35)  Data provided by Fur Europe, based on data supplied by their members operating as chinchilla shippers/brokers. Fur Europe is an umbrella organisation representing all parts of the fur sector in Europe including farmers, feed kitchens, auction houses, dressers and dyers, furriers, manufacturers, designers, and retailers.

(36)  Data confirmed by MS in October 2023.

(37)  AT, BE, BG, DE, EE, FR, IE, IT, LU, NL, SI, SK.

(38)  AT, BE, BG, CZ, DE, EE, FR, HU, HR, IE, LV, LU, LT, MT, NL, SK, SI.

(39)  Data based on Eurostat SBS – NACE 14.20: Manufacture of articles of fur.

(40)  Zara, Armani, Tom Ford, Prada, Gucci, Versace, Michael Kors, Jimmy Choo, DKNY, Burberry, Chanel, Calvin Klein, Hugo Boss, Furla, Ralph Lauren, adopted fur free policy, online retail platforms Net-A porter and Farfetch as well, H&M banned farmed fur but still uses fur of exotic animals.

(41)  Henning Otte Hansen, Global fur retail value, Department of Food and Resource Economics, University of Copenhagen, May 2021.

(42)  Malmberg, B. and Moran, J., Fur Free Europe – Why we need to ban fur farming and the placement of farmed fur products on the European market from public health, legal, environmental and ethical perspectives, Fur Free Europe, 2022.

(43)  Covering products falling under HS 41 (raw hides and skins (other than furskins) and leathers) and HS 43 (furskin and artificial fur).

(44)  Hansen, S. W., Malmkvist, J., Palme, R., & Damgaard, B. M. (2007). Do double cages and access to occupational materials improve the welfare of farmed mink?. Animal Welfare, 16(1), 63-76.

(45)  Meagher, R. K., & Mason, G. J. (2012). Environmental enrichment reduces signs of boredom in caged mink. PloS one, 7(11), e49180.

(46)  Korhonen, H. T., Jauhiainen, L., & Rekilä, T. (2003). In-cage sandbox as a ground substitute for farmed blue foxes (Alopex lagopus): Effects on digging activity and welfare. Canadian Journal of Animal Science, 83(4), 703-712.

(47)  Koistinen, T., Turunen, A., Kiviniemi, V., Ahola, L., & Mononen, J. (2009). Bones as enrichment for farmed blue foxes (Vulpes lagopus): interaction with the bones and preference for a cage with the bones. Applied Animal Behaviour Science, 120(1-2), 108-116.