EN    EN EN 
 
EN    EN  COMMISSION OF THE E UROPEAN COMMUNITIES 
Brussels, 18.9.2008 
SEC(2008) 2424 
  
COMMISSION STAFF WORKING DOCUMENT 
 
accompanying the 
Proposal for a 
 
COUNCIL REGULATION 
 
on the protection of animals at the time of killing 
  
IMPACT ASSESSMENT REPORT 
{COM(2008) 553} 
{SEC(2008) 2425} 
 
EN 2   EN TABLE OF CONTENTS 
1. Procedural issues and consulta tion of interested parties.............................................. 8 
1.1. EFSA opinions and guidelines of the World Organisation for Animal Health 
(OIE) .......................................................................................................................... .. 8 
1.2. External study (FCEC)................................................................................................. 8 1.3. Consultations of interested parties ............................................................................... 8 1.4. Food and Veterinary Office reports ............................................................................. 9 1.5. Internet consultation..................................................................................................... 9 
1.6. Consultation of the Member States.............................................................................. 9 1.7. Inter-Service steering group on the impact assessment ............................................. 10 1.8. Follow-up to Impact Assessment Board recommendations....................................... 10 2. Problem definition...................................................................................................... 10 2.1. Background ................................................................................................................ 10 
2.1.1. Background on the slaughter sector in the EU........................................................... 10 2.1.2. Background on Directive 93/119/EC......................................................................... 10 2.2. A new context ............................................................................................................ 1 1 
2.3. Specific problems arising from this new c ontext and the application of Directive ... 13 
2.3.1. Different approaches taken by the Me mber States on the new methods of 
stunning creating unsatisfactory welfare conditions and impeding innovation......... 13 
2.3.2. Different approaches taken by operators in integrating animal  welfare rules in 
their operations........................................................................................................... 13 
2.3.3. Unregulated areas with increas ing animal welfare concerns ..................................... 15 
2.3.4. Religious slaughter..................................................................................................... 15 
2.4. Subsidiarity .............................................................................................................. .. 16 
3. Objectives.................................................................................................................. . 17 
3.1. General objectives...................................................................................................... 17  
3.2. Specific objectives ..................................................................................................... 17  
3.3. Relationship between objectives a nd with other EU  initiatives................................. 17 
4. Policy options............................................................................................................. 1 9 
4.1. The main policy options............................................................................................. 19 4.1.1. The baseline = Do-nothing......................................................................................... 19 4.1.2. Option 2: Adoption of non-biding recommendations ................................................ 19 
4.1.3. Main option 3: Amending the Directive .................................................................... 20 4.1.4. Main option 4: Reorganising the legislation .............................................................. 20 
 
EN 3   EN 5. Impacts analysis ......................................................................................................... 21 
5.1. Identifying the impact/General remarks..................................................................... 21 5.2. Analysis of the baseline scenario ............................................................................... 23 5.2.1. General remarks on the baseline scenario / qualitative elements............................... 23 
5.2.2. Economic impacts ...................................................................................................... 25  
5.2.3. Social impacts .......................................................................................................... .. 30 
5.2.4. Environmental impacts .............................................................................................. 30 5.3. Analysis of option 2: no n-biding recommendations .................................................. 31 
5.3.1. Achieving the objectives............................................................................................ 31 5.3.2. Economic impacts ...................................................................................................... 32  
5.3.3. Social impacts .......................................................................................................... .. 32 
5.3.4. Environmental impacts .............................................................................................. 32 5.4. Analysis of option 3: amending the directive ............................................................ 32 5.4.1. Achieving the objectives............................................................................................ 32 5.4.2. Economic impacts ...................................................................................................... 33  
5.4.3. Social impacts .......................................................................................................... .. 36 
5.4.4. Environmental impacts .............................................................................................. 36 5.5. Analysis of option 4: reorga nising the EU legislation ............................................... 36 
5.5.1. Achieving the objectives............................................................................................ 36 5.5.2. Economic impacts ...................................................................................................... 39  
5.5.3. Social impacts .......................................................................................................... .. 45 
5.5.4. Environmental impacts .............................................................................................. 45 5.5.5. Summary of costs....................................................................................................... 4 5 
6. Comparing the options ............................................................................................... 49 6.1. Main policy options ................................................................................................... 49 
6.2. Comparing the components of option 3 "amending the directive" ............................ 50 
6.3. Comparing the components of option 4 "Reorganising the legislation".................... 51 
7. Monitoring and evaluation ......................................................................................... 54 8. Conclusion ................................................................................................................. 5 5 
ANNEX I - List of main organisations and companies consulted ........................................... 56 ANNEX II – Stakeholders consultation................................................................................... 57 ANNEX III – Missions of the Food and Veterinary Office..................................................... 62 
 
EN 4   EN ANNEX IV - Main outcomes from th e Member States consultation ...................................... 65 
ANNEX V – EU sectors affected  by Directive 93/119/EC ..................................................... 66 
ANNEX VI - Current Stunning and bleeding te chniques used in slaughterhouses................. 73 
ANNEX VII - Main requirements of Directive 93/119/EC on the protection of animals at 
the time of slaughter or killing ............................................................................................... .. 74 
ANNEX VIII - Main technological developments  in slaughtering techniques and their 
welfare relevance.............................................................................................................. ........ 75 
ANNEX IX - Hygiene package requirements in a nutshell ..................................................... 76 ANNEX X - Example of the discrepancies of situation in Europe concerning Controlled 
Atmosphere Stunning from information collected from manufacturers .................................. 78 
ANNEX XI – Directive or Re gulation in this case? ................................................................ 79 
ANNEX XII – Comparative price level indices of the survey, EU 27=100 ............................ 80 ANNEX XIII – Illustration of the impact of the baseline scenario on innovation: the 
example of controlled atmos phere stunning of poultry............................................................ 81 
ANNEX XIV – Complementary questionna ire to the Member States .................................... 82 
 
EN 5   EN EXECUTIVE SUMMARY  
Every year nearly 360 millions pigs, sheep, goats and cattle as well as more than 
4 billions of poultry are killed in EU slaughterhouses. In addition the European 
fur industry kills around 25 millions an imals while hatcheries kill around 
330 millions day-old-chicks. The control of contagious diseases may also require the killing of thousands to millions of animals. 
The killing of farm animals is regulated by Council Directive 93/119/EC
1 on the 
protection of animals at the time of sla ughter or killing. The directive has never 
been amended. The present impact assessment will therefore mainly focus on whether the problems have changed and wh ether the original objectives are still 
valid. 
The starting point of the Commission propos al has been the adoption in 2004 and 
2006 of two scientific opinions from the European Food Safety Authority, which suggest revising the technical  annexes of the Directiv e. In parallel the World 
Organisation for Animal Health adopted in 2005 two guidelines on the welfare of 
animals at slaughter and kill ing leading to similar conclusions. As a consequence 
the Commission mandated an external cons ultant in 2006 to carry out a study on 
stunning/killing practices in slaughterhouses and thei r economic, social and 
environmental consequences. The study was finalised in 2007. At the same time 
the Commission conducted consultations of interested parties and Member 
States. Reports from the Commissions' experts from the Food and Veterinary 
Office (FVO) were analysed as they reflect the state of implementation of the current directive within the Member States. An internet consultation was also performed from December 2007 to February 2008. 
This legislation mainly affects sla ughterhouses, fur farming, hatcheries and 
killing performed for disease control pur poses. The meat industry is the most 
concerned sector since it kills the larges t number of animals. This is also where 
legislative requirements are more detailed  and explain why most of the impact 
assessment focuses on this industry. 
The context for killing farm animals has considerably changed since 1993. New 
technologies have been introduced, new scie ntific research have been carried out 
making current standards obsolete in some areas. Animal welfare concerns have also grown in our society and European citizens are increasingly more demanding on this aspect of the food ch ain. The legal environment has also 
changed for slaughterhouses with the adoption of the "Hygiene Package", a 
series of EU legislation on food safety which emphasizes the responsibilities of 
the food business operators. Massive kil ling during large animal epidemics have 
also raised questions on our way to ensure humane killing of animals. In 2006 the Commission adopted the first Commun ity Action Plan on the Protection and 
Welfare of Animals, introducing new concep ts such as the welfare indicators and 
the need for further research programs  and centres of reference on animal 
welfare. 
                                                
 
1 OJ L 340, 31.12.1993, p. 21. 
 
EN 6   EN Specific problems have also been identified with the present EU legislation such 
as the lack of harmonised methodology fo r new stunning methods, the lack of 
clear responsibilities for ope rators on animal welfare, the insufficient competence 
of personnel handling animals, or insu fficient conditions for the welfare of 
animals during killing for disease control purposes. 
The killing of farm animals is an area subject to EU legislation since 1974 and 
Community competence has been rein forced in 1993. Cons ultations from 
stakeholders and Member States confirm the relevance of Community initiative 
in this domain. This legislation affects th e meat industry, the sector of equipment 
manufacturers and some farmers' activities. All of them are working at international level and as k for an EU framework. 
The general objectives of the initiative attached to this impact assessment is to 
improve the protection of animals at th e time of slaughter or killing, while 
ensuring a level playing field for all busin ess operators concerned, so that their 
competitiveness is not affected by discrepancies in their costs of production or their market access. This initiative should also contribute to the Better 
Regulation/simplification policy.  
The specific objectives are to enc ourage innovation for stunning animals 
humanely, to ensure better integration of animal welfare in the production 
process of slaughterhouses , to increase the level of  knowledge of personnel 
concerned and to improve the protection of animals when massive killings occur. 
The options range from doing nothi ng (=baseline= option 1), non-biding 
recommendations (option 2), amending the directive (op tion 3) through its 
technical annexes and reorganisi ng the legislation (option 4).  
Slaughtering costs represent a limited part  of the total costs of slaughterhouses 
activities (20%) but could affect their co mpetitiveness. However changes in costs 
for slaughtering animals are unlikely to  affect the fina l price of meat. 
Slaughterhouses are already submitted to permanent official inspection through food safety legislation. The current anim al welfare legislation does not introduce 
additional requirements for official inspections. Animal welfare has a positive impact on meat quality and o ccupational safety. It also represents positive market 
values. No significant environmenta l impacts have been identified. 
From the comparison of the options it a ppears that doing nothi ng (option 1) have 
a number of negative impacts on the objectiv e pursued. None of them is likely to 
be achieved by this option. Animal welf are on many aspects is likely to be 
worsened while businesses will have to operate in an increasingly different environment from Member State to anothe r. Therefore simplification is far from 
being improved. Innovation will be discouraged by this situation despite efforts made in some Member States. Economic  costs on business and authorities will 
be limited in the short term. But de trimental effects on meat quality, public 
perception and occupational safety c ould have long term negative economic 
impacts on the meat sector. 
 
EN 7   EN The comparison between the other options in the light of the objectives makes 
clearly more advantageous to reorgani se the legislation (option 4) while 
amending the directive (option 3) woul d bring some benefi ts and providing non-
biding recommendations (option 2) will not suffice to tackle most of the objectives. Therefore option 2 alone can not be considered as to be sufficient way 
to address the issues, but could be cons idered interesting as a complementary 
instrument. 
Non biding recommendations (option 2)  would in particular contribute to 
improve animal protection and meat quality. It could also contribute to establish 
a certain level playing field among busine sses but in a very limited way due to 
the non mandatory nature of the option. 
Reorganising the directive (option 4) is  the only option where innovation can be 
encouraged and simplification provided  (changing the legal instrument and 
having a new approach). It is also brings more be nefits than amending the 
directive (option 3) as regard s animal protection. It is also the option that is likely 
to bring the most positive impacts in te rms of meat quality, public perception and 
better working condition s in slaughterhouses. 
Options 3 and 4 will generate short terms costs for certain businesses but their 
effects will depend if specific measures  are taken like po ssible transitional 
periods or exemption in specific cases.  
Environmental impacts are considered to be neutral for all op tions as there was 
no evidence during the collection of data of  substantial and/or direct effects on 
environment. 
The general monitoring of the legislati on on animal welfare is included in the 
Regulation 882/2004 on official controls of food and feed
2 and this document 
does not suggest developing at this stage specific instrument that would create 
administrative burden for the Member States.  
                                                 
2 OJ L 165, 30.4.2004, p. 1–141. 
 
EN 8   EN 1. P ROCEDURAL ISSUES AND CONSULTATION OF INTERESTED PARTIES  
1.1. EFSA opinions and guidelines of th e World Organisation for Animal Health 
(OIE) 
Following a Commission request, the Eur opean Food Safety Authority adopted 
two scientific opinions in 20043 and 20064 on the different stunning and killing 
methods to be used for main farm sp ecies either for slaughter for human 
consumption or for disease control purposes. 
In parallel, the OIE provided two guidel ines on the welfare of animals for the 
slaughter of animals and for the killing of animals for disease control purposes. The two guidelines have been first adopted in 2005 and revised every year
5. They 
contain detailed technical requirements fo r the different aspects of the slaughter 
or killing of animals. OIE guidelines ar e not legally binding for the Community 
but represent a large consensus in the world.  
1.2. External study (FCEC) 
The Commission ordered in July 2006 an  external study on the stunning/killing 
practices in slaughterhouses and their economic, social and environmental consequences
6. The study was finalised in July 2007. 
In the framework of the study, major stakeholders such as meat industry 
associations, competent authorities a nd animal welfare associations were 
consulted at European and nationa l level (see Annex I). Individual 
slaughterhouses, consulting firms, farmers' organisations and equipment manufacturers were also c ontacted for that purpose. 
For all species studied, there was a globa l perception among most stakeholders 
that animal welfare was progressively inte grated as one of th e key dimensions to 
continue their business in Europe. In pa rticular this evolution explained the 
success and the development of new methods of stunning considered more 
humane like the use of modified atmos phere for poultry or pigs, although such 
new techniques required much higher investment and operational costs. 
1.3. Consultations of interested parties 
Regular bilateral meetings were also held with the major stakeholders and with a 
number of scientific, technical and lega l experts concerning different aspects of 
the proposal. Consultations started from July 2006 and included organisations of 
slaughterhouse operators, organisations of animal together ns of farmers, etc.
7 
                                                 
3 The EFSA Journal  (2004), 45, 1-29, Welfare aspects of the main systems of stunning and killing 
the main commercial species of animals. 
4 The EFSA Journal  (2006) 326, 1-18, ”The welfare aspects of the main systems of stunning and 
killing applied to commercially farmed deer, goa ts, rabbits, ostriches, ducks, geese and quail. 
5 See http://www.oie.int/eng/n ormes/mcode/en_titre_3.7.htm 
6 http://ec.europa.eu/food/animal/welfare/s laughter/slaughter_econostudy_en.htm 
7 Main organisations and companies consulted on bilateral basis are listed in Annex I. 
 
EN 9   EN The initiative was also publicised8 through regular presentations at industry 
forums and at the Commission relevant advisory committees of the Directorate 
General for Agricultur e during the period 2006-2007. 
The initiative was also presented at a working group of the Advisory Group for 
the Food Chain and Animal and Plant Health on 19 December 2007 (see Annex II). The Group
9 contains 36 European organi sations from which some of 
them are directly concerned such as meat industry sector, farmers, retailers, veterinarians and animal welfare organisations.  
1.4. Food and Veterinary Office reports 
Commission experts from the Food a nd Veterinary Office (FVO) performed 
regular inspections in order to verify that Member States take the necessary implementing measures to ensure complia nce with Community rules. As regards 
Directive 93/119/EC, FVO experts have re gularly visited the Member States for 
years and collected valuable information on the difficulties of implementation faced at national level. The general report of a series of missions carried out in 
2006-2007 to evaluate controls at the time of slaughter and killing provides an overview of the outcomes of the most recent missions
10 and important 
information on the effectiveness of th e supervision by Member States on the 
enforcement of animal welfare require ments. Annex III provides the list of 
missions performed on slaughter since 2003. 
1.5. Internet consultation 
Specific webpages11 were also created on the website of the Commission, 
providing the background of the initiative as  well as a list of the main topics of 
reflection. Roadmap and timetable of th e proposal, terms of reference of the 
socio-economic study, details of the cons ultant realising the study were also 
available on those pages. The report of  the study was published on the website in 
September 2007. The webpages have been regularly updated in order to publish 
the different position papers of the stakeh olders and to stimulate exchange of 
views. From December 2007 to February 2008 a specific mailbox was opened with an update on the main topics of reflect ion in order to invite stakeholders to 
provide their views on the subject. 
1.6. Consultation of the Member States 
The initiative was presented in details to the Member States in the framework of 
a working group on 25 January 2008. Afterw ards some Member States provided 
specific contributions (see Annex IV). An additional questionnaire was sent to all 
Member States for collecting complement ary data from which the Commission 
received 11 replies (see complement ary questionnaire in Annex XIV). 
                                                
 
8 Round table Seminar on the issue of Slaughter and stunning of animals, 24 July 2007, Markfield 
(UK) co-organised by the Islamic Foundation and CIWF; General Assembly of the OABA in Paris 
12 May 2007; Training Session "Bienestar animal, Protecion de los animals en el momento de su 
sacrificio, Madrid, March 2007; Symposium sur le Veau de boucherie, St Malo, novembre 2006; General Assembly FNICGV, Toulouse, June 2006. 
9 The list of members was published in OJ C 97, 21.4.2005, p. 2. 
10 DG(SANCO)/2008-7974 – GR General report of a series of missions carried out in 20062007 to 
evaluate controls of animal welfare at the time of slaughter and killing. 
11 http://ec.europa.eu/food/animal/welfare /slaughter/slaughter_directive_en.htm 
 
EN 10   EN 1.7. Inter-Service steering gro up on the impact assessment 
Two Commission inter-service steering gr oups took place, one at a very early 
stage of the IA draft (in February 2008) a nd one at the final stage of the draft (in 
April 2008). Were invited DG AGRI, TR ADE, EMPL, ENV, ENTR, JLS, RTD, 
LS and SG. 
1.8. Follow-up to Impact Assessment Board recommendations 
The Impact Assessment was submitted  to the Board on  14 May 2008 and 
discussed at the Board meeting of 4 J une. In its opinion, the Board made the 
recommendations and the document was accordingly redrafted. This includes: 
• merging the information of the st atus quo in a single comprehensive 
baseline scenario; 
• clarifying the links between main and specific objectives; 
• clarifying the links between the main options and the possible sub-options; 
• applying more consistently criteria for assessing each options; 
• identifying better costs for businesses and for public administrations in 
implementing each option. 
2. P ROBLEM DEFINITION  
2.1. Background  
2.1.1. Background on the slaughter sector in the EU 
Nearly 360 millions pigs, sheep, goats and cattle are killed in EU slaughterhouses 
as well as more than 4 bi llions of poultry every year12. Slaughter for human 
consumption may also take place outsi de slaughterhouses in certain cases 
(farmed game, derogations, etc.). In add ition some productions require the killing 
of millions animals on a regular basis (around 25 millions for the fur industry13 
and more than 300 millions for hatcheries) or occasionally (casualties, accidents). 
The control of contagious diseases may al so require the killing of thousands to 
millions of animals. Details on the differe nt sectors affected are provided in 
Annex V. Stunning and bleeding methods di ffer according to species. Details on 
the current stunning/bleeding techniques us ed in the EU are provided in Annex 
VI. 
2.1.2. Background on Directive 93/119/EC 
Directive 93/119/EC provides conditions for the stunning and killing of farm 
animals. It was never amended since it  started to apply in 1995. The Directive 
applies to the slaughter or killing of animals inside and outside slaughterhouses. 
Main requirements of Directive 93 /119/EC are listed in Annex VII. 
                                                 
12 Based on 2007 statistics, 258 millions pigs, 72 millions sheep and goats and 29 millions bovines 
are slaughtered in the EU yearly. Based on partia l 2007 data there are at least 4 billions poultry 
slaughtered every year in the EU. 
13 Based on 2006 data. 
 
