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mmmll Supporting better implementation of the Zoos Directive Meeting Report First Member State and Stakeholder Meeting (18 February 2020)

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Page 1: Supporting better implementation of the Zoos Directive · 2020. 5. 7. · Better Implementation of the Zoos Directive – 1st Meeting Report 6 Inspections need to be carried out before

mmmll

Supporting better

implementation

of the Zoos Directive

Meeting Report

First Member State and Stakeholder Meeting (18 February 2020)

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Table of Contents

1 Introduction ................................................................................................ 3 2 Licensing .................................................................................................... 4

2.1 Presentations and discussion .................................................................. 4 2.2 Good practices .....................................................................................10

3 Inspections ................................................................................................13 3.1 Presentations and discussion .................................................................13 3.2 Good practices .....................................................................................19

4 Follow-up actions ........................................................................................22 4.1 Next meetings .....................................................................................22 4.2 Trainings .............................................................................................22 4.3 Technical assistance and information exchange (TAIEX) ............................23

4.3.1 Expert missions, study visits and workshops ......................................23

4.3.2 Application procedure .....................................................................24

4.3.3 Costs covered ................................................................................24

4.4 Sharing platform ..................................................................................24 Annex I – List of attending participants ...............................................................26 Annex II – Agenda ............................................................................................27 Annex III – Existing resources ............................................................................28

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1 INTRODUCTION

The first Member States and stakeholders meeting on better implementation of the Zoos

Directive took place on 18 February 2020.

In order to tailor the meeting to the needs of Member States and key stakeholders, a survey

was carried out between September and November 2019 to identify the priority topics for

discussion at the meeting. The results of the survey pointed out that the most important topic

for all surveyed stakeholders is the organisation of an effective and efficient licencing and

inspection system (45 out of 54 consulted stakeholders rated it as ‘very important’), followed

by inspections processes (39 out of 54 consulted stakeholders rated it as ‘very important’).

For this reason, the first meeting focused on these topics.

This meeting report summarises the points of discussion, the good practices identified and

existing resources relevant to licensing and inspection.

The meeting was chaired by Micheal O’Briain from the European Commission. He

highlighted that the prime objective of Zoos Directive is to ensure that zoos contribute to

wider nature conservation. The Zoos Directive doesn’t provide for a formal committee,

expert group or reporting obligations, which reflects the strong subsidiary nature of this

legislation.

Ute Goerres from the European Commission gave a presentation of the Zoos Directive

evaluation’s results, conclusions and follow-up actions. Ms Goerres underlined that only 10-

20% of European zoos belong to zoo associations and therefore need to comply with certain

conservation standards set and monitored by the associations. However, the Zoos Directive’s

minimum standards also apply to the remaining 80% of zoos and therefore help to close the

gap between zoos being member of an association and those that are not. Progress is most

needed in zoos not belonging to an association.

In order to address still remaining shortcomings in the Zoos Directive’s implementation, the

Commission embarked on several evaluation follow-up actions. It has already translated the

EU Zoos Directive Good Practices Document into seven languages last year (Bulgarian,

French, German, Italian, Polish, Romanian and Spanish) and will translate it into further

seven languages in 2020 and 2021 each. The first seven translations can be accessed through

the Zoos Directive’s website and the Commission encouraged Member States and

stakeholders to make good use of them.

Furthermore, the Commission will offer pilot trainings on all important Zoos Directive’s

provisions, will support better use of the so-called TAIEX-Peer-To-Peer mechanism and

organise three annual Member State and stakeholder meetings in 2020-2022. These actions

are supported by a contract the Commission has concluded with the consultancies VetEffect

and Milieu.

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2 LICENSING

2.1 PRESENTATIONS AND DISCUSSION

Opening

The Commission stressed that citizen’s expectations towards a stronger role of zoos in

biodiversity conservation have increased over time. Member State’s licencing and

inspection systems are the cornerstones to ensure that zoos live up to these expectations

and effectively contribute to biodiversity objectives. Whereas the Directive leaves

flexibility to Member States, it does require a national governance system that guarantees

a stronger contribution of zoos to biodiversity protection. The EU is keen to support

improving licencing and inspection systems and will also use enforcement as the last resort

to ensure compliance.

Supported by presentations from Milieu, Member State competent authorities from France

and the Netherlands as well as the European Association of Zoos and Aquaria (EAZA) and

Animal Advocacy and Protection (AAP), this session examined different practices identified

in implementing the licencing systems. The group also discussed existing shortcomings,

ways to improve and good practice examples.

Milieu gave an overview of the Directive’s licencing provisions, the diversity of existing

licencing systems in the EU, elements of effective licencing systems, progress achieved so

far and possible future improvements.

Expertise

The ensuing discussion covered aspects regarding human resources for licencing and the

possibility to increase of Member States authorities’ capacities through the use of external

experts. It would be beneficial to have greater expertise in the inspectorate to enable better

enforcement action on the ground.

While it is useful to have external expertise complementing potentially missing knowledge

in authorities, this raises the problem of external experts’ legal status. External experts often

lack decisional power and it is not clear, how and to what extent experts’ conclusions are in

the end enforced by authorities. Gaps between experts’ conclusions and authorities’

enforcement action might lead to delayed action or even inaction. A clear legal relationship

between authority and experts is important.

In this respect, Germany emphasized the need to ensure the independence of external

experts such as zoo associations or animal welfare NGOs. Legal decision power needs to

stay with the authorities. In Germany, authorities can benefit from the knowledge of a

working group on ‘Zoos and circuses’ that is established as part of the German Veterinary

Association for Animal Welfare. This participation provided the authorities with increased

knowledge, awareness of issues and facilitated respect between the different actors involved.

Ireland also mentioned that it is difficult to coordinate the biodiversity side being

responsible for licencing and the veterinary service side carrying out the inspections and

often focused on animal welfare.

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The Commission agreed that the availability of human resources might always be an issue

in public administration. While authorities dealing with nature and biodiversity are

responsible for the Zoos Directive, they indeed often lack the necessary specialisation on

zoo issues.

However, the EU has enormous potential for capacity building, for example through this

meeting but also through further exchanges between Member States and stakeholders or the

peer-to-peer-learning.

French two-fold licensing system

France presented its licencing system, which places strong emphasis on a two-fold obligation

process addressing the zoo owner’s competency and the authorisation of the zoo itself as

regards premises and programmes.

