Illegal breeding of chinchillas for fur

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Ministry of Agriculture
Cabinet of the Minister
Attn Mr. Tomislav Tolusic, Minister and Deputy Prime Minister
Ulica grada Vukovara 68
10 000 Zagreb

Ministry of Agriculture
Veterinary and Food Safety Administration
Attn Damir Tudan, VMD, Assistant Minister
Planinska 2a
10 000 Zagreb

Dear Sir,

we are writing to warn you of a breach of Article 5, paragraph 2, item 21 of the Animal Protection Act, which states that it is forbidden to "breed animals for the purpose of fur production" (NN 102/2017).

Violation of the Act is publicly acknowledged by Bruno Ivancan, a chinchilla breeder, in an article entitled "They bred chinchillas, ostriches and cultivated immortelle (Helichrysum): After investing millions, they lost everything", published on November 3, 2018, on The article states that since January 1, 2017, when it was banned to breed animals for the purpose of fur production, out of more than 2,000 breeders in Croatia, seven farms remained „which the law treats as pet breeders“. However, Bruno Ivancan doesn't hide the fact that he continued to breed chinchillas for fur production after the ban on breeding: „I managed to stay in business thanks to a buyer from Hungary, but I have to point out that the situation in Croatia is a lot worse than in other European competitor countries. We have to export live chinchillas which makes the purchase price much lower than that of our competitors.“

Speaking on chinchilla breeding in Croatia, Ivancan doesn't hide the fact that chinchillas „need to be exported alive“, which is an undeniable evidence that he doesn't breed them for the purpose of selling as pets, but for fur production.

The fact that Ivancan violates the Act is confirmed by the information already known to the Ministry of Agriculture, given that the Veterinary and Food Safety Administration sent a query to Hungary about the export of chinchillas in order to determine, through the TRACES system, how many chinchillas entered Hungary from Croatia and where they ended up. The answer unequivocally confirms that Bruno Ivancan's chinchillas are exported to the Hungarian company Wanger, whose website clearly shows they use chinchillas to produce fur and that imported chinchillas are slaughtered for fur in Hungary:

• Traceability is ensured. On the cages there are barcodes which accompanies the fur as well. The company keeps a computerised traceability system according to the barcodes.
• The company Pannonchin is the acquirer who transfers the live animals to the company Wagner Csincsillatenyésztési Rendszer Kft.. The latter company undertakes the slaughter and the fur production process.
• The imported animals are slaughtered after 6 weeks holding, depending on the quality of the fur.

More information on transcripts that prove that Bruno Ivancan breeds chinchillas for the purpose of fur production may be found in the enclosed document.

We remind of the fact that the ban on animal breeding for the purpose of fur production was adopted by the Animal Protection Act in 2006 and entered into force on January 1, 2017, after 10 years of transitional period. After the ban entered into force, chinchilla breeder Bruno Ivancan continued to breed chinchillas for the purpose of fur production. His company is a representative of the Hungarian company Wanger, which had been buying Bruno Ivancan's chinchillas for fur production prior to the ban and is buying them still. After the ban, Ivancan re-registered his company for chinchilla rearing (not for fur production), but still exports chinchillas in the same number and to the same Hungarian company as before the ban entered into force. That fact indicates that he continues to export chinchillas for the purpose of fur production, given that this is the Hungarian company's business.

The great majority of breeders gave up the chinchilla breeding entirely during the 10-year transitional period because they didn't want to wait for the Act to enter into force. The others stopped with the breeding immediately after the ban came into effect, sold the cages and sold or gave the chinchillas up for adoption. It is unfair to other former chinchilla breeders and very shameful that the ban does not affect Bruno Ivancan, not even after 10 years of transition period nor two years after the ban on the breeding of chinchillas for fur entered into force. By continuing with the breeding of chinchillas for fur, he is mocking the Ministry of Agriculture, representatives of the Croatian Parliament and the citizens, out of which more than 73% supported the fur farming ban.

It should be clarified that rearing of chinchillas means breeding of chinchillas for fur. Namely, rearing of chinchillas is not a special category of breeding, but chinchillas are reared for breeding or for the purpose of fur production or for the purpose of selling as pets. It is clear that in this case rearing is an integral part of the breeding of animals for fur and that breeding does not remove the purpose of rearing, which is, in this case, breeding for the purpose of fur production. Although chinchillas can also be bred for pets, even in the Veterinary and Food Safety Administration was confirmed to us that neither in Croatia nor in European countries there is no great demand for chinchillas as pets and that all rearing and all breeding are carried out for the production of fur. All of this clearly indicates that Bruno Ivancan is openly violating the Animal Protection Act because he still breeds chinchillas for fur.

It is logical that if there is a ban on the breeding of animals for the purpose of producing fur, then sales of chinchillas to a company in another state (which slaughters the chinchillas for fur) violates the law in Croatia. We consider that, regardless of how someone registered his company, if the result of his breeding is the killing of animals for fur, the law of the country forbidding such breeding is being violated. It is also logical to us, according to Croatian law, the legal responsibility of the chinchilla breeder does not cease at the time of a sale to a country where breeding or selling for fur is not forbidden.

Please note that in other countries that have banned animal breeding for fur, such as the United Kingdom, Austria, Slovenia, Macedonia, the Czech Republic, the Netherlands, and others, there were no such problems because where breeding is forbidden, then it is indeed banned in practice, not just on paper.

Everything stated above is supported by the opinions of legal experts on the interpretation of Article 5, paragraph 2, item 21 of the Animal Protection Act (attached).

Based on the information presented, we are asking for the Ministry of Agriculture's urgent action to ban Bruno Ivancan from the further breeding of chinchillas and, in accordance with the provisions of the Animal Protection Act, sanction his illegal work, through which he gained profit.

The public has supported the fur farming ban in a huge number and will strongly condemn these manipulations and scams by breeders as well as your passivity if the Ministry allows further violation of the law and if it fails to defend the legal provision it itself put into force.

In anticipation of your urgent action, we remain at your disposal for any additional information and we kindly ask for the reply within the legally prescribed deadline.

Kind regards,
Ivana Lunka, mag.iur.

• opinion by Assoc. Prof. Ph.D. Boris Bakota, University of Osijek, Faculty of Law
• opinion by mag. iuris Maida Sabeta, legal adviser for the environment and animal welfare
• opinion by lawyer Sladana Panic Siljes
• opinion by lawyer Paula Kis

Zagreb, November 4, 2018

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