Born Free Foundation - Keep Wildlife in the Wild

The EU Zoo Inquiry 2011
An evaluation of the implementation and enforcement of EC Directive 1999/22

Following the meeting with the Competent Authorities in Estonia, post Report production, it has become necessary to clarify which enforcement agencies are involved in the zoo inspections. Roles have recently changed.

It would appear that zoos are initially inspected by the Environment Board, with advice from the Advisory Commission, before they are licensed and able to operate. Once licensed, zoos are then required to be regularly inspected (Estonian law 237/2003 & Article 4 of the Directive) to ensure they meet the requirements applicable to zoos (Estonia law 245/2004 & Article 3 of the Directive). Zoo inspections are undertaken by the Veterinary and Food Board and in some cases by the Environmental Inspectorate (for CITES-listed species), however, following discussions with the Estonian Competent Authorities on 3rd May 2011, it appears that neither of the inspection agencies are competent in the assessment of wild animals in captivity and the provision of appropriate animal care and only a few inspections of zoos have taken place. Concerns over the frequency and quality of zoo inspection, expressed in the Estonia Report, therefore still apply.   

Taking into account the above clarifications, the following alterations to the Estonian report must be taken into account:

1) Page 6, second section – where reference is given to the Environmental Inspectorate, this should instead refer to the Veterinary and Food Board;

2) Page 6, second section, points 3 & 4 – where reference is given to Article 32, this should instead refer to Article 31. The inspection authorities cannot close the zoo, but they can suspend the licence. This is a shortfall of the existing law, and should be resolved by the amendment of APA;

3) Page 12, paragraph 5 - where reference is given to the Environmental Inspectorate, this should instead refer to the Veterinary and Food Board, which cooperates with the Environmental Inspectorate and the police;

4) Page 30, paragraph 3 - where reference is given to the Environmental Inspectorate, this should instead refer to the Veterinary and Food Board, which cooperates with the Environmental Inspectorate and the police;

5) Page 30, paragraph 4 – where reference is given to Article 66-11 of APA is not appropriate, instead, there should be a general reference to APA.

6) Page 35 paragraph 2 - where reference is given to the Environmental Inspectorate, this should instead refer to the Veterinary and Food Board, which cooperates with the Environmental Inspectorate and the police;

The Environmental Inspectorate is an agency, which is the responsibility of the Ministry of the Environment and the Veterinary and Food Board is of the responsibility of the Ministry of Agriculture.

For more information about The EU Zoo Inquiry 2011, please contact Daniel Turner, Project Manager at daniel@bornfree.org.uk