A certificate of competence is required from persons in charge of institutions dedicated to

the breeding of wild animals as well as those in charge of public institutions dedicated to the

public exhibition of indigenous or exotic fauna. The certificate is attributed to a person with

the appropriate competences for specific species. The zoo can only hold species for which a

member of staff has an appropriate certificate of competence.

The zoo must also hold an authorisation to open. This permit is linked to the zoo as a

designated institution whether public or private. It aims at ensuring adequate housing

conditions for animals and is conditional on the permanent presence of a holder of a

certificate of competence.

Regular monitoring is carried out by different administrative services. The system is based

on a ministerial order from 2004, covering housing, conservation actions, security, education

and the prevention of ecological risks.

Authorities are supported by expert commissions who provide opinions. In each French

department (101 in total), there is a zoo commission composed of experts in zoology and

captive wild fauna. This departmental commission reviews the application for a zoo

authorisation. At national level, a national commission also exists, which contributes to

gathering and sharing information as well as expertise on specific topics. In addition, the

country uses external experts for particular species who nevertheless don’t act in legal

capacity. French authorities also cooperate with the two French zoo associations to solve

problems on the ground.

Dutch zoo committee

The Dutch licencing system relies on different actors involved, namely the Agriculture

Ministry, the Netherlands Enterprise Agency (RVO), the Netherlands Food and Consumer

Product Safety Authority, the Zoo and Aquarium Inspection Committee and the Dutch zoo

association.

The Zoo Committee consists of experts from the zoo community and veterinarians and

is chaired and funded by the authority. Experts are selected by the chair, need to be

independent and cannot give advice on zoos they worked for. The Zoo Committee as well

as the Dutch zoo association send reports to the ministry, on which the licencing decisions

are based.

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Inspections need to be carried out before new licences are issued or if there are major

changes to existing licences. Licencing conditions cover different elements such as the

competences of animal caretakers, security aspects, keeping of an adequate animal register,

species-specific behaviour, social grouping, enclosure elements resembling natural habitats,

environment temperature or lightning.

EAZA’s accreditation system

The European Association of Zoos and Aquaria (EAZA) explained its accreditation system

and how the organisation could support authorities in their licencing and inspection work.

Accreditation screening is based on the Zoos Directive and takes into account local law.

The evaluation of a member zoo’s conservation performance implies in situ conservation

plans, activities implemented on the ground, as well as their impact. The screening report

with recommendations has to be approved by the Membership Committee. Concerns have

to be addressed within six months, otherwise a temporary membership of two years will be

granted to provide a longer time for improvements. EAZA accreditations might be used by

Member State authorities as an indicator of good zoo quality. Some zoos already share

EAZA reports with local authorities and EAZA offered to provide all their report

templates to authorities upon request.

EAZA is open to collaborate with authorities and is already part of expert bodies used in

licencing and inspection systems. Moreover, EAZA could support authorities in finding

experts. The association shares its best practice guidelines on its website and will make more

of these available in the future. EAZA provides the capacity to improve sub-standard zoos

and offers trainings on a variety of zoo-related topics. EAZA is also involved in organising

the pilot trainings as a follow-up action to the Zoos Directive evaluation.

In case of zoo closure, EAZA is ready to help with the decision to keep animals in the zoo

or rehoming them.

The association stressed the need for a holistic approach on zoos role in conservation. It

would also be important for authorities to move from a so far animal welfare to a

conservation focus.

Zoos closures and AAP’s rescue centres

Animal Advocacy and Protection (AAP) informed about their work on rescuing animals

during zoo closures and problems related to rescue centres needing a licence in some

countries.

AAP raised that, as some rescue centres are open to the public in order to raise funds, in

some national governance systems, they need a licence under the Zoos Directive. Whereas

rescue centres can offer some education, they have a non-breeding policy and no collection

plans. Therefore, the licencing requirement could be revisited by national authorities or a

specific legislation could apply to rescue centres.

The organisation was involved in 32 zoo closures so far. In seven cases, the zoo was closed

by authorities, whereas the others were self-initiated. In the major part of closures, AAP was

contacted by NGOs or zoos themselves and not by the authorities. There were also cases,

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where the zoo closed down without active intervention happening to rehome the animals.

AAP advocated for a multi-stakeholder solution, based on mutual trust. There’s a European

Alliance of Rescue Centres and Sanctuaries (EARS, 18 centres) that could be contacted. Zoo

closures don’t happen quite often as authorities first give the establishment time to

improve. However, a clear plan is needed to bring zoos into compliance. If the final

closure decision is taken, standardised closure protocols might be useful. It is also

important to prevent non-compliant zoos from opening, based on the licencing and

inspection obligations. According to AAP’s experience, penalties are often counter-

productive, as they render zoos unable to invest and implement the required changes.

Germany pointed to the fact that local authorities might not be experienced with zoo closure

and it is often not clear who will have to pay for rehoming the animals.

Eurogroup for Animals suggested making the financial liability of the zoo owner part of

the licence. They also reminded that a closure protocol is embedded in the licencing system

of some Member States.

In Italy, a zoo has to sign an agreement with another zoo to take care of animals in case

of closure.

General discussion

The discussion following the morning presentations addressed zoo animal accommodation

standards as well as the question of the evaluation of zoo conservation performance in

licencing and inspection.

The Commission stated that 21 years after the adoption of the Directive, some unlicenced

zoos are still operating. The meeting provides an opportunity to address the so far lack of

discussion among Member States as well as the lack of opportunities to share expertise and

good practices. The Commission asked if there were issues that could be flagged and

addressed within this forum or if participants felt that recognising diversity across the

Member States would be enough and wouldn’t need any specific actions.

Eurogroup for Animals thought that while there is heterogeneity in the national situations,

there are some lessons learnt that can be observed:

The financial viability of zoo owner should be checked and the business plan of

the zoo should be checked;

Minimum standards are in place in some MS and it would be useful to see how

this helps the licensing process;

The issue of possible harmonisation of licencing processes could be discussed;

A protocol for closure should be in place and checked during licensing (and

following inspection) phase.

Germany pointed to a possible lack of expertise in decentralised authorities that might not

even have the budget to pay for external experts. The Zoos Directive might not be so high

on the political agenda, so funding for public authorities implementing and enforcing it

might be difficult.

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The Commission stressed that the EU cannot push for harmonisation of standards or

licencing processes, which would be decisions for Member States to take, in line with the

subsidiarity principle.

