Consultation outcome

Summary of responses and government response

Updated 10 December 2021

Introduction

This document provides a summary of responses to the government’s consultation and call for evidence on controls on the import and export of hunting trophies, as well as the government response and policy statement that outlines next steps.

The purpose of the consultation was to:

• seek views and evidence to inform aspects of government policy and action on the import and export of hunting trophies, gathering opinions on options considered
• seek views on the definition of hunting trophies, which species any potential further restrictions should apply to, exemptions to be considered and our proposed enforcement regime

The purpose of the call for evidence was to gather evidence on the impact of imports and exports of hunting trophies to and from the UK on conservation and natural environment, businesses, local livelihoods, and animal welfare, to inform aspects of government policy.

Timing

The consultation and call for evidence ran for 16 weeks from 2 November 2019 until 25 February 2020.

Number of responses

In total, we received 44,470 responses to the consultation and call for evidence. 7,536 responses provided answers to the consultation questions and 36,771 did not directly address the consultation questions. As the consultation and call for evidence ran simultaneously, and email responses were submitted to a single email address, there was no precise way to separate the two types of responses. For that reason, we are unable to provide separate figures for email responses to the consultation and call for evidence.

Total responses were made up of:

• 7,043 responses through the online questionnaire on Citizen Space to the consultation (of which approximately 500 were campaign linked)
• 162 responses through the online questionnaire on Citizen Space to the call for evidence
• 37,254 responses via email (of which approximately 5,800 were campaign linked, and a further 24,000 responses drew on campaign text). This total includes both consultation and call for evidence responses. 166 individual email attachments were submitted.
• 10 responses to the consultation by post (of which 6 were campaign linked), and 1 response to the call for evidence by post
• 1 petition response (with 269 signatures). We also noted an online petition which collected 140,446 signatures but was not submitted as part of the consultation.

Respondents’ demographics are addressed separately below.

Consultation: summary of responses

Option preference

Question 8 gave an opportunity for respondents to indicate their preferred option.

Many of the respondents who provided general comments by email or post included an option preference. For that reason, we have considered all responses received (44,307) for this question.

• 2,699 (6%) did not indicate a preference
• 583 (1%) supported’ Option One: A ban on hunting trophies from certain species entering or leaving the UK’
• 303 (0.7%) supported ‘Option Two: Stricter requirements for clear benefits to conservation and local communities to be demonstrated before hunting trophies from certain species are permitted to enter or leave the UK’
• 37,058 (84%) supported ‘Option Three: A ban on all hunting trophies entering or leaving the UK’
• 3,664 (8%) supported ‘Option Four: Do nothing - continue to apply current controls based on internationally agreed rules’

A total of 86% of responses to this question therefore supported further action beyond current controls. Overall, the most common rationales for supporting an option were ethical reasons (6,319 responses), species conservation (5,952 responses), and animal welfare concerns (3,984 responses).

What is a hunting trophy?

Questions 5 and 6 considered the definition of a hunting trophy.

Q5. Is there anything you would consider to be a hunting trophy that falls outside of the definition found in CITES and the EU Wildlife Trade Regulations?

Of the 7,536 responses to the consultation, 5,400 (72%) believed that the Convention on International Trade in Endangered Species (CITES) definition of a hunting trophy was sufficient. 1,925 (26%) expressed a view that there are several situations that the definition does not adequately cover. Key points raised were:

• Over 1,000 responses stated that any dead animal could be a hunting trophy. Some further emphasised that CITES did not cover all species, and some expressed concerns about how CITES classifies specimens for trade.
• Around 850 responses noted that CITES considers hunting trophies as part of an individual’s personal effects.
• Around 330 responses noted that the CITES definition does not include illegal trade and should be expanded to include illegally hunted trophies.
• A small number of respondents mentioned that trophies hunted for resale, or ‘commissioned kills’ should also be included within the definition. Concerns about hunting captive bred animals were also raised.

Q6. Is there anything that falls within the definition used in CITES and the EU Wildlife Trade Regulations that you consider should not be treated as a hunting trophy?

