Consultation on the unique identification of juvenile tortoises in wildlife trade
IZVG's Zoo and Aquarium Consultancy
The Joint Nature Conservation Committee (JNCC) has commissioned us to conduct a study to identify potential methods of permanently and uniquely marking juvenile Testudinids (tortoises) that are too small to be safely fitted with a microchip transponder.
European regulations require that live Annex A vertebrates being used for commercial purposes, other than captive born and bred birds, be marked by a uniquely numbered unalterable microchip transponder, or, where this method is not appropriate because of the physical or behavioural properties of the specimen/species, the specimen shall be marked by means of a uniquely numbered ring, band, tag, tattoo or similar means, or be made identifiable by any other appropriate means.
Advice provided by veterinary experts in the UK in 1998 recommended that tortoises with a shell length of under 100mm (measured along the plastron, the flat under part of the shell) were too small to be safely fitted with a microchip transponder. In the absence of an acceptable alternative form of marking, the UK policy has been that Annex A tortoises in trade, under 100mm shell length, are not required to be marked.
Whilst there has been general agreement throughout the EU that juvenile tortoises cannot be safely fitted with a standard microchip, alternative marking requirements and conditions have not been applied uniformly, with some Member States accepting photographic identification as an acceptable alternative means of linking a specimen to a permit. However, this approach (of photographic identification) is difficult to administer and is considered impractical by UK enforcement agencies. As a result it is not considered an acceptable approach in the UK.
As tortoise species have declined, both in the wild and in terms of their availability to trade, the selling price has increased, which is likely to have encouraged illegal trade. Until a method of marking juvenile tortoises is found and accepted by all EC Member States, enforcement of trade will continue to be difficult, which could cause severe declines of some species in the wild.
The JNCC therefore aims to identify a method of uniquely and permanently marking tortoises that are too small to be fitted with a standard microchip transponder. Such a marking method must:
- allow individuals to be uniquely identified
- be permanent or semi-permanent (to last at least until the tortoises reach 100mm in length)
- be unalterable and tamper proof
- be of low cost to apply in large numbers
- not affect physical or behavioural properties of the tortoise
- be suitable for juvenile tortoises under 100mm plastron length, and
- be practical to implement.
- It is preferable that the marking method can encode information to identify the breeder and ISO code of the country where the specimen was marked.
We are currently carrying out a consultation to ask the opinion of interested parties and stakeholders regarding possible marking methods for juvenile tortoises. We would welcome your views and comments on this issue. In particular, we would welcome comments on:
- The importance of identifying a marking method suitable for use in small tortoises
- Any limitations of currently known marking techniques that we should be aware of
- The practicalities of implementing a new marking method for small tortoises
- The numbers of unmarked tortoises – both below 100mm and above 100mm in circulation for commercial purposes
- How often you mark tortoises on attaining 100mm in length, and for what purpose
- Proposals for novel marking methods for consideration by our study.
The list of tortoise species included in Annex A of the EC Wildlife Trade Regulations which require marking under the legislation can be found here.
The text of the relevant legislation is here
Responses
Please send responses to office@izvg.co.uk before August 8, 2008.
It is possible that JNCC will wish to make responses to this consultation publicly available. The information contained in responses may be used in the final report and may be made public.
If you do not consent to this, you must clearly request that your response be treated confidentially. Automatic confidentiality disclaimers generated by e-mail signatures will not be considered as a request. You should be aware that there may be circumstances in which JNCC will be required to communicate information to third parties on request, in order to comply with its obligations under Freedom of Information legislation.
Thank you for your help in this matter. If you have any queries, please e-mail Penny Cusdin, or ring her on 1535 661298.
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