EN 11   EN 2.2. A new context 
The general context at the time of adoption of Directive 93/119/EC has 
substantially changed and motivates the Commission to envisage the revision of 
this EU legislation. The following consider ations have been taken into account: 
(1) New technological developments : Since 1993 science and technology in 
slaughtering farmed animals, for the production of food or other purposes, 
have noticeably developed (see Annex VIII for examples). 
(2) Increasing animal welfare concerns amongst EU citizens:   
 According to the latest Euro-barometer survey14 performed in 2006 "  
animal welfare is an issue which citizens  rank highly, giving it 8 out of 10 
on average in terms of importance. (…) ." This high level of importance 
given to animal welfare is in line with the result of the first survey where 55% of EU citizens said that they be lieve animal welfare and protection do 
not receive enough importance in th eir country's agricultural policy . This 
concern has been enshrined in the Treat y with the adoption of the Protocol 
on the Protection and Welfare of Animals
15 in the EC Treaty of Amsterdam 
in 1997.  
 However, when consultation was carri ed out concerning a possible grading 
system for slaughterhouses according to different levels of animal welfare standards applied, there was a unanim ous opinion from organisations of 
animal protection as well as from th e meat industry that animal welfare 
standards at slaughter  were not negotiable  and should be determined by the 
legislation. According to them, th ere is a strong expectation amongst 
consumers that animals are slaughtere d correctly but they would be very 
reluctant, when buying meat, to ge t information on the details of 
stunning/killing methods used in order to make their choice. 
(3) Changes in the EU legislative cont ext applicable to slaughterhouses : The 
EU legislative context applicable to  slaughterhouses operators has been 
substantially changed by the introduc tion of the general food law and the 
subsequent legislation adopted in 2004 (the so-called "Hygiene 
package")16. One of the key changes of this set of legislation was to 
increase the responsibilit y of food business operator s regarding food safety. 
Officials' role is mainly to ensure that operators develop and implement adequate measures to meet this objectiv e. As a consequence, the legislation 
is technically less prescriptive but requires more documentation on operational procedures. More details on the Hygiene package requirements 
are provided in Annex IX. 
                                                
 
14 This survey was carried out by TNS Opinion & Social, interviewing 29,152 citizens in the 
25 Member States and 4 accession and candidate countries between 6 September and 10 October 2006. 
15 Protocol on the Protection and Welfare of Animals (OJ C 340, 10.11.1997, p. 110). 
16 Regulation (EC) No 178/2002 (OJ L 31, 1.2.2002, p. 1), Regulation (EC) No 852/2004 (OJ L 226, 
26.6.2004, p. 3), Regulation (EC) No 853/2004 OJ  L 226, 26.6.2004, p. 22) and Regulation (EC) 
No 854/2004 (OJ L 226, 26.6.2004, p. 83). 
 
EN 12   EN (4) The EU has faced in recent years major animal epizooties  involving 
massive culling of animals for control ling the spread of animal diseases 
(Foot and Mouth Disease in 2001, Avia n Influenza in 2003). The massive 
scale of the killing has generated welfare concerns among the public and underlined the weaknesses of the EU legislation in this regard. 
Number of slaughtered animals as result of major epizooties that 
took place in the EU in recent years17 
1997-1998 Classical Swine Fever in the Netherlands: 
11 millions pigs  
1999-2000 Avian Influenza in Italy:  14 millions birds18 
2001 Foot and Mouth Diseas e in the UK (mainly): 
10 millions animals (mainly sheep, but also cattle 
and pigs) 
2003 Avian Influenza in the Netherlands and Belgium: 
30 millions birds  
 
(5) The Commission adopted in 2006 the Community Action Plan for the 
Protection and Welfare of Animals 2006-201019 introducing new concepts 
regarding the initiatives of the Commun ity in this field. Two concepts are 
particularly relevant: 
(a) the introduction of animal welfare indicators . The EU legislation 
today mainly focuses on input-based  parameters to establish welfare 
standards20. Animal welfare indicators are based on animals21 
(outcome based approach) and are different from the traditional input-based approach. 
(b) the development of research programs and centres of reference  on 
animal welfare. As animal welfare is a developing science with sometimes complex technical aspects,  operators and officials need to 
rely on centres of reference where they can develop their knowledge and request technical assistance when necessary.  
                                                
 
17 Figures on Classical Swine Fever and Foot an d Mouth Disease are extracted from the impact 
assessment study realised for the new Community  Animal Health Strategy (SANCO/10116/2007). 
Data on Avian Influenza are based on the requests for reimbursement addressed to the Commission by the Member States.  
18 Commission Staff Working Document SANCO/10613/2004 Rev. 4 Impact Assessment of the new 
Community measures for the cont rol of Avian Influenza, in acco rdance with the draft Commission 
proposals for a new Council Directive on the c ontrol of Avian Influenza and for a Council 
Decision amending Council Deci sion 90/424/EEC as regards Community compensation for Avian 
Influenza control measures. 
19 COM(2006) 13. 
20 For example in the case of electrical stunning, input based parameters could be the current (A), the 
frequency (Hz), the time of exposure (s) and the voltage (v). 
21 This could be for example the scoring of animals falling down in a passageway or the number of 
animals not properly stunned at the first time. 
 
EN 13   EN (6) International developments:  The World Organisation for Animal Health 
(OIE) adopted in 2005 tw o international guidelines22 on the subject, 
demonstrating the interest of the wo rld community in providing better 
information and guidance for slaughtering and killing farmed animals.  
(7) Market-driven developments:  the development of private standards by 
retailers/major food ma nufacturers that include animal welfare 
requirements have led to the applicati on of higher animal welfare standards 
in several cases. For example, the FC EC study confirms that in the case of 
poultry retail, demands often exceed  national legislation and the 
development of gas stunning has been mainly motivated by client demands despite higher costs. This has been al so observed in the case of pigs. In 
order to reflect consumer concerns on animal welfare, retailers have 
progressively integrated this dimensi on in their requirements including for 
slaughterhouses within and outside the EU, indi rectly affecting third 
countries exporting meat to the EU. 
2.3. Specific problems arising from this  new context and the application of 
Directive 
2.3.1. Different approaches taken by the Member States on the new methods of 
stunning creating unsatisfactory welfar e conditions and impeding innovation 
Directive 93/119/EC lacks technical de tails for implementation and has never 
been updated. For example, stunning of  poultry through the use of modified 
atmosphere is now being used  at industrial scale while it is not mentioned in the 
current EU legislation. Techniques for st unning animals with gas or electricity 
have evolved for different species but technical parameters in the Community 
legislation have not changed. 
This situation has caused unequal and sometimes unsatisfactory welfare 
conditions amongst EU slaughterhouses. It  has also generated fragmentation on 
the market for certain stunning equipment manufacturers and has contributed to 
impede innovation. 
This is typically the case for the de velopment of Controlled Atmosphere 
Stunning (see Annexes VIII and X). Similarly the development of water bath stunners using high frequency currents w ithout precise indicat ions in the EU 
legislation has led in some Member St ates to improper welfare conditions as 
highlighted by inspections perf ormed by Commission' experts
23. 
2.3.2. Different approaches taken by operators in integrating animal welfare rules in 
their operations 
Three main problematic areas have been identified: 
• Inadequacy of slaughterhouse facilities  
 Slaughterhouses facilities and fixe d equipments for restraining and 
stunning animals are not always designe d and built in order to take into 
account the welfare needs of animals, resulting in useless suffering during 
                                                 
22 See http://www.oie.int/eng/normes/mcode/en_titre_3.7.htm   
23 Final report of a mission carried out in France in February 2007 (DG (SANCO)/2007/7330-MR-
final). 
 
EN 14   EN handling. A similar problem has been faced for ensuring adequacy of 
facilities for food safety purposes and one of the key responses of the EU 
legislation in this area was to in troduce a system of pre-approval of 
slaughterhouses. 
 According to the FCEC study offici als tend to check welfare standards 
related to the design a nd facilities of slaughter houses too late, making 
changes for operators difficult and costly . This is partly due to the legal 
text which mixes structural elements  with operational ones under the same 
chapter. 
 Examples of structural aspects that  would need to be introduced in the 
legislation: a separate accommodation fo r sick animals, larger passageways 
for sheep and pigs, water supply in la irage facilities, r ecording device for 
electrical stunning apparatus or gas stunning systems, constant current 
stunners and a number of improvement s in shackling lines for poultry. 
• Responsibilities for animal we lfare are not clearly defined  
 Operators killing animals have not syst ematically integrated animal welfare 
as part of their operational objecti ves. Many operators still rely on the 
official veterinarians to implement animal welfare standards with unreliable results. A comparable pr oblem has been faced by the EU 
legislation on food safety and one of the key responses was to increase the 
responsibilities of the operators through the requirements of specific 
operating procedures (HACCP
24). 
• Lack of knowledge of offici als and slaughterhouse personnel  
 Despite the fact that training on an imal welfare is required by Regulation 
N° 854/2004, Article 6 of Regulation (EC) No 882/2004 of the Hygiene 
Package and Directive 93/119/EC, offici als in slaughterhouses, mainly in 
charge of controlling food safet y, have developed limited knowledge on 
animal welfare while the increasing complexity of the stunning techniques 
have made their tasks of inspection even more challenging. There is a 
structural problem due to the fact that  officials spend most of their time to 
post-mortem inspection, having litt le time to develop competence on 
animal welfare. 
                                                 
24 The requirement of implementing Hazard Analysis  Critical Control Points principles has been 
generalised to all food business operators through Article 5 of Regulation (EC) No 852/2004.  
 
EN 15   EN  As regards slaughterhouses' staff, the study performed by the external 
consultant indicates even though the EU legislation re quires training, 
implementation is in practice far from uniform as the text does not specify 
the way it should be done. Meat an d poultry slaughterhouses respondents 
declare that training is mainly  provided on a voluntary basis  (61% of 
respondents for the red meat sector and 60% for poultry) without being necessarily approved or s upervised by the competent authorities (56% of 
respondents for the red meat sector a nd 52% for poultry). In most of the 
Member States there is no compulso ry system of certification by the 
competent authorities to ensure that proper training is provided to staff. 
2.3.3. Unregulated areas with increasing animal welfare concerns  
Two areas have been subject  to specific concern: 
(1) In recent years, massive killing of animals have been carried out mainly for 
disease control purposes . The insufficient guidance regarding killing for 
disease control in the EU  legislation has raised serious concerns among the 
public on the efficiency of the me thods used and the corresponding 
depopulation strategy for controlling animal diseases. This concern is 
mainly due to the risk of insufficient preparedness of the Member States on 
the welfare aspects and the need of the public for more information on the 
measures taken to ensure that the we lfare of animals is properly addressed. 
(2) The current legislation does not contain provisions for farmed fish . 
Scientists consider that many methods  of killing comm only practiced are 
not acceptable from a welfare point of  view. However, this problem will 
not be addressed with the pres ent proposal for technical reasons . Fish 
present substantial physiological di fferences compared to terrestrial 
animals. In addition technical pro cesses and economic organisation for 
slaughtering fish can not be assimila ted to the ones used  for terrestrial 
animals25. Fish species will be dealt with in a separate in itiative later on. 
2.3.4. Religious slaughter 
The current Directive provides a deroga tion to perform slaughter without 
stunning in case of religious slaughter (J ewish and Muslim rites) when it takes 
place in slaughterhouses. However Sweden, Lithuania, Latvia and some regions 
of Austria require prior st unning for religious slaughter26. 
                                                 
25 It should be noted that in the framework of the World Organisation for Animal Health that have 
developed international codes for animal health and welfare, aquatic animals are subject to a different code than terrestrial animals. 
26 Outside the EU, Norway and Switzerland have  not authorised slaughter without stunning. 
 
EN 16   EN NGOs claim that the derogation is abus ed by some slaughterhouse operators who 
slaughter without stunning in excess to the re ligious market needs.  In fact part of 
the carcass from animals slaughtered without stunning is normally going to the 
non-religious meat market27. NGOs consider that non-Jewish/non-Muslim 
consumers need to be informed and they should be given the right to choose meat obtained from animals that have been stunned. 
Religious slaughter and animal welfare co ncerns are presentl y dealt by a specific 
Community Research project called DIAREL
28 not yet finalised. Animal welfare 
labelling is also subject to a separa te ongoing Commission initi ative to determine 
its feasibility. 
As the main objective of the proposal is to take into account the new context and 
technological developments, religious sl aughter will not be subject to specific 
changes in the proposal and therefore will not be addressed in the impact 
assessment.  
2.4. Subsidiarity 
The present initiative will not change th e scope of the current EU legislation 
adopted in 1993. The principle of subsidia rity was considered at the time of 
adoption of Directive 93/119/EC as it  was explicitly mentioned in its 9th recital29. 
Since then, the relevance of legislation at EU level has not been questioned and 
consultation with stakeholders has c onfirmed that furthe r harmonisation is 
preferred rather than more subsidiarity. 
Directive 93/119/EC is based on Artic le 37 of the EC Treaty on the Common 
Agriculture Policy as it provides a level playing field on animal welfare for all 
slaughterhouses in Europe. This legisla tion directly affects competition between 
the different operators within the internal market and in particular 
slaughterhouses within th e Community. It also aff ects Community trade policy 
since the measures apply to  slaughterhouses of third countries which intend to 
export to the EU.  
Besides temporary restrictions due to  outbreaks of animal diseases, meat 
produced in slaughterhouses is freely traded in the EU . Food safety rules have 
been harmonised and any meat from an approved establishment in one Member 
State can be sold in another Member State.  In addition, in some cases, the lack of 
harmonisation has created a certain fragme ntation of the market concerning the 
equipment used for stunning the animals (see example in Annex X). 
                                                 
27 This situation may be due to different reasons. In the case of Halal meat, most Muslim customers 
in Europe have a limited purchasing power and they tend to buy the cheapest part of the carcass. In 
the case of Kosher meat, some religious requireme nts make the use of hindquarters practically 
difficult (need to extract the sciatic nerve). In ad dition some slaughterhouses  operators may see the 
slaughtering of lambs without stunning faster to perform increasing their productivity and the 
possible future markets. 
28 http://www.dialrel.eu/ 
29 " Whereas in so doing Community action must comply with the requirements arising out of the 
principle of subsidiarity laid down in Article 3b of the Treaty; " 
 
EN 17   EN 3. O BJECTIVES  
3.1. General objectives 
The main objectives at the origin of current EU legislation are still valid.  
(1) Improving the protection of animals at  the time of slaughter or killing to 
respond to increasing citizens concerns in this respect30; 
(2) Encouraging innovation and the uptak e of new technological developments 
in relation to stunning an d killing techniques, 
(3) Ensuring rational development of production and providing a level-playing 
field within the internal market for operators, in particular for equipment 
manufacturers31. 
The initiative should also contribute to the better regulation/s implification policy.  
3.2. Specific objectives 
In order to reach those objectives and address the different problems identified, 
this proposal will aim at the following specific objectives: 
(1) Develop a common methodological a pproach to encourage innovation for 
stunning/killing animals;  
(2) Ensure a better integr ation of animal welfare concerns in the production 
process; 
(3) Ensure that the design of slaught erhouses facilities or infrastructures 
respecting the welfare of animals;  
(4) Increase the level of competence of operators as well as facilitate the 
access to technical and scientific information on animal welfare; 
(5) Improve the protection of animals at killing operations performed under a 
large scale (as for disease control purpose); 
3.3. Relationship between objectives  and with other EU initiatives 
Specific objective 1 contributes to all gene ral objectives. First of all it improves 
innovation (general objective 2) and simplification by ma king a single procedure 
for approving new stunning methods. Manufacturers will only have to proceed once and according to a transparent system, making innovation easier to commercialise. Secondly it creates a level playing field for manufacturers of stunning equipments (general obj ective 3) by establishing a common 
methodology for putting such goods on the EU  markets. Finally it by setting up 
                                                
 
30 The 5th and 8th recitals illustrate this objective:  
"Whereas at the time of slaughter or killing animals should be spared any avoidable pain or 
suffering;"  
"Whereas in the declaration on the protection of animals annexed to the Final Act of the Treaty on European Union, the Conference calls upon the European Parliament, the Council and the 
Commission, as well as the Member States, when drafting and implementing Community 
legislation on the common agricultural policy, to pay full regard to the welfare requirements of animals;" 
31 The third recital of Directive 93/119/EC: " Whereas there is therefore a need to establish common 
minimum standards for the protection of animals at the time of slaughter or killing in order to ensure rational d evelopment of production and to facilitate th e completion of the internal market in 
animals and animal products;"  
 
EN 18   EN transparent criteria for approving new stunning methods, this objective will 
contribute to improve animal welfare (general objective 1). 
Specific objective 1 is consistent with th e EU policy to develop animal welfare 
standards based on sound sc ientific basis a nd to encourage innovation. However, 
this objective should avoid the possible in crease in administrative costs and 
favour the principle of subsidiarity as much as possible. 
Specific objective 2 derives from ge neral objective 1 (improving animal 
protection) as it is crucial to integrate welfare standards in the daily management 
of the killing. In addition this objective contributes to create a level playing field 
for slaughterhouses and other operators ki lling animals (gener al objective 3). 
Specific objective 2 is in line with th e EU policy on food safety towards a 
simplified legislative framework that has be en developed in the recent years with 
the adoption of the so-ca lled "hygiene package". Empha sis has been given on the 
responsibilities of food business ope rators through improved operating 
procedures, better training and pre-appr oval of food producing establishments. 
This objective is also in line with the Community Action Plan on the Protection and Welfare of Animals 2006-2010 which emphasized the importance of outcome based indicators. 
Specific objective 3 also derives from general objective 1 (improving animal 
protection) since good practices can not pe rformed easily in ba dly conceived or 
constructed premises. But most importantly this objective is important for achieving general objective 3 since upgrad ing slaughterhouses in frastructures has 
an impact on investments and therefore on establishing a level-playing field for 
slaughterhouse operators. 
Specific objective 3 is consistent with th e EU approach of the Hygiene Package. 
This objective should avoid the possibl e increase in administrative costs, 
especially for small facilities
32. 
Specific objective 4 mainly contributes to improve animal welfare (general 
objective 1) but also to simplification. No progress can be achieved without 
proper training of personnel. It plays a ro le in simplification since training is a 
flexible and efficient way of implementing policies that avoid very prescriptive and complex legislation. 
Specific objective 4 is also part of th e strategy developed in the Community 
Action Plan on the Protecti on and Welfare of Animal s, which underlines the 
importance of better awareness and tec hnical knowledge on animal welfare. 
                                                
 
32 Article 5 (4) (a) of Regulation (EC) No 852/2004 insists that proof of compliance to HACCP 
principles to the authorities shall take into account the nature and the size of the food business. 
 
