EUROPEAN COMMISSION 
Brussels, 30.8.2011 
SEC(2011) 1009 final 
  
COMMISSION STAFF WORKING PAPER 
EXECUTIVE SUMMARY OF THE IMPACT ASSESSMENT 
Accompanying the document 
Proposal for a 
 
REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL 
amending Regulation (EC) 1760/2000 as regards  electronic identifi cation of bovine 
animals and deleting the provisions on voluntary beef labelling 
{COM(2011) 525 final} 
{SEC(2011) 1008 final}  
 
1 EXECUTIVE  SUMMARY  OF THE  IMPACT  ASSESSMENT 
Accompanying the document 
Proposal for a 
REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL 
amending Regulation (EC) No 1760/2000 as regar ds electronic identification of bovine 
animals and deleting the provisions on voluntary beef labelling 
1. INTRODUCTION  
 
Regulation (EC) No 1760/2000 a nd in particular bovine identification and voluntary beef 
labelling were described as " information obligations with spec ial importance in terms of the 
burdens they impose on businesses"  in the Communication from the Commission to the 
Council and the European Parliament (COM  (2009)544) "Action Programme for Reducing 
Administrative Burdens in the EU ". This Regulation establishes a system for the identification 
and registration of bovine animals and label ling of beef and beef products (including 
voluntary labelling) and include s provisions for double ear tags , holding registers, cattle 
passports and national computerised databases.  Community rules on the identification and traceab ility of bovine animals were reinforced in 
1997 in the light of the Bovine Spongiform Encephalopathy (BSE) crisis by introducing 
conventional tagging. At that time electronic identification (EID) was not sufficiently 
technically developed to be introduced but has considerably improved during the last 10 
years. EID based on (Radio Frequency Identifi cation) RFID introduce d, among other things, a 
faster and more accurate readin g of individual animal codes di rectly into data processing 
systems (enabling faster traceability of potentia lly infected animals or  infected food). This 
saves labour costs for manual read ings but at the same time, in creases equipment costs. Thus, 
the existing legislation on bovi ne identification does not refl ect these latest technological 
developments.   The overall general objectives of  this proposal in terms of animal identification  are the 
following: 
1. To support the competitiveness of the sector;  
2. To reduce administrative burden and simplify pr ocedures in relation to animal passports 
and holding registers 
3. To contribute to better animal and public  health through a faster and more accurate 
system for bovine traceability 
The general objective in terms of beef voluntary labelling  is: 
1. To reduce unnecessary administrativ e burden concerning beef labelling 
 
  
 
2 2. POLICY OPTIONS  
 
Different policy options  are analysed in this report for bovine EID and beef  labelling:   
   
2.1 Bovine EID 
OPTION
 1: “DO NOTHING ” (OR STATUS QUO) REGIME (BASELINE SCENARIO ):    
No change to the current prov isions would mean that bovine animals would continue to be 
identified by two conventional visible ear tags and there would be no reduction in the current 
administrative burden. The current legal framew ork does not prohibit Me mber States from 
using electronic identifiers on a voluntary basis, but this must  be done in addition to the 
official visible tags. As no harmonised technical EU standa rds have been established, 
different types of electronic identifiers and read ers with different RFID  frequencies could be 
used in different places.   OPTION 2: 
VOLUNTARY REGIME WITH TWO SUB-OPTIONS:   OPTION  2 will introduce EID 
as a tool of official identific ation. It would not be possible for a Member State to opt for the 
“Do Nothing” scenario under option 2. EU Member States may opt for a mandatory 
introduction on their territory (OPTION 2A) or  to allow farmers to decide whether to 
introduce it (OPTION 2B). The establishment of  harmonised technical standards for EID and 
reading equipment on EU level would be essentia l to this option (unlik e option 1). However, 
these standards will not go beyond ISO international standards. 
 