Of the 7,536 responses to the consultation, 6,437 (85%) thought no part of the definition should be removed. 454 (6%) stated that there are some items that the definition should not cover. Key points raised were:

• nearly 500 responses thought items for personal (edible) consumption should be excluded from the definition. Most of these mentioned meat or traditional medicine products.
• around 450 responses thought that an item should be considered a hunting trophy regardless of whether it requires a CITES permit or certificate.

How should controls and enforcement work?

Questions 7, 10, 11 and 14 considered the design, implementation, and enforcement of controls on hunting trophies.

Q7. Do you envisage any challenges or difficulties which might arise from using the definition in CITES and EU Wildlife Trade Regulations, for example, when it comes to enforcement?

Of the 7,536 responses to the consultation, 4,978 (66%) did not envisage any challenges or difficulties. 1,870 (25%) did envisage challenges or difficulties.

• Over 1,100 responses raised concerns about CITES capacity or effectiveness in regulating imports and exports of hunting trophies, such as concerns about record-keeping or adherence to quotas.
• Over 900 responses raised the difficulty of obtaining or validating relevant information for permits, for example verifying whether animals are wild or captive-bred, verifying the purpose of an import or export, and correctly identifying species and animal parts in processed items.
• Nearly 600 responses raised issues about enforcement and potential for loopholes due to the scope of the definition.

Q10. Do you think there should be different restrictions on hunting trophies imported and exported to and from countries within the EU, compared with countries outside of the EU?

• Of the 7,536 responses to the consultation, 6,286 (83%) stated they do not think that there should be different restrictions on hunting trophies imported and exported to and from countries within the EU, compared with countries outside of the EU.
• Some responses suggested alternative criteria on which to base restrictions, such as conservation criteria (around 110) or ethics (around 240).

Q11. Do you have additional information or evidence on:

a) Potential impacts of increased restrictions as set out in options one to three?

Of the 7,536 responses to the consultation, 2,075 (28%) provided a response to this question. Key points raised were:

• Over 800 responses suggested that increasing restrictions could lead to growth in alternative forms of wildlife tourism, such as eco- or photo-tourism.
• A similar number thought that increasing restrictions would benefit species conservation, due to trophy hunting contributing to decreasing populations. Around 400 responses expressed an opposite view, stating that the loss of the financial incentive offered by trophy hunting would harm conservation efforts, increasing land-use change and human-wildlife conflict. Over 250 responses specifically mentioned negative impacts on local communities and livelihoods.

b) Potential barriers to implementation for options one to three?

Of the 7,536 responses to the consultation, 1,744 (23%) provided a response to this question. Key points raised were:

• Over 850 responses stated that there were no insurmountable barriers to implementation, and Option 3 (a ban on all hunting trophies entering or leaving the UK) would be simplest to implement. This included a significant number of campaign responses.
• Potential barriers that were mentioned included stakeholder interests, such as hunters and businesses seeking to avoid the effects of additional restrictions, or a lack of capacity for governments and public authorities to implement further controls.

Q14. Do you agree with our proposed enforcement regime?

Of the 7,536 responses to the consultation, 5,378 (71%) agreed with the proposed enforcement regime, while 1,410 (19%) did not. Key points raised were:

• Over 800 responses objected to the proposed sanctions, proposing tougher sanctions to increase the deterrent effect of penalties. Responses suggested custodial sentences over 5 years or higher fines.
• Nearly 600 responses agreed with the proposed regime and 400 responses expressed concerns about enforcement capacity.

Which hunting trophies should controls apply to?

Questions 9, 12 and 13 considered the scope of controls.

Q9. Options One and Two introduce further restrictions for certain species. Which species do you think these further restrictions should apply to?

Of the 7,536 responses to the consultation, 2,810 (37%) said that the further restrictions from Options One and Two should apply to species listed on Annex A or B of the EU Wildlife Trade Regulations; 1,310 (17%) chose species listed on the International Union for Conservation of Nature (IUCN) Red List, and 1,659 (22%) provided an answer under ‘Other’. Key points raised were:

• Many comments stressed that further restrictions should apply to all species.
• Some responses proposed that further restrictions should be applied to both options (Annex A and B of the EU Wildlife Trade Regulations) and (b) (species listed on the IUCN Red List) to ensure coverage of all endangered species.
• Some responses mentioned specific IUCN Red List categories that the restrictions should apply to.
• Some responses noted that species may be endangered only in certain areas, meaning a blanket approach was not appropriate.