EN 19   EN Specific objective 5 mainly contributes in  implementing general objective 1 on 
animal protection. Despite that killing for disease control purposes is a relatively 
occasional, it involves high number of animals and this specific objective is therefore important for m eeting general objective 1. 
Specific objective 5 is coherent with the need for better crisis preparedness and 
prevention-led approach that is at the core of the new EU strategy on Animal 
Health
33. 
4. P OLICY OPTIONS  
4.1. The main policy options 
4.1.1. The baseline = Do-nothing 
The do-nothing option would simply leave th e current situation as it is with a 
possible increased divergence between the legal framework and the current 
practices; this could lead to preventing innovation and to the creation of barriers 
for operators, while public concerns of citizens on animal welfare would not be addressed. 
4.1.2. Option 2: Adoption of non-biding recommendations 
This option would consist in complementing the existing legal framework with 
the provision of Community  guidelines or the recogni tion of possible guidelines 
or self-regulatory codes by the industry and market players. These are no binding 
instruments and provide higher flexibility to operators. Providi ng guidelines is an 
attractive option as it does not complicate the legal framework. 
Guidelines have been developed at the international level by the OIE
34 but their 
practical effects are not assessed. The FCEC  study revealed that  several retailers 
or catering chains have been using code  of practices on anim al welfare as to 
ascertain that their suppliers meet the expectations of their clients regarding 
animal welfare. However, today there is no unique pan-European reference on 
animal welfare that slaught erhouses are referring to. 
More specifically this option includes the following sub-options: (1) Voluntary operational standards for slaughterhouses (sp ecific objective 2). 
This option would imply providing a gr eat number of technical parameters 
so that nearly all types of processe s and techniques w ould be covered by 
the guidelines.  
(2) Voluntary standards for slaughterhous es infrastructures (specific objective 
3). This sub-option will aim at provi ding recommendations related to the 
design of the facilities and the e quipments of slaughterhouses in 
accordance with recent scientific and technical findings (in line with the 
EFSA recommendations and the OIE guidelines). 
(3) Voluntary standards for massive kill ing (specific objective 5). This option 
would consist in provid ing specific technical recommendations on the 
methods that could be acceptable for massive killing. 
                                                
 
33 The new strategy is available at: http://ec.eur opa.eu/food/animal/diseases/strategy/index_en.htm 
34 For more details on this aspect see for read meat Table 18 of Annex 1 (Part 1) and for poultry 
p. 28-29 of Part 2 of the study. 
 
EN 20   EN 4.1.3. Main option 3: Amending the Directive 
This option would consider revising th e annexes without modifying the main 
legal framework. The general approach an d the basic structure of the directive 
will remain unchanged while technical requirements would be updated according to the latest scientific data. 
More specifically this option includes similar options as the previous one 
(corresponding to the content of the present annexes of the Directive) but in a way which is compulsory: 
(1) operational standards for slaugh terhouses (specific objective 2).  
(2) standards for slaughterhouses in frastructures (specific objective 3). 
(3) standards for massive ki lling (specific objective 5). 
4.1.4. Main option 4: Reorganising the legislation 
This option would introduce changes concerning the legal text, giving the 
opportunity to introduce more radical tran sformations than the previous option. 
In particular, this option would include modifying the legal nature of the text 
(regulation vs. dire ctive) and introducing new c oncepts such as welfare 
indicators or national networks of refe rence for animal welfare (for discussion 
between Directive and Re gulation see Annex XI). 
This option will make available new approaches such as the following: (1) New methodology for approving stunning methods
 (specific objective 1). 
This could be done by a centralised or a partially decentralised approach. A 
centralised approach would be to only rely on EU centralised authorisation 
of new methods of stunning/killing. As  there is today no mechanism or 
institutions responsible for this tas k, such option would imply a number of 
structural changes on this approach  (e.g. establishment of a specific 
administrative body or use of an exis ting agency such as the European 
Food and Safety Authority). An intermediate option would be to authorise the European Commission to lay dow n common rules for the methodology 
while leaving Member States to implem ent it with more transparency than 
today. 
(2) Improving integration of animal welf are in the production process (specific 
objective 2) by the requirement fo r Standard Operating Procedures
 (SOPs). 
this approach would be, as in the "Hygiene package" to lay down in the legislation the main objectives  and a common methodology under the 
supervision of the competen t authorities, while leav ing more flexibility to 
the operators in the way they coul d achieve those objectives (with the 
possibility for them to adopt guidelines). 
 
EN 21   EN (3) Improving integration of animal welf are in the production process (specific 
objective 2) by the appointment of an animal welfare officer  (AWO). This 
measure consists of introducing an ob ligation for operators to assign to a 
specific employee the responsibility for supervising the welfare of animals during the production process (so-calle d "Animal Welfare Officer"). This 
person would be responsible for managing animal welfare in the establishment with a sufficient level of power. This would not imply the 
creation of a new post as many sla ughterhouses employ a quality manager 
for the daily running of their quality system. 
(4) Increase the level of competence of operators (specific objective 4) through 
the introduction of a re quirement for a certificate of competence
. This 
measure would consist of setting up, as already implemented in other 
animal welfare legislation, a system of  certification on an imal welfare for 
employees handling animals. The system  is already implemented in the UK 
on a compulsory basis for slaughtermen. 
(5) Facilitate the access to technical and scientific information on animal 
welfare (specific objective 4) by the establishment of national centres of 
reference . This measure would require Memb er States to set up a national 
centre/network of reference where offi cials and operators could refer to 
when they need specific technical ba ck up. National networks of reference 
already exist for other veterinary issues and scientific resources are available on animal welfare in many Member States but they have no 
formal role in the EU legislation. 
(6) Improve the protection of animals at killing operations performed under a 
large scale  (specific objective 5) by th e introduction of a harmonised 
methodology . This option would introduce ge neral principles to enhance 
logistical preparedness, animal welfar e supervision and transparency on the 
animal welfare performan ce during killing operations. 
5. I MPACTS ANALYSIS  
5.1. Identifying the im pact/General remarks 
As previously presented the scope of the current legislation covers a wide range 
of activities where slaughterhouses repres ent the main amount of animals killed. 
Other activities are also a ffected but due to the importance of slaughterhouses, 
the impact assessment will focus on impacts for slaughterhouses only. 
The present impact analysis is based on the data collected by the FCEC study, as 
well as from the consultation of various s ources as presented in the first section 
of this impact assessment (procedural issu es). In particular it takes into account 
opinions expressed by stakeholders a nd Member States which have been 
consulted on various occasions and thr ough a complementary questionnaire at a 
later stage of this work. 
 
EN 22   EN The main impacts that have been identifie d and will be analysed in section 5 are 
the following: 
Economic impacts:  
• Direct impacts on production costs of slaughterhouses and on their 
competitiveness – this include analysising the costs implication of the 
different elements proposed in the opti ons, in particular (1) introduction of 
an animal welfare officer in sla ughterhouses (2) increased training 
requirements for slaughterhouse employees  (3) adaptation to infrastructure 
of slaughterhouses (4) new authorisa tion process for new stunning/killing 
methods (5) setting up Standard Operating procedures and monitoring requirements 
• Costs for authorities related to th e authorisation of new stunning/killing 
methods, establishing and running a system  of certificate of competence for 
personnel handling animals at slaught erhouses; setting up national centres 
of reference; producing a report on animal welfare results during 
operations of massive killi ngs (for disease control). 
• Indirect impacts on th e retail price of meat products - based on the 
conclusions of the FCEC study, no signi ficant impact on pri ce is expected 
from any change in slaughter practices. Therefore we have not analysed this impact further in the different options 
• Impact on meat quality – benefits of animal welfare requirements for meat 
quality are considerable – potential for such benefits are analysed 
quantitatively in the baseline option and are therefore not estimated in the detailed impact analysis of policy options 
• Impacts on third countries - The impacts of the envisaged changes on 
welfare animal standards would be lim ited in third countries, as in most 
cases they have already high animal welfare standards in place (beyond current EU requirements) and adapted fairly pro-actively to market demands. We have therefore not analys ed the variations in impacts for the 
different policy options in detail. 
Social impacts
 
• Animal welfare benefits 
• Public perception of animal production and meat products 
• Impacts on occupational safety of workers in slaughterhouses 
 
EN 23   EN Environmental impacts  
• No major direct impact except limited impacts in terms of reduction of 
spoiled meat (and meat waste) 
Data limitations 
The stakeholders' consultation delivere d only limited information on financial 
impacts. Generally stakeholders (both industry and competent authorities) 
claimed that estimation was very di fficult or even impossible for them. 
The costs to comply with the Regulati on are perceived by industries as much 
higher than administrative costs, and therefore some of them focused their 
answers on assessing complia nce costs. In addition, requirements established in 
the Directive overlap with other requirements (Hygiene package, Good 
Manufacturing Practices) and it is often difficult to estimate whether or not a 
given cost occurs only as a result of an  obligation resulting from the animal 
welfare rules. Even when stakeholders can provide some estimation of overall 
administrative costs imposed on them by cu rrent legislation it is difficult for 
them to assess how an eventual change of  legislation would affect these costs.  
Based on these limitations, the assessment of the options has not been carried out 
using the Standard Cost Model (Annex 10 of the impact assessment guidelines). 
We have nevertheless tried to quantify to the extent possible the impact of the 
options on administrative costs by using e xperience at national level and/or from 
similar policy areas and by basing cal culations on a number of assumptions 
where appropriate.  
5.2. Analysis of the baseline scenario 
5.2.1. General remarks on the baseline sc enario / qualita tive elements 
As regards the protection of animals at the time of slaughter or killing, the 
baseline scenario (i.e. do nothing) is likely to  worsen the situation.  
Already today due to a number of loopholes  of the current legislation, animal 
welfare is not properly ensured.  
Some techniques of stunning or killing are used, sometimes at large scale, 
without proper scientific assessment; Ne w slaughterhouses are often approved by 
the authorities without consideration fo r the welfare of the animals; Personnel 
slaughtering animals are not always qualifie d for their tasks and the efficiency of 
stunning is not regularly as sessed on the animals. O fficials in charge of 
controlling animal welfare in slaughte rhouses have not enough time and limited 
skills to perform adequately their res ponsibilities. Research and innovation on 
animal welfare at slaughter is some times neglected leaving officials and 
operators without proper information on the optimal way to slaughter animals. 
Commercialisation of innovative stunning methods or equipments has been 
delayed in the past due to lack of harmonised approach, and there is no reason to believe that innovation will be encour aged by maintaining the status quo. 
Differences in welfare standards between  Member States have been noticed, 
creating distortion of competition between operators. 
 
EN 24   EN To be more specific, the baseline  scenario would imply the following 
consequences, regarding the specific objectives : 
As regards the approval of  new stunning methods, today they are examined and 
evaluated by Member States individu ally without a common methodology. From 
the legal point of view, the situation is uncertain since the subsidiarity on this 
aspect is not properly defined in the Di rective. In fact Article 13 (2) (b) and 
Article 18 (2) of Directive 93/119/EC does not clearly ban Member States from 
approving new stunning methods  at national level. 
Doing nothing will therefore leave the Me mber States grant authorisation for 
new stunning methods. However this situ ation has up to now delivered unequal 
welfare outcomes in the EU while creating technical barriers to the 
commercialisation of positive innovations  for the welfare of animals. 
This could be illustrated by the emergen ce of the use of high frequency electrical 
stunning for poultry where, some Member  States have established clear 
indications while other competent authori ties have left local inspectors without 
instructions. Annex XIII provides an illu stration of the impacts on innovation of 
the baseline scenario in the specific cas e of controlled atmosphere stunning of 
poultry (CAS). 
Concerning a better integrat ion of animal welfare concerns in the production 
process, the current rules re quire that operators must apply legal requirements but 
the competent authorities are mainly responsible for enforcing the measures through direct control. Therefore there is no incentive for ope rators to develop 
their own knowledge and operational proced ures with the present legislation. 
Despite voluntary approaches, this ma kes outcomes heavily dependant on the 
level of initiatives and resources of the slaughterhouses an d of the competent 
authorities. Experience derived from inspections performed by Commission 
experts has indicated very mixed results in this regards. If some efforts have been 
achieved by the authorities in some Memb er States and part of the industry has 
developed pro-active schemes on animal welfare, the situation is far from 
homogeneous. There are still situations in the EU where the welfare standards 
are unsatisfactory due to systemic failure of the authorities in controlling operators. 
The do-nothing option is likely to worsen the situation by the fact that the current 
legislation lacks specific details on many aspects of the stunning procedures 
opening the way for bad practices. This has been observed by the Commission's experts when the central authorities did not provide sufficient technical 
instructions to their field inspectors. However, even in case of adequate instructions provided by th e authorities, current official resources do not allow 
permanent supervision at places where animals are handled and slaughtered. In 
addition, other places where animals are regularly killed do not benefit from 
permanent veterinary inspections (e.g. fa rms for fur animals, hatcheries, etc.). 
Regarding the design of slaughterhouses,  the present EU legi slation provides for 
certain requirements that are not in line with new knowledge and upgrading is necessary. In addition the r eadability of the Directive is pres ently poor on this 
aspect: structural requirements are disseminated among operational ones making 
the implementation by the competent authorities uneven. 
 
EN 25   EN Staff competence in slaughterhouses is criti cal for the welfare of live animals and 
there is little evidence that market pre ssure will increase alone the training of 
employees handling and killing animals. Nowadays those tasks are physically 
demanding and often performed by sta ff with little educ ational background. 
According to the FCEC study, training is often provided without supervision of 
the competent authority and mainly on a voluntary basis. Therefore the situation 
depends mainly on the initia tive taken by the operators. 
Competence on animal welfare of officials is also essential. Commission' experts 
have observed serious discrepancies, some  officials in the Member States having 
little knowledge of the basic principles of animal welf are in slaughterhouses, as 
outlined in recent FVO reports35. 
Today's legal framework on killing for disease control purposes allows national 
authorities to take nearly all possible mean s to perform tasks with little regard to 
animal welfare issues. Commission expe rts have found that in some Member 
States, some methods of killing have been widely used without being scientifically assessed from a welfare poi nt of view. This does not necessarily 
mean that those methods should be reject ed but questions the approach taken by 
each Member State. Killing for diseas e control purposes involve public money 
(included at Community level)  and have raised in the past serious public concern 
on animal welfare grounds. 
Doing nothing will perpetrate a situ ation where massive killing could be 
performed without necessarily enough cons ideration for the welfare of animals. 
This in return could lead to serious re sistance on certain asp ects of the animal 
health Community policy (eradication of animal disease thr ough killing infected 
and suspected animals). 
5.2.2. Economic impacts  
Production costs of slaughterhouses in the EU and impact on competitiveness
 
Although the cost structure varies for each  slaughterhouse, the data collected by 
the external consultant indicate that th e part represented by the process where 
live animals are treated in a sla ughterhouse is cu rrently limited. 
As regards the red meat industry, costs rela ted to the treatment of live 
animals represent approximately 20% of the total costs for producing a 
carcase . No major differences were found in  the allocation of  operating costs 
between Member States, species or st unning techniques (see Table 1). As 
indicated, costs were relatively evenly spr ead between the reception of animals in 
lairage, and the operations of restrain ing, stunning and bleeding. In most cases 
those costs were mainly represented by labour costs. 
                                                 
35 http://ec.europa.eu/food/fvo/index_en.htm 
 
EN 26   EN Competitiveness of the European red meat sector at the time of the study was not 
homogenous. While the pig sector has not been protected and stakeholders did 
not express specific concerns on its competitiveness, the picture is more nuanced regarding the beef sector. As it has been  supported by import du ties, it could be 
more vulnerable to imports from Brazil or Argentina. However, the EU beef 
sector presents some competitive advantages (less dependent on feed and better labelling and traceability system) with  the present context (higher feed 
costs/higher demand from consumers). In a ny event, the welfare requirements for 
animals at slaughter equally apply to sl aughterhouses in third countries which 
guarantee a level-playing field. 
Table 1: Allocation of costs in the slau ghterhouse production chain (red meat) 
 
In the poultry industry, the cost linked to the process where live animals are 
treated at the slaughterhouses (excluding transport – not subject to this 
legislation)  represent between 22% and 7.1%  (see reception + shackle + 
waterbath + bleeding in Table 2). Investment a nd installation costs are 
significantly different between waterb ath stunners (less than 20.000 €) and 
controlled atmosphere stunning systems and estimates of additional costs greatly vary (between three and five times higher than electrical systems). There is also a 
significant difference in running cost s between these two major stunning 
techniques. While running costs for elec trical stunning are considered as 
negligible by the industry (1€/1000 birds) , it is more expe nsive for gas stunning 
(up to 5€/1000 birds when using Argon or other anoxic gases). On the other hand 
costs generated by gas stunning system ar e partly compensated by a number of 
direct or indirect benefits (greater throughput, incr eased meat quality and yield, 
less labour and better working conditions). 
 
