I Ulvetid er vi som så mange andre forundret over EU-kommissionens holdning, og ikke mindst Virginijus Sinkevičius kovending i spørgsmålet om ulvens fredning i EU. Det ligner mest af alt et politisk “stunt” fra Ursula von der Leyens side.

I den anledning har vi forfattet nedenstående mail til Miljøkommissær Virginijus Sinkevičius. Det er en forholdsvis lang mail, men det er også skæbnetimen for ulvene i Europa.

OBS! Vi har fået svar fra kommissionen. Det er – helt som forventet – nogle standardformuleringer, som på ingen måde forholder sig til vores konkrete indsigelser. Du kan finde svaret fra kommissionen her: The downgrade of the protection of the wolf _Svar fra kommisionen

Dear Commissioner Virginijus Sinkevičius


Re.: The downgrade of the protection of the wolf:

We find the decision to downgrade the protection of the wolf unjustified and disturbing, which is the reason for sending this message.

In December 2022 you rejected a proposal from Switzerland to move the wolf from Appendix II to Appendix III in the Bern Convention. In all the years you have been the EU-environmental commissioner, you have argued that there are plenty of possibilities to handle wolf’s depredation on livestock, even though the wolf is protected as an annex IV species the Habitats directive.

However, in a press release from September the 4th 2023 it seems as you made at 180-degree U-turn. The press release was sent by you AND surprisingly together with Ursula von der Leyen. I am not the only person to be surprised that the President of the commission interfered directly in the wolf issue.

Anyway, since this inappropriate interference by Ursula von der Leyen, everything seems to be hurried through the system.

In order to justify downgrading the protection of the wolf, the Commission had the N2K Group to produce a document “The Situation of the wolf (Canis lupus) in the European Union” subtitled “An In-depth Analysis.”

Nowhere in the analysis can a biological or scientific argument to justify or support a downgrade of the protection level of the wolf be found. It sure looks like at political project since the analysis solely is targeting the wolf and not the overall problem of predator attacks. it seems strange that the commission has not focused on the member states’ obvious disregard of the directive 98/58/EF, leaving most livestock without sufficient protection, or in some cases without any protection at all.   

Paradoxically it seems that the expected mandatory biological and scientific arguments, in the analysis to justify the suggested downgrade of the protection of the wolf, is conspicuous by their absence. On the contrary, a number of arguments that supports the view, not to downgrade the protection status can be found in various part of the analysis.

Underneath is some copy-pasted pieces of text from the In-depth analysis, followed by relevant comments.


  1. Text from the analysis:

IUCN Red List European assessment

According to the wolf assessment carried out in 2018 by the International Union for Conservation of

Nature (IUCN) Red List, six of the nine European wolf populations were considered as non-threatened.

Three of these populations were considered as “Near Threatened” (Iberian, Italian Peninsula and

Karelian populations) and a further three were of “Least Concern” (the Dinaric-Balkan, the Carpathian

and the Baltic populations). The remaining three were listed as “Vulnerable” (the Western- Central

Alps, the Scandinavian and the Central Europe populations). Red List assessment of the wolf is not

uniform at a pan-European level.

European Red List assessment of the wolf

(…) The non-threatened categories are Near Threatened (NT) (not threatened but

close to qualifying for or likely to qualify for a threatened category in the near future (…)

  1. Comment:

As a consequence of that, six out of nine populations are not in favorable conservation status. 3 populations at vulnerable and 3 populations are near threatened, meaning that they are close to qualifying for or likely to qualify for a threatened category in the near future. Hence 6 out of nine populations are NOT fulfilling the criteria for favorable conservation status mentioned in Article 1 point i) in the Habitats directive.

  1. Text from the analysis

Updated information on wolf numbers in the European Union

In 2023, wolves have been detected across all EU Member States except Ireland, Cyprus and Malta,

and there are breeding packs in 23 countries. In this analysis, about 20.300 wolves have been estimated,

in 2023 across the EU, a figure slightly higher than the 19,400 wolves estimated by Boitani et al. (2022)



According to Table 2.4.1. the wolf population in the EU member states is estimated to 20.356 individuals. However, the actual number of wolves in Europe is not known. Table 2.4.1. presents two uncertainties.

1 as described on page 26 in the In-depth analysis “The Situation of the wolf (Canis lupus) in the European Union” in the chapter “Wolf trends”, counting the wolves I Europe presents a number of challenges that all together entails an uncertain result, with the consequence that the number of wolves in Europe (20.300), stated in the analysis Europe is subject to a fairly large degree of uncertainty.

2 In table 2.4.1. the Bulgarian population lists the number of wolves to 2.712. individuals. Although it is the official number of wolves in Bulgaria, it is heavily questionable if 2.712 is the real number, as Boitani suggest that about half the number would be more trustworthy. If that is the case, the total number of 20.300 wolves is exaggerated with more than a thousand individuals. In other words: Taking into account that the estimate of individuals is very imprecise, the sentence “This figure is slightly higher than the 19,400 wolves according to the estimate by Boitani et al. (2022)” must be assessed with caution.



  1. Text from the analysis

Predation on farm and domestic animals

In general, damage to livestock has increased as the wolf population has grown. But, in some of the

German federal states with the highest number of wolves, the frequency of wolf attacks on livestock

has decreased significantly in recent years, which was associated to the use of adequate preventive measures. (…)

  1. comment

The sentence “has decreased significantly in recent years, which was associated to the use of adequate preventive measures” proves that the decision taken by the commission, simply disregard the fact that the problem is not the wolf, but in the words of the “in-depth analysis”, inadequate protection.   

