It’s time to end the UK Primate Pet Trade It’s time to end the UK Primate Pet Trade
WILD FUTURES IS COMMITTED TO PROTECTING PRIMATES AND HABITATS WORLDWIDE. Wild Futures is a UK registered charity founded upon five decades of experience as a leader in the field of primate welfare and conservation, environmental education, and sustainable practice. The Wild Futures Monkey Sanctuary in Cornwall, has an international reputation for the quality of care, enclosure design and innovative management techniques afforded to the monkeys there. Open to the public for seven months a year, the Sanctuary offers a unique insight into primate conservation and welfare issues.
1 | It’s time to end the UK Primate Pet Trade
Dr Jane Goodall DBE, Primatologist
“I have no hesitation in stating, categorically, that primates should not be kept as private pets. Almost all primates are social animals, and need to be with others of their kind for their mental and physical well-being. I have visited many people in different parts of the world who have, mistakenly, bought a primate. I have never seen a situation where the primate was in a good condition. It is very important that better information is published regarding this. I sincerely hope that a ban on private ownership of primates as pets will be introduced.”
Bans have successfully been implemented in at least 15 European countries1, Australia, and in various U.S. states. So far, there has been no evidence of significant underground trade.
Ian Redmond
OBE, Primatologist, Biologist and Advisor to the UNEP Great Ape Survival Project (GRASP) “All primates are intelligent social animals and keeping them in captivity seldom gives them the quality of life they deserve. Even when captive bred, young primates already having a place in a social group are taken from their mothers for the pet trade, which causes stress to both the youngster and mother, perpetuating the cycle of cruelty. Anyone who loves primates should support conservation programmes, not keep them as pets.”
Stephen Fry Actor
“We are meant to be a nation of animal lovers, so why the trade in a wild, social animal with complex needs is still legal, continues to astound me. Joey’s story is not unique – many of the monkeys rescued by Wild Futures have their own terrible tales. Taking part in this project was important to me and I sincerely hope that many people are moved to support Wild Futures’ work, so that the charity can campaign to put an end to the trade and rescue more monkeys in need.”
Julie Walters
CBE, Actress & Comedienne “Having witnessed first-hand the rescue and rehabilitation work that the Wild Futures’ dedicated team carries out, I have no hesitation in offering my support to their valuable efforts to protect primates and habitats, and I wish their campaign to end the primate pet trade every success.”
1. RSPCA. (2014) ‘Do You Give a Monkey’s? [Online] Available from: http://www.rspca.org.uk/adviceandwelfare/pets/other/primates [accessed: 5th November 2014]
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INTRODUCTION The aim of this document is to introduce a number of case studies that will help demonstrate that the primate pet trade is a significant animal welfare problem in the UK. This problem cannot be mitigated or remedied within the existing framework of legislation; what is in place is disjointed, ambiguous, contradictory and ineffective. The Government has stated that its animal welfare policies are to be based on evidence.2 Evidence submitted to the Environment Food and Rural Affairs (EFRA) Select Committee illustrated how the current regulatory framework is failing to protect primates from harm3 ; on the other hand, evidence of “specialist keepers” who have been able to successfully meet the needs of the primates in their care has not been presented. The Government’s response to the EFRA Committee’s Eleventh Report of Session 2013–14 (Primates as Pets) was published in September 2014 and indicated that minimal action was required in order to address concerns about the UK primate pet trade4. The Government commented on the recommendations made by the EFRA Committee following the inquiry that was launched late 20135. Here we address several of those comments.
2. Defra. (2014) Policy: Protecting Animal Welfare. [Online] Available from: https://www.gov.uk/government/policies/protecting-animal-welfare [Accessed: 20th October 2014]. 3. House of Commons Select Committee. (2014) Primates as Pets (Oral and Written Evidence). [Online] Available from: http://www.parliament.uk/business/committees/ committees-a-z/commons-select/environment-food-and-rural-affairs-committee/inquiries/parliament-2010/primates-as-pets/?type=Oral#pnlPublicationFilter [Accessed: 3rd November 2014]. 4. Defra (2014) Primates as Pets: Government’s response to the Committee’s Eleventh Report of Session 2013-2014. [Online] Available from: http://www.publications.parliament. uk/pa/cm201415/cmselect/cmenvfru/656/656.pdf [Accessed: 3rd November 2014]. 5. Defra (2014) Primates as Pets: Government’s response to the Committee’s Eleventh Report of Session 2013-2014. [Online] Available from: http://www.publications.parliament. uk/pa/cm201415/cmselect/cmenvfru/656/656.pdf [Accessed: 3rd November 2014].