EN 27   EN Table 2: Allocation of costs in the sl aughterhouse production chain (poultry) 
 
According to the external study, the EU  poultry industry as a whole (including 
farming) is relatively uncompetitive and potentially likely to be highly vulnerable. The industry points out two ma in threats that are higher domestic 
production costs (feed) and compliance costs with the EU legisl ation. There is a 
perception within the industr y that slaughterhouses in some third countries are 
less likely to invest in controlled atmo sphere stunning due to a lack of access to 
credit and a relatively uncertain econo mic environment. However it should be 
noted that up to now progress towards bett er welfare standards in this sector has 
been significant and due to market pressure. 
Indirect costs: relations hip to the price of meat
 
As regards cattle, the costs of stunning is considered as representing about 
0.02% of the whole sale value of the meat36. For pigs, running costs for 
stunning by electricity are considered neglig ible compared to the wholesale value 
of the meat and it is estimated that ga s stunning would only contribute to an 
additional 0.1% of this value. Those figur es do not take into account the fact that 
the wholesale price does not include othe r costs (further proc essing, distribution, 
and retailers' margins) which can constitu te an additional 60% price increase in 
some markets. Therefore any additional costs on the stunning process are likely 
to be even more diluted than the figur es previously mentioned. The same would 
apply for poultry meat. The total costs rela ted to the slaughterhouses represented 
approximately 1/3 of the final costs (r anging between 11 to  42% of the total 
production cost to the whole bird stage), so overall the live treatment of poultry 
will represent no more than 6-7% of the final cost . At consumer level 
stunning costs are also even further diluted37, in particular if meat is sold 
processed or cut (breast fillet) .  
                                                 
36 Figures of this paragraph come from the FCEC study. 
37 Based on a specific estimate, the consultant cal culated that the stunning costs, using an upper 
estimate, could comprises 1.2% of the whole sale price of a whole bird. This percentage would be 
further diluted by the retailer margin and even further in case of sale by cuts. 
 
EN 28   EN Comparison of meat pri ce indices level in 200638 does not indicate that there is a 
visible correlation between welfare st unning techniques/standards and meat 
prices. France, Italy, Germany and th e UK have indices of similar value 
(respectively 122 for FR, 118 for IT, 118 for DE and 126 for UK) while the 
demand for welfare standards have been higher in the UK and Germany (see Annex XII for the complete table). 
Administrative costs
 
Presently, Directive 93/119/EC on ly imposes compliance costs . There are no 
administrative costs as there is no inform ation obligation listed in the Directive. 
Private operators only have to comply w ith technical rules w ithout the need for 
registration, reporting or paperwork of any kind. 
However, as the present text is a Dir ective, Member States have sometimes 
transposed the EU legislation into more specific rules that could lead to administrative requirements. In particular this is the case for derogations granted 
for religious slaughter that each Member State has administrated in a particular 
way depending on their national context and to a lesser extent of the provisions 
on stunning equipments or  on staff competence. 
In addition it is useful to  consider that slaughterhouses are submitted to other 
administrative obligations deriving from th e food safety legislation which causes 
administrative costs both for the privat e and public sectors (see box below on the 
Hygiene package). Furthermore in seve ral Member States, the programmes for 
internal audits
39, as required by Regulation (E C) No 882/2004 have included 
animal welfare at slaughter and are showing promising results.  
The Hygiene package and administrative costs 
Private operators 
As animal welfare is integrated in to the hygiene package, a number of 
administrative requirements are applic able to slaughterhouses. They are 
described in Regulations (EC) No 852/2004 and No 853/2004. From an 
administrative point of view they im ply for slaughterhouses the following 
obligations40: 
– being registered and approved by the competent authorities, 
– establishing HACCP procedures, 
– providing information on the orig in of the animals (food chain 
information), 
Competent authorities  
For the competent authorities, obligations regarding official controls are laid 
down in Regulation (EC) No 854/2004 and imply amongst others the following 
administrative tasks (for live animals): 
                                                 
38 Statistics in focus Economy and Finance 90/2007, Comparative price levels in 37 European 
countries for 2006. 
39 Article 4 (6) of the Regulation requires comp etent authorities to perform internal audits. 
40 We have listed here only the administrative requirements that relate to live animals in a 
slaughterhouse. 
 
EN 29   EN – management of the registration and a pproval procedures of slaughterhouses 
(among other food producing establishments), 
– audits of HACCP procedures and good hygiene practices, 
– performance of specific official contro ls including on animal welfare, food 
chain information and ante-mortem inspection. 
Although the Hygiene package is relativel y new and started to apply from 2006, 
it should be underlined that some administ rative obligations were simply carried 
over from precedent EU directives . 
Impacts on meat quality  
The do-nothing option has negative impacts in term of meat quality. The positive 
correlation between the implementation of  high animal welfare standards in 
slaughterhouses and improved meat quali ty is substantiated by many examples. 
In particular, blood splashes, bruising and meat maturation problems related to 
stress (e.g. PSE and DFD41) are reduced. 
Considering that in the EU-25 in tota l 238.9 million pigs were slaughtered in 
2005, these figures suggest tota l losses to the EU meat industry due to PSE that 
could range from 60.5 million EUR to  140.5 million EUR (and an additional 
14.2 million EUR for bruises). Quiet, calm handling of slaughter hogs can reduce 
the incidence of carcasses with PSE mu scle by 10% to 12% based on field 
studies conducted at two packing plants. 
Using these figures, this would imply EU-wide economic loss reduction of 
6.05 million EUR to 16.86 million EUR pu rely due to better handling in the 
slaughterhouses. 
Similar gains can be had for the beef indus try. US data indicate s that bruises cost 
the US beef industry $1.00 per animal on feedlot beef and $3.91 per animal on 
cows and bulls. 22.2 million heads of adult cattle were slaughter ed in the EU in 
2005 implying that bruising could lead to economic losses of between 
16.5 million EUR to 64.6 million EUR . Rough handling at either the 
slaughterhouse or the feedlot will increa se bruising; bruising can occur at all 
phases of production, including afte r stunning but prior to bleeding. 
Impacts on third countries  
Overview of meat imports in the EU 
Beef was the most imported meat in absolute term in 2005 with 565.000 tonnes 
(7.20% of the EU production) . Most of the imported m eat originates from Brazil 
and Argentina. The EU has become a net im porter of beef, in particular due to 
successive crisis (BSE in the 1990's, FMD in 2001) as well as a consequence on 
the implementation of a new tariff policy. 
Sheep meat is also largely imported with 284.000 tonnes or 27% of the EU 
production. Most of the imported meat  originates from New Zealand and 
Australia. On the opposite, there are near ly no importati ons of pig meat with only 
14.000 tonnes in 2005 representing less th an 0.1% of the EU production. 
                                                 
41 PSE stands for Pale Soft Exsudative and DFD for Dark Firm Dry. 
 
EN 30   EN Concerning poultry, the impor t data show that the EU  has been increasingly 
importing cuts and prepared poultry m eat (up to 500.000 tonnes in 2002) while 
the import of carcasses remain limited. However, the total imports from third 
countries do not represent more than 5%  of the EU production. The bulk of these 
imports come from Brazil and Thailand. 
Legally speaking, animal welfare standard s of slaughterhouses approved in third 
countries to export meat to the EU have to be equivalent  to the ones of the EU 
and must be certified by the competent au thorities signing the veterinary export 
certificates (Article 15 of Directive 93/119/EC).  In addition these 
slaughterhouses are regularly visited by Commission's experts who verified the 
implementation of the different Community  rules applicable to them including 
welfare ones. 
In practice, in third co untries slaughterhouses from where most EU imports 
originate, high welfare standards have been developed that go sometimes beyond 
the current EU requirements . This is due to either governmental initiatives or 
pressure from their main customers. For example, New Zealand and Australia 
have developed detailed le gislation on animal welfar e at slaughter. Equally, 
South American main beef meat exporte rs have implemented animal welfare 
policy in order to satisfy their European customers. 
5.2.3. Social impacts 
Doing nothing will have long  term negative impact on  the public perception of 
animal production and meat . European consumers ha ve been increasingly 
sensitive to animal welfare issues and th ey would be shocked if they learn that 
this is done in a cruel way42. Images of cruelty to animals can generate large 
public outcry and have a negative effect  on the activity concerned. This also 
applies in the case of killing of animals for disease control purposes where the 
stamping out policy has been questioned by the civil society when animals are killed without proper consideration for their welfare. 
In addition the do-nothing scenario will a ffect occupational safety of workers
 in 
slaughterhouses. Handling animals is a difficult and often dangerous job. Large 
animals may be dangerous if stressed and manipulation of stunning instruments 
or knives increases risks for workers. Improved animal welfare standards are 
likely to improve occupational safety  in different ways. Better designed 
equipment and technology which will lead to  calmer animals is likely to create a 
safer workplace. Proper and reliable stunning also improves workers' safety. Limiting handling with live animals such as  in the case of ga s stunning of poultry 
is increasing welfare (no shackling of liv e birds) while provid ing better working 
conditions for employees. Better training on an imal welfare is likely to lead to 
calmer animals, more efficient stunni ng and lower number of work accidents. 
5.2.4. Environmental impacts 
No major direct impact of the base line scenario was identified on the 
environment (in terms of air quality, energy use or CO
2 emissions) in relation 
                                                 
42 This was recently the case in th e US where the Humane Society US  revealed the bad treatment of 
dairy cows in a Californian slaughterhouses, leading the US federal government to suspend his contract with the firm supplying food for federal program for schools. See 
http://www.hsus.org/farm/news/ourn ews/undercover_investigation.html
 
 
EN 31   EN with the different stunning and bleeding t echniques. However, there are possible 
minor indirect negative impacts on the envi ronment of the baseline scenario in 
case of a lack of application of animal welfare measures which are linked to the 
decrease of the meat quality . 
An indirect relationship may exist be tween environmental aspects and the 
improvement of meat quality due to bette r animal welfare, which may affect the 
quality and durability of meat. Slaught erhouses which are designed to prevent 
stress or physical contact with animals may have a higher meat yield and a lower 
amount of meat that needs to be cut away or discarded. An FAO publication43 
identified this as "perhaps the biggest cause for meat wastage during the production process". Better animal welfare can therefore contri bute to reducing 
spoiled meat , limiting the amount of waste and increasing the efficiency of 
production. 
5.3. Analysis of option 2: non-biding recommendations 
5.3.1. Achieving the objectives 
Alone, non-biding recommendations are likely to present similar impacts as the 
previous option, since they do not provide compulsory changes.  
There is evidence that the structure of industry concerned and the market demand 
will not suffice to achieve the different objectives. In partic ular the FCEC study 
has indicated that among slaughterhouses, there is still a strong reference to the 
legislator for animal welfare standards. But there is no unique European based reference for a number of animal welfare guidelines or recommendations that are 
really put in pract ice by the operators. 
Providing EU recommendations could theref ore fill this gap and in particular 
contribute to partially achiev e the following main objectives: 
(1) improving animal protection at slaughter (main objective 1), 
(2) encouraging innovation (main objective 2) by promoting the most efficient 
methods available. In fact bad welfare practices are partly  due to ignorance 
and increasing awareness through EU recommendations could promote the 
advantages of using new stunning methods. However introduction of 
innovations is also limited by other fa ctors (investments in particular). 
However it will not be able to establish a level-playing field for the industry due 
to its not binding nature (main objective 3). 
More specifically non-biding recommenda tions could improve the following 
technical dimensions: 
(1) animal welfare operational standards (specific objective 2); (2) structural design of slaughte rhouses (specific objective 3); 
                                                
 
43 Chambers, P., Grandin, T., (2001) Guidelines for humane handling, transport and slaughter of 
livestock . FAO publication, page 5. 
 
EN 32   EN (3) the killing for disease control purposes (specific objective 5). 
However those objectives will be only partially achieved and a number of 
important issues will be left unaddr essed (approval of new stunning methods, 
competence of staff). The level of ac hievement of non-biding recommendations 
will depend in particular on the possibility of financing of awareness campaign associated with the recommendations. 
Therefore this option leaves a number of objectives unaddressed. 
5.3.2. Economic impacts 
As for the previous option, compliance and administrative costs are likely to be 
limited due to the voluntary nature of the option and the narrow scope of changes 
that may be covered by such recommendations. Costs for those companies that follow the recommendations related to introducing animal welfare operational standards, structural design of slaught erhouses and killing for disease control 
purposes are similar to the ones studied in  section 5.5 (option 4). Similarly this 
option will not create a level-playi ng field for the diffe rent operators. 
However since it will make available a number of technical references for 
improving welfare, it could certainly cont ribute to improve the situation in 
particular as regards animal welfare a nd meat quality. But the effect of such 
recommendations will depend on their visibility and the publicity given to them. 
5.3.3. Social impacts 
As regards public perception, non-biding recommendations are certainly not as 
convincing as legislation. During the consultations, there was a unanimous 
position amongst stakeholders that incr eased harmonisation is necessary as 
regards the protection of animals at sla ughter. Killing animals is a non-negotiable 
matter where a minimum should be provided and guaranteed. Providing non-
biding instruments would th erefore be well percei ved as a complementary 
measure but probably not sufficient to persuade consumers that welfare is 
ensured in slaughterhouses. 
Concerning occupational safety, it can be assumed that increasing knowledge 
through guidelines will have a positive effect. However due to the problems identified in this area (hard work, difficu lty in recruiting peopl e, etc.), and the 
limited effect of the current legislation (where no precise requirements are made 
on training), it can be assumed that non-biding recommendations will not address the competence of ope rators seriously. 
5.3.4. Environmental impacts 
This option is likely to have limited impact on environment. As it could 
indirectly contribute to reduce waste in  slaughterhouses, it could be assumed that 
this option could have a slight positive impact on environment. 
5.4. Analysis of option 3:  amending the directive 
5.4.1. Achieving the objectives 
As regards the protection of animals (m ain objective 1), amending the directive 
will certainly improve the situation. This  option would include in the legislation 
considerable technical details in line with the latest scientific data available. This 
 
EN 33   EN would be easy and straightforward to implement for officials and would be 
legally secure, defining precisely whic h methods are in compliance or not. 
However, this approach would also br ing drawbacks as it will increase the 
complexity of the legal text. Many species are concerned (six main farmed species) and for each species different met hods are available. Then each method 
has many parameters which can be critical. Listing all technical details in the legislation would risk creating a very complex structure altering readability. 
In addition, fixing technical details in  the legislation would not allow any 
flexibility in time or depending on a sp ecific process. In some situations, 
different combinations of parameters
44 are acceptable. Therefore due to its legal 
nature and its technical complexity it is unlikely to encourage innovation (main 
objective 2).  
Since this option will provide a comprehe nsive set of technical rules, it will 
ensure a level playing field for the opera tors (main objective 3) but at a certain 
cost in term of compliance and flexibility.  
In addition amending the directive would address the following specific 
objectives: 
(1) It would contribute to a better integration of anim al welfare in the process 
of production (specific objective 2); 
(2) It would improve the design of sla ughterhouses (specific objective 3); This 
option will be also an opportunity to  increase the readability of the 
legislation on this aspect by clearly identifying structural standards, which 
will have to be verified during the ap proval process of a slaughterhouse at a 
very early stage (foreseen by the Hygiene package) from the operational aspects that relate to the daily work of officials. 
(3) It would improve the protection duri ng massive killing of animals (specific 
objective 5). It would create a precise legal framework at EU level, but would not allow the flexibility needed in case of disease outbreaks. Killing 
animals in disease control situation is often a crisis where despite good preparedness, conditions for carrying out the killings are not optimal due to 
practical constraints (high number of animals, location difficult to reach, 
shortage in competent personne l or in equipment, etc.). 
Therefore this option "Amending the dir ective" will not address innovation (main 
objective 2) and will not contribute to si mplification. In addition some specific 
objectives will not be completed by this option (innovation – specific objective 1, 
competence of operators - specific objective 4). 
5.4.2. Economic impacts 
This option would represent important co mpliance costs for operators that will 
have to adjust their methods  to all the requirements. It is very difficult to 
calculate all costs related to such requirem ents but certainly this would mean that 
some operators would have to change  their equipments and their modus 
operandi. 
                                                
 
44 For example, in the FCEC study the consultant listed 21 different combinations used by 
slaughterhouses only for chickens based on 5 different electrical parameters. 
 
EN 34   EN This option will not bring any administrative costs since it will not introduce new 
information requirements. 
Costs for businesses  
Compliance costs related to a set of ope rational standards were not possible to 
evaluate precisely since they will depend on the final parameters adopted. But due to the diversity of parameters obser ved in certain techni ques, establishing 
precise operational standards would certain ly have noticeable costs due to the 
lack of flexibility of the legislation. 
Compliance costs related to structural  standards of slaughterhouses were 
evaluated by the FCEC consultant. Cha nges could be introduced concerning in 
particular the lairage facilities and different stunning equipments. Those 
measures have been implemented by some  slaughterhouses in the EU either on a 
voluntary basis or were made compulso ry through more restrictive national 
legislation. 
According to the FCEC study those measures are considered by most 
respondents of the red meat se ctor to be slightly to fa irly costly depending on the 
measures concerned. Those costs are primarily related to investment costs and not operational costs. In absolute terms the consultant however considers that 
those investments are not very significan t compared to the overall investment 
cost for a slaughterhouse, es pecially if implemented at the construction phase. 
Impact on competitiveness was also disc ussed and most respondents considered 
that those investments were positive for their competitiveness since they expect 
economic returns because of improved m eat quality and better adequation with 
customers' demand.  
Regarding the poultry sector, the FCEC st udy indicates that a significant part of 
the industry has already implemented some  of the measures foreseen (between 
50 to 80% of the respondents see Figure 2). 
 
