Raccoons do not belong on the EU invasive species list

EU Regulation No. 1143/2014 of the European Parliament and of the Council of 22 October 2014 defines the criteria for the inclusion of, among other things, animal species on the Union List.

Looking more closely at these criteria, it should quickly become clear that there are reasons other than scientific ones behind the listing of the raccoon (Procyon lotor) — and other huntable species — which appear to have been placed on the list primarily because hunting-affiliated groups lobbied for their inclusion.

For example, recital (10) of the Regulation states: «An invasive alien species should be considered to be of Union concern where the damage it causes in the affected Member States is so significant as to justify the adoption of specific measures applicable across the Union, including in those Member States that are not yet affected or are even unlikely to be affected. In order to keep the identification of the subset of invasive alien species of Union concern to a manageable scale, the Union list should be established and updated in stages and should focus on those species whose inclusion on the Union list will genuinely prevent, minimise or mitigate their adverse impacts in a cost-effective manner.«

This justification for inclusion in the Union list does not apply to the raccoon. It is not accurate that raccoons cause such significant ecological, epidemiological, or economic damage in Germany or other EU member states that their inclusion in the Union list would be necessary or justified. While there are observations that raccoons can threaten local populations of protected species, there is no reliable evidence of a large-scale or population-threatening danger to these species posed by the raccoon.

Extensive, long-term scientific studies from the Müritz National Park — where raccoons reach the highest population densities for near-natural habitats in Europe — were unable to confirm any negative ecological impacts on other native animal species in this habitat (Michler, B.A., 2020: Koproskopische Untersuchungen zum Nahrungsspektrum des Waschbären).

Furthermore, in Germany — where the raccoon population has now reached approximately one million animals and continues to spread — it is not apparent how adverse impacts, in particular the further spread of the species, could realistically be prevented, minimized, or mitigated in a cost-effective manner:

Since 2013/14, the hunting bag — an indicator of population trends — has more than doubled in this country to over 200,000 animals. Where raccoons are intensively hunted across large areas, only the average age of the animals decreases — the populations remain constant or increase, depending on habitat capacity. This is also confirmed by various scientific studies (e.g. Robel, R.J.; N.A. Barbes & L.B. Fox (1990): Racoon populations: Does human disturbance increase mortality? Transactions of the Kansas Academy of Science 93 (1-2), 22-27). The decades-long attempt to reduce raccoon populations across large areas through arbitrarily conducted hunting has long since failed. It is rather more likely that hunting activities promote the spread of raccoons and make the local ecological situation worse rather than better. Beyond this, the responsible ministries actively encourage the cruel treatment of this species through their legislation — supported by the public communications of hunting associations, fuelled by numerous media outlets, and carried out by a particular species of licensed hunters.

Nor is it apparent where raccoons pose a significant threat to biodiversity and the associated ecosystem services. While there is evidence that raccoons, as omnivores, have attracted attention in certain smaller habitats through the predation of bird clutches and amphibians, addressing this through appropriate management measures does not require the inclusion of this species in the Union list. Local conservation measures within the framework of national legislation are entirely sufficient here.

To date, no serious impacts on native species or on the structure and function of ecosystems – whether through habitat modification, predation, competition, disease transmission, displacement of native species across a significant portion of their range, or genetic effects due to hybridization – have been reliably documented in Europe as a result of raccoons. Such impacts have certainly not been scientifically proven. If one were genuinely serious about halting the decline of various protected animal species that raccoons occasionally use as a food source, one would need to address the root causes. These lie primarily in the destruction and alteration of habitats driven by economic interests.

Raccoons also have no significant adverse effects on human health or the economy. Economic damage, for example to fruit trees or residential buildings, does not come close to having a macroeconomic dimension. Each individual can address such issues through appropriate, animal welfare-compliant measures. How people can coexist with these animals is demonstrated, for example, by the cities of Kassel and Berlin.

From an epidemiological perspective, raccoons do not pose any significant risk either. While they may potentially transmit the raccoon roundworm (Baylisascaris procyonis), studies conducted in North America have shown that the likelihood of a human becoming infected through this route is extremely low. The Robert Koch Institute does not even have an entry on the subject.

«The EU Regulation should focus exclusively on species that enter the Union as a result of human activity.» (7) This aspect, too, does not apply to raccoons. Raccoons have been expanding their range across Europe from Germany as a starting point since the 1930s. In Germany, the animals have long been established. Serious adverse consequences for biodiversity and the associated ecosystem services, as well as other social and economic impacts, cannot be demonstrated across the board.

Recital (15) of the Regulation further states: «Priority should be given to including in the Union list invasive alien species that are not yet present in the Union or are at an early stage of invasion, as well as invasive alien species likely to have the most significant adverse impacts. Since new invasive alien species can constantly be introduced into the Union and existing alien species may spread and expand their range, it must be ensured that the Union list is continuously reviewed and kept up to date.»

Already at the time of the raccoon's inclusion in the Union list, the raccoon was established at least in Germany. At that time, there were approximately 500,000 of these animals. How little effect the inclusion of raccoons in the Union list has had is illustrated by the doubling of the population over the past eight years. This development cannot be halted through ethically justifiable measures.

For the reasons stated above, we urge the EU Environment Commissioner to consider removing the raccoon and, where applicable, other animal species for which the aforementioned criteria apply in a similar manner from the Union list, in order to focus on those species whose adverse impacts can genuinely be prevented, minimised, or mitigated in a cost-effective way.

Link to the EU Regulation on Invasive Species

Link to the letter addressed to EU Environment Commissioner Sinkevicius