Due to their far-reaching negative impact on wildlife -especially on rare and threatened species- as well as on domestic animals and public health, the use of poison baits or “fo-les ”-as they are also known in Greece- is strictly prohibited throughout the whole Greek territory by law.

Because of their widespread use, many species of the Greek fauna, -especially of avifauna, are now in an unfavorable conservation status or their population is at the brink of collapse. The most common victims of this practice are scavenger bird species such as the Bearded Vulture (Gypaetus barbatus), the Griffon Vulture (Gyps fulvus) and the Egyptian Vulture (Neophron percnopterus) but also other mammals like the Brown Bear (Ursus arctos) and the Wolf (Canis lupus), working dogs (shepherd and hunting dogs), pet or stray dogs and foxes. Despite its severe impact, the use of poison baits is one of the least recorded illegal practices in crime statistics.

The current in force legal framework for combating the use of poison baits includes a large number of provisions. Already since 1981, by provision of the Presidential Decree 67 on the protection of native wild flora and fauna, the use of “[…] toxic substances and poisonous substances in general” for the control of “vermin species” is prohibited, taking into account that they endanger protected animal and native flora species.

The Forest Code (article 252, p. 5) prohibits the distribution and use of poison baits or other equivalent means with the aim of “[…] killing, capturing or tranquilizing” any wild mammal or bird. Offences referred to the above article are punished by imprisonment of at least two years and a penalty payment of one thousand euros (€ 1,000).

According to law concerning the well-being of pets (4830/2021, article 24, 34 and 35 ), animal poisoning is prohibited and this prohibition includes both pets and protected species (mammals, reptiles, amphibians, as well as trigger species and species of cetaceans –as defined by relevant Joint Ministerial Decisions and international conventions). The penalty is now incarceration up to ten (10) years and a penalty payment between €25,000 and €50,000, and an administrative fine of €30.000.00 – €50.000.00 per harmed animal per incident.

Apart from the above, poisoning with intent (with the use of poison baits) also falls within the scope of Article 3f of the law 4042/2012, (equivalent of the article 3f of the Directive 2008/99/ΕΚ), which –among others- provides for the punishment of “…the killing, the elimination, the keeping or capturing of protected species of wild flora or fauna”, with the exception of instances when the act concerns a negligible amount of these species and has negligible impact on their conservation status.

Regarding avifauna protection and the relevant administrative fines and criminal penalties, for those who use poison baits, the Joint Ministerial Decision Η.Π. 37338/ 1807/ E.103/2010 (by which the EU’s Directive on the conservation of wild birds was transferred into the Greek national legislation), prohibits ‘the use of any means, installations or methods of mass or non-selective capturing or killing that could possibly cause the local extinction of a species […]’ for the purposes of hunting, capturing or killing birds (article 8 p. 1), including the use of poison baits or anesthetics . Art. 11 of the above Decision provides that a fine between €100 and €300 is imposed to the offenders, who are also punished with imprisonment of up to one year and penalty payment. In addition, apart from the aforementioned criminal penalties, it is possible for additional administrative measures to be imposed, wherever necessary, i.e. suspension of hunting license, confiscation of equipment etc.

On what concerns the use of poisons to kill other wild species, the Joint Ministerial Decision 33318/3028/11.12.1998 (by which the Habitats Directive was incorporated into the Greek legal framework), specifically prohibits «…every form of capturing or killing, by intent, of specimens of these species taken from nature” while it clearly specifies that “…the use of all indiscriminate means of capture or killing capable of causing local disappearance and serious disturbance to populations of such species” is prohibited while for the offenders, criminal penalties are foreseen.

Finally, law 1335/1983 ratified the International Convention on the Conservation of European Wildlife and Natural Habitats (also known as the Bern Convention), by which the use of all indiscriminate means of capture or killing capable of causing local disappearance and serious disturbance to populations of such species, including poisons, and especially for the species mentioned in Annex IV (article 8), is prohibited.

Local Action Plans on the control of the illegal use of poisoned baits against both wild and domesticated animals are also an important tool in the struggle against the illegal use of poison baits. Aim of these plans is to improve the coordination between the competent authorities and other services that take part in the operational planning and in the implementation of actions to tackle this phenomenon. In addition, they define: a) the relevant protocols for managing and recording of all information that could assist in the investigation of the causes and b) the necessary measures for the preservation of the natural environment and biodiversity (see Greek Government Gazette 4459, vol. Β, 22 August 2022).