The EU Zoos Directive Good Practices Document contains information on zoo closure

protocols but does not address the question of financial responsibility of zoo closure.

EAZA was not in favour of binding minimum standards for the accommodation of animals.

While they are easy to measure, they don’t push zoos to aim higher than the minimum.

EAZA felt that best practices would be a better solution. It established many best practice

guidelines that are publicly available.

VdZ (German zoo association) reported on their German experience with minimum

standards on mammals. It was a long and painful process and VdZ has the impression that

the final document is rather based on societal agreement than on scientific evidence.

Matt Hartley cautioned that best practices could be considered as the only way of ensuring

appropriate keeping conditions of zoo animals. This would however not appropriately take

account of the variety of existing zoos. In reality, looking after an animal in the north of

Europe is very different to the south, so one needs to take and apply the husbandry

documents in the right way.

Bulgaria and Poland also have minimum standards. Bulgaria prefers them as the easiest way

to measure compliance. The country finds the EAZA standards difficult to access. It rather

makes use of American and Australian husbandry standards that are more easily accessible.

Minimum standards protect and ensure legal certainty for zoo operators. Bulgaria

stressed that many zoos cannot go at a higher level than the minimum standards, and

EAZA membership is too costly for them.

Spain favoured standards focussing on certain species groups and didn’t find enclosure

size the most important criterion for proper animal accommodation, as there are so many

additional aspects to be considered. The country has minimum standards on habitats and

species’ needs, which have been developed in close cooperation with the University of

Barcelona.

Italy held that the existence of binding standards proves beneficial in court cases. As judges

often lack expertise on zoo animal specific issues, they need to rely on concrete legal

requirements to impose sanctions. In Italy’s view, the existence of binding standards

facilitates enforcement.

On this aspect, the Commission agreed that legal certainty is indeed critical. Yet, a one-fits-

all method, given the current lack of scientific knowledge on all species, is impossible.

From the European Court of Justice’s perspective, courts can look at guidance documents

and they are taken seriously.

In France, a lot of work on standards is undertaken by the competent authorities in

collaboration with veterinarians. France reminded that veterinarians specialised in zoo

animal welfare could act as experts before a judge. The French authorities have the

possibility to pay experts to prepare reports in the context of a trial.

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Eurogroup for Animals suggested that a minimum level of standards harmonisation

would be useful and not necessarily a full alignment. If the minimum standards are too

general, they risk to be watered down, but if the standards are sufficiently general, it limits

subjectivity and gives some level of certainty. The UK is now revising its standards, which

indicates that it is possible to update standards to adapt to scientific knowledge. Eurogroup

finds minimum standards necessary for the many non-EAZA zoos.

The Commission reminded that the Zoos Directive’s main objective is not to establish

minimum accommodation standards but to strengthen zoos’ contribution to the

conservation of biodiversity. The Commission wondered how zoos’ conservation

performance is checked during licencing and inspection. Faced with a massive species

extinction crisis, how are Member States looking appropriately at the role of zoos in that

context? How do they make sure that their licencing systems push zoos in the right direction?

Germany agreed that indeed a lot more work is needed on this, as zoos’ conservation

activities are often not properly evaluated during inspections.

In Italy proofs of a zoo’s conservation research and education activities need to be

provided before a licence is granted.

Eurogroup for Animals found conservation measures to be vaguely defined in the Directive

and wondered what extent of conservation activities would be regarded as sufficient.

Zoos might do well in one area such as in situ research but might not comply in another area

such as education as it promotes entertainment activities only.

Sweden pointed to the fact that the size of a zoo is critical in determining how much effort

is put into the conservation. Big zoos can have scientific teams and long-term projects,

which might not be possible for small zoos. They might only be able to do the minimum on

conservation which is often awareness raising.

Ireland agreed that the situation is different in large and in small zoos. In smaller zoos, the

question will rather be how to tie in conservation measures according to what they do (e.g.

pollination areas). An overall strategy, which can cover all zoos and reach a balance,

would be useful.

In Spain, zoos play an important role in the conservation of locally threatened species

such as the Iberian lynx. The conservation role of zoos must be clearly justified.

VdZ suggested to include ex situ conservation work in the next EU Biodiversity Strategy in

order to boost better integration of in situ and ex situ activities.

EAAM suggested authorities to liaise with zoo associations in order to gain better

knowledge on possible conservation activities in zoos. Authorities could then support

small zoos by advising them how they could participate in existing nationwide campaigns,

such as on pollinators or other environmental issues.

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2.2 GOOD PRACTICES

This section provides an overview of good practices extracted from the presentations and

discussions.

Decision-tree on zoo licencing

The Netherlands have set up a decision-tree to determine whether a zoo license is needed

(see slides of the representative of the Dutch authority).

Licencing conditions and obligations on zoos

The authority needs to ensure that the zoo complies with all Article 3 conservation

obligations before a licence can be granted.

Authorities could liaise with zoo associations to gain a better overview of

conservation activities that are possible in zoos of different sizes.

Authorities could advise small zoos on how to tie in conservation measures according

to their capacity. EAZA has examples of small zoos with a very good conservation

performance.

In addition, more detailed conditions might prove beneficial:

o Obligations regarding the competence of zoo personnel (for example zoo owner,

management, caretakers).

o Obligations concerning zoo premises, enclosures and equipment (for example

adequate housing conditions, enrichment, environmental conditions, veterinary

facilities).

o Licences could be issued only for certain species for which the zoo is competent

and provides appropriate accommodation.

o Economic viability aspects in order to ensure the zoo has sufficient budget to

properly care for the animals and take part in conservation activities.

Consultation of a zoo commission or other existing expert groups

Zoo commissions or other external advisory bodies are used in many Member States

to support licencing authorities in their work.

The legal status of such a body needs to be clear. In the majority of cases, external

expert groups provide reports or opinions, which are taken into account by

authorities, but they don’t have legal enforcement powers.

As external advisory bodies often include former or current zoo professionals or

representatives of animal welfare NGOs, their impartiality needs to be ensured and

conflicts of interested excluded. The legal decision power needs to stay with the

authorities.

In Germany, authorities can benefit from the knowledge of a working group on ‘Zoos

and circuses’ that is established as part of the German Veterinary Association for

Animal Welfare. This participation provided the authorities with increased

knowledge.

EAZA offered to support authorities in finding experts and is already part of expert

panels in different countries.