Q12. In Options One, Two and Three, do you think there should be different restrictions on hunting trophies obtained from: wild animals, animals that have been bred in captivity to be hunted, or animals which have been hunted in confined enclosures?

Of the 7,536 responses to the consultation, 6,526 (87%) stated that there should not be different restrictions on hunting trophies obtained from captive bred animals, wild animals, or animals which have been hunted in confined enclosures. 596 (8%) stated that there should be different restrictions. Key points raised were:

• Around 900 responses showed support for a ban, stating that restrictions should apply to all animals, with no distinction based on the source.
• Around 400 responses stated that captive-bred animals and animals hunted in confined enclosures should face different restrictions. Most of these thought that ‘canned hunting’ and hunting of captive-bred animals should be banned or further restricted. However, some stated that there should be fewer restrictions on such trophies, as they do not directly impact wild populations.
• A smaller number gave views on the definition of ‘canned hunting’, for example distinguishing it from hunting of captive-bred animals depending on the size of the enclosure.

Q13. For Options One, Two and Three, do you think there should be any exemptions considered? Please state your reasons why.

Of the 7,536 responses to the consultation, 6,278 (83%) stated that there should not be exemptions considered for Options One, Two or Three. 569 (8%) thought that exemptions should be considered. Key points raised were:

• Over 500 responses stated that exemptions could create loopholes and should therefore not be considered.
• Around 150 responses suggested trophies taken as part of wildlife management should be exempt, as culls are necessary and trophy hunting can contribute funding to this work.
• Around 110 responses suggested an exemption for sustainable trophy hunting, for example which delivered benefits for conservation and local livelihoods.

Call for evidence: summary of responses

Conservation impacts

Approximately three quarters of the detailed responses submitted to the call for evidence did not support a ‘blanket’ ban on imports and exports of hunting trophies from all species. Key points included were:

• Suggestions that trophy hunting has negative impacts on species conservation, including due to poorly and unsustainably managed hunting. A range of evidence flagged the negative impact of trophy hunting on social structures and genetics within populations, as well as on wider ecosystem balance. Some responses mentioned trophy hunting leading to declining population numbers and illegal practices. Other evidence stated that captive-bred hunting provides no benefits for species conservation.
• Suggestions that trophy hunting can have a positive impact on species and habitat conservation, through raising revenues which can then be reinvested into wildlife management and generating incentives to restore wildlife and protect natural habitats; anti-poaching activities; and reducing human-wildlife conflict. A variety of evidence was submitted associating trophy hunting operations with increasing population numbers.
• Evidence regarding domestic trophy hunting, suggesting that hunting is necessary to manage deer populations and protect the natural environment, and could add economic value to wildlife and generate funds to maintain it.

The scale of the impact of potential stricter controls on the import and export of hunting trophies

The CITES trade database provides data on imports and exports of hunting trophies from CITES-listed species. Outside of this commonly-cited resource, there is less information available on the scale of trade and the potential impact of stricter controls on imports or exports to or from the UK. Key points included:

• The CITES trade database was the most cited source of information on the number of hunting trophies imported to and exported from the UK. The information that was submitted suggests that the volume of trophies imported and exported to and from the UK is relatively small. For example, a 2016 report by the International Fund for Animal Welfare (IFAW)^{[footnote 1]} found that, based on its analysis of CITES data, the UK is not a large importer or exporter compared to other developed countries.
• However, information about imports and exports of hunting trophies from species not covered by CITES permits is very limited.
• Overall, very limited evidence was submitted to show how many companies derive a significant proportion of their income from the movement of hunting trophies to or from the UK.
• Some evidence was submitted listing the types of industries involved in the value chain of imports and exports of hunting trophies, including: hunting outfitters, hospitality and catering, transport companies, taxidermists, vets, shipping companies, weapons manufacturers. Some evidence suggests that mostly small and medium businesses in rural areas may be most affected.
• Evidence was submitted suggesting that the impact of further restrictions on UK businesses would be quite significant, for example based on the contribution of the hunting of red deer to the UK’s rural economy. Opposing evidence was submitted suggesting a limited impact, for example because of the relatively low numbers of imports and exports of hunting trophies to and from the UK recorded under CITES.