  1. Text from the analysis

Prevention measures to avoid livestock predation.

The best way to reduce livestock losses due to wolf attacks is to apply effective and adapted measures,

to prevent wolf depredation.

  1. Comment

This text speaks for itself and proves that the commission, by setting all other possible solutions aside, has chosen the wrong path. It is hard to misunderstand the words “The best way to reduce livestock losses due to wolf attacks is to apply effective and adapted measures, to prevent wolf depredation.”


  1. Text from the analysis

Lethal control/culling of wolves.

Evidence in North America show that lethal control reduced damage to livestock only when it was

intense enough to reduce wolf populations over large areas. (…)

When lethal control is aimed at reducing wolf depredations, at best, only solves conflicts

temporarily, unless the wolf population is exterminated or severely reduced over large areas (Bradley

et al. 2015; Linnell and Cretois 2018). Where wolves are killed, their territories will usually be rapidly

filled by other wolves and it will be necessary to continue killing wolves year after year. For example,

in Scandinavia, lost wolf territories were re-occupied in less than one year when wolf population density

was high. The re-occupation was faster after legal culling of individuals as compared to territories where

both individuals disappeared for unknown reasons (Sand et al. 2022).


In summary, the research on targeted wolf culling carried out in Europe is inconclusive, and nontargeted

culling (i.e., hunting) does not seem to reduce wolf depredations on livestock unless it is carried

out with such intensity that it effectively reduces the density of wolves over large areas. However, this

type of hunting may not be compatible with the Habitats Directive and is socially rejected by much of

the public in Europe.

  1. Comment:

As the overall aim of the suggested downgrading of the protection of the wolf by moving the species from annex IV to annex V, is to decrease the livestock depredation, these two chapters strongly oppose that moving the wolf from appendix IV to appendix V will produce the desired result. In worst case, it might turn out to prove counterproductive.  


  1. Text from the analysis:

3.5 Considerations about public safety

In the last 40 years, despite the large number of wildlife biologists collecting reliable information on

large carnivores, there has not been a single verified record of a fatal wolf attack on humans in Europe.

When the frequency of wolf attacks on people is compared to that from other large carnivores, wolves are among the least dangerous species for their size and predatory potential.


The number of years, without fatal attacks by wolves in Europe is 50, not 40. The latest fatal attack from wolves on humans I Europe, was the so called Rante episode in Spain in July 1974.

This sentence indicates that the wolf is not dangerous to humans. Hence It put shame on Ursula von der Leyens words in the Commissions press release from September 4th 2022, that the wolf is potentially dangerous to humans. 

  1. Text from the analysis:

Wolf management under Annex V of the Habitats Directive

Wolf populations included in Annex V of the Habitats Directive can be managed as far as exploitation

is compatible with their being maintained at a favorable conservation status (Article 14 of the

directive). In some of the countries where wolves are in Annex V, they are managed as a game species

(i.e., Estonia, Latvia, Lithuania and Bulgaria).



 At this point it is important to underline that the following line is copied directly from “The situation of the wolf (Canis lupus) in the European union – An in-depth analysis.”

In some of the countries where wolves are in Annex V, they are managed as a game species”

That single line describes, without equality, the problem which emerges by moving the wolf to Appendix III in the Bern Convention and annex V in the Habitats directive. Namely that in a number of countries where the wolf is “protected” by Article V, but the reality is that they are managed as a game species. In case the wolf is moved to annex V in all EU countries, it might turn out to be a disaster for the wolf populations all over Europe. Bearing in mind that farmers and hunters are longing to kill wolves, and they will for sure put heavy pressure on the authorities in their respective countries, to get license to shoot wolves. Furthermore, the one and only protection the wolves will enjoy as an article 14/annex V species, is if the species has not yet reached a favorable conservation status. In case they have, they can be considered as a game species. That is exactly what will happen, the very minute the protection of the wolf is downgraded.

At present it seems quite unclear in which context the FCS is to be evaluated. It is almost for sure that farmers and hunters will argue for an evaluation for the species with aspect to the total population. So far, the only “indication” from EU about how to evaluate the seize of the area, that the evaluation should be decided, is from the proposal for decision, from the Advocate General of the EU Court of Justice in case 601/22.   



The “in-depth analysis” does not provide any biological or scientific prove that justifies downgrading the protection status for the wolf, neither in the Bern Convention nor in the Habitats directive. On the contrary, it provides a range of very good arguments, to keep the protection status as it is at present.

The fact that the commission aims at a single species, and totally ignores the impact from other carnivores and domestic dogs, and the fact that most – if not all – member states fail to ensure the use of preventive measures, which is a mandatory requirement according to directive 98/58/EF, indicates that the commissions suggesting downgrade the protection of the wolf is based on a personal political desire rather than scientific arguments.

We know that the above message won’t change the decision. However, we hope that you will reflect to our arguments.

Best regards

Ole Pedersen


The association Ulvetid

Maglemosen 1 – 4070 Kr. Hyllinge – Danmark

Tlf.: + 45 60613739

E-mail: formand@ulvetid.dk

Web: www.ulvetid.dk

Wolf in Denmark – Naturally