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Wild Futures carries out annual research on licensing for primates under the Dangerous Wild Animals Act. Data has been collected each year since 2005, using the Freedom of Information Act 2000. From the information gathered Wild Futures believes that there are around 5000 privately kept primates in the UK 6, 7. LICENCES ISSUED UNDER THE DWA ACT 2010-2014*
LICENSED PRIMATES IN 2014
Total number of primates: 269 *data collected by Wild Futures
No non-human primate species has ever been domesticated; comparisons with cat or dog keeping are meaningless. Although there are cases in which well meaning owners of domesticated animals cause suffering by failing to meet their pets’ needs, there is also plenty of evidence that these animals, having adapted to lives in domestic environments over the course of thousands of years, can and often do thrive in such environments. There is no evidence that this is the case for any primate species. It has been recognised by governments8, academics9, veterinarians10, and even primate owners11 that primates do not make good pets, due to inherent and substantial compromises to animal welfare, human safety, and nature conservation. The experiences of sanctuaries around the world attest to this unsuitability.
6. RSPCA & Wild Futures (2009) Primates as pets: Is there a case for regulation? 7. This estimate includes species removed from the list of those requiring licences under the Dangerous Wild Animals Act in 2007 , (i.e. squirrel monkeys, tamarins), but doesnot include the most commonly kept primates (marmosets), because they have never been listed and are therefore impossible to account for using this method. Nevertheless,marmosets are clearly abundant in the UK pet trade, accounting for a large portion of the RSPCA’s actions involving pet primates, calls to Wild Futures, and commonly appearingin media stories of neglect or mistreatment. These estimates also allow for apparent high levels of non-compliance for DWAA licensing; See page 6 8. Defra (2014) Primates as Pets: Government’s response to the Committee’s Eleventh Report of Session 2013-2014. [Online] Available from: http://www.publications.parliament. uk/pa/cm201415/cmselect/cmenvfru/656/656.pdf [Accessed: 3rd November 2014]. 9. Warwick, C., Arena, P. C., Steedman, K. & Jessop, M. A review of captive exotic animal-linked zoonoses. Journal of Environmental Health Research 10. EFRA (2014) BVA Submisson to EFRA inquiry into the keeping of primates as pets. [Online] Available from http://data.parliament.uk/writtenevidence/committeeevidence.svc/ evidencedocument/environment-food-and-rural-affairs-committee/primates-as-pets/written/5183.html [Accessed: 3rd November 2014] 11. Daily Mail (2013) The Horror of suburbia’s squalid pet monkey trade: Thanks to stars like Justin Bieber the animals are all the rage, but behind the fad is shocking cruelty. [Online] Available from: http://www.dailymail.co.uk/news/article-2530146/Thanks-stars-like-Justin-Bieber-pet-monkeys-rage-fad-cruelty.html [Accessed: 4thNovember 2014]
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The EFRA inquiry into the keeping of primates as pets was launched in December 2013. This inquiry set out to examine the issues around this subject in the UK and whether or not a ban should be introduced. Following the written and oral evidence gathered, the Committee found scope for improvement in the regulatory framework covering the keeping of primates as pets and its implementation. The Committee was of the opinion that additional research into the numbers of primates kept as pets was needed and recommended some minor changes12.
The Code of Practice for the Welfare of Privately Kept Non-Human Primates (Code of Practice) was developed in 2010 in response to concerns about the welfare of primates being kept as pets and was supposed to provide additional protection for all primates, including those removed from the schedule in the 1976 Act13. It is stated that “Primates should not be considered as pets in the accepted sense of the word�14. It was believed that the Code of Practice would restrict the keeping of primates to zoos, scientific institutions and specialist keepers15. Since 2010, the number of primates has been relatively stable and primates continue to be kept in unsuitable environments. The Code is scheduled for review in 2015. The EFRA Committee recommended that the Government takes this opportunity to ensure that the Code of Practice is drafted in a clear and precise manner that makes it easy to enforce and comply with.