International action

• Some countries have introduced further restrictions, with various effects. These include countries that have restricted imports of hunting trophies from certain species (such as France, the Netherlands, Australia, and the USA), as well as countries which have restricted trophy hunting, either for a set time period, or indefinitely (such as Botswana and Kenya).
• Evidence was submitted on both sides of the debate, providing examples where further restrictions on trophy hunting may have had negative or positive impacts on species conservation and natural environments, livelihoods and the well-being of rural communities living with wildlife, as well as economic development.

Building a wildlife economy

• A number of case studies submitted suggested the import and export of hunting trophies to and from the UK has a positive impact and supports local livelihoods. A variety of evidence suggested that trophy hunting has a positive impact on local livelihoods, highlighting that communities benefit from income from hunting concessions, meat, and jobs, and more widely, from the ability to make decisions on how they manage their land and wildlife.
• Alternative evidence submitted suggested that trophy hunting has a very limited impact on supporting local livelihoods. Some evidence suggested that other forms of wildlife tourism could generate greater benefits than trophy hunting, such as photo-tourism or eco-tourism.
• Various submissions suggested that alternatives to trophy hunting are not always readily available. Evidence suggested that alternatives may not generate as much revenue as trophy hunting, may take time to introduce, may be environmentally harmful, and would not meet the need for wildlife management.

Animal welfare

• Some evidence submitted suggested that trophy hunting is not harmful to animal welfare and that hunting is a regulated activity, hunters are expected to perform ‘clean kills’ and that it does not create any greater suffering than natural death.
• Alternative evidence was submitted suggesting that there are welfare concerns associated with trophy hunting, especially with ‘canned hunting’ and hunting of captive bred animals.

Campaigns and petitions

A number of organisations ran campaigns encouraging the public to submit responses, expressing sentiments both in favour and against a ban.

Approximately 1,235 email responses contained “I support option 3 - a ban on all hunting trophies entering or leaving the UK”, which indicated that it was likely to be linked to or inspired by a campaign. A further 24,000 email responses contained variations of that text.

One petition was submitted as part of the consultation from UK Deer Stalking with 269 respondents expressing their support for maintaining current controls. Some respondents flagged a petition by the Campaign to Ban Trophy Hunting which supported a ban on all hunting trophies entering or leaving the UK and collected 140,446 signatures. This petition was not submitted as part of the consultation.

Petition numbers have not been included in the option preference statistics in this summary of responses but have been noted.

Policy statement

Background

Wildlife populations are declining rapidly and face significant threats including habitat loss, over-exploitation, and climate change. The import of hunting trophies to the UK from endangered and threatened species may be putting additional pressure on species conservation, contributing to over-exploitation of wildlife and loss of biodiversity. It is with this in mind that this government included a commitment within its manifesto to ban the import of hunting trophies from endangered animals.

Currently permits are only required for the import or export of hunting trophies from species protected under CITES. This is implemented in Great Britain through the UK Wildlife Trade Regulations and in Northern Ireland through the EU Wildlife Trade Regulations. All species listed on Annex A of the UK Wildlife Trade Regulations, and 6 species listed on Annex B, require an import and export permit. These permits are issued by the Animal and Plant Health Agency based on advice from the UK Scientific Authority the Joint Nature Conservation Committee. They are only issued if there is assessed to be no negative impact on conservation of the species in the wild. Hunting trophies from all other Annex B species require only an export permit issued by the country of origin.