Option 2a: Introduction of electronic identificati on is voluntary at EU level, and individual 
Member States have the possibility to opt for a mandatory regime in their territory. In 
case the Member State opts for the mandatory regime , the same obligation as under O PTION  3 
would be applicable in that Member State (e.g.:  each bovine animal is to be identified by one 
conventional visible ear tag AND one electronic identifier , either an ear tag or bolus) . In case 
the Member State opts for the voluntary regime , bovine animals could then be identified by: 
1. two conventional ear tags, or 
2. One conventional visible ear tag AND one electronic identifier (i.e. an electronic 
ear tag or a bolus) that has been officially approved. 
 
Option 2b:  Introduction of electronic identification is voluntary at EU level, and individual 
Member States do not have the possibili ty to opt for the mandatory regime. Under the 
voluntary regime, bovine animals could be identified by: 
1. two conventional ear tags, or 
2. One conventional visible ear tag AND one electronic identifier (i.e. an electronic 
ear tag or a bolus) that has been officially approved . 
OPTION 3:  MANDATORY  REGIME 
Each bovine animal is to be identified by one  conventional visible ea r tag AND one electronic 
identifier (ear tag or bolus). Unlike Option 1, this option would require the development of 
EU legal obligations for EID and readi ng equipment which would not go beyond ISO 
international standards.   
 
  
 
3 Table 1: Summary of means of official identification in one bovine animal for each option 
 
   2.2 
Voluntary beef labelling 
 
Two different scenarios are analys ed for voluntary beef labelling: 
OPTION 1  – do nothing (baseline scenario ): no change in the current system  
OPTION 2 – abolishing the voluntary beef labelling. The specific provisions on voluntary 
beef labelling would be deleted from Regulation (EC) No 1760/2000  
 
3. ANALYSIS OF THE OPTIONS  
 
3.1 Bovine EID 
 
This analysis is based on three sources:  i) an external study finalised in 20091; ii) data 
supplied by Member States competent authori ties and iii) data collected during stakeholder 
consultations. The analysis show s that direct costs and benef its are not distributed equally 
along the food chain. Costs, which are mainly  related to equipment (transponders and 
readers), are mainly borne by farmers. However, the full financial benefits of the electronic 
device (such as from early e-reading at farm ga te level), are for downstr eam actors in the food 
chain (e.g. markets, assembly centres and slau ghterhouses). Additionally, CAs profit from the 
fact that all data can be automatically co mputerised, reducing labo ur costs. The study 
concludes that the voluntary op tion (2A) for the introduction of  EID in the bovine sector on 
the basis of harmonised standards would be the preferred option.  
 Impacts of option 1 “Do nothin g” regime (Baseline scenario)  
 
No change to the current provisions would mean th at each bovine animal is to be identified by 
two conventional visible ear tags . If keepers want to use elec tronic identifiers on a voluntary 
basis, this would be in addi tion to the two official tags . OPTION 1 does not address the 
problems as reported by several CAs in audit reports (Food and Veterinary Office (FVO) Overview Report 9505/2003). There would also be  no reduction of the administrative burden 
for the sector. Most interviewees consider th at the current system for identification and 
                                                
 
1 Study on the introduction of electronic identification (EID) as official method to identify bovine animals within 
the EU  : http://ec.europa.eu/food/animal/identification/bovine/docs/EID_Bovine_FinalReport_04062009_en.pdf 
 
/ 
  Option 1  
"Do Nothing  
scenario" Option 2 
VOLUNTARY 
" EU MS may opt for a 
mandatory regime "  
2A Option 2 
VOLUNTARY 
" stakeholders may 
voluntarily choose EID"  2B Option 3 
"Mandatory  at 
EU level" 
Conventional 
ear-tag   
       2 
 1 (for EU MS going  
mandatory ) 
2/1 (for EU MS under 2B)   1 (willing to use  EID)/ 
 2(not willing to use EID) 
 1 
 
 
Electronic 
transponder (ear-
tag or bolus)   0 1 (for EU MS going  
mandatory ) 
1/0 (for EU MS  under 2B) 
 1(willing to use  EID)/ 
0(not willing to use EID) 1 
 
