To Mr Varhelyi - EU Commissioner - Animal Health & Welfare,

On behalf of Responsible Reptile Keeping’s European and global membership, we express deep concern over RPA’s June 10th presentation on the feasibility of an EU-wide positive list.

Please see our attached open letter, which will be circulated tomorrow. It highlights the urgency with which RPA must address the major legal, scientific, economic, ecological, and welfare issues these lists pose, including:

• Current positive lists have failed

• Positive lists are unenforceable

• Positive lists curtail science advancement

• Positive lists make dispersal of knowledge and best practices impossible

• Positive lists harm conservation

• Positive lists are unnecessary due to existing laws

• Positive lists are unnecessary as there is no significant problem to solve

• Positive lists create poor welfare, eliminating access to vets and expert help

• Positive lists promote illegal wildlife trade

• Positive lists send keepers underground

• Positive lists cause harm to mental health

• Positive lists cause harm to the economy, here and in other countries

• Positive lists are plagued by legal issues

• Positive lists create political unrest

• Positive lists are an unjustified curtailment of rights

• Positive lists are disproportionate and unfair

We stand ready to support science-based policymaking and can provide strong evidence for our position. To this end, we have prepared a detailed response to guide RPA’s future work, which will be sent to them and the Commission shortly.

Ignoring expert input leads to policy failure, and regulation without stakeholder support will not succeed.

In short, positive lists are alarmingly unworkable and will face firm opposition.

Tony Wigley
Co-founder of Responsible Reptile Keeping