EN 35   EN Figure 2 – Additional technologies impl emented by the poultry industry for 
waterbath 
 
Those measures have a cost. However, this  cost should be seen in light of the 
depreciation of existing infrastructure  and the average change/adaptation of 
infrastructure in slaughterhouses. If  operators renovate and change their 
infrastructure on an average every 10- 15 years, the costs of adapting their 
infrastructure to animal welfare standards would be absorbed. Therefore a transition period is envisaged.  
In addition, it is also important to cons ider their potentially positive impacts on 
revenue. Some benefits are, according to  the respondents, difficult to quantify 
such as improved meat quality from birds that are less exposed to stress in the 
slaughterhouse (arising, for example, from  the use of appropr iate ventilation in 
the lairage, low level of lighting in the shackling area or breast plates on the shackle line).The economic benefit of welfare improvement measures depends 
on the marketing chain
45. The poultry industry agrees that, in general terms, 
equipment design to ensure good animal welfare has positive economic impacts. 
Costs for authorities  
These costs are only related to the establishment of t echnical standards 
applicable in case of  massive killing. 
                                                 
45 For example, the whole carcass market would demand no visible damage or bruises. In contrast, 
the fresh portions market would demand no internal bruises. Traditionally, a slight improvement in 
the value of breast meat, which is the most expensiv e portion of a carcass, is more valuable than a 
significant improvement in the quality of, for example, wings. However, increases in the popularity 
of other products, for example processed wings may change the traditional economic analysis. 
 
EN 36   EN Following a specific questionna ire to the Member States on the issue, only seven 
provided responses. Most of them declar ed to use only auth orised methods. On 
the other hand, the ones that have used other methods consider that a lack of 
flexibility in the legislation would ha ve enormous costs, not only for the 
authorities but mainly for the society as whole since it will result in failing to ensure proper and rapid eradi cation of diseases outbreaks. 
5.4.3. Social impacts 
Detailed and prescriptive legislati on will have a positive impact on public 
perception. They are strongly supported by animal welfare organisations who 
want to secure precise standards that can be easily implemented and verified by 
the authorities. 
There is no evidence that such approach would be positive or detrimental to 
occupational safety for workers. However it can be assumed that due to the positive correlation between animal welfar e at slaughter and occupational safety, 
this option would bring some benefits in this regard. 
5.4.4. Environmental impacts 
Same as option 2. 
5.5. Analysis of option 4: re organising the EU legislation 
5.5.1. Achieving the objectives 
This option would address all the main a nd specific objective s since it opens the 
widest range of possible measures. 
The protection of animals at the time of slaughter or killing would be improved 
through a combination of new measures (main objective 1) that are described 
below. It will also contribute to en courage innovation (main objective 2) and 
create the opportunity for establishing a level-playi ng field for all operators 
(main objective 3). 
It can also contribute to simplification. Simplification will be due to the fact that, 
if the form of regulation is retained, national legislations will disappear. In addition this option could better integrate the animal welfare legislation applicable to slaughterhouses, in the f ood safety legislati on ("hygiene package") 
using common procedures and terminology. 
Concerning the specific objectives this option will offer a broader scope of 
possibilities in introducing changes that go beyond the technical aspects of the 
legislation. In this way it could address all the specific problems identified by introducing new measures: 
• A methodological approach to encour age innovation could be developed 
(specific objective 1) 
• A better integration of animal welf are in the production process (specific 
objective 2) could be envisaged th rough the introduction of standards 
operating procedures (SOPs) and the requirement of an animal welfare 
officer (AWO). 
 
EN 37   EN • Design of slaughterhouses could be also  improved (specific objective 3) by 
a more traditional approach (as for amending the Directive); 
• Competence of personnel in slaughter houses could be ascertained through 
the requirement of a certificate of comp etence (specific objective 4) as well 
as by the establishment of national cen tres of reference as to provide 
technical support for officials. 
• A methodological appro ach could be establishe d for massive killing 
(specific objective 5). 
More specifically here are how some sp ecific measures attached to this option 
could affect the comple tion of the objectives. 
Standard Operating Procedures (SOPs)  
Requirement for SOPs has been favoured in the Food Hygiene package as it was 
considered as the best option to face the variety of processes in the food business 
industry. Different species are concerned a nd within a species, different types of 
animals are slaughtered. Parameters to stun them depend on th eir characteristics 
(live weight, bone structure) but also on the final products to be produced (meat 
quality). This measure was also favoured  by operators during the consultations 
on the initiative. 
Another reason for increasing operators' responsibility is based on the 
assumption that official checks are limite d compared to the overall duration of 
the production process. Theref ore it is better to ensure  that operators design and 
put in place their own quality system in stead of imposing external parameters 
sometimes far from optimal to their objectives. 
Advantages of such approach is therefore to provide more flexibility to operators 
on the way they could achieve the object ives set up by the legislation, while 
providing official authorities a way to supervise and audit operators quality system instead of focusing on technical deta ils. Such an approach will also be 
preferable for small and medium-sized operators.  
Animal Welfare Officer (AWO)
 
The appointment of a specific employee dedicated to follow-up animal welfare 
issues has been experienced  on a voluntary basis in so me slaughterhouses (in the 
UK) and is also compulsory in some Member States (Austria and Germany). 
Similarly to SOPs it provides a practical tool for improving animal protection in 
slaughterhouses while keeping a high leve l of flexibility, contributing to keep 
legislation simple. 
Certificate of competence  
This measure would address the need for systematically checking the 
competence of staff handling animals in slaughterhouses and possibly in other 
situations. 
The positive impact of such measure w ould be to ensure that competence is 
assessed independently and that any person having a certificate possesses a 
common technical knowledge to carry out hi s/her tasks properly. In addition this 
would simplify the task of inspection pe rformed by officials at slaughterhouses. 
This measure is already implemented in the UK in red-meat slaughterhouses with 
success. 
 
EN 38   EN It creates a level-playing field fo r all slaughterhouse employees (main 
objective 3) contrary to the present situ ation where national  requirements on 
training is far from being uniformly im plemented within the Member States. 
The impact on simplification could be viewed  in different ways. From one side it 
creates an additional administrative burden for businesses. On the other side it goes hand by hand with a simplification of the legislation. Inde ed the legislation 
can not be more flexible if operators do not provide further guarantees on their 
ability to manage animal welfare on a daily basis. Therefore to a certain extent this administrative burden contributes to make legislation more flexible. 
National Centre of Reference
 
This measure would be complementary to  the previous one, as it would address 
the difficulty for officials in slaughterhouses to have access to a reliable and recognised scientific and technical ba ck-up in their inspections tasks. 
A national centre of reference would have  the advantages of providing support to 
slaughterhouse inspectors for any technical or sc ientific aspects on the welfare of 
animals at slaughter. In particular this  would include the assessment of complex 
restraining or stunning equipments or t echnical parameters, as well as other 
possible related tasks such as ensuring th e accreditation of b odies delivering the 
certificate of competence. 
It can be concluded that this measure will contribute to improve animal welfare 
(main objective 1) and encourag e innovation (main objective 2). 
Methodology for massive killing
 
This measure would emphasize legal requirements on a nu mber of principles to 
be respected rather than precise tec hnical figures. For example at present, 
contingency plan to eradicate disease do not require any information on animal 
welfare consideration at  killing (stunning met hods, etc.). Harmonised 
methodology would imply better transpar ency on the preparedness of the 
authorities to control outbr eaks of contagious diseases as well as better reporting 
on animal welfare when cases occur. 
The advantage of such approach would be to  keep a certain level of flexibility on 
the means to be used by the authoritie s while ensuring a better level of 
supervision on animal welfare. Another advantage of requiring a reporting on 
animal welfare would be to promote good in itiatives in this do main. Outbreaks of 
contagious diseases are relatively unus ual events within the Community and not 
all Member States have gained practical  experience in killing large number of 
animals. Therefore better reporting on an imal welfare on those occasions would 
also help in promoting solutions for futu re outbreaks taking plac e in other part of 
the Community. 
A methodology for approving new stunning methods  
Reorganising the legal framework will also  make possible to address the question 
of innovation (main objective 2). 
It could be performed through a centralised  or partially decentralised approach. 
 
EN 39   EN Scientific assessment on animal welfare at slaughter alread y exists through the 
EFSA opinions. However, the current wo rk of the EFSA on animal welfare 
consists in gathering information al ready published on specific questions. A 
centralised approach would therefore re quire a different t ype of work which 
would be the examination of specific appl ication like the ones presented for food 
additives or medical drugs. This option w ould have the advantage of providing a 
full harmonised approach at EU level, and therefore a consistent methodology in assessing any new technology in relation to the slaughter or  the killing of 
animals. It is also likely to provide scientific opinions independent from a 
national interest. 
A partially decentralised system would combine certain advantages. For 
example, Member States would be allo wed to grant authorisation on a national 
level for a limited period of time, provided that they inform the other Member States and the Commission. In this way, other author ities could assess whether 
the methodology used is sufficiently robus t and reliable and during this period, 
the applicant could gain e xperience and refine its me thod on a commercial scale. 
After an adequate period the method w ould be either banned through a decision 
taken at EU level. 
5.5.2. Economic impacts 
Compliance and administrative costs for businesses
 
Based on the data collected, the main compliance costs by order of importance 
are related to the following measures  included in the present option: 
– Requirements for upgraded standards fo r the design of slaughterhouses (see 
option 3)  
– Requirement for Standard Operati ng Procedures and Animal Welfare 
Officer 
From the external FCEC study, it appears that in the red meat sector, the large 
majority of slaughterhouses responde nts had put in place animal welfare 
procedures through client requirements (70%) and had their own code of good 
practice (61%). In particular this in cludes internal procedures for cleaning 
stunning equipments, for checking animals on arrival to identify weak animals and for supervising the bleeding procedures . Implementation of a plan of controls 
for animal welfare based on HACCP was also frequently mentioned as well as the assignment of an employee to be re sponsible for animal  welfare (see below 
animal welfare officer). Those two ini tiatives were perceived as the most 
beneficial for animal welfare by the res pondents. Plans of control in particular 
include practical animal welfare indicators that could be scored on regular basis. 
Most procedures such as putting in place a quality assurance pl an and an animal 
welfare officer were not considered cos tly and even considered by the majority 
of respondents as having a fairly or  significant posit ive impact on the 
competitiveness of their operations. 
 
EN 40   EN The FCEC study revealed similar figures  for the poultry sector (69% of the 
respondents had their own code of pract ice on animal welfare) but a higher 
proportion of respondents have implemente d animal welfare procedures. Quality 
assurance plan for animal welfare and an imal welfare officer were implemented 
by almost 70% of the respondents and a number of animal welfare indicators 
were regularly monitored (with different  frequency up to continuous monitoring). 
Identically most of respondent s considered quality assuranc e plan as no costly or 
slightly costly (80%). 
Disadvantages possibly raised by this option have been pointed out during 
stakeholders' consultation, following th e experience of the Hygiene package. 
Despite the fact that requirements for procedures and records in the Hygiene 
package must be proportionate to the complexity and the size of the process 
envisaged, small businesses were concerne d by possible excessi ve bureaucratic 
requirements. Therefore, the Commissi on has presented a proposal to exempt 
micro businesses from the requirement to  establish a reporting system on their 
HACCP system in place – meaning that the micro businesses would still have to comply with all safety rules, but are ex empted from the requirement to report on 
it as this proofed disproportionately bur densome on them. This concern could be 
transposed equally for animal welfare in a similar approach to align the animal welfare regulation with the principles of Better Regulation. 
Administrative costs generated by SOPs are likely to be minor. Slaughterhouses 
are already subject to the Hygiene package where SOP for food safety are much 
widely developed and implemented. Additi onal costs related to the extension of 
SOPs for animal welfare will only affect slaughterhouses that have not yet implemented such policy (the FCEC surv ey indicated that between 60-70% of 
the respondents had already implemented such policy anyway). This means that 
the increased responsibility woul d probably affect less than 6.000 
slaughterhouses across Europe (out of an estimate of 16.000 establishments, 2/3 
of them being small scale establishments)  on a relatively limited part of their 
operations, requesting the de velopment of standard operating procedures during 
the implementing phase (3 days) and then  the maintenance and the follow-up of 
the procedures in place (1 hour a day for a middle size establishment). 
Figure 1: Assessment of costs of opera tional measures and procedures by 
slaughterhouses operators (red meat) 
 
 
EN 41   EN Similar conclusions could be drawn as re gards the impact related to the Animal 
Welfare Officer. 
According to the FCEC study, most respondents had implemented measures for 
having an "animal welfare offi cer" in their plant (61% in  the red meat sector and 
more than 70% in th e poultry sector).  
In practise, appointing an AWO would be less bureaucratic than SOPs and 
probably quite efficient. It would favour direct communication towards 
employees which is a good channel for a relatively limited number of employees. 
However, the requirement for AWO could be considered as a disproportionate measure for businesses which slaughter animals on a very small scale. Therefore possibilities for exemption for small slaughterhouses will be foreseen. 
As currently an Animal Welfare officer is already in place at national level in 
Austria and Germany, no addi tional costs are to be expe cted in those countries. 
For other countries, it should be highlighted that in pr actice this would not mean 
that a new person would have to be em ployed as the additional animal welfare 
surveillance could be covered by the pers on in charge of general quality meat 
control. Responses from Member States indicate that this ta sk could represent 
10 to 20% of the time of a full-time empl oyee. This is currently the case in some 
slaughterhouses e.g. in the UK. However,  in those extreme cases where nothing 
is in place and the hiring of a new officer  specifically in charge  of animal welfare 
in slaughterhouses would be needed, this  would amount to estimated costs of up 
to 50.000 Euros per slaughterhouse (this figure  is based on UK estimate, salaries 
in other Member States might well be lower). 
AWO has been envisaged since the FC EC study has indicated that most 
respondents of slaughterhouses would comb ine AWO with SOPs. It is in fact 
logical since having procedur es to deal with animal we lfare is unlikely to have 
effect without proper management system . It combines advantages to produce 
very good welfare outcomes while providing good economic returns for relatively limited costs according to the operators who have implemented this policy. 
As underlined by the consultant the only limiting factor of such option would be 
the possible bureaucracy and the costs involved for very small businesses 
compared to the possible benefits. In th is case reference to common guidelines 
could be a solution (as foreseen in the Hygiene package). 
– Certificate of competence 
 Training does involve costs. For ex ample in Germany, a 4-hour external 
training course provided by specialis ts for slaughterhouse staff costs 
around 200 € per participant for the theoretical and practical training and the exams. Training and examination costs for animal transport have been estimated in the UK to range fr om 126 to 630€ per participant. 
 However, the majority of respondents of the FCEC study considered that 
the cost of their training measur es had no significant impact on their 
production costs. Slaughterhouse responses  assess the impact of training on 
competitiveness of operations to be more positive than on production costs. Better animal handling (re sulting from better training of employees) has a 
positive impact on meat quality which results in better quality products, which may increase meat products’ competitive value on the market. 
 
EN 42   EN  A very large majority of respondents reported very  or fairly significant 
positive impacts of training on meat quality and occupational safety, 74% and 73% respectively for the red meat sector and poultry sectors. There is 
also a likely positive correlation between training measures and occupational safety; better trained personnel may lead to less stressed and calmer animals that are easier and safer to work with. 
– Application for new stunning methods 
 Manufacturers of stunning equipments provided a very wide range of 
expenses for authorisation for new stunning methods based on application 
made in third countries. Those costs we re essentially related to research 
and development costs and no distinc tion was actually provided between 
R&D costs and administrative costs. From data from the Member States, it appears that currently independent  testing imposed by the competent 
authorities could range between 10.000 to 60.000€ per authorisation 
(scientific and administrative costs in cluded). It is almost impossible to 
disentangle which parts of the prep aratory work for authorisation are 
research and developing costs that w ould have been done in any event by 
business e.g. for marketing purposes a nd which parts are solely linked to 
bureaucratic requirements. In any event, it can be assumed that those costs affect only equipment manufacturers which represent a small number of 
companies in the EU (major players fo r each technique are limited to three 
companies) and innovation for new techniques will be relatively 
exceptional (today's methods will con tinue to be authorised without 
specific authorisation process).  
 It should be noted that in any cas e for operators (and similarly for public 
authorities), administrative costs will be reduced as one single application 
will be needed instead of different applications in each Member State. 
Costs for authorities
 
– Establishment of a national centre of reference 
 Many Member States have developed applied research centres or network 
working on animal welfare at slaught er but there is not a formalised 
organisation that could be compared to  this sub-option at  the moment. It 
would be therefore mislead ing to assume that the cost of this measure 
would be equivalent in establishing a complete new structure from scratch. 
In most cases, it would consist in re cognising the roles of  already existing 
structures and experts. Therefore certai n elements of costs are difficult to 
estimate and will in any case depend on how much each Member State has already invested on this issue. 
 
EN 43   EN  Based on estimates provided by the UK, setting up an entirely new 
independent structure would amount for an investment of 12 to 24 millions 
euros and yearly operating costs of 2.5 to 3 millions euros (based on 50 
staff). Very few MS have been able to  reply to the Commission's request of 
information on this issue to provide further estimations. However the EU 
legislation could draw a flexible framework (a network rather than a 
centre) allowing Member States to use existing structures (such as research 
institutes or universities) as to reduce costs of establishment while 
redirecting existing operating funds to lower operating costs. As a matter of 
comparison, the same Member State46 dedicated in the last 10 years an 
average of 250.000 euros per year in re search projects on the welfare of 
animals at slaughter. In addition it devotes 80.000 euros per year to 
vocational training on animal welfare at slaughter for its official inspectors. 
Based on this case, it could be assumed that the development of a network could be estimated of around 350 to 4 00.000 euros a year for a similar size 
Member State (UK) if nothing is in pl ace. The Netherlands is spending at 
present 1.2 M Euros a year on research  on animal welfare at slaughter  
 A national network would have the a dvantage of providing a clear visibility 
to officials and slaughterhouses oper ators on where to refer to on when 
questions on animal welfare at slaught er are raised, inst ead on relying on 
informal network. Such centre would al so provide higher legitimacy to the 
officials working in the field whil e ensuring better  harmonisation at 
national level. 
– Massive killing methodology 
 On the negative side, requesting mo re requirements on animal welfare 
could be considered by cer tain Member States as additional technical and 
administrative constraint and especially if reporting is requested. There is 
no evidence that better animal welfar e preparedness and supervision would 
entail higher costs. Good welfare measur es relates mainly to good logistical 
preparedness and not necessarily to co stly techniques. In addition, Member 
States have increasingly integrated an imal welfare issues as part of their 
contingency plans and provide public  reports for major outbreaks (as 
national parliamentary inquiries or  audits are often performed).  
                                                
 
46 The list and the amount of UK research projects dedicated on animal at slaughter can be consulted 
at:  http://randd.defra.gov.uk/Default.aspx?Menu= Menu&Module=ProjectList&Completed=0&Keywo
rd=Slaughter 
 
EN 44   EN  Administrative costs generated by su ch measure will depend to a large 
extent to the current pr actices presently in pla ce in the Member States. 
From the data collected by the Co mmission, this option is already 
implemented in some Member States where competent authorities performed veterinary supervision and reporting on animal welfare for every 
cull
47. It is the case for the UK, Netherlands, Cz ech Republic and is under 
development in Sweden and Germany. Since killing animals in case of 
outbreaks is not a regula r activity, reporting costs may vary depending on 
the size of the killing pe rformed. From data collec ted in one major Member 
State this would require the developm ent of computerized system that 
could amount for a unique cost of 125.000 euros. 
– Auditing SOPs 
 Following questionnaire sent to the Member States regarding the possible 
additional costs possibly generated by the need for auditing SOPs by the competent authorities, all respondents that due to the application of the 
current legislation on official contro ls in slaughterhouses, controls on 
animal welfare in slaughterhouses were  already integrated in their overall 
costs of inspection. 
– Administrating certificate of competence 
 As regards the administrative costs for public authorities, similar certificate 
of competence has been required in th e UK, Germany and Lithuania. It is 
also required by the legisl ation on the welfare of animals during transport. 
The main disadvantage of such measur e is to request the examination of 
existing working staff, requesting an im portant administrativ e task for both 
the industry and the public sector duri ng the first years of implementation 
of the legislation. In the case of transport, the implementation phase was 
extended to three years but accordi ng to the data collected by the 
Commission a longer peri od would be probably mo re appropriate (i.e. 5 
years). 
 Based on the UK experience for issu ing a certificate of competence for 
slaughterman, the administrative costs ch arged to the applicant is today of 
25 € of mere licensing costs (not incl uded the training and the examination 
costs) – to be paid by the requesting operator. 
– Approval of new stunning methods 
 From the data collected from the Member States, public authorities all 
consider that the process of approval of new stunning methods will not create additional public e xpenses. Despite the fact  that up to now, no 
formal system was established and therefore no official request was processed, public author ities considered that ma in costs of approving new 
stunning methods would be at the expenses of the applicant. 
                                                
 
47 Information collected is details on the method of killing, time of death, checks for the death made 
and details of any problems or welfare issues. 
 