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For court cases, it is possible to use external experts experienced with the particular

issue of non-compliance, for example animal welfare of a certain zoo animal species.

Involvement of zoo associations and use of their accreditation system

Some Member States use association accreditation systems in their licencing process

as they usually ensure high quality and good compliance with the Zoos Directive’s

provisions.

While authorities may use knowledge from the accreditation reports, this should form

only part of the decision criteria and should not result in zoos inspecting themselves.

The final licencing decision has to be based on an impartial, independent process.

EAZA has its own accreditation system, which takes into account the Zoos

Directive’s legal obligations as well regional or local law. Some zoos share their

EAZA accreditation (screening) reports with local authorities. EAZA is willing to

provide all accreditation report templates to authorities.

In France, the two national zoo associations help to solve problems identified by the

authorities on the ground. EAZA also provides the capacity to improve sub-standard

zoos.

In the Netherlands, reports of the Dutch zoo association are, among other sources

(Zoo Committee report, scientific journals, husbandry guidelines, documents

provided by the zoo), taken into account for the licencing decision.

Regular training

In Germany, authorities attend training courses provided by the national Veterinary

Association for Animal Welfare every other year.

The European Association of Zoo and Wildlife Veterinarian (‘EAZWV’) organises

an annual conference as well as summer schools, which would be relevant for

competent authorities and inspectors. If they receive a request for training from

authorities or zoos operators, EAZWV will do their best to address it.

EAZA offers trainings on a variety of zoo-related topics.

Use of standards and guidance documents

Some Member States have developed minimum accommodations standards or

guidelines that they use in inspections.

Many standards, husbandry manuals or best practice guidelines exist that are

accessible on the internet, developed by different organisations, please see links

throughout the report and Annex III.

Born Free suggested a traffic lights system, which includes minimum standards

(orange), improved standards (yellow) and best practices examples (green).

Non-compliance and zoo closure

Decision-trees for non-compliance show ways for zoos to improve before the

decision to close needs to be taken.

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A multi-stakeholder approach involving authoirities, the concerned zoo, zoo

associations and other zoos, rescue centres and sanctuaries and NGOs is beneficial

in order to bring sub-standard zoos into compliance or to close them.

A protocol for closure should be in place and checked during the licensing (and

following inspection) phase.

The EU Zoos Directive Good Practices Document contains additional information

on zoos closure protocols (contacting other zoos, zoos association, other MS, NGOs).

In Italy, the zoo must prove that it has a written agreement with another zoo that will

take care of the animals in case of closure as part of the licensing process.

Organisations such as AAP, EARS or EAZA are ready to help rehoming animals

Insufficient resources and poor management can lead an institution to bankruptcy

and closure. The financial viability of the zoo owner as well as the business plan of

the zoo could be checked during the licensing process.

Uncontrolled breeding, notably of monkeys, is a recurring issue leading to zoo

closure, and should be identified early as a potential risk.

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3 INSPECTIONS

3.1 PRESENTATIONS AND DISCUSSION

Opening

The session started with a presentation by Milieu, highlighting the intertwined nature of

the process of licensing and inspection and the importance of designing both in a consistent

manner geared towards the nature conservation objectives of the Directive. Presentations

on inspections were given during the afternoon by the Bavarian State Office for Health and

Food Safety (Germany), by a representative of the Irish competent authority, and by a

representative of the European Association of Zoo and Wildlife Veterinarians (EAZWV).

Bavarian inspection system

The Bavarian State Office for Health and Food Safety gave a summary of its inspection

process. The authority is responsible for four big zoos and 100 smaller zoos and animal

parks. Regional and local authorities jointly perform inspections. Inspector teams

consist of veterinarians, personnel from authorities and rarely biologists. Authorities can

involve external experts in special cases and might also be supported by federal state level

experts. Besides the Zoos Directive, inspectors have many other duties, restricting the time

that can be spent on zoo inspections.

Inspections are carried out without prior notice to the zoo. The licencing data is used to

prepare inspections. During the onsite inspections, Bavaria finds the dialogue with animal

caretakers and other zoo employees very important. Inspectors use a standardised

inspection protocol and the German minimum standards for mammals, reptiles, parrots,

ostriches, birds of prey, owls, small granivore birds and ornamental fish. Further to this, the

authority relies on Swiss, Austrian and EAZA standards, guidelines and best practices.

The Bavarian authorities take consistency of inspections and the use of standardised

inspection protocols as very important in order to ensure that the same inspection criteria

apply to different zoos. They prefer to give zoos time to improve and don’t apply penalties

that anyway cannot be paid by the zoos.

Bavaria finds the EU Zoos Directive Good Practices Document very helpful but reiterated

the need for translations, especially for local authorities to use it.

The authority would appreciate increased expertise at national and federal state level, an EU-

wide expert database, more standardised inspection protocols on conservation, education and

animal welfare, the envisaged EU training course as well as more accessible EAZA

guidelines.

In the following discussion, EAZA offered to make more best practice guidelines available.

Eurogroup for Animals referred to a CITES expert database that is being established and

mentioned the European Alliance of Rescue Centres and Sanctuaries (EARS) for

rehoming animals in case of zoo closure.

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The Commission stated that inspectors’ advice to zoos on conservation, captive

programmes or animal welfare is of outmost importance. Hence, it is very useful to engage

with zoos’ personnel during inspections. Most zoos take part in the inspection system now

and can therefore be reached. They benefit a lot from information sharing by the

authorities.

Trainings could make inspection processes more consistent but are difficult to fund. A good

practice example from the nature directives are trainings given by Europarc to protected site

managers.

The best strategy might be to first bring zoos into compliance before enforcement actions

are taken, particularly as the process of zoo closure is quite complex.

Ireland’s outsourced inspection process

Ireland tendered out its inspections process and presented the different steps of such a system

as well as its advantages and shortcomings.

As the National Parks & Wildlife Service’s biodiversity unit responsible for the Zoos

Directive doesn’t have the necessary veterinary expertise to deal with zoo inspections and

all knowledgeable people work for Irish zoos, it was decided to contract the inspectorate.