12. Efra (2014). Primates as pets. [Online] Available from: http://www.parliament.uk/business/committees/committees-a-z/commons-select/environment-food-and-rural-affairscommittee/news/primates-as-pets-publication-of-report/ [accessed: 1st November14] 13. Defra (2009), Impact Assessment of the Code of Practice on the Welfare of Privately Kept Non-Human Primate. [Online] Available from http://webarchive.nationalarchives.gov. uk/20130123162956/http:/www.defra.gov.uk/corporate/consult/welfare-cop-primates/ia-primates.pdf [Accessed:2nd November 2014] 14. Defra (2010). Code of Practice for the Welfare of Privately Kept Non-human Primates. 15. Efra (2014). Primates as pets. [Online] Available from: http://www.parliament.uk/business/committees/committees-a-z/commons-select/environment-food-and-rural-affairscommittee/news/primates-as-pets-publication-of-report/ [accessed: 3rd November14]
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The Government response to the Committee’s Eleventh Report of Session 2013–14 stated: “…there is no evidence to support the higher level estimates of the numbers involved which might justify the considerable effort and public expense involved in research in this area... The Government notes the evidence from Andrew Greenwood of the British Veterinary Zoological Society that “the numbers are way overestimated, possibly by a factor of 10. The numbers of primates in this country is probably fewer than 1,000.”16 It is important to note that although the higher estimates given for the number of privately kept primates currently in the UK are just that – estimates – they are based upon the best (and only) available data. The estimate provided by Wild Futures and the RSPCA was based in part on non-compliance rates suggested by “animal-keeping organisations and the pet trade” in Dr Greenwood’s paper17, but the existence of high non-compliance rates for primates is well borne out by data from Wild Futures’ rescue work and that of the RSPCA18. On the other hand, Wild Futures has seen no evidence supporting the claim that there are fewer than 1000 privately kept primates in the UK at this time. But if it is supposed that this number is correct, then there is still a grave cause for concern. According to the RSPCA’s latest report19, over the last ten years, they have been contacted with concerns about approximately 94 individual primates per year. This would indicate a serious problem that needs addressing. Furthermore, over the past ten years, the RSPCA has been contacted with concerns about 937 individual primates20. If survivorship amongst the majority of privately kept primates is good, then there should be close to 900 in the UK at present, at least. If the estimate that the Government seems inclined to accept is correct, and there are less than 1000 privately kept primates in the UK, then as only 269 primates were licensed in 2014, 71% of the 937 are unaccounted for via the DWAA; the authorities do not know the whereabouts of the majority of these animals, but there have been welfare concerns expressed about nearly every single one of them. Whilst the estimated numbers may be in dispute, what is important is that these primates, whether there are one hundred or ten thousand of them, face a disproportionately high chance of welfare compromise – from which the Animal Welfare Act (theoretically) should be protecting them.
16. Parliament UK. (2014) Primates as pets: Government responds to the Committee’s report. [Online] Available from: http://www.parliament.uk/business/committees/committeesa-z/commons-select/environment-food-and-rural-affairs-committee/news/primates---government-response-pub/ [Accessed: 1st November 2014]. 17. Greenwood, A., Cusdin,P &Radford, M.(2001) Effectiveness study of the Dangerous Wild Animals Act 1976: DEFRA research contract CR0246. 18. Wild Futures & RSPCA. (2009) Primates as pets: Is there a case for regulation? [Online] Available from http://wildfutures.s3.amazonaws.com/wpcontent/blogs.dir/1/ files/2009/09/PrimatePack_minusRegulatoryOptions.pdf [Accessed: 1st November 2014] 19. RSPCA. (2014) ‘Do You Give a Monkey’s? [Online] Available from: http://www.rspca.org.uk/adviceandwelfare/pets/other/primates [accessed: 24th October 2014] 20. RSPCA (2014) ‘Do You Give a Monkey’s?. [Online] Available from: http://www.rspca.org.uk/adviceandwelfare/pets/other/primates [accessed: 24th October 2014]
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The Government response to the Committee’s Eleventh Report of Session 2013–14 stated that the Pet Animals Act 1951 “provides appropriate protection for the welfare of animals sold as pets” As the Government has pointed out, the Pet Animals Act defines a pet shop as the “carrying on at premises of any nature (including a private dwelling) of a business of selling animals as pets…” However, the Act also states that “a person shall not be deemed to keep a pet shop by reason only of his keeping or selling pedigree animals bred by him, or the offspring of an animal kept by him as a pet”21. This proviso ensures that very few breeders or dealers of primates are licensed under the Act, and therefore remain entirely unregulated. In 2010, only 5 primate breeders in the UK were licensed under the Pet Animals Act22. In a recent case brought to the attention of Wild Futures, a breeder has been keeping marmosets since at least 200823. Baby marmosets are advertised for sale on the internet and on the 2nd of November 2014, it is mentioned that “there has (sic) been some babies born within the past few weeks that will be available and ready to go in 7 weeks”24. Wild Futures was told that this person does not have a Pet Animals licence25; they believe they are exempt due to the definition of a pet shop, as quoted above. Some of the marmosets sold by this person have ended up being kept on their own26.