EN 45   EN  The treatment of an authorisation file means that public authorities have to 
evaluate a study that the manufacturers submitted. It is difficult to obtain 
estimates from national authorities regard ing purely administrative costs, as 
today new methods are very often e volving from resear ch programs for 
which administrative costs have not been separated from R& D and other 
costs. One Member State indicate d that the costs are currently 
approximately between 6.000 and 15.000 Euros per authorisation48. These 
costs are recovered via fees to operators. 
5.5.3. Social impacts 
Main social impacts are related to th e positive public perception in improving 
welfare standards. This pe rception would derive from all the measures included 
in this package (such as SOPs, AW O, better design of slaughterhouses, 
certificate of competence for personnel, establishment of national centre of 
reference). 
However if the requirement for AWO wa s very much supported by Organisation 
of animal protection, requirement for SOPs was less favoured since they fear that a less prescriptive legislation will create a less solid legal base for officials to 
sanction bad practices. 
As previously mentioned, there is positive correlation between occupational 
safety and animal welfare measures. As this option is likely to provide more 
instruments for improving the welfare of anim als, it could be assumed that it will 
also be the option that will bring most benefits for the safety of the workers. This is particular clear through measures that will be directly addressed to 
slaughterhouses employees such as: 
– Certificate of competence: this m easure will provide employees better 
skills for preventing them havi ng accidents with animals; 
– Animal welfare officer: this meas ure will increase the likelihood to 
moderate the possible excess of caden ce requested by the line managers; 
– Standard Operating Procedures: this measure will increase their ability to 
control the process and reduce their ri sk of accident and increase their 
comfort in working. 
5.5.4. Environmental impacts 
No environmental impact as been specifically identified for this option (see 
option2). 
5.5.5. Summary of costs  
The table 3 below provides a summary of the compliance and administrative 
costs that have been compiled as a result of the specific questionnaire on costs that was sent to operators and Member St ates. In addition, we have calculated in 
some cases the estimated total costs of the different measures for business/Member States.  
                                                
 
48 UK estimates were significantly higher (100.000 pounds per project) which can be explained also 
by the fact the current UK authorisation regime  is very embedded in DEFRA research activities 
and hence might overestimate the mere bureaucratic costs.  
 
EN 46   EN These calculations are based on estimates from the FCEC study on the 
percentage of market opera tors that do not currently comply with the measures 
envisaged and would therefore need to  adapt. These estimations may be 
underestimated as it is lik ely that the respondents to the FCEC study are in 
majority operators with well-advanced practices on animal welfare.  
In addition, it should be re minded that there are importa nt data limitations behind 
the estimated monetised value of the different cost elements, due to a very low rate of responses to the costs questionnaire and uncerta inty behind some of the 
figures provided in the questionnaires' responses. 
Additional economic figures used for th e calculation are based on Eurostat 
annual detailed enterprise statistics (labour costs)  for 2005, average personnel 
costs in the production of  meat and poultry meat products sector (NACE, 
da1513). The yearly average personnel cost s per employee in this sector for EU-
27 is 23 000 euros. As regards the number of employees working in slaughterhouses, we have used the estim ated figure of the trade associations 
UECBV/AVEC of a total of direct 600 000 jobs in the production of meat in the 
EU (2005). Taking the assumption that on e fifth of these employees work in 
slaughterhouses and are in charge of th e treatment of live animals, we have 
considered roughly the figure of 120 000 em ployees to extrapolate and calculate 
training costs. 
 
EN 47   EN Table 3 – Summary on the impacts on costs 
Qualitative description Quantitative description Monetised value Estimated total costs in the EU 
FOR OPERATORS  
Animal welfare officer in 
slaughterhouses 31-40% of slaughterhouses i.e. less 
than 6000 establishments (2/3 are small scale establishments)  The UK figure of 50 000 Euros per year per slaughterhouse should 
be considered only in extreme case (large slaughterhouse where nothing is in place) and is certa inly overestimated for most EU 
countries. On average, it is foreseen that the function of AWO 
would represent on average 10-20% of one staff time (i.e. 2300- 4600 euros per year for one slaughterhouse)  13.8-27.6 mio Euros per year 
Monitoring the efficiency of 
killing/stunning procedures 
(Standards Operating 
Procedures - SOPs) 30-40% of slaughterhouses concerned 
i.e.less than 6000 establishments in the 
EU It is estimated that for middle-size establishment, the development 
of SOPs would require 3 days/man work and for maintenance and 
follow-up 1 hour a day i.e. no more than 15% of staff time. 
However, this time would be combined with the time spent in the function of an AWO.  20.7 mio Euros per year  
It should be highlighted that most of these 
costs are already included in the costs of 
AWO  
Increased training of 
slaughterhouse employees 8% of red meat and 4% of poultry 
slaughterhouses employees (although content of training is often too limited 
for the 92% and 96% who receive 
training) so approx. 6% of employees Approx. 200 Euros/participant/year (high estimation based on 
German experience) plus costs fo r certificate of competence (25 
Euros/application) i.e. a total of 225 Euros 1.62 mio Euros per year 
This figure needs to be balanced in light of 
benefits of well trained workers on meat quality estimated at 6.05 million EUR to 
16.86 million EUR 
Upgrading standards for the 
design of slaughterhouses 20-50% of the slaughterhouses 
depending on the type of infrastructure Costs would be absorbed by the amortisement of equipment of 10-
15 years (transitional period in the legislation) - 
Authorisation of new 
stunning/killing methods  New authorisations are relatively 
exceptional – between 2-5 per year – and only apply to equipment 
manufacturers 6.000-15.000 Euros per authorisation (fees to be paid to 
administrations) This figure does not include costs for preparation 
of the file and research (total costs estimated between 10.000 and 
60.000 Euros per file) but most of these costs would in any case 
have been done in any event by business for marketing purposes. 12.000 – 75.000 euros per year maximum 
for submitting applications. This figure 
represents savings for operators as 
compared to the present situation where 
they have to submit different applications in different MS so current costs are in most 
cases much higher today. 
 
EN 48   EN Qualitative description Quantitative description Monetised value Estimated total costs in the EU 
FOR PUBLIC AUTHORITIES  
Setting up national networks 
of reference National centres of reference exist in 
most Member States in an informal or more formal role. We estimate that a 
maximum of 10 MS would have to set 
up something new in place. If nothing is in place it would cost  approx. 350-400. 000 Euros for a 
big Member State, based on UK estimates 4 mio Euros per year maximum 
Production of a report on 
animal welfare conditions during operations of massive killings Approx 15 Member States would have 
to put a system in place The development of a computerised  system (estimated at 125 000 
Euros) would be the most important cost.  1,875 mio Euros (one-off) 
Establishing and running a 
system of certificate of 
competence It would apply to most employees since 
it exists only in 3 Member States (UK, 
Lithuania, Germany) i.e. approx to 100. 
000 employees Public administration staff cost s (partly recovered via a fee) 
estimated at 25 Euros/application 
 2,5 mio Euros 
Authorisation of new 
stunning/killing methods (at EU level) New authorisations are relatively 
exceptional – between 2-5 per year – and only apply to equipment manufacturers. As applications will be 
centralised, current costs born by 
national public authorities will be reduced and instead will be born at 
central level. 6.000-15.000 Euros per authorisation (to be recovered by fees from 
operators most probably) marginal costs as it is anticipated that 
these costs will be recovered via fees from operators.  
 
EN 49   EN 6. C OMPARING THE OPTIONS  
6.1. Main policy options Table 3 – Comparing main policy options 
Impacts/ Options 1- Do-nothing 
(baseline) 2- Non-biding 
recommendations 3- Amending the 
Directive 4- Reorganising 
the legislation 
Main objectives     
Animal protection 0 0/+ + ++ 
Encouraging innovation 0 0 0 + 
Level playing-field 0 0/+ ++ + 
Simplification 0 0 0 + 
Economic impacts     
Costs for businesses 0 0 - - 
Costs for SMEs 0 0 - - 
Costs for authorities 0 0 0 - 
Meat quality 0 0/+ + ++ 
Trade from third countries 0 0 0 0 
Meat retail prices 0 0 0 0 
Social impacts     
Public perception 0 0 + ++ 
Occupational safety 0 0 + ++ 
Environmental impacts 0 0 0 0 
(--) very negative impact, (-) nega tive impact, (0) no impact, (+) po sitive impact, (++) very positive 
impact  
(+/-) the situation will depend on the national context. 
The comparison between the different op tions in the light of the different 
objectives makes clearly more advantag eous to reorganise the legislation 
(option 4) while amending the directive ( option 3) would bring limited benefits 
and providing non-biding recommendations (o ption 2) will not suffice to tackle 
most of the objectives. Therefore option 2 alone can not be considered as to be 
sufficient way to address the issues, but could be considered interesting as a 
complementary instrument. 
 
EN 50   EN Option 2 would in particular contribute to improve animal protection and meat 
quality. It could also contri bute to establish a certai n level of harmonisation in 
the competition between operators but in a very limited way due to its voluntary 
nature. 
Reorganising the directive (option 4) is  the only option where innovation can be 
encouraged and simplification provided  (changing the legal instrument and 
having a new approach). It is also brings more be nefits than amending the 
directive (option 3) as rega rds animal protection. This is mainly due to the fact 
that amending the technical annexes of the directive, flexibility will be reduced. 
Option 3 may appear to be better to ensure a level playing field for businesses 
since it provides clear and unambiguous standards. However in practice, the 
complexity in establishing such standard s for all sorts of animals and stunning 
methods may end up with a limited effect. 
As regards the socio-economic consequences, options 3 and 4 will generate short 
terms costs for certain operators but are lik ely to bring long term  benefit in term 
of meat quality, public perception of meat and occupational safety for workers in 
slaughterhouses.  
Environmental impacts are considered to be neutral for all op tions as there was 
no evidence during the collection of data of  substantial and/or direct effects on 
environment. 
6.2. Comparing the components of option 3 "amending the directive" 
A more detailed comparison (or policy com ponents) of option 3 indicates that the 
three components of this option ha ve a different effect on each areas. 
Upgrading slaughterhouse infrastructure  has a potentially important negative 
impact on businesses due to the need fo r certain operators for investing on new 
infrastructures and equipments. However this effect can be mitigated by 
transitional period. 
Imposing operational standards through a pr escriptive approach has mainly the 
disadvantage of being compli cated and rigid while having  a limited scope due to 
the difficulties in finding a compromise. Therefore the main weakness of this 
component is its negative impact on simplif ication. This aspect can also limit its 
positive effect on animal protection and its potential in ensuring a level-playing field in the long run. 
Providing standards for massive killing through a prescriptive approach has the 
same drawbacks. Effects on businesses are however not considered here since the 
standards mainly affect competent authorities. 
 
EN 51   EN Table 4 – Summarising the impacts of the components of the option "Amending the 
directive" 
Impacts/ Options Upgrading 
slaughterhouses 
infrastructure Operational standards 
for slaughterhouses Standards for massive 
killing 
Main objectives    
Animal protection + + + 
Encouraging innovation 0 0 0 
Level playing-field ++ ++ 0 
Simplification 0 -- -- 
Economic impacts    
Costs for businesses -- - 0 
Costs for SMEs -- - 0 
Costs for authorities 0 0 - 
Meat quality + + 0 
Trade from third countries 0 0 0 
Meat retail prices 0 0 0 
Social impacts    
Public perception + + + 
Occupational safety ++ 0 0 
Environmental impacts 0 0 0 
(--) very negative impact, (-) nega tive impact, (0) no impact, (+) po sitive impact, (++) very positive 
impact.  
(+/-) the situation will depend on the national context.  
6.3. Comparing the components of option  4 "Reorganising the legislation" 
Among option 4, several components have been presented and their impacts are 
summarised in Table 7. 
While they all contribute to animal  protection (objective 1), only the 
establishment of a methodology for author ising new stunning methods, is likely 
to encourage innovation (objective 2). Th e requirement of a national centre of 
reference will also contribute to this objective since it will make durable resources for research in this field. 
 
EN 52   EN Most measures will also contribute to en sure a level playing field for operators 
(objective 3) in different ways. The most important in this regard will be the certificate of competence and the esta blishment of a common methodology for 
new stunning methods. This last component  will positively affect the conditions 
of competitions of manufact urers of stunning equipments. 
Most measures have little impact on simplification. Certifi cate of competence 
will increase administrative burden while the requirement for SOPs will provide 
more flexibility than prescriptive rules. A common methodology for authorising new stunning method will also be benefici al in simplifying th e current situation 
where all Member States have their own procedures. 
Impacts on costs for businesses would be mainly neutral or negative depending 
on the situation of each company. As we have  stated before, an important part of 
slaughterhouses have already implem ented the proposed measures (better 
infrastructures, SOPs, AWO and in so me Member States, certificate of 
competence) which will limit the negative e ffects of such measures in the short 
term. Their negative effects could be also diminished by the introduction of 
transitional period (for infrastructures or  certificate of comp etence) or possible 
exemption justified by the si ze of the business (AWOs). 
Impacts on costs for the authorities are mainly due to the establishment of a 
national centre of reference and to a less extend by the requirement for a 
certificate of competence. However those costs will depend whether they have already implemented some of those requi rements. In particular many Member 
States have scientific bodies that play an  equivalent role as the one foreseen for 
national centres of reference. Similarly a system of certificate of competence has 
been established in other welfare le gislation without creating substantial 
administrative costs for the authorities. Therefore there is no reason to believe 
that those requirements woul d be bring heavy costs whil e there is clear evidence 
that they will bring substantial benefits. 
Impacts on meat quality are positive for most of the component of this option 
since they will reduce alteration of the meat due to stress and bad handling. This 
provides positive economic returns for slaughterhouses. 
Similar conclusions can be drawn as re gards the public per ception of the meat 
production. Positive image of the meat, has also positive economic effect for the sector. 
Occupational safety is also positivel y affected by most of the components 
presented. Better design of slaughterhouses, existence of SOPs and better trained 
personnel contribute significantly to ensu re that slaughterhouses are a safe place 
for workers. 
 
EN 53   EN Table 5 – Summarising the impacts of the components  of the option "Reorganising the legislation" 
Impacts/ Options Methodology for 
authorising 
stunning methods Upgrading 
slaughterhouses 
infrastructure Standard 
operating 
procedures Animal welfare 
officer Certificate of 
competence National centre of 
reference Methodology for 
massive killing 
Main objectives        
Animal protection + + ++ ++ ++ ++ ++ 
Encouraging innovation ++ 0 0 0 0 ++ + 
Level playing-field ++ ++ + + ++ 0 0 
Simplification + 0 + 0 - 0 0 
Economic impacts        
Costs for businesses + -- 0/- 0/- 0/- 0 0 
Costs for authorities - 0 0 0 +/- +/- +/- 
Meat quality 0 + ++ + + + 0 
Social impacts        
Public perception 0 + 0 ++ ++ ++ ++ 
Occupational safety 0 ++ ++ + ++ 0 0 
Environmental impacts 0 0 0 0 0 0 0 
(--) very negative impact, (-) negative impact, (0) no im pact, (+) positive impact, (++) very positive impact.  
(+/-) the situation will depend on the national context. 
 
EN 54   EN 7. M ONITORING AND EVALUATION  
The general monitoring of the legislati on on animal welfare is included in the 
Regulation (EC) No 882/2004 on offi cial controls of food and feed49. This 
Regulation foresees that the Member  States implement efficiently the 
requirements of the food legislation in cluding those on animal welfare. The 
Commission (Food and Veterina ry Office) controls the correct implementation of 
EU legislation in the Member States.  
Some Member States like  the UK have developed a system of reporting on the 
results of inspections on animal welfare at slaughter50 that could be used by other 
Member States. Another example of specifi c evaluation done in this area can be 
found in the USA where reports have been performed by the General Account Office on humane killing of animals
51. 
However from experience with other an imal welfare legislation, harmonising 
reporting from the Member States is a complex issue and comparability of the data is often critical. In  addition it generates admi nistrative burden for the 
Member States while providing data that ar e difficult to exploit and analyse in a 
significant way. 
Therefore monitoring of the situation should rely on the general instruments that 
already have been developed and where a general methodology has been extensively discussed. At present, findings from Comm ission experts remain the 
most reliable and specific source of in formation on the subject. In addition, the 
frequency of controls is relatively high
52 and provides adequate indications on 
the level of compliance with the legisl ation. Finally Commission experts have 
performed specific exploratory missions on animal welfare on subjects for which 
there were no detailed provisions in the cu rrent EU legislation and this has been 
an adequate source of information on the level of welfare of animals within the 
Member States. 
Another approach would be to conduct regu lar external studies as to evaluate 
every five years not only the welfare di mension of the subject but also other 
related elements (socio-economic aspects). 
Regarding killing for disease control, specific public reporting of animal welfare 
performance has been envisaged (see issu e 5 sub-option 3) and it could be a good 
source of information on those specific massive killing situations. 
Based on the outcome of the monitoring, an  evaluation of the relevant issues 
should be envisaged after 5 to 7 years de pending on the gravity of the issues to 
change. This evaluation c ould be part of a comprehe nsive evaluation of the 
animal welfare policy. 
                                                 
49 OJ L 165, 30.4.2004, p. 1–141. 
50 See the review published in 2004:  
http://www.defra.gov.uk/animalh/we lfare/farmed/slaughter/awr03.pdf   
51 Report GAO 04-247 http://www.gao.gov/ne w.items/d04247.pdf  and more recently GAO 08-686T 
http://www.gao.gov/new .items/d08686t.pdf   
52 Usually Commission's services would control Member  States on animal welfare at slaughter at not 
less than every five years. 
 