The resulting inspection process is characterised by the following elements:

Target is to inspect all identified zoos at least once every 12 months;

Two qualified inspectors at each inspection, one of these with expertise in the zoo’s

specialty;

Usually a specialist zoo vet also attends each inspection as well as wildlife rangers

and conservation officers

The qualifications of the zoos inspectors must meet the following criteria:

High level veterinary qualifications (i.e. usually veterinarians);

Zoo management and enforcement qualifications / experience;

Knowledge of CITES and wildlife legislation, as well as BALAI and welfare

legislation;

Experience with invasive animal species (e.g. identification, management, handling);

Captive breeding management programs (EEPs);

Zoo inspectorate personnel are not permitted to work in any zoo in Ireland;

Conflict of interest list is submitted annually by all inspectors.

The inspectorate receives training to ensure consistent application.

The contractor also provides workshops, sets up the authority’s website on inspections

(providing information on the Irish legislation), and offers a wide network of contacts.

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Inspection protocols contain clear, measurable criteria to evaluate the Zoos Directive’s

Article 3 measures. Conservation contribution is evaluated, but husbandry and welfare

aspects are prioritised. The inspectors apply the animal welfare five domains model.

The Irish system emphasises continued progression towards higher standards and a

consistent inspection process. Zoos benefit from information sharing and interaction

with the zoo inspectorate, which implies a strong advice component how zoos could

improve. The biodiversity unit brings in the conservation element and smaller zoos could

link with the Wildlife Service’s local research and conservation projects.

In case of non-compliance, the authority uses an enforcement decision-tree to determine

what are the best ways forward. The main difficulty is to implement closures, where

rehoming is the first priority.

In 2015, Ireland published the Irish Standards of Modern Zoo Practice.

Expertise and support from the EAZWV

The European Association of Zoo and Wildlife Veterinarians (EAZWV) presented their

work and how this could support authorities and stakeholders in better implementing the

Zoos Directive.

The organisation supports veterinarians in any capacity and offers training and summer

schools. It represents 1100 zoo and wildlife veterinarians and has 10 regional sections.

According to EAZWV, effective inspections comprise several criteria, such as adequate

competency of inspectors, a well-designed inspection protocol, ensuring that claims made

by zoos are put into practice or the use of best practices and guidelines. The organisation

recommended the Australian approach of not asking “if” a certain criterion is fulfilled,

but “how”, e.g. how individual or group needs are met.

EAZWV stressed the importance of managing zoos for biodiversity. More conservation

needs to happen through zoos. This might lead to a consolidation of the zoo landscape, with

less zoos that are nevertheless capable of contributing to biodiversity conservation.

Veterinary services need to be competent in assessing conservation issues, as well

animal health and welfare and should therefore receive regular professional training.

Whereas EAZW’s trainings are mainly given by volunteers, if they would receive a request

for a training on Zoos Directive related issues, they would do their best to accommodate it.

EAZWV’s veterinary advisors for EAZA’s EEPs (European Endangered Species

Programmes) could be contacted by authorities in need of particular expertise.

FVE (Federation of Veterinarians Europe) and EAZWV also offer trainings on animal health

law.

Peer-to-peer and training opportunities

VetEffect gave a presentation on peer-to-peer learning opportunities as well as pilot trainings

organised by the Commission.

The TAIEX-Peer-To-Peer instrument funds different activities:

1. Workshops

Most frequently used of the TAIEX instruments; Single or multi-country workshops.

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Normally last two days; 20-30 participants.

Private experts or representatives from zoo associations can only participate and be

reimbursed when they are involved in official tasks (role in licensing and/or

inspection).

2. Study Visits

Employees (maximum three) from a requesting environmental authority go on a working

visit to other EU Member State institutions; two to five days;

3. Expert Missions

Experts from an EU Member State environmental authority visit an environmental authority

in other Member States; two to five days.

TAIEX pays for:

Costs for travel and accommodation for participants in study visits or multi-country

workshops; for participants from the hosting country travel and accommodation is

only financed when the distance between their residence and the venue of the

workshop exceeds a certain minimum.

Working language is English. Interpretation can be financed if duly justified.

TAIEX does not cover costs for the venue, catering or the printing of background

material.

Application

Notify the responsible official at DG ENV about the P2P request. Once DG ENV has

agreed with the application, the applicant should send his request for evaluation to:

[email protected]..

Currently there is a vacancy for the coordinator.

VetEffect supports the applications: [email protected].

Ireland asked if it would be possible that employees from several requesting authorities go

on a study visit to another Member State. According to the rules, this would rather be a

workshop but TAIEX-Peer-To-Peer could be contacted on this issue under the above-

mentioned address [email protected]..

The peer-to-peer instrument is also open to local and regional authorities, which might be

particularly important for federal states.

The Commission will organise four pilot trainings in different EU regions, addressed to

competent authorities, zoos and their associations. The courses will be for 20-30 participants

and last 3.5 days. They are given by independent tutors and follow the train-the-trainers

principle, so that participants will be able to train colleagues in their organisation. The

trainings will be held in zoos and will contain small group exercises and mock inspections.

Training content will cover all Zoos Directive’s provisions and in particular Article 3

conservation measures and effective licencing and inspection systems.

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Details regarding invitations and registrations for the first trainings scheduled in Wroclaw

Zoo on 1 November 2020 will be circulated to meeting participants and published on the

training website.

The group discussed the possible training locations. Instead of having three trainings in the

southern European region, one training could take place further north. Ireland suggested

Dublin Zoo as it is easy to reach by reasonably priced flights and located close to the airport.

The Commission will consider this proposal.

The Commission invited participants to send further suggestions for the training

content, implementation successes and challenges as well as training material such as

inspection protocols to [email protected] and [email protected].

General discussion

The Commission opened the discussion of the afternoon session by summarising the most

prevalent issues that became apparent from stakeholders’ interventions. Important topics

in licencing and inspection identified through the presentations and discussions are the

following:

Zoos’ conservation performance

Capacity of small zoos to contribute to conservation

Keeping animals in appropriate conditions

Better integration of the work of different authorities (notably nature authorities and

veterinary services)

Ways to source and bring in expertise

Effective responses to zoo failures, including zoo closures

Born Free advocated applying minimum accommodation standards while at the same time

offering zoos avenues to improve. It is also possible to have both minimum standards and

best practice examples. The organisation suggested a traffic lights system with minimum

standards (orange), improved standards (yellow) and best practices examples (green).

Species-specific standards might be problematic, as for many species the expertise does

not exist. Even close species within a same group might act very differently and require very

different care.

Eurogroup for Animals suggested to increase inspection frequencies and to adopt more

persuasive penalties. Collection planning should also take into account species that are not

of conservation value, for example rescued animals that could be of high educational

value.