(Screenshot taken on the 2nd of November 2014) Marmosets for sale offer
These primates have been failed and have not been provided with the appropriate protection. The Pet Animals Act did not protect them when they were sold as pets nor did the Animal Welfare Act.
Many of the major UK animal welfare organisations, the International Primatological Society, the Primate Society of Great Britain and the British Veterinary Association have all called for an end to the trading and keeping of primates as pets.27
21. Pet Animals Act, 1951.London:HMSO 22. Wild Futures, Unpublished data 23. Marmosetdiets (2014) Welcome to Marmoset diets. [Online] Available from: http://www.marmosetdiets.com/about-us.html#.VFiicjSsXKN [Accessed 4th November 2014] 24. Marmosetdiets (2014) Welcome to Marmoset diets. [Online] Available from: http://www.marmosetdiets.com/video-s-of-our-marmosets-9th-february-2014-.html#.VFijsDSsXKM [Accessed 4th November 2014] 25. Personal communications, Wild Futures 26. Marmosetdiets (2014) Welcome to Marmoset diets. [Online] Available from: http://www.marmosetdiets.com/read-your-comments-about-us-.html#.VFij7TSsXKM [Accessed 4th November 2014] 27. Parliament UK. (2014) Efra Inquiry. [Online] Available from: http://www.parliament.uk/business/committees/committees-a-z/commons-select/environment-food-and-ruralaffairs-committee/inquiries/parliament-2010/primates-as-pets/?type=Written#pnlPublicationFilter [Accessed 11th November 2014]. IPS. (2014) Private Ownership of Nonhuman Primates. [Online] Available from: http://www.internationalprimatologicalsociety.org/PrivateOwnershipOfNonHumanPrimates.cfm. [Accessed 11th November 2014].
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The Government response to the Committee’s Eleventh Report of Session 2013–14 stated that forthcoming guidance on the Dangerous Wild Animals Act 1976 will include: “…a reference to the potential use of zoo inspectors or zoo vets for accommodation inspections which involve the more exotic species, such as primates, prior to the grant or renewal of a licence.” At present, a DWA licence may legally be granted only if “a veterinary surgeon or veterinary practitioner has inspected the premises where the animal is held”28. Regardless of this requirement, local authorities regularly fail to ensure that such inspections take place, and may ignore the outcome of such inspections when they have occurred. It is doubtful that further (optional) guidance will achieve much where primary (mandatory) legislation has failed. Additionally, such guidance would not offer any additional protection to the large proportion of privately kept primates that are unaccounted for under the DWAA (see page 4).
Failure to provide veterinary inspections Canterbury has been issuing a licence for capuchin monkeys since before 2009, (the first year for which Wild Futures holds detailed information for this council). Yet by its own admission, Canterbury Council has not provided a veterinary inspection since the initial granting of the licence, more than ten years ago. They stated that they would arrange for a veterinary inspection, “if we identified any concerns during subsequent renewal visits”, yet even with the apparent passing from a pair of monkeys to a singly kept monkey (the licence has been issued for a single monkey since 2012), no such concerns seem to have been identified. Canterbury is not the only authority failing to ensure that veterinary inspections are conducted according to requirements; in response to the same query, Havant Borough Council replied that their animal welfare and licensing warden does the inspections and if she has any doubts she will then contact the vet29. In 2014, 12 other responding authorities that had granted licences for primates failed to provide reports, either giving no explanation for the absence of a report, or stating that “no report was held”30.
28. Dangerous Wild Animal Act, 2006.London:HMSO 29. Wild Futures (2014), unpublished data 30. Wild Futures 2014, unpublished data
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Licences granted despite poor inspection outcome Horsham District Council has been issuing licences for 2 lemurs since at least 2005 (the first year for which Wild Futures holds detailed information for this council). A veterinary inspection report provided to Wild Futures in July 2013 noted a lack of environmental enrichment and stated that the lemurs “would be better off if a good home can be found for them”31. A subsequent report (dated 2014) states that the owner “does not at present have the resources to comply with the animals’ welfare needs, nor to ensure that the public are not put at risk, in compliance with the Dangerous Wild Animals Act… the circumstances cannot be described as ‘good practice’, in the modern keeping of captive primates.” Nevertheless, a new licence was granted for the lemurs to be kept and will remain valid until December 2015.