EN 55   EN 8. C ONCLUSION  
From the comparison of the main polic y options envisaged it appears that 
reorganising the legislati on would appear to be the most advantageous choice. 
Keeping the existing legal structure with or without technical changes would not 
address effectively important aspects of the current issues identified (new stunning techniques, lack of know ledge of officials etc.). 
Regarding the question of authorisati on of new stunning methods, the present 
system is clearly not satisfactory. It give s the appearance of a harmonised system 
while Member States act by themselves without coordination. But this situation is far from delivering good results. A centralised system for assessing new 
stunning method would be a better altern ative but a partially decentralised 
system would have some benefits. Some Member States have invested resources to support innovation and good we lfare standards while br inging other social and 
economic benefits. National structures are also more available and more reactive. 
A partially decentralised system s hould therefore be also considered. 
Better integration of animal welfare in the process of production brings clear 
positive outcomes for the welfare of anim als, occupational safety and meat 
quality. This could be achieved by the requirement for standard operating 
procedures and/or by the appointment of  an animal welfare officer. Economic 
costs are limited for both options wh ile benefits are appreciated by 
slaughterhouses which have implemented those measures. 
This impact assessment indicates that there is a need for updating the current 
standards on slaughterhouses infrastructures and fixed equipments. It will bring social benefits and investment costs coul d be reduced if a reasonable transitional 
period is considered. 
Better competence of personnel killing an imals as well as setting up specific 
national structure for providing technical back-up on animal welfare for officials 
appear to be two complementary appr oaches. Knowledge policy is highly 
efficient in terms of animal welfare and socially positive for the personnel 
(killing animals is not always a well considered job). 
Finally the issue of killing of animals fo r disease control also indicates that a 
flexible option is more likely to provide  adequate results than a traditional 
approach. Increasing transparency to such events is legitimate as it concerns public spending. Better prepar edness, better supervisi on and better reporting 
would also increase credibility of official services and their sub-contractors dealing with those issues.  
 
EN 56   EN ANNEX I - List of main organis ations and companies consulted  
Name Type of organisation Geographical 
base 
Anglia-Autoflow Equipment manufacturer EU/UK 
Animals Angels Animal welfare organisation EU 
AVEC Poultry meat industry EU 
Butina Equipment manufacturer EU/Denmark 
CIWF Animal welfare organisation  EU 
COMPACT EUROPE Equipment manufacturer Belgium 
COPA-COGECA Farmers EU 
EUROGROUP FOR ANIMALS Animal  welfare organisation EU 
European Fur Breeders Association Fur industry EU 
Federation of Veterinarians of Europe 
(FVE) Veterinarians EU 
Finnish fur breeders associ ation Fur industry Finland 
FNICGV Red meat industry France 
Humane Slaughter Association Animal welfare organisation UK 
OABA Animal welfare organisation France 
PVE (Product Boards for Livestock, 
Meat and Eggs) Meat industry Netherlands 
Stork Food Systems Equipment manufacturer EU/NL 
UECBV Red meat industry EU 
 
 
EN 57   EN ANNEX II – Stakeholders consultation  
 EUROPEAN COMMISSION 
HEALTH & CONSUMER PROTECTION DIRECTORATE-GENERAL  
 
Directorate D - Animal Health and Welfare  
D2 - Animal Welfare and Feed  
 Brussels,  
 D2/DS D(2008)420068  
Summary report on the Working group of  the Advisory Group on the Food 
Chain and Animal and Plant Health 
 
On the revision of the directive on the protecti on of animals at the time of slaughter or 
killing and on animal transport 
 
Brussels on 19 December 2007 
Attendance : see Annex. 
Stakeholders represented : AA Animals Angels (animal welf are organisation), AVEC (poultry 
industry), CLITRAVI (meat indus try), EUROCOMMERCE, COPA-COGECA, 
EUROGROUP FOR ANIMALS (animal welfare organisation), FVE (veterinarians), 
UEAPME (small businesses), UECBV (red meat  slaughterhouses), I BC (butchers), CIWF 
(animal welfare organisation), EFBA (fur breeders). 
Main outcome : 
The Commission presented the main topics rela ted to the proposal to revise Directive 93/119, 
already available on the website of the Comm ission. Paper copies of the website and other 
supporting documents were handed out to participants. 
The Commission received construc tive support from all stakeholde rs for most of the subjects 
discussed. In particular they agreed on the principle that operators should be made more 
responsible for animal welfare (as for the hygiene package). Al l participants also welcomed 
the proposal for a regulation rather than a direc tive. However some of them stressed the need 
for keeping a number of prescriptive requirements as well as the possibility for EU guidelines 
in order to provide sufficient guidance to the indu stry and to officials and to ensure effective 
controls and sanctions across Member States. 
Stakeholders were informed of the possibili ty to send detailed comments up to 31 January. 
A short presentation by Animals' Angels underlining the lack of sufficient enforcement of the 
new EU legislation on animal transport was also  made followed by an exchange of views (see 
presentation annexed).  
 
EN 58   EN Specific outcomes  (on slaughter) Presen tation is annexed  
Increase the operators' responsibility 
All stakeholders were supportive of an increas ed responsibility of the industry. UECBV and 
FVE strongly supported this view while CIWF was concerned about t oo much flexibility 
being given to operators and insist ed that operators need to be monitored by inspections of the 
competent authorities. CIBC was also supportive of the approach but stressed the need for 
proportionate measures depending on the size of  the company concerned. All stakeholders 
preferred the new legal text to  be in the form of a regula tion rather than a directive. 
A more specific scope for permitt ed slaughtering/killing methods 
Stakeholders accepted that permitted methods should be better defined, in particular regarding 
their scope (type of animals to be used for a particular method) and the parameters to be 
checked. UECBV considered that manufactur ers of stunning/kill ing equipment should 
provide the necessary instruc tions. However UECBV was concer ned that some equipment, 
already in use, could no longer be used. A transi tional period should be foreseen in this case. 
The Commission representative said  that it was essential to provide scientific arguments to 
support the authorisatio n or to ban specific methods of slaughter. 
CIWF and EUROGROUP welcomed the Co mmission suggestion on this issue. 
EUROGROUP also asked whether farmed fish would be include d in the current initiative. 
The Commission explained that this was not im mediately foreseen for a number of reasons 
(need for a specific impact assessment, different  physiology, different insp ection system etc.). 
However the Commission made clear that it intends to undertake a specific initiative on the issue later. 
The question of mobile equipment (e.g. capti ve bolts) was also raised. The Commission 
explained why the responsibility should remain at local level as for fixed equipment. The 
importance of manuals – clear instructions on how to use the machines for ensuring good 
animal welfare conditions- was highlighted. 
Improving knowledge by a national  centre/network of reference 
All stakeholders agreed on th e need for a better knowledge po licy on this issue since both 
official inspectors and operators sometimes l acked technical assist ance. The FVE supported 
the idea of a centre. The industry (CLITRAV I, AVEC) was doubtful of the possibility of 
creating new structures at a time of budgetary reductions in many Member States, although 
they considered that providing support on AW  was necessary. CLITRAVI suggested that the 
different functions proposed for a centre of re ference could be dealt with separately, in 
particular by establishing an EU list of scientis ts specialised in a particular area of animal 
welfare at slaughter. The FVE s uggested that the existence of national networks of reference 
should be included as a part of  the Official Feed and Food C ontrol Regulation (incorporated 
in national control plans). 
 
EN 59   EN Improving the design of restra ining/stunning/killing equipment 
The FVE agreed on the principle of integrating AW requirements in the process of the general 
approval of slaughterhouses. The Commission e xplained that since most equipment was a 
fixture of the slaughterhouse it self, only a local assessment w ould be relevant. As regards 
mobile equipment, the Commission suggested th at the responsibility sh ould remain with the 
slaughterhouse operators as ther e was no available legal and pr actical system to ensure a 
harmonised system of pre-approval at EU leve l. Therefore it would be up to the Member 
States to possibly develop a pr e-approval system for mobile e quipment. Most stakeholders 
accepted the views presented by the Commissi on. However CIWF declared that all new 
equipment or new parameters for using eq uipment (such as new electrical stunning 
parameters or gas stunning/killing parameters) should, before being put  into use, require 
approval from the competent authority that th ey are capable of properly fulfilling their 
intended function. 
The Commission also evoked the possibility in th e future legislation to request manufacturers 
to provide instructions of use as to  ensure the welfare of the animals. 
Competence of personnel on animal welfare 
All stakeholders (UECBV, CLITRAVI, FVE,  AVEC and AA) expres sed their support in 
implementing a harmonised system of certifi cation of competence for personnel handling 
animals in slaughterhouses. FVE and AA insisted  on the need for an independent assessment 
so that the length of experience alone would not be automatically recognized. UECBV also 
stressed the need for applying such a requirement  to all slaughtermen including in the case of 
slaughter without stunning in order to ensure rational developm ent of production. It was also 
mentioned that voluntary schemes in certain slaughter houses already existed and should be 
taken as examples. Some stakehol ders insisted on the need for having a certification linked to 
a specific test as a result of passing an independent examination of competence.  
Introducing Standard Operating Pr ocedures for animal welfare 
Although the industry was mostly supportive of the idea, the AVE C questioned the feasibility 
of finding measurable objectives in all cases . UECBV also expressed concern about the 
possible risk of requesting excessive docu mentation from small or medium size 
slaughterhouses (creating potential additi onal administrative costs). The question of 
proportionality of the requirement for SOPs wa s also raised by the FVE. Adaptability for 
SMEs (possible transition period) was also mentioned.  
 
EN 60   EN Animal Welfare Officer (AWO) 
All stakeholders backed the idea of a require ment for an AWO provided that she/he has 
proper qualifications and respons ibilities within the slaughter house (mentioned by AA). Such 
an AWO already exists in Germany (details are provided in the FVE submission). It was 
clarified that the AWO would not replace the official veterinarian. 
Welfare indicators at st unning/killing/bleeding 
Although all stakeholders agreed on the need for a system to monitor animal welfare at these 
particular stages of the pro cess (stunning/killing/bl eeding), UECBV expressed the view that 
the legislation should not set out specific welf are indicators taking into account that national 
laws have an impact on the conditions of comp etition and accordingly on the operation of the 
common market. UECBV considered that it shoul d be up to operators to establish welfare 
indicators in SOPs and with a recording syst em so that officials could perform audit and 
controls. FVE and EFBA also supported the opini on that a general requirement for monitoring 
outcomes and the creation of SOPs should suffi ce. CLITRAVI also considered that more 
specific considerations should be developed in guidelines rather than the legislation, as for 
food safety. 
However CIWF was more doubtful of this approach  and advocated specific parameters in the 
legislation, since this stage (s laughter/killing/bleeding) of the process was critical for the 
welfare of animals. 
Killing for disease control purposes 
Stakeholders agreed on the Commission’s pro posal to request more AW supervision and 
recording of the circumstances. The FVE also suggested establishing a list/network of EU 
experts on the best killing techniques for dis ease control purposes in order to facilitate 
exchange of information and good practices betw een Member States. It was also suggested 
that methods used for killing for disease control purposes should be part of the general list of approved methods. 
On farm killing 
UECBV expressed concern about the possibility of allowing more flexibility for on farm 
slaughter for human consumption. EUROGROUP also  considered that slaughter on farm for 
private consumption should not be exem pted from AW rules including stunning. 
CIWF declared that fur farmi ng killing was a serious concern and had already provided the 
Commission with additional material on this issue. They mentioned in particular the 
recommendation of scientists not to use carb on dioxide for minks. CIWF was also against 
batch killing for minks. EFBA stated that they were ready to implement SOPs and certificate 
of competence but the ban on specific methods of  killing should only be based on a scientific 
evaluation. 
AA deplored the systematic  killing of male chicks
53 and called for a way to stop this practice 
in the long term. AA also requested suppressing the possibility of transporting sick or injured 
animals to slaughterhouses (as presently perm itted under Article 12 of Directive 93/119/EC). 
                                                 
53 Male chicks of breeds used for producing eggs are systematically destroyed. 
 
EN 61   EN AVEC advocated authorisation of neck dislocatio n in the case of poultry. CIWF said that they 
were opposed to neck dislocation as scientific research shows that this does not necessarily 
cause immediate unconsciousness. 
Some stakeholders also raised  the subject of killing for private consumption – outside 
slaughterhouses. 
Religious slaughter 
The issue was raised by animal protection or ganisations (CIWF and AA) who requested that 
slaughter without prior stunning should be st opped. FVE also considered it an unacceptable 
practice.  
UECBV supported the actual status quo  and considered that a good decision on religious 
practices should be taken only at a political level as, if it is carried out in an abattoir, 
performed by trained personal and mechanical rest raining always applied (cattle and sheep), it 
does not pose any particular problem from an animal welfare poi nt of view. UECBV 
underlined its wish to avoid any discriminatio n between Halal and/or Kosher meat because 
any interdiction might be translated in possibiliti es to fuel illegal slaughter already existing in 
some Countries. 
AAs also mentioned the problem  of meat from animals slaughtered without stunning entering 
in the normal channel of distribution (i.e. non-la belled as religiously slaughtered meat) and 
considered that such practice did not a llow consumers to be properly informed.  
The Commission informed stakeholders of  the ongoing Community research project 
DIALREL and the fact that there were very fe w Member States (Sweden and some Länder in 
Austria) which had banned slaughter without st unning. The probability of  a ban being adopted 
at EU level looked rather limite d. In addition such a position would be in conflict with other 
EU policies such as the prot ection of fundamental rights. 
AW labelling 
AVEC asked if the Commission intended to introdu ce a specific labelling scheme or grading 
system with respect to the welfare conditions at slaughterhouses. The Commission reported that in all consultations carried out in this  respect there had been a unanimous opinion among 
stakeholders that slaughtering or killing animals should not be  subject to any grading or 
differentiation system. All stake holders considered that slau ghtering animals should be done 
correctly and that the legi slation should not introduce a grading system between 
slaughterhouses or slaughter methods. 
 
EN 62   EN ANNEX III – Missions of the Food and Veterinary Office   
on the protection of animals at the time of slaughter and/or killing  
Part I: List of FVO missions which covered aspects of animal welfare at slaughter in 
Member States and Candidate Countries 
Details of missions  
Member State Dates of mission Report reference 
Portugal 14-21.5.01 DG(SANCO)/3311/2001 
Luxembourg 5-9.11.01 DG(SANCO)/3343/2001 
Italy 25.2 to 1.3.02 DG(SANCO)/8556/2002 
Belgium 18-22.3.02 DG(SANCO)/8555/2002 
Spain 2-11.4.02 DG(SANCO)/8553/2002 
France 24-28.6.02 DG(SANCO)/8554/2002 
Denmark 9-13.9.02 DG(SANCO)/8676/2002 
Austria 14-18.10.02 DG(SANCO)/8677/2002 
Ireland 25-29.11.02  DG(SANCO)/8678/2002 
Greece 13-17.1.03 DG(SANCO)/9002/2003 
Lithuania* 27-31.1.03 DG(SANCO)/9020/2003 
Latvia* 10-14.2.03 DG(SANCO)/9053/2003 
Hungary* 3-7.3.03 DG(SANCO)/9052/2003 
Czech Republic* 7-11.4.03 DG(SANCO)/9051/2003 
Germany 19-23.5.03  DG(SANCO)/9038/2003  
Portugal 2-6.6.03  DG(SANCO)/9039/2003  
Greece 15-19.9.03 DG(SANCO)/9211/2003  
Finland 1-5.9.03  DG(SANCO)/9212/2003  
Sweden 29.9 to 3.10.03  DG(SANCO)/9210/2003  
United Kingdom 20-24.10.03  DG(SANCO)/9213/2003  
The Netherlands 3-7.11.03 DG(SANCO)/9214/2003  
Belgium 24-28.11.03  DG(SANCO)/9281/2003 
 
EN 63   EN Spain 9-17.12.03  DG(SANCO)/9215/2003 
Poland * 23-27.2.04 DG(SANCO)/7209/2004 
Italy  10-14.5.04 DG(SANCO)/7010/2004 
Slovakia 24-28.5.04 DG(SANCO)/7233/2004 
Lithuania 21-25.6.04 DG(SANCO)/7306/2004 
Hungary 13-17.9.04 DG(SANCO)/7237/2004 
Greece 4-8.10.04 DG(SANCO)/7273/2004 
Czech Republic  10-14.1.05 DG(SANCO)/7519/2005 
Estonia 5-9.9.05 DG(SANCO)/7714/2005 
Latvia 31.5 to 3.6.05 DG(SANCO)/7367/2005 
Cyprus 9-13.1.06 DG(SANCO)/8037/2006 
Greece 21.2 to 1.3.06 DG(SANCO)/8042/2006 
Bulgaria* 6-10.11.06 DG(SANCO)/8054/2006 
Romania* 6-10.11.06 DG(SANCO)/8053/2006 
Croatia* 4-8.12.06 DG(SANCO)/8046/2006 
DG(SANCO)/8331/2006 
Hungary 23-27.4.07 DG(SANCO)/7331/2007 
Poland 22-26.10.07 DG(SANCO)/7734/2007 
 
