The EU remains a main hub and destination for wildlife that has been stolen from third countries according to a new report by animal welfare NGO Pro Wildlife together with four other organisations (Humane World for Animals, International Fund for Animal Welfare, FOUR PAWS and Wildlife Conservation Society).
The exotic pet trade involves the smuggling of species from all over the world, including those that are nationally protected in their country of origin. The report shows how the EU is driving the demand for this illegal trade and makes the case for stricter regulation and the closure of legal loopholes.
The EU is one of the world’s biggest importers of wildlife. Only a small proportion of species traded are covered by international and/or EU legislation. Yet many wild species being traded in the EU are protected under domestic legislation. These species are often wild caught and exported from their country of origin in violation of national law.
The report includes detailed case studies from 17 countries in five geographic regions. The unique giant bronze gecko, a rare species of lizard from the Seychelles, is just one example of the species impacted by this form of wildlife trafficking. Lizards are also threatened in New Caledonia, a French territory in the Pacific Ocean which is called “the smallest single biodiversity hotspot in the world”.
North Macedonia, a candidate country, figures also in the report because of the Macedonian grayling. a butterfly exclusively found in a small area in the country. Despite national protection, the species is illegally collected and traded, and shipments are often declared as “decorative objects”. Specimens are sold in Europe for €18-50, with traders from Belgium, Germany, Ireland, Poland, Spain, and UK involved.
As the case of the endangered butterfly from North Macedonia demonstrates, the smuggling of illegally sourced animals is not limited to the trade in exotic pets, but is also driven by collectors of rare dead insects. While those specimens, if illegally obtained, can be seized at the EU border, there are no penalties for selling or possessing them once they have entered the EU market.
“Wildlife smugglers are openly selling illegally acquired animals within the EU in the full knowledge that they can get away with it because of existing loopholes in the EU legislation,” commented Dr Sandra Altherr, Head of Science at Pro Wildlife. “Unscrupulous criminals can make big money without taking any significant legal risks. And it’s the global biodiversity that pays the price for this.”
Recommendations for legislation
The report ends with a number of recommendations in line with the revised EU Action Plan against Wildlife Trafficking. The plan, issued by the European Commission in November 2022, provides a framework for tackling wildlife trafficking, ensuring that EU policies are consistent with its international commitments and based on the best available evidence.
The plan includes an indicative timetable for actions from 2022 to 2027. One of the actions was to examine whether existing measures are sufficient—or whether new tools may be needed—to reduce unsustainable and illegal trade in wildlife. Among the options considered is the possible criminalisation of all trade in illegally sourced wildlife.
In this context, the Commission tasked a consultancy, Trinomics, to carry out a feasibility study in late 2023. The results of the study were published in June 2025 (TRINOMICS 2025). The report assesses various legislative and non-legislative options, their potential benefits, and implementation challenges.
According to the study, Malta is the only EU Member State which restricts trade of species illegally sourced in the country of origin. Is there a need for an EU Directive which would prohibit and criminalise illegally sourced wildlife and, if so, has the Commission started working on it?
“It is important to underline that this was an exploratory study;” a Commission spokesperson told The Brussels Times. “The Commission will assess the study’s findings, together with the views of stakeholders, in depth before considering any potential next steps.” According to the spokesperson, the study’s conclusions do not predetermine any future legislative or non-legislative measures.
He added that follow-up work is expected to intensify in 2026, once resources are available after the Conference of the Parties to the Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES CoP20) which will take place in Uzbekistan from 24 November to 5 December 2025.
“The feasibility study confirms what legal experts have been saying for years,” commented Aubrey Collins, EU Wild Animal Policy Specialist at FOUR PAWS and international wildlife lawyer. “The criminalization of nationally protected species does not require courts to apply foreign law. It is time EU laws catch up to current trends.”
The five animal welfare NGOs are calling on the EU to take prompt legislative action to introduce supplementary legislation to close the loopholes in the current EU Wildlife Trade Regulations by prohibiting the import, sale, purchase and possession of wild animals that have been illegally obtained in their country of origin.
How is the recommendation for an EU Directive related to the idea of an EU-wide positive list of animals that can be traded as pets?
“This report and the related recommendations are not about the positive list, though there is some important clarification as the two tools are complementary, and both necessary,” Nicholas Clark, Wild Animals Programme Leader at Eurogroup for Animals in Brussels, replied.
The tools tackle different legislative gaps that currently exist within the EU wildlife trade framework. Both approaches will help the Commission meet the goals set out in the Revised Wildlife Action Plan, he explained.
"The prohibition of import of illegally-sourced wildlife will regulate the trade of all wild animals, including their parts and derivatives; while, the Positive List will regulate the trade of live wild animals in the context of private keeping. Many species are not suitable for a life as a pet for welfare reasons or can escape and present a risk for native biodiversity. This major loophole would be addressed by the Positive List.
The assessment for the establishment of an EU-wide Positive List should take into consideration the requirements of the future Directive and only include species that can be legally sourced. For instance, endemic species whose capture is prohibited in their origin country should automatically be excluded from the Positive List."