Eurogroup again raised the problem that rescue centres sometimes need zoos licences under

national legislation, yet they are not zoos. Inspections should therefore focus on different

aspects. The organisation would also find thematic working groups helpful.

On the issue of working groups, the Commission replied that it doesn’t have the capacity

and resources to organise additional meetings. The Commission however invited Member

States and stakeholders to have discussions and gather information on certain topics. The

TAIEX-Peer-To-Peer could be a useful tool to do so and stakeholders are encouraged to use

it. VetEffect is ready to support stakeholders on this.

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Matt Hartley mentioned that zoos struggling with animal welfare problems usually do not

contribute to conservation. If they don’t keep animals in good conditions, conservation is

not possible. Consequently, improving animal welfare will facilitate a zoo’s conservation

role.

On the topic of zoo closures, AAP offered to look more closely at the financial

responsibilities from the cases they handled. Money should not be a barrier when it comes

to zoos closures and contingency plans should be in place. AAP will see if they can provide

an overview of costs related to zoo closure.

With a view to the next meeting, Ireland would find it useful to gather information on the

type of failures and breaches, which is linked to the topic of closures and decision-tree

for sanctions.

EAZA saw still shortcomings in defining zoos’ direct contributions to conservation. It

has a document available on ‘how to define contribution to conservation’. It has to be

considered that zoos also fund in situ conservation. EAZA also has members that are very

small institutions and medium size institutions that nonetheless have a conservation strategy.

EAZA will look into existing practices and draft recommendations that could be used in

other zoos. A strategic approach to zoos’ conservation role seems warranted. The zoos

community should participate in the next policy cycle discussion on biodiversity.

Especially in light of the current extinction crisis, zoos should be involved in tackling it.

The Commission found that at EU level, the nature and conservation community is not

aware of the contribution of zoos to their efforts. The zoos community could reach out

more to their environmental colleagues to push for bridges between environmental

policies and zoos management. On the other side, many EU citizens have no idea what the

Natura 2000 network is. Zoos could be a window to nature strategies that could be exploited

to better inform citizens on environmental actions. Zoos could become sustainability

centres, which opens possibility of funding. The Commission inquired if there was any

Member State with a conservation strategy for their zoos.

On this topic, VdZ mentioned that in Germany, zoos are rarely mentioned in biodiversity

policies and they are often not considered by the environmental authorities. Zoos and

national zoos associations could help authorities in highlighting how they can

contribute to nature policy.

The Netherlands referred to existing EAZA collection plans. The Dutch zoo association is

pushing its members to establish national collection plans. Maybe also regional collection

plans could be drafted across Member States. That would benefit the debate on the

conservation strategy and roles of zoos.

Born Free reminded that 80% of zoos are not members of associations and saw the need

to focus on those. Member States might want to exchange experiences with this kind of non-

member zoos. Big zoos being an association member usually contribute much more to the

Directive’s objectives.

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EAZA proposed to make better use of zoo association accreditation standards, as already

discussed in the morning, in order to focus on non-member zoos.

Conclusion

Based on the overall exchanges, the Commission summarised the most important topics

that could be further discussed at the next meeting.

One main theme concerned zoos’ overall conservation role. This covers issues in relation

to better integration of zoos conservation work into national biodiversity policies, zoos’

collection planning, regional collection planning, conservation of locally or regionally

threatened species or educational topics such as pollination or circular economy.

Another strand of interest was the treatment of non-compliant zoos, including types of

non-compliance, key challenges for zoos to comply and criteria and decision trees for

improvements or closure.

The Commission closed the meeting by thanking participants for their attendance as well as

their valuable contributions to the exchanges of knowledge and good practices.

3.2 GOOD PRACTICES

This section provides an overview of good practices extracted from the presentations and

discussions at the meeting. Some good practices overlap with the “Licencing” session and

the reader it therefore referred to that section.

Zoo inspection team/use of external experts

Please see the good practices under “Licencing”.

Ideally, zoo inspectorates involve members with different expertise, particularly

experts in zoo animals, zoo management, biodiversity and conservation issues.

In several Member States, the government bears the cost of hiring external experts

on particular issues regarding licencing, inspections or court cases.

EAZWV offered that authorities could contact their veterinary advisors to EAZA

EEP programmes in particular cases.

Use of existing zoo association accreditation schemes

The fact that a zoo is an accredited member of a recognised zoo association (national

or EAZA) can alleviate the time- and resource-pressure on the inspectorate. In the

Netherlands, the existence of an active accreditation excludes zoos from physical

inspection (unless specific circumstances arise such as complaints from citizens or

an NGO).

As zoo association membership usually ensures compliance with the Zoos Directive

provisions, this could be taken into account during inspections.

Use of existing documents and standards

The same documents as mentioned under “Licencing” may be used.

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The German authorities referred to existing data from the licencing process, expert

opinions on animal health and welfare, the Swiss, Austrian and EAZA husbandry

guidelines and the Zoos Directive Good Practices Document. The country developed

minimum standards for certain species groups, which, although not legally binding,

are used in inspections (mammals, reptiles, parrots, ostriches, birds of prey, owls,

small granivore birds and ornamental fish). The German representative offered to

share these standards.

Ireland issued the “Irish Standards of Modern Zoo Practice”.

Use of well-designed and consistent inspection protocols

Standardised inspection protocols, including clear and measurable criteria to evaluate

Article 3 measures.

Questions asked in inspection protocols to be rather open, than just “yes-no” tick

boxes. This enables the authority to better evaluate how and to what extent a certain

conservation obligation is fulfilled.

Inspections need to prove that measures indicated by the zoo are really put into

practice and show measurable effects and impacts.

Trainings

Although they are regarded as extremely useful and necessary, funding at national or

regional level might be difficult. The Commission will offer four pilot trainings addressed

to competent authorities, zoos and their associations between 2020 and 2022.

Tendering out the inspectorate

Please see the Irish presentation and discussion. The system enables high quality inspections

with clear criteria and delivered by experts in the field.

Coordination between different authorities

Coordination between nature authorities and veterinary services make the licencing and

inspection systems more effective and enable inspectors to judge zoos’ conservation

performance.

Zoos’ conservation performance and inspectors’ advisory role

Inspections need to be more focused on evaluating zoos’ contribution to

conservation.

Different authorities should integrate zoos conservation contribution into national

biodiversity policies, strategies and action plans.

Integration of ex situ and in situ and an overall strategy for zoos’ conservation role.

