The keeping of European tortoises is notifiable and must be reported to the competent authority immediately. European tortoises are classified as specially protected animal species and are included in Appendix I of a total of three appendices in the Washington Convention on Endangered Species.
At EU level, since June 1, 1997, the new species protection regulation EC No. 338/97 has implemented the Washington Convention on the Protection of Species as well as other protective provisions that have been in force since 1984 in even stricter rules. The European tortoises are listed in Appendix A. Labeling has been mandatory since 01/01/2001.

A delivery of any kind is only permitted with the yellow EC certificates. Until June 1st, 1997 it was the blue Cites certificates that are still valid.

The photo documentation is part of the yellow EU certificate as a label.  At intervals of one year and with a body weight of 500 grams or more for five years, current photos with details of the date and weight must be attached as an attachment.

The documentation
According to the study by BENDER & HENLE, 2001, the identification of European tortoises is carried out on the basis of a total of eleven different features of the neck and fifth vertebral shields as well as the five points of intersection of the abdominal armor shields.
In the neck shield, the lines of the lateral seams to the edge shields and the seam to the first vertebral shield and in the fifth vertebral shield the contours of the seams to the two adjacent rib shields and to the fourth vertebral shield are used as distinguishing features and identified with an alphanumeric code.
With the belly armor, 9 different variations of crossing points are possible, from which a number combination is formed for each of the five crossing points.
For every turtle, three formulas result from the shield contours of the neck and fifth vertebral shields and five formulas from the intersection points of the abdominal armor. These 11 formulas allow an individual identification of each individual turtle and are recognized as documentation according to the new version of the Federal Species Protection Ordinance.
But don't worry now. The responsible state authorities do not require every turtle keeper to create the appropriate individual formula for their animals.
For the documentation of the features necessary to create the formula, the state authorities only require corresponding photos.

With the application for an EU certificate to be issued, the pictures of the hatchling, usually in duplicate, are sent to the responsible state authority. A picture is attached to the issued EU certificate as an attachment and stamped. The following images are then to be attached promptly by the current turtle owner himself and, at least in Baden Württemberg, only have to be presented to the authorities on request. However, this is handled differently from state authority to state authority.

The yellow EU certificate forms are a multiple set that contains the application for the certificate to be issued.

The photographs
The documentation takes place with format-filling, sharp 9 x 13 cm color photos, each of the back and the belly armor. Not necessarily the whole animal, only the tank has to be shown, whereby it is particularly important that the seams of the shield are clearly recognizable without reflections.
The animals must of course be cleaned and dried beforehand. To identify the size, take a photo of a centimeter ruler or use a square centimeter paper as a base.
The labeling requirement is also required for offspring that remain with the breeder and for which therefore no EU certificate has to be applied for, as well as for animals imported or bred before the Washington Convention on the Protection of Species came into force.

That means that all more European tortoises, since 01.01.2001, have to be marked in the form of a photo documentation.