Joint Ministerial Decision 83415/2715/2022 on “Measures and procedures for the management of the illegal use of poison baits against wildlife species – Coordination of competent services and bodies” (Greek Government Gazette 4459, B, 22 August 2022)

Having recognized the severe impact of wildlife poisoning, in August 2022, four Ministries co-signed the Joint Ministerial Decision defining the responsibilities of each Authority and the measures that must be taken for the mitigation of this extremely harmful and illegal practice. By this Joint Ministerial Decision, which replaced the previous relevant Decision of the Ministry of Environment, a new, more comprehensive framework is established, enhancing the coordination and improving the cooperation between competent authorities, aiming at combating this phenomenon more effectively. The four Ministries co-signing the new Joint Ministerial Decision are: Ministry of Environment and Energy, Ministry of Rural Development and Food, Ministry of Citizen Protection and Ministry of the Interior.

According to the new Joint Ministerial Decision, the Directorate of Forest Management (Wild Life and Game Management Department) of the General Directorate for Forests and Forest Environment of the General Secretariat of Forests of the Ministry of Environment was designated as the head competent authority, with responsibility to combat the illegal use of poison baits. Consequently, as competent authorities are also considered the regional Forestry Services of the Ministry of Environment and Energy, i.e. both the Forestry Services and Forest Directorates without Forestry Services. The head competent authority, jointly with the General Directorate of Veterinary of the Ministry of Rural Development and Food, are responsible for the provision of instructions for the preparation and formulation of Local Action Plans, as well as for the coordination and supervision of the Forestry Services and Forest Directorates. The head competent authority shall also provide information to other competent authorities – such as N.E.C.C.A. – as well as cooperate with the other involved bodies and authorities. It is furthermore the responsibility of the head competent authority to compose a list of laboratories for carrying out toxicological analysis and to provide instructions and coordination to the other authorities for composing the list of veterinarians who will undertake the autopsy and sampling in the field.

Both the Forestry Services and Forest Directorates, in turn, have first of all the obligation to draft Local Action Plans and secondly, when an incident occurs, to activate other authorities and bodies immediately. Furthermore, they are responsible for the implementation of awareness programs for the general public, as well as training seminars for all those involved in the implementation of the Local Action Plans in their respective area of responsibility. In addition, they are responsible for keeping statistics on poisoning incidents and for ensuring the supply of all necessary equipment. For each area, the Forestry Service or the Forest Directorate will designate a coordinator for the implementation of the Local Action Plan, who will undertake the communication with the other competent authorities.

The remaining competent authorities and bodies involved in the combating of poison baits are: the General Directorate of Veterinary of the Ministry of Rural Development and Food, the Plant Production Protection Department of the General Directorate of Agriculture of the Ministry of Rural Development and Food, the Veterinary Services of Municipalities and Regional Units, the N.E.C.C.A., the Hellenic Police, Local Administration Units, local hunting clubs and Environmental NGO’s.

According to the JMD, the implementation of Local Action Plans in specific, high-risk areas is of decisive importance for the prevention of the use of poison baits. Local Action Plans coordinate the involved services and agencies, while at the same time help in making full use of the personnel and all available means (equipment, facilities, etc.) for the management and mitigation of poisoning incidents. For the preparation of the Local Action Plans, as well as their annual update, a Coordination Team is formed, convened by the Director of the Forest Directorate of each Region. The annual meeting of the Coordination Team aims to evaluate the Local Action Plans and to improve the information and mobilization of the competent Services.

Briefly, the actions that should be carried out in case a poison bait or a poisoned animal is detected, are the following:

1. Identification and removal of the poison bait(s) or/and the poisoned animal(s) from the countryside.
2. Recording of the poisoning incident(s) in a database.
3. Filing an official complaint of the incident(s) to the Hellenic Police or the Forestry Service.
4. Carrying out of autopsy and sampling.
5. Carrying out of toxicological analysis.
6. Implementation of preventive actions to limit the use of poison baits.
7. Activation of protocols for the prosecution of the illegal use of poison baits.