Zoos community to reach out more to nature protection authorities and organisations.

Better use of zoos’ collection as well as national and regional collection planning.

An inspectorate that is informed about a country’s biodiversity policies is much

better equipped to steer zoos in their conservation activities.

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Inspectors’ advice to zoos on conservation, captive breeding programmes or animal

welfare is of outmost importance for zoos to improve and become more engaged in

conservation.

Inspectors could also liaise with zoo associations in order to receive information on

zoos conservation actions, conservation strategies or collection planning.

EAZA could provide a document on how to define contribution to conservation.

Also small zoos can effectively contribute to conservation at local or regional scale.

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4 FOLLOW-UP ACTIONS

The meeting has shown that a wealth of information and good practices exist in Member

States and stakeholder organisations, which could be used to facilitate better

implementation of the Zoos Directive. This knowledge will feed into follow-up actions in

the form of subsequent meetings, training, peer-to-peer sharing and documents exchange.

4.1 NEXT MEETINGS

Following this first meeting of Member States and stakeholders on the implementation of

the Zoos Directive, the European Commission will organise two additional meetings, in

2021 and 2022, as forums of exchange of knowledge, experiences and best practice. The

topics for discussion at those meetings have not yet been fixed.

However, as concluded by the Commission, two major themes evolved during the

discussions of the first meeting that would need further attention:

One topic concerned zoos’ overall conservation role and performance. This covers issues

in relation to better integration of zoos conservation work into national biodiversity policies,

better assessment of zoos’ conservation performance throughout the licencing and inspection

process, better coordination between nature authorities and veterinary services, zoos’

collection planning, national and regional collection planning, conservation of locally or

regionally threatened species and the conservation contribution of small zoos.

Another strand of interest was the treatment of non-compliant zoos, including types of

non-compliance, key challenges for zoos to comply and criteria and decision trees for

improvements or closure. Stakeholders are interested in gathering information and sharing

experience on attributed costs of zoo closures, on failures and breaches that they have been

dealing with, and how they addressed them in different Member States.

4.2 TRAININGS

Under the current contract held by VetEffect and Milieu, trainings of competent authorities,

zoos and their associations are scheduled to take place in four different geographical

regions, each covering several Member States. The trainings will involve 20-30 participants

and courses will take 3-4 days. Trainings will be in English and led by independent tutors.

They will combine theory and practice with the practical sessions organised in zoos,

including mock inspections, case studies and practical examples. The dates and places of the

trainings are currently scheduled as follows:

Date Country Zoos

November

2020 Poland Wroclaw Zoo

April

2021 Spain Valencia Biopark

September

2021 Romania Brasov Zoo

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November

2022 Italy Aquaria di Genova/Verona parco Naturame Viva

Each training will cover the following topics (for more details, please see slides on

‘Training’):

Introduction to the Zoos Directive and legislative framework;

Implementation of the Zoos Directive;

Definitions and interpretation (Article 2);

Article 3 conservation measures:

Ex situ and in situ conservation including captive breeding and reintroduction;

Research and education;

Accommodation of animals and veterinary care;

Preventing the escape of animals including invasive alien species;

Record keeping.

Inspections (expertise, process, coordination, forms, standards);

Enforcement (recommendations and conditions, penalties, closures).

Participants raised the issue of proximity of the training venues to airports. Dublin was

suggested as a possible training location in the more northern region.

The dates, places and topics of the trainings have not yet been fixed. If stakeholders have

suggestions, please address them to: [email protected];

[email protected].

4.3 TECHNICAL ASSISTANCE AND INFORMATION EXCHANGE (TAIEX)

4.3.1 Expert missions, study visits and workshops

A new tool that will be explored to support Member States competent authorities in better

implementation of the Zoos Directive is the TAIEX-EIR P2P programme1. TAIEX

(Technical Assistance and is an Instrument of the Commission's Directorate-General for

Neighbourhood and Enlargement Negotiations that was established more than twenty years

ago. TAIEX supports public administrations in the enlargement and neighbourhood

countries in the approximation, application and enforcement of the EU acquis through peer-

to-peer exchanges of public officials. The TAIEX-EIR P2P builds on the success of the

TAIEX-REGIO P2P Tool and applies it to environmental laws and policies in the context of

the EIR, which includes conservation and biodiversity, key elements of the Zoos Directive.

Three possibilities of information exchange are financially supported under TAIEX:

Expert Missions - Experts from an EU Member State environmental authority visit

an environmental authority in other Member States that have requested peer advice

and exchange of experience on a specific topic. Expert missions can last between two

1 http://ec.europa.eu/environment/eir/p2p/index_en.htm

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to five days;

Study Visits - Employees (maximum three) from a requesting environmental

authority go on a working visit to other EU Member State institutions to learn from

peers and exchange good practices. Study visits can last between two to five days;

Workshops - Workshops with environmental authorities from one or several EU

Member States (single or multi-country workshops) can be organised in a requesting

institution. Workshops would normally last two days.

4.3.2 Application procedure

If a stakeholder is interested by either of these options, the application procedure is as

follows.

1. Application - Notify the responsible official at DG ENV about the P2P request. Once

DG ENV has agreed with the application, the applicant should send his request for

evaluation to: [email protected].

2. Evaluation - After submission, the request is being evaluated and adjusted in an

exchange between the applicant and the responsible EU official. Upon award, the

activity can start. After completion of the activity, the applicant must send to TAIEX

the reimbursement claim with receipts/evidence etc.

Would you need help with the applications, VetEffect can support you - please contact

[email protected]

4.3.3 Costs covered

While TAIEX does not cover costs for the venue, catering or the printing of background

material, it covers the costs of:

Travel and accommodation for participants in study visits or multi-country

workshops; for participants from the hosting country travel and accommodation is

only financed when the distance between their residence and the venue of the

workshop exceeds a certain minimum.

Interpretation can be financed if duly justified. The working language is English.

4.4 SHARING PLATFORM

The Zoos Directive evaluation underlined that developing cooperation and coordination

between Member States and stakeholders is paramount to fully reach the Directive’s

objectives. The discussions at the meeting highlighted that an important number of

documents have been drafted and used by Member States and stakeholders but are not

necessarily known by all authorities (see a non-exhaustive list in Annex III). Besides the

meetings, trainings and P2P mechanisms explained above, the Commission’s CIRCABC

platform will be used to share and disseminate existing documents such as legislation,

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guidelines, checklists, decision-trees, protocols, publications on licensing, inspection, or

conservation measures. For this purpose, a Zoos Directive space with restricted access

through the ECAS system will be established.

