Toetsingskader huis- en hobbydierenlijst

Reactie

Naam FOUR PAWS International (Thomas Pietsch)
Plaats Vienna, Austria
Datum 21 december 2018

Vraag1

Heeft u -binnen het opdrachtkader dat u in de bijlage kunt vinden- wetenschappelijk gefundeerd commentaar op het toetsingskader voor zoogdiersoorten dat ten behoeve van de beleidsregel positieflijst huis- en hobbydieren is ontwikkeld?
Dear Minister Schouten,
we would like to stress that many stakeholders are following the process to establish a Positive List for exotic pets in the Netherlands with great interest.

First of all, an additional model for a scientifically sound assessment methodology for suitability of species as companion animals could be a decisive argument for decision-makers in other countries to start and complete the implementation of Positive Lists. E.g. in Germany the ExoPet study revealed many welfare problems related to sales and private keeping of exotic species.We are confident that the careful approach that has been chosen by The Netherlands to develop a positive list will be considered as a positive example in Germany as well as other countries sooner or later. A huge benefit of the Dutch efforts is also that scientific sources available and used for the risk-assessment of species aren’t country-specific, and the search for sources consequently does not need to be repeated. It is our conviction that the implementation of Positive Lists across the European Union would significantly improve the welfare of many animals, while simultaneously protecting human health and safety, reducing risks to biodiversity and saving public costs. We therefore support you and your Ministry in your persevering efforts to this end.

Towards the proposed method of assessing animal species – currently open for consultation - we have one remark. The final methodology will probably never be able to include all criteria to assess all risks of animal species and the level of these risks. As in other sectors dealing with non-quantifiable and relative instead of absolute measures, even the most reliable scientific sources will be insufficient to give absolute certainty about risks or the extent thereof. Suspicion of such risks are sufficient to legitimately use the precautionary principle, and give the animal the benefit of the doubt, as stated by the European Court of Justice (in CJEU Case C-219/07, Andibel, ECLI:EU:C:2008:353): “where it proves impossible to determine with certainty the existence or extent of the risks envisaged, because of the insufficiency, inclusiveness or imprecision of the result of the studies conducted, but the likelihood of real harm to human or animal health or to the environment persists, should the risk materialize, the precautionary principle justifies the adoption of restrictive measures”.
Yours Sincerely
FOUR PAWS International