 
4 traceability is effective but could be improved. For instance,  accurate tracing of bovine 
animals in case of emergency may be difficult due  to the fact that holding registers are not 
always up to date. For example, there could be  missing documentation; badly organised data 
and documentation; delays, mist akes or an absence of reporting certain events (births, 
movements, deaths) to the central database; and the recording of animal movements through markets & assembly centres is not always respected.  
 Most of the interviewees consider that the curr ent traceability system is efficient and effective 
but could be improved. Some stakeholders ar e convinced of the added value of a fully 
integrated EID system in which electronic identification is a pre-requisite. Farmers that are not engaged in any field trials and/or research on the subject reject the idea of mandatory 
introduction of EID: they  do not see any added value by simp ly replacing a conventional ear 
tag with an electronic one.  
 
The main concern in this option is the lack of harmonised EU technical standards.  Each MS 
can select the standards it wants and this appr oach may lead to a lack of harmonisation. If 
technologies used in a given MS are not the one s selected in another MS, electronic exchange 
of data would not be possible in case of export from one MS to another and the benefits of 
having EID systems would be lost. No change to  the current provisions would mean that each 
bovine animal has to be identified by two c onventional visible ear tags. The individual 
traceability of bovine animals is guaranteed. If keepers want to use electronic identifiers, the 
current legislation allo ws for doing so but only in addition  to the two official (conventional) 
ear tags, resulting in a total of three means of identification. If farmers decide to go this way 
despite no harmonisation of technical standard s, this option would be more expensive 
compared to option 2 (voluntary) and to op tion 3 (mandatory) since animals would need three 
instead of two identifiers.  
 
Impacts of option 2 Voluntary regime 
 
Under OPTION 2 is not possible to predict exac tly which EU Member States and/or which 
holdings would introduce EID on a voluntary basi s, making specific calculations for these two 
sub-options in the cost model difficult. Therefor e, the total cost of OPTION 2 is expected to 
be in a range between OPTION 1 a nd OPTION 3. After all, if under O
PTION 2A EID would 
become obligatory in a specific Member State, this w ould entail identical costs to OPTION 3 . 
Therefore, cost figures per MS would be as in Annex VI as well as at the Study on the 
introduction of electronic identif ication (EID) as an official method to identify bovine animals 
within the EU. There is no definitive data available on which EU MS would decide to go for 
OPTION 2A or 2B  and guessing this information in this report would be di fficult. However, 
this report has already referred to a number of  EU MS which have decided to go for bovine 
EID on a voluntary basis. 
 
One of the main advantages of the voluntar y approach, regardless of whether it is O PTION 2A 
or O PTION 2B, is based on the fact that actors would have time to familiarise themselves with 
the EID system and identify the added value it would bring in particular circumstances. The 
voluntary option approach leaves open the possib ility of EU Member States and the private 
actors organising themselves, so they can evaluate  if it is really an improvement: to consider 
regional differences, different types of producti on and whether it is flexible enough to be 
supported by the public authorities. Already now,  bovine EID is permitted in several MS and 
used by farmers/private operators because of commercial interests and management requirements. If the introduction of EID became vol untary, it can be assumed that this regime 
 
5 would be chosen by the keepers that currently make use of the immediate benefits for farm 
management. This is a completely private decision taken for economic reasons ( market 
driven ) by each operator. However, these actors ar e also prepared to consider voluntary EID 
depending on what the Commission proposes in terms of regulatory benefit. For instance, if 
individual information were record ed centrally there should be no need to maintain on farm 
holding registers or use movement documents  (which are necessary even if passports are not 
required); a llowing reporting from third parties  (e.g. transporters - so that the keeper does not 
have to report off movement as it is already in place for other species) would also be an 
incentive. Also, it was highlighted that there woul d be significant benefits  if the off movement 
could be recorded at a critical  control point (i.e. a market or slaughterhouse). By including 
these other changes in the regu lation, users will identify quan tifiable regulatory benefits, and 
would therefore decide by themselves to use EID. Full extrapolation at the Member State level 
or at EU level would, however, remain arbitrar y and could quickly lead to wrong conclusions. 
However, the voluntary approach may lead to ne gative consequences in short term, as the EU 
could be faced with different situations in diffe rent MS leading to a certain level of confusion 
in terms of identification. In the case of intra-EU trade it may become rather difficult to trace which kind of official identification is being used.  Similar to OPTI ON 1, some EU MSs (and 
stakeholders) consider th at the current system for bovine id entification and traceability is fully 
operational and satisfactory as it is. With resp ect to consumer confidence, under OPTION 2 it 
will be difficult to determine the difference between EID-meat and conventionally-tagged-
meat, so there should be no impact. Howe ver, national or regional systems for traceability 
may gain accuracy and speed for those EU MS deciding to go for Option 2A which would 
strengthen consumer confidence. 
 Impacts of option 3:" Mandatory regime" 
 