From 2015 to 2019, the UK recorded 335 imports and 7 exports of hunting trophies under CITES. Imports included trophies from elephants, hippos, lions, leopards, black and brown bears, scimitar-horned oryx, and southern white rhinoceros. Data on imports and exports from non-CITES listed species are not routinely collected.

We undertook a consultation and call for evidence to inform aspects of government policy and action on the import and export of hunting trophies.

We note the strong response to the consultation and call for evidence, which received 44,470 submissions, and thank those who took the time to share evidence and their views. All input has been vital in informing our next steps.

The responses to the consultation indicated a clear preference (86% of responses) for the government to put in place additional restrictions beyond current controls The majority of those who provided a response to the consultation (84%) indicated that their first preference would be for a ban on imports and exports of hunting trophies from all species to and from the UK.

However, around three quarters of the detailed responses submitted to the call for evidence did not support a ban on imports and exports of hunting trophies from all species. We note the evidence which suggests that in some cases, trophy hunting can support species and habitat conservation, as well as local livelihoods, and that there may not always be readily available or feasible alternatives which deliver the same benefits. We also note evidence of damaging impacts of unsustainable and unchecked trophy hunting in some cases, and examples of where local populations do not benefit from the activity.

Policy response

The government is committed to supporting wildlife and the environment, both in the UK and internationally. After considering the outcomes of the consultation and call for evidence, and views of stakeholders and experts, we intend to take action to strengthen and broaden our controls on the import of hunting trophies.

The aim of this policy is to prohibit the import to the UK of hunting trophies from species of global conservation concern, which in turn should disincentivise trophy hunting of these species, and send a positive signal internationally in support of species conservation.

We will do this by introducing legislation to ban the import of hunting trophies from species of global conservation concern. Species in scope of the ban will be those listed on Annex A and B of the UK Wildlife Trade Regulations and any other species not covered by these regulations but subject to hunting and of particular conservation concern (namely those assessed by the International Union for Conservation of Nature as Near Threatened, Vulnerable, Endangered, Critically Endangered or Extinct in the Wild). We will keep this under review as new evidence emerges around species’ conservation status and threat. For all species in scope, the import of hunting trophies from both wild and captive-bred animals will be banned.

Existing CITES controls under the Wildlife Trade Regulations will remain in place for exports of hunting trophies from the UK. This measure will not ban the practice of trophy hunting itself or ownership of hunting trophies. These two concepts were not included in the scope of the consultation and call for evidence.

The policy will apply in Great Britain only, respecting the devolution settlements and terms of the Northern Ireland Protocol as it is currently operated. The UK has set out a proposed new approach to the Protocol, looking to secure significant changes to processes and governance if the Protocol is to work in future.

Definition of a hunting trophy

A hunting trophy is defined by CITES as “a whole animal, or a readily recognisable part or derivative of an animal, specified on any accompanying CITES permit or certificate, that:

i. is raw, processed or manufactured
ii. was legally obtained by the hunter through hunting for the hunter’s personal use
iii. is being imported, exported, or re-exported by or on behalf of the hunter, as part of the transfer from its country of origin, ultimately to the hunter’s state of usual residence.”^{[footnote 2]}

We note that the majority of respondents found the CITES definition of hunting trophy acceptable, and we propose to retain this definition under the new controls.

Scope of further restrictions

After considering the outcomes of the consultation and call for evidence, CITES trade data, and views from stakeholders and experts, the government will take action to introduce a ban on the import of hunting trophies from thousands of species of global conservation concern, including those listed on Annex A and B of the UK Wildlife Trade Regulations and any other species not covered by these regulations but subject to hunting and of particular conservation concern (namely those assessed by the IUCN as Near Threatened, Vulnerable, Endangered, Critically Endangered or Extinct in the Wild). Hunting trophies from these species will be prohibited from entering Great Britain, unless considered outside the scope of the ban. The ban will include many species of concern, such as elephants, hippopotamuses, lions and cheetahs.