The Anti-poison Dog Units that patrol the countryside comprise specially trained dogs and their handlers. These units play an important role in detecting poison baits and collecting evidence that could lead to the perpetrator. Anti-poison Dog Units can be operated by the Forestry Services, the Management Units of N.E.C.C.A., Hunting Federations and Clubs and the Environmental NGO’s.

Thus far, according to the list included in the new Joint Ministerial Decision, the Areas of Local Application of the Local Action Plans have been grouped into five areas; however, additional areas are expected to be added after the first annual evaluation. Currently, the areas listed in the Joint Ministerial Decision include:

• The areas of responsibility of the Forest Directorate of Rhodope and the Forestry Services of Xanthi, Alexandroupolis, Soufli and Didymoteicho.
• The areas of responsibility of the Forest Directorate of Florina and the Forestry Services of Kilkis, Goumenissa, Aridaia, Edessa, Veria and Naoussa.
• The areas of responsibility of the Forest Directorate of Grevena, Arta and Corfu and the Forestry Services of Ioannina, Metsovo, Kalabaka, Trikala.
• The areas of responsibility of the Forestry Services of Amfilochia, Agrinio, Karpenisi and Messolonghi.
• The areas of responsibility of the Forest Directorates of Chania, Rethymno, Heraklion and Lasithi.

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Summary list of applicable legislation

• National legislation:– Law 86/1969 Forest Code: Prohibition of use of pb (Art. 252 par. 5).- PD 67/1981 “On the protection of indigenous Flora and Wild Fauna and on the determination of the coordination procedure and the Control on their Research” (OGG 23/v. Α’/30.01.1981): Toxic substance or any other poison use for the elimination of identified harmful species is prohibited (Art. 9).- Joint Ministerial Decision 37338/1807/E.103/01.09.10 “Definition of measures and procedures on the conservation of wild birds and their habitats, in compliance with the provisions of Directive 79/409/EEC…», (OGG 1495 / v. Β’ / 06.09.2010): During the hunting, capturing or killing of birds, it is prohibited to use any means, facility or method of mass or non-selective capture or killing that can cause the local extinction of a species, including pb (No. 8, 11 and Annex III (section 1) of article 14).

  – Joint Ministerial Decision 33318/3028/11.12.1998 “Definition of measures and procedures on the conservation of habitats and the wild fauna and flora” (OGG 1289/v. Β’/28.12.1998): The use of all non-selective means that may cause local extinction or seriously disturb the peace of populations of a species, including pb, is prohibited (No. 11, Annex VI, Art. 28 etc. Law 1650/1986).

  – Law 4042/2012 “On the protection of the environment through criminal law”: The killing, annihilation, possession or capture of protected species of wild flora or fauna is a crime and is punished according to art. 28 Law 1650/1986 (Art. 3).

  – Law 4830/2021 “New framework for the well-being of pet animals – Program “ARGOS”…”: The poisoning of pet animals and protected species of wild fauna is prohibited and is punished (No. 24, 34 and 35).

  – Ministerial Decision Y.P.EN./DDD/83415/2715 “Measures and procedures for the control of the illegal use of poisoned baits targeting wild animals – Coordination of competent services and bodies (Local Action Plans)” (OGG, v. B’, 4459 2022): Coordination tools for the competent authorities and the other services involved in operational planning and the implementation of actions targeting the phenomenon of pb.

• EU legislation:– Directive 2009/147/ EC on the conservation of wild birds: During hunting, capturing or killing birds, the use of any means, installation or method of mass and non-selective collection or killing that may cause local extinctions of a species, incl. pb, is prohibited (art. 8, Annex IV).- Directive 92/43/EEC on the conservation of natural habitats and wild fauna and flora: The use of all non-selective means that may cause local extinction or heavily disturb the populations of a species, is prohibited (Ar. 15, Annexes IV, V, VI).

• International legislation:– Law 1335/1983 “Ratification of International Convention on the conservation of European wildlife and natural habitats” (Bern Convention, 1979) (OGG 32/v. Α’/14.03.1983): The use of any non-selective means of capture or killing as well as of means that may induce local extinction or heavily disturb the populations of a species, such as poison baits, is prohibited.