This option may  not be the best approach as some stakeholders (e.g. small farmers) would be 
disadvantaged economically, but it  would be the most efficient option in terms of consumer 
protection (traceability), reduction of administrative burde n, and to avoid risks related to 
the co-existence of two systems of identification. This option would be justifiable in terms 
of better coherence with EU policies on EID in other animal species (e.g. sheep),. The 
analysis of O
PTION 3 (mandatory) leads to the conclusion th at most of the costs are borne by 
the farmers while benefits are distributed al l along the food chain. One main criticism from 
stakeholders is that it is not  those who pay who actually bene fit from the investment. The 
Study  makes a distinction under OPTION 3 between the approach by which all bovine 
animals need to have an electronic identifier within the first year  of the new regulation 
coming into effect ( one-off regulation -see Table 8)  and a transitional approach  which would 
entail only newborn animals getting an electronic identifier. Some stakeholders (in particular 
representatives of the meat industry) have e xpressed their preference for the mandatory option 
and the “within one year”  implementation. Option 3 would not  lead to the problems described 
under OPTION 2 related to the coex istence of two different system s of animal identification. 
OPTION 3 would imply all stakeholders us ing EID allowing optimal improvements for 
traceability in terms of  accuracy and speed. 
 In relation to the economic impact on stakeh olders, the most affected group would be 
livestock farmers  because they bear the costs of ta gging. A comparison of electronic reading 
and manual reading (option 3 versus option 1), clearly demonstrates that the increase in 
equipment costs (identifiers and readers) is not automatically compensated by the saving of 
labour costs for farmers. Some EU MS may c hoose to compensate farmers for the costs of 
tagging by making use of rural development f unds and other types of public state aids. 
 
6 However, OPTION 3 may positively reduce the risks of mistakes when identifying, 
registering and/or notifying animal  movements, resulting in potent ial reductions of the Direct 
Payment and other CAP schemes compared to OPTIONS 1 and 2. The impact of the use of 
RFID transponders in dairy and veal automation  is described in detail in Annex XXI, 
concluding that the use of the RFID transponders for farm automation is beneficial for beef 
farming, although less beneficial for dairy farms that already have a high degree of 
automation. On the other hand, electronic r eading would be more cost efficient for markets, 
assembly centres and to a lesser extent, for slaughterhouses . These stakeholders move 
animals frequently and they will face only the costs of reading equipment and no costs of tagging. The impact for EID suppliers (compa nies) may depend on the how the EU Member 
State decides to organise supply among them (for example, call for tender, national bodies, 
single supplier/government per EU MS, etc). Some  stakeholders (in particular representatives 
of the meat industry) have expressed thei r preference for the mandatory option and the 
“within one year”  implementation. There would be budgetary consequences for the 
competent authorities  as current IT systems would need to be adapted to cover electronic 
identification. The Study  concluded that CAs would profit from the fact that all data would be 
automatically computerised, saving labour costs  and reducing administrative burden for 
the competent authorities. EID may have a positi ve impact in terms of easing CA's activities 
like auditing the Direct Payment and other CAP schemes (as inspectors are already likely to 
be equipped with readers for electronic readi ng of sheep and goats). Competent authorities 
may benefit more from OPTION 3 than from  Options 2 and 1. The possible impact on 
consumer  prices will be minor compared to OPTI ON 1. On the assumption that an increase 
in the price for meat would need to occur to se t off the increase in pr oduction costs caused by 
EID, meat prices would rise by a maximum of 1%.   The summary tables below provides informati on on the economic impact s of the estimated 
cost of all official bovine reco rding tasks for the baseline scen ario (Option 1 but referred in 
the tables as Option 3) and the mandatory option (Option 3 but refe rred in the tables as Option 
1) per task and for all actors. There the total cost in excess of the baseline scenario can be 
retrieved. The cost of the Mandatory option (re ferred as option 1 in the table) reflects the 
variations depending on whether electr onic ear-tags and boluses are used. 
 