Social primates continue to be kept on their own
The Government’s response to the Committee’s Eleventh Report of Session 2013–14 stated that: “keeping a primate as a pet would compromise its welfare and therefore be an offence under the Animal Welfare Act 2006”. In addition, Lord De Mauley, Parliamentary Under Secretary for Defra, testified that primates must be kept “in social groups of their own species and in large enclosures”, that “keeping primates in a domestic setting in isolation… is already against the law” and that “It would be extraordinarily difficult to do that under the Animal Welfare Act”32
Nineteen percent of the licences issued in 2014 were issued for single primates – despite the above statements. If this proportion is achieved under licences, it seems likely that a much greater proportion of nonDWA non-inspected primates will be singletons. Referencing the Government’s figures, even if there are only 1000 primates in the UK it is likely that 200 of these would be singly, and thus illegally kept.
31. Wild Futures 2014, unpublished data 32. Oral evidence: Primates as Pets, HC 984
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Many cases obtained by Wild Futures via the Freedom of Information Survey revealed situations where local authorities and vets allowed solitary housing, early separation from mothers and poor housing conditions. These are clear violations of the Animal Welfare Act and the Code of Practice. Following a statement from a marmoset owner claiming she had a single pet monkey33, Wild Futures made an inquiry. Wild Futures was told that the owner was advised by both the seller and other sources to not have 2 marmosets as they would eventually fight for dominance34. The local authority, who looked into this case, stated that there were no welfare issues. According to the Government’s previous statements, the marmoset is being illegally kept but no action has been taken. The situation does not even seem to be considered as a violation of the Animal Welfare Act by the authorities in charge. Even though the local authority mentioned the Code the Practice in this case, it was not implemented, as the marmoset is still being kept on its own. There is a lack of transparency in the UK primate pet trade, making it impossible to guarantee that all regulations protecting primates are met. With the present licensing system, primates apparently disappear from year to year and occasionally re-appear35. A combination of a high level of non-compliance with the Dangerous Wild Animals Act and the fact that the majority of pet primates do not require a licence makes it difficult to monitor the welfare of these primates. The Government response to the Committee’s Eleventh Report of Session 2013–14 stated that Defra will continue to work... “to ensure that the key message that primates should not be kept as pets is disseminated as far as possible.” Currently people are being licensed to keep primates as pets and many primates are sold, bought and kept as pets36 even though the Code of Practice was supposed to restrict the keeping of primates to “specialist keepers”.
33. Harrogate advertiser (2014) Just taking our naughty raccoon for a short walk. [Online] Available from http://www.harrogateadvertiser.co.uk/news/local/just-taking-ournaughtyraccoon-for-a-short-walk-1-6466145 [Accessed 10th November 2014] 34. Wild Futures, unpublished data 35. For example, according to Wild Futures’ annual survey, 4 Saki monkeys were licensed in 2013 and in 2014 they were not licensed anywhere. They apparently disappeared from the radar and Wild Futures did not manage to locate them. 36. Wild Futures, calls received from members of the public wanting to re-home their “pet” monkey and data collected from rescued monkeys by Wild Futures’ Monkey Sanctuary.
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CONCLUSION If higher estimates about the number of privately kept primates in the UK are correct, then serious problems in terms of compliance with the Animal Welfare Act 2006, the Dangerous Wild Animals Act 1976, and the Pet Animals Act 1951 are indicated. The fewer primates there are, the more shockingly disproportionate the risk of compromised welfare becomes. In addition, primates are being sold into the pet trade and their sale often goes unregulated thus failing those individuals. Despite clear statements made by the Government that it is, in fact, illegal to keep a primate as a pet, and illegal to keep primates on their own, licences continue to be issued by the Government for pet primates, many of whom are completely isolated from conspecifics. The existing regulatory framework is not applied effectively nor does it offer adequate protection for the welfare of privately kept primates. The Government has recommended minor changes which will not prevent primates from being kept as pets. There is a need for a clear message. Wild Futures believes that the trading and keeping of privately kept primates should be banned in the UK. Bans have successfully been implemented elsewhere and there is no substantial evidence of any thriving underground trade or any particular economic hardship caused by such legislation. This is the only effective means of protecting primate welfare, the only enforceable option, and economically, the most feasible option.
Wild Futures Registered Charity No. 1102532 www.wildfutures.org • info@wildfutures.org • Tel: 0844 272 1271
Wild Futures would like to thank Viridian Nutrition for their continued support.