Would you be interested in contributing information to be shared on CIRCABC, please

send the documents or links to [email protected]; [email protected].

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ANNEX I – LIST OF ATTENDING PARTICIPANTS

Country/ organisa

Austria

Belgium

Bulgaria

Cyprus

Czechia

Estonia

Finland

France

Germany

Greece

Ireland

Italy

Latvia

Lithuania

Netherlands

Poland

Slovak Republic

Slovenia

Spain

Sweden

European Commission

AAP

Born Free

EAAM

EAZA

EAZWV

Eurogroup for Animals

Four Paws

FVE

Milieu

Odisee College

VdZ

VetEffect

Zoo and Wildlife Solutions

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ANNEX II – AGENDA

First Member State and stakeholder meeting on better implementation of the Zoos Directive

18 February 2020, Meeting Centre Albert Borschette, Room 3B, Rue Froissart 36, 1040 Brussels

9:00 – 9:30 Welcome coffee - Registration

9:30 Adoption of the Agenda and introduction to the meeting

09:45 Introduction to morning topic: Licensing

Milieu

10:15 Presentation by Deborah Infante, Direction départementale de la

protection des populations de la Seine et Marne, France

10:30 Presentation by Astrid Rox, Ministry of Agriculture, Nature and Food

Quality, and Jorden Jansen, Chair of the Zoo Commission, The

Netherlands

10:45 Presentation by Myfanwy Griffith, European Association of Zoos and

Aquaria (EAZA)

11:00 Presentation by Olga Martin Carrera, Animal Advocacy and Protection

(AAP)

11:15 Short break

11:30 Discussion of remaining issues and identification of potential follow-up

actions and possible mechanisms

12:45 – 13:45 Lunch break

13:45 Introduction to afternoon topic: Inspection

Milieu

14:15 Presentation by Johanna Moritz, Bavarian State Office for Health and

Food Safety, Germany

14:30 Presentation by Alan Moore, Biodiversity Policy Unit, Department of

Culture, Heritage and the Gaeltacht, Ireland

14:45 Presentation by Stephanie Sanderson, European Association of Zoo and

Wildlife Veterinarians (EAZWV)

15:00 Trainings and peer-to-peer learning: training priority topics and regions

VetEffect

15:30 Coffee break

15:45 Discussion of remaining issues and identification of potential follow-up

actions and possible mechanisms

17:00 Meeting ends

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ANNEX III – EXISTING RESOURCES

Description Author Where to find it

Decision tree for zoos licensing Dutch authorities Slides in Annex III

Rescue centres database European Alliance on

Rescue centre and

Sanctuaries

https://search.ears.org/

EU Zoos Directive Good Practices

Document

European Commission,

VetEffect

https://ec.europa.eu/environment/nature/pdf/EU_Zo

os_Directive_Good_Practices.pdf

Zoos Directive Evaluation Report https://ec.europa.eu/environment/nature/legislation/

refitzoosdirective/pdf/SWD%20Zoos%20Directive

%20Evaluation.pdf

https://ec.europa.eu/environment/nature/legislation/

refitzoosdirective/pdf/Final%20Report%20Zoos%2

0Directive_Full_Milieu_20170816.pdf Standards for the Accommodation and

Care of Animals in Zoos and Aquaria

(2014 updated 2019)

EAZA https://www.eaza.net/assets/Uploads/Standards-

and-policies/2019-04-EAZA-Standards-for-

Accomodation-and-Care.pdf

Research Standards (2003) EAZA https://www.eaza.net/assets/Uploads/Standards-

and-policies/EAZA-Research-Standards-2003.pdf

Conservation Standards (2016) EAZA https://www.eaza.net/assets/Uploads/Standards-

and-policies/EAZA-Conservation-Standards-

2016.pdf

Conservation Education Standards

(2016)

EAZA https://www.eaza.net/assets/Uploads/Standards-

and-policies/EAZA-Conservation-Education-

Standards-2016-09.pdf

Guidelines on the definition of a direct

contribution to conservation (2015)

EAZA https://www.eaza.net/assets/Uploads/Guidelines/Co

ntribution-to-conservation-definition-2015-04-

Revisions.pdf

Accreditation manual (2018) EAZA https://www.eaza.net/assets/Uploads/Accreditation/

EAZA-Accreditation-Manual-2018.pdf

Zootier-Lexikon Peter Dollinger, Bern Zoo https://www.zootier-

lexikon.org/index.php?option=com_k2&view=item

&layout=item&id=5891&Itemid=684

Swiss law on animal protection Switzerland https://www.blv.admin.ch/blv/fr/home/tiere/tiersch

utz/heim-und-wildtierhaltung.html

https://www.admin.ch/opc/de/classified-

compilation/20080796/index.html#app2ahref0

Austrian animal Welfare Act https://www.ris.bka.gv.at/GeltendeFassung.wxe?Ab

frage=Bundesnormen&Gesetzesnummer=2000386

0

Facility assessment Australia https://www.environment.gov.au/biodiversity/wildli

fe-trade/non-commercial/zoos/facility-assessment

National Zoo Biosecurity Manual Self-

Audit checklist (2011)

Australia https://www.farmbiosecurity.com.au/wp-

content/uploads/2019/03/Australias-National-Zoo-

Biosecurity-Manual-Self-audit-Checklist.pdf

Irish Standards of Modern Zoo Practice

(2015)

Ireland https://www.npws.ie/sites/default/files/publications/

pdf/ISMZP%202016.pdf

Secretary of State’s Standards of

Modern Zoo Practice (2012)

United Kingdom https://assets.publishing.service.gov.uk/government

/uploads/system/uploads/attachment_data/file/6959

6/standards-of-zoo-practice.pdf

Zoos experts committee handbook

(2012)

United Kingdom https://assets.publishing.service.gov.uk/government

/uploads/system/uploads/attachment_data/file/6961

1/pb13815-zoos-expert-committee-handbook1.pdf

Zoo Biology Scientific journal https://onlinelibrary.wiley.com/journal/10982361

Journal of Zoo and Aquarium Research Scientific journal https://www.jzar.org/jzar

International ZOO Yearbook

Scientific journal https://zslpublications.onlinelibrary.wiley.com/jour

nal/17481090