Table 2: cost comparison for the mandatory and baseline options per task and under two scenarios 
 
 
7  
Table 3: cost comparison for the mandatory and baseline options per each type of actor (in 1000 Euros and in 
%) and under two scenarios 
 
 
 3.2 Voluntary beef labelling  
Two different scenarios are presen t for voluntary beef labelling: 
Option 1  – do nothing (baseline scenario ): no change to the current system  
Option 2 – abolish the voluntary beef labelling . The specific provisions on voluntary beef 
labelling would be deleted from Regulatio n (EC) No 1760/2000, however, compulsory 
labelling for the origin of beef would remain unchanged. Economic impact of preferred op tion compared with baseline: the administrative procedure to 
approve voluntary indications on beef labels would disappear. Operators would be able to 
continue using existing labels. Consumer inform ation would not be at risk as all labelling 
indications would fall under existi ng horizontal EU legislation th at would be applicable to 
beef in the same manner as it is  currently already applicable fo r other meats. The "EU project 
on baseline measurement and reduction of ad ministrative costs" calculated a possible 
reduction of administrative burden of €362,000. Annex VIII gives a detailed overview of the 
impacts on different operators.  
 4 THE PREFERRED OPTIONS
 
 4.1 Bovine EID 
 
It could be concluded that “O
PTION 3 : Mandatory” is not the best approach at the moment  as 
some stakeholders (e.g. small farmers) are di sadvantaged economically, but it would be the 
most efficient option in terms of consumer protection (traceability), reduction of 
administrative burden and avoidan ce of risk in intra-EU trade .  “OPTION 1 : Do Nothing” 
may lead to different technical standards and to negative intra-EU trade consequences. In 
 
8 addition, this option does not fulf il the expectations of the se ctor in terms of reduction of 
administrative burden.  The “OPTION 2B: Voluntary at stakeholder level" was not 
considered as a valuable opti on by most of the interviewees as it might result in the 
establishment of two different systems in ever y EU MS, and ultimately two different markets, 
leading to confusion with possi ble impacts on the efficiency of the current traceability system.  
The change in the identification system  can be best introduced on a voluntary basis 
(OPTION 2A) with the possibility for each EU MS to decide  if it wants to introduce EID on 
a mandatory basis in its national territory. EU Member States have very different farming 
practices and sector organisations. For these r easons, it would be advisable to recommend that 
it is up to each Member State to work collabor atively with all actors  in the food chain to 
identify the added values of EID and to s ecure its acceptance so that EID can be made 
compulsory at the right moment. Each MS could decide to intr oduce EID by law at a 
convenient time and not be pushed into it. OPTION 2A  may limit problems linked to the co-
existence of two different system s of identification compared to OPTION 2B. In terms of 
reduction of administrative burden, OPTION 2A is preferable to OPTION 2B . In conclusion, 
even if electronic identification entails higher costs compared to conventional identification, it 
has been demonstrated that benef its can occur for businesses in spec ific cases. It is only when 
considering regulatory and business benefits toge ther that EID is likely to be accepted by the 
actors. Therefore the preferred option would be a volunt ary regime (option 2) with the 
possibility for Member States to introduce a mandatory regime at nat ional level (sub-option 
2A.) The effectiveness, efficiency and coherenc e of Option 2A could be assessed some time 
after implementation. On the basis of this ev aluation, the Commission c ould further reflect on 
the need to strengthen the mandatory implementation of EID at EU level. 
 
 
4.2 Voluntary beef labelling 
 
It can be concluded that Op tion 2 is the preferred option.