Do you agree or disagree with our proposed approach with respect to the trap marking requirements?

Agree

Trap marking is clearly in the interest of the trap user. Trap users need confidence that what they buy is fit for purpose on both legal and humane grounds. Manufacturers and distributors must recognise this and offer game/wildlife management equipment that is fully fit for purpose and verifiably conforms with all the expected standards. The person who sets the ‘trap’ is legally responsible for ensuring that their actions conform with the such standards. Unmarked traps that fall short of these standards could place operators in a compromising situation.

The possibility of untested copies of approved trap models being introduced into the market is clearly not in the interests of humaneness, because copies may not be made to the same tolerances and power, and because the business of manufacturers of bona fide humane traps would be undermined. For the latter reason, we anticipate that manufacturers will be happy to comply with the marking requirement.

However, we are concerned about the seeming ease and accuracy with which manufacturer’s marks can be copied. We have seen ‘pirate’ copies of DOC traps from China, which had stamped or engraved marks that were indistinguishable from those of the original New Zealand manufacturer. The traps themselves were superficially identical too, but substantially different in quality of construction and usability. Identification will be used in two contexts: by the buyer, to ensure that he is buying a genuine approved trap; and by wildlife crime investigators wishing to verify compliance with the law. In both cases, the identifier must be easily read, and tamper-proof. We don’t think extra plates attached by rivets would be as satisfactory as embossed, engraved or etched marks; but this is probably best decided by manufacturers, individually or as a group, since it is in their interests.

The consultation document makes no mention of ‘clone’ traps (traps which are identical to approved models in all functional respects), which are allowed under the current STAOs. We suggest these must be disallowed. It can be argued that a trap that is identical in all functional respects to an AIHTS-certified model must also be compliant. Even if one could assume this, it is difficult to confirm that a copy has even the same physical characteristics (sensitivity, strike force, clamp force, manufacturing consistency) as the model originally tested. Presumably because of this, the authorisation of clones is contrary to AIHTS requirements, which dictate that tested and certified traps must be identified as such by their manufacturers; this could not truthfully be done for clones.

The automatic approval of clones permits the use of traps whose humaneness is untested, and which cannot be necessarily be recognised in the field (e.g. at least one Fenn trap clone has no markings whatsoever). The approval of clones also makes it difficult to follow up any manufacturing deficiencies, because the true manufacturer may not be traceable. Finally, the approval of clones creates a market for pirate manufacturers who have not incurred the expense of development. This seems commercially unfair, and contrary to the aim of improved humaneness because it will inevitably discourage manufacturers from further improvement of trap designs.

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