Evidence received suggests that some other forms of trade are appropriately controlled by CITES and should not be within scope of the ban, because doing so could negatively affect other CITES users. Items not in scope of the ban will include:

• trophies imported for educational or scientific purposes, or as part of a circus or travelling exhibition
• other personal effects, not obtained through hunting for the hunter’s personal use: for example, family heirlooms or items moved as part of a person’s household effects
• antique hunting trophies
• trophies not considered antiques, but from animals hunted before the ban comes into effect
• commercial trade in animal parts

Within the consultation, we asked whether exemptions should be considered, for example for conservation reasons. We note the strength of sentiment from those who did not support exemptions, and there will be no exemptions for hunting trophies from species in scope of the ban.

Enforcement of further restrictions

In the consultation document we proposed an enforcement regime whereby UK Border Force would use existing powers to enforce controls on hunting trophies at the UK border, and the police would do so away from the border. We also proposed that any new criminal and civil sanctions would be consistent with existing offences under the Control of Trade in Endangered Species Regulations 2018 (COTES).

Responses to the consultation stressed the importance of robust enforcement mechanisms. Our approach will utilise existing powers and processes currently in place to control the trade in endangered species under the Customs and Excise Management Act 1979 (CEMA). Border Force will continue to use these existing powers to confiscate banned items at the border. We have confidence in this existing framework. We will continue to work with UK enforcement bodies to ensure that enforcement of this ban is effective, efficient and measures are proportionate.

Next steps

We intend to bring forward legislation to deliver this policy. Engagement will continue with public/statutory bodies such as the Joint Nature Conservation Committee, the Animal and Plant Health Agency, Border Force and the National Wildlife Crime Unit as well as further external engagement with relevant stakeholders.

Notes

Demographics

Responses provided through Citizen Space allow for respondents to provide demographic information (questions 1 to 4). This information was not collected for email responses.

• Of the 7,043 responses to the consultation received through Citizen Space, 6,651 were from individuals, 177 were from organisations and 215 provided no identifying information.
• Of the 162 responses to the call for evidence received through Citizen Space, 135 were from individuals, 25 were from organisations and 2 provided no identifying information.

Responses from individuals were submitted by representatives of the UK public, as well as those from other countries. A wide range of organisations submitted responses, including UK-based and international NGOs, foreign governments, hunting outfitters, wildlife management organisations, estates and safaris, taxidermists, academia, gun makers, game farmers, community interest and advocacy groups, nature conservation organisations, local governments, and antique dealers.

Responses to the consultation and call for evidence

The evidence included in this report comes from a range of sources. Sources assessed as high-quality evidence include well-referenced information and facts from reliable sources, information produced from conservationists and academics, papers and reports from reputable journals and publications, and official responses from other countries, as well as from industry representatives.

However, even after identifying the higher quality evidence, there remain a number of key caveats:

• Any figures on the value of trophy hunting should be used cautiously – but evidence did suggest that many activities or jobs could be attributed to trophy hunting.
• The management of trophy hunting is quoted by some as being to a sustainable standard. This cannot necessarily be generalised to all cases of trophy hunting.
• The revenue trophy hunting generates and the contribution to local communities is widely debated with sources quoting a range of figures. It is therefore important to take into account all of these figures rather than isolating individual ones.
• The evidence presented may provide only part of a picture to demonstrate the point of the stakeholder. For example, it may discuss the benefits and not include information on the costs.
• Some of the evidence is less recent. Whilst key messages and points may still be relevant, specific numbers may have altered and care should be taken when considering these.

EU exit

The wording of the consultation questions reflects the UK’s relationship with the EU at the time of the consultation. The UK left the EU on 31 January 2020, after the start of the consultation and call for evidence, and the transition period ended on 31 December 2020.

Therefore, the EU Wildlife Trade Regulations, which were directly applicable to the UK when the UK was an EU member state, are now part of UK law (the UK Wildlife Trade Regulations).

Note that the UK Wildlife Trade Regulations currently apply only to Great Britain (England, Wales and Scotland). In Northern Ireland, the EU Wildlife Trade Regulations continue to apply under the terms of the Northern Ireland Protocol.

1. IFAW (2016) Killing for Trophies: An analysis of global trophy hunting trade ↩

2. CITES Resolution Conf. 12.3 (Rev. CoP18) ↩