 
EN 64   EN Part II: List of FVO missions which covered animal welfare at slaughter and killing of 
animals  for disease control purposes. 
Details of missions 
Member State Dates of mission Report reference 
Denmark 6-10.2.06 DG(SANCO)/8039/2006 
Czech Republic 20-24.3.06 DG(SANCO)/8040/2006 
The Netherlands 6-9.6.06 DG(SANCO)/8041/2006 
Slovenia 27.11 to 1.12.06 DG(SANCO)/8038/2006 
France 12-16.2.07 DG(SANCO)/7330/2007 
Spain  5-9.3.07 DG(SANCO)/7328/2007 
United Kingdom 25.6 to 3.7.07 DG(SANCO)/7337/2007 
 
All reports (except for the missions carried in candidate countries before Accession and 
marked with * ) can be found by entering the mi ssion number in the search engine of the 
SANCO web page: http://ec.europa.eu/f ood/fvo/ir_search_en.cfm  
 
EN 65   EN ANNEX IV - Main outcomes from the Member States consultation  
Following the meeting of 25 January 2008 several Member States provided specific written 
contribution to the Commission (Finland, Fran ce, Germany, Italy, Netherlands, Portugal, 
Sweden and the UK). 
From the meeting and the contri butions received, the main reac tions from the Member States 
could be summarised as follows. 
General approach 
There was a general agreement for the need to revise the directive as many provisions were 
obsolete and the legal framework did not fit with the current new approach developed in the food safety area. However Member States we re more divided as regards if the most 
appropriate form should be a direct ive or a regulation, si nce some of them feared that it would 
be put into question stricter sta ndards that they have implemented. 
List of stunning methods / Approving new methods 
Member States would all agree that list of stunning/killing methods would need to be updated 
and more strictly defined, in line with new scientific evidence. However if some of them wanted a strict adherence to international guideli nes, others would prefer  a certain flexibility 
for the killing for disease control purposes. 
As regards new methods Member  Stats agreed that new met hods should be evaluated with 
strict scientific methodology. But some of them  would favour a centralis ed approach (through 
the EFSA) rather than a pa rtially decentralised option. 
Standard Operating Procedures / Animal Welfare Officer 
There was also a large support for introd ucing requirements on standards operating 
procedures in line with the Hygiene Package. The introduction of animal welfare officer was 
also well received by the Member States. However some Member States were attached to a legislation that secures techni cal parameters and were doubtful on the possibility of leaving 
animal welfare indicators in the legislation. C oncerns were also expressed of requesting SOP 
and AWO for small size businesses. 
Certificate of competence 
Member States also largely supported the in troduction of a certification process for staff 
working in slaughterhouses. 
National centres of reference 
Member States were more reluctant for establishing a national centre of reference for the 
protection of animals at the time slaughter, desp ite that they admit that the assessment of 
equipment and facilities of slaughterhouses need  some technical back -up. While some were 
opposed since they consider that the system of scientific back-up already exists, others were 
positive of the idea but would favour a more flexible wording (like a list of recognised specialists) or a network of reference. 
Killing for disease control purposes 
Better preparedness and reporting on animal welfare in case of killing for disease control 
purposes received a positive response from the Member States. While some Member States would prefer strictly adhere to international gui delines in this area, others would advocate for 
a certain level of flexibility  as regards the list of k illing methods to be used. 
 
EN 66   EN ANNEX V – EU sectors affe cted by Directive 93/119/EC  
Red meat sector 
The overall red meat sector produces around 30 million tonnes with the large predominance 
of pig meat production (2/3 of the total red meat and half of the total me at sector if poultry is 
included – see Figure 3 below). 
The EU's pig meat sector is self-sufficient and strong while cattle and sheep sectors are both 
net importers and likely to remain so  (see Table 1). The main Member States producing pig 
meat are Germany (19.4% of total EU produc tion), Spain (14.7%), France (10.3%), Poland 
(8.9%) and Denmark (8.3%). 
EU beef meat production accounts for about 19% of total gross EU production of meat (see 
Figure 3). The main producers within the EU (and their share of EU total production) are 
France (29.7%), Germany (10.2%), and Italy (11.6%). 
Sheep meat production comprises just 3% of the to tal gross internal produ ction of meat in the 
EU-25 (see Figure 1 below). The major sheep a nd goat meat producing MS in the EU are 
Spain (with 29.7% of the total production in  2005), the UK (20%), Greece (16.1%), and 
France (14.7%). 
Slaughterhouses have become increasi ngly large and automated within the EU . Many are 
specialised and only slaughter one species, th ough it is still common for several red meat 
species to be slaughtered in the same plant. Most Member States have seen a reduction in 
slaughterhouse numbers as the remaining sla ughterhouses increase in size. Figure 2 and 
Table 2 provides more specific data on  the sector in each Member State. 
 
 
EN 67   EN Figure 1: Gross internal EU production (2005) 
 
 
Figure 2: Slaughtering by  Member States (2004) 
 
 
 
EN 68   EN Table 2: Number of slaughterhouses in EU Member States (survey data 2007) 
 
 
Poultry sector 
The European poultry meat sector is the second largest meat-producing sector after pig meat. 
Poultry meat production in the EU in 2005 reached 11.1 million tonnes with France 
accounting for 17% of total EU -25 production. The other major producers are the UK (14%), 
Spain (12%), Germany (11%), Italy (10%) and Poland (9%). Th e EU is 106% self-sufficient 
in poultry meat.  
Chicken and turkey are the main poultry spec ies produced, with chickens comprising around 
three quarters of total EU poultry production an d turkeys 20%. The balance is accounted for 
by ducks and fowl. The UK was the largest producer  of chickens in 2005 with a share of 17% 
of total EU chicken production. It was followe d by Spain (13%), and France (12%). Among 
the New Member States, Poland is the biggest  chicken producer su pplying over 11% of EU 
broilers. As far as turkeys are concerned, the biggest produ cers are France (30%), Germany 
(18%), Poland (14%), and Italy (14%). Figur e 3 provides more deta ils on EU poultry meat 
production. 
The EU poultry meat processing sector is char acterised by strong regi onal concentration and 
specialisation (driven by increased competition) and vertical integration, particularly between 
the animal feed industry, broiler producers,  and the slaughtering a nd distribution sectors . As 
regards poultry meat imports, while imports of poultry alive and carcass are insignificant (less 
than 10 000 Tonnes in 2005), impor ts of poultry cuts and prepar ed have increased, reaching 
512,000 tonnes in 2002 and 400,000 tonnes in 2005.  
Figure 3 and Table 3 provide more details on th e sector and capacity in Member States.  
 
EN 69   EN Figure 3: EU poultry meat producti on, by species 1995-2006 (‘000 tonnes) 
 
 
EN 70   EN Table 3: Number of poultry slaught erhouses and slaughter capacity 2000-2006 
 
 
Fur farming 
The fur farming industry represents in Europe  some 6000 fur farmers who produce 60% of the 
world's farmed fur. This industry is the basis for important related economic activities in the 
trade and the treatment of fur. It also consumes 1.200.000 tonnes of animal by-products 
reducing waste on the environment. 
While fur farming is practiced in different part  of the EU, it constitutes in some regions a 
major agricultural activity, in particular in geographical areas where the climate is unsuitable for other agricultural production. In Finland it is estimated th at 50% of fur breeders rely 
exclusively on fur farming for their incomes. 
Mink and foxes constitute the main species fa rmed for their fur. Denmark is the world's 
leading mink fur producer while Finland the leading fox fur producer. 
The main figures of the fur farming sect or are laid down in the table 4 below. 
 
EN 71   EN Table 4: Main figures of the EU fur sector (2006) 
Number of fur farms in the EU (2006) 6.000 
Number of mink pelt 25.1 millions 
Number of fox pelt 2.6 millions 
Estimated employees in the fur sector 
(whole chain) 164.000 full time + 174.000 part time 
Value of farmed fur 1.500 millions euros 
Source: European Fur Breeders' Association/International Fur Trade Federation documents 
Table 5: Main figures of the EU fur farming sector in 2006 
Mink Fox Fitch Raccoon  
Production Farm Prod. Farm Prod. Farm Prod. Farm 
Belgium 185.000 22           
Denmark 13.420.309 1.727 12.000 35       
Finland 1.465.000 569 2.120.000 1.266 1.200 12 104.000 234 
France 180.000 17           
Germany 400.000 25           
Greece 50.000 20           
Netherlands 3.500.000 148           
Iceland 155.000 22 1.500 4       
Ireland 175.000 6 200 1       
Latvia 500.000 12 17.700 7       
Italy 130.000 21           
Lithuania 351.230 18 7.600 4       
Norway 530.000 170 280.000 480       
Poland               
Spain 420.000             
Sweden 1.500.000 125           
EFBA Countries 
TOTAL 22.961.539 2.902 2.439.000 1.797 1.200 104.000 234 
Source: European Fur Breeders' Association 
Hatcheries and killing of chickens on farms54 
Male day-old chicks of laying hen strains are systematically killed by using gas mixture as 
they can not be used for other purposes. It is estimated that in the EU about 335 millions day old male chicks of the laying strain are killed  and the gas killing method applied to all male 
chicks would amount the costs at 1,665,000 Euros. This method is mainly used in hatcheries 
for the egg laying sector. 
                                                
 
54 Data of this paragraph have been provided by the Association of European Hatcheries (AEH) and 
Association of European Hatching Egg, One Day Olds and Pullets Exporters (EPEXA). 
 
EN 72   EN In addition hatcheries for the meat types are incidentally k illing day old chicks and the 
number of killed chicks  both male and female is rather lo w. The method used for killing day 
old chicks in these hatcheries is by rotating or whirling knives which are mincing the chicks 
in a split second. The costs implied can be  considered not to be substantial. 
Chickens on the farm are incidentally killed mainly for animal welfare reasons. When it is 
done by farmers themselves, they dislocate the n eck. It is not easy to give a common figure 
for the number of chicks that is killed by this method since it varies per flock and depends on 
the quality of the day old chicks when they arrive at the farm. About 3,700 million day old 
chicks of the meat strains are yearly plac ed on the farms and about 1 – 1.5 million are 
estimated to be killed. 
Killing for disease cont rol and other killing 
Outbreaks of contagious diseases can sometim es only be controlled through the systematic 
destruction of animals possibly in contact with infected animals. If vaccination can be used in 
some cases and is more and more integrated in  the future policy on animal health, there are 
still reasons for proceeding to massive killing in order to limit the spreading of particular 
pathogens agents. 
Figures on killing for disease control are obviou sly extremely volatile since outbreaks are not 
part of a normal produc tion activity. However in the last decade, two major outbreaks have 
affected mammals species with around 10 milli ons animals killed in each case (Classical 
Swine Fever in the Netherlands and Foot a nd Mouth Disease in the UK) while two other 
major outbreaks have affected bi rds with around 30 millions birds killed in each case (Avian 
Influenza in Italy and in the Netherlands). 
In addition other killings are performed on farms where no estimate is available. Less 
spectacular outbreaks of contagi ous diseases, as well as cont amination of animals by feed 
may lead to the killing of entire farms. 
Animals are also killed on farm s because they are not sufficien tly productive. If animals are 
sometimes transported to slaughterhouse, many such animals are unsuitable for human consumption and are killed on farms. 
 
EN 73   EN ANNEX VI - Current Stunning and bleeding techniques used in slaughterhouses  
Table 1 summarises the different  techniques for stunning and bl eeding used in the different 
species. The results are based on the survey of EU slaughter house operators done in the 
framework of the external impact assessment study carried out by the Food Chain Evaluation 
Consortium (FCEC). 
Table 1: Overview of current stunning/bleed ing techniques used in slaughterhouses 
% of 
slaughterhouses 
who responded Stunning technique Bleeding techniques 
Cattle Penetrative captive bolt: 79% on cattle, 96% 
for calves 
Non-penetrative captive bolt: 4% for claves 
and 7% for cattle  
Electrical stunning: 0%  for calves, 12% for 
cattle Chest sticking: 50% for cattle and 56% 
for calves  
1 carotid artery: 16% for cattle, 26% for 
calves 
2 carotid arteries: 34 % for cattle, 18% 
for calves 
Pigs Electrical stunning: 36% for pigs up to 150kg, 
38% for pigs more than 150 kg 
Gas stunning: 64% for pigs up to 150kg, 62% 
for pigs more than 150 kg Chest sticking: 86% for pigs up to 150 
kg , 100% for pigs more than 150 kg  
Neck cutting: 14 % for pigs up to 150 
kg 
Sheep Electrical stunning : 93% of lamb, 100% of 
adult sheep 
Non-penetrating captive bolt: 7% of lamb 2 carotid arteries: 62 % for lamb, 54% 
for adult sheep 
1 carotid artery: 38% for lamb, 46% for 
adult sheep 
Chickens Head only stunning: 10% 
Reversible water bath: 55% 
Irreversible water bath: 24% 
Neck dislocation: 10% (but only used in 
emergency back-up) 1 carotid artery cut and 1 external 
jugular vein cut: 50% 
2 carotid arteries cut: 29% 
1 jugular vein cut: 8% Manual knife: 4% (only emergency 
back-up) 
Decapitation: 4% 
Turkeys Reversible water bath: 67% 
Irreversible water bath: 33% 1 carotid artery cut and 1 external 
jugular vein cut: 9% 
2 carotid arteries cut: 82% 
1 jugular vein cut: 9% 
Source: EU survey of slaughterhous e operators, consultants reports 
 
EN 74   EN ANNEX VII - Main requirements of Directive 93/119/EC on the protection of animals at 
the time of slaughter or killing  
Scope:  
Animals slaughtered for human consumption, fur animals, killing for disease control 
purposes, killing of animals in farm.  
Requirements for slaughterhouses : 
General obligation of stunning animals but derogation in case of religious slaughter 
List of permitted methods and specific requi rements for stunning or  killing of animals 
Specific requirements for: – unloading and keeping animals at slaughterhouses 
– restraining animals 
– bleeding animals 
General requirements on equipment and personne l to perform the slaughtering operations in a 
professional way respecting the welfare of the animals 
Outside slaughterhouses:
 
General animal welfare principles but possibl e derogation from stunning in case of private 
consumption of poultry or rabbits 
General requirements for the killing of  animals for disease control purposes 
List of permitted methods and speci fic requirements for the killing of: 
– fur animals 
– surplus day-old-chick 
 
EN 75   EN ANNEX VIII - Main technologica l developments in slaughtering techniques and their 
welfare relevance  
There are two species where the main technological developments took place: poultry and 
pigs 
Poultry  
Use of high frequency alternating current an d/or pulsed direct current for water bath 
stunning 
The first water bath stunners were using alternat ing current at a frequency of 50 Hz since this 
is the frequency delivered by electricity prov iders. However due to meat quality problems 
(blood splashes, broken bones) it appears that so me slaughterhouses have been using either 
higher frequency (e.g. 400 Hz) of alternating current or pulsed direct current. Scientists have 
pointed out that increasing the fr equency of alternative current or using pulsed direct current 
may decrease the effectiveness of the stunni ng with animals being immobilised while 
submitted to painful electrical shocks instead of being stunned. 
Development of Control Atmosphere Stunning  
The use of stunning/killing poultry with gas mixtures (also named Control Atmosphere 
Stunning) was not foreseen in 1993 when the Directive was adopted. A recent study55 
requested by the Commission indi cates that at least three different CAS methods are now used 
in the EU within around 25 slaughterhouses. CAS is used in the larges t slaughterhouses and 
experts estimate that between 20 to 25% of br oilers in the EU are now slaughtered under 
CAS. 
Pigs 
While the use of carbon dioxide was foreseen  in Directive 93/119/EC at a minimum 
concentration of 70%, scientists have indicated  that carbon dioxide can be aversive above 
30%. The meat industry has increas ingly used higher concentrati ons up to 90% in order to 
shorten the time of exposure wh ile ensuring a longe r stunning time. 
                                                 
55 Study on the stunning/killing practices in slaughterhouses and their economic, social and environmental 
consequences, Part II: Poultry, Food Chain Evaluation Consortium, September 2007. 
 
EN 76   EN ANNEX IX - Hygiene package requirements in a nutshell  
Main requirements of the "Hygiene pack age" applicable to slaughterhouses  
The "Hygiene package" is a set of several regu lations implementing the general principles of 
the "Food Law" laid down in  Regulation (EC) No 178/2002. The relevant regulations 
applicable to slaughterh ouses are the following: 
Regulation (EC) No 852/2004 on hygiene of foodstuffs  
This regulation makes compulsory to any food business operator to put in place, implement 
and maintain permanent procedures based on the HACCP principles . HACCP stands for 
Hazard Analysis Critical Control Points and is a complex methodology internationally 
recognised for preventing food safety. 
The Regulation lists seven HACCP principles (Article 5) which can be summarized as 
follows: 
(1) identification of food safety hazards, 
(2) identification of critical  control points CCP (i.e. the steps of the production process 
where you can prevent, reduce or eliminate the hazards), 
(3) establishment of critical limits fo r each CCP (what is acceptable or not), 
(4) establishment of monitoring procedures for each CCP, 
(5) establishment of corrective actions  when a CCP is not under control, 
(6) establishment of verification procedures to ensure that the system is effectively 
working, 
(7) establishment of documents and records co mmensurate with the nature and the size 
of the food business to demonstrate the effective application of the measures 
requested. 
Regulation (EC) No 853/2004 laying down sp ecific hygiene rules for food of animal 
origin 
This regulation requires establishments to be registered and a pproved by the competent 
authority and laid down specific requirem ents for each type of establishments. 
For slaughterhouses, pre-approval is based on the inspection by th e competent authority as to 
assess the compliance of requirements relate d to construction, layout and equipments. 
In addition the regulation asks for the operational requirements to ensure the safety of the 
meat (identification, marking, HACCP-based procedures, slaughter hygiene, etc.). In 
particular it requires HACCP based procedure in order to check the welfare of animals at 
arrival. 
 
EN 77   EN Regulation (EC) No 854/2004 layi ng down specific rules for th e organisation of official 
controls on products of animal or igin intended for human consumption 
This regulation laid down the organisation of of ficial control includi ng in slaughterhouses. 
In particular the process of approval of sla ughterhouses and audit of HACCP procedures is 
specified. The regulation explicitly  indicates that for slaughter houses, animal welfare is part 
of the inspection tasks of the competent authority. 
The regulation also specifies the obligations and the powers of the official veterinarian in a 
slaughterhouse regarding animal welfare. The official can in particular slow down and stop 
the production line, depending on the nature an d the gravity of the problem encountered. 
 
EN 78   EN ANNEX X - Example of the discrepancies of si tuation in Europe concerning Controlled 
Atmosphere Stunning from informat ion collected from manufacturers  
Current UK legislation only allo ws anoxic mixtures to be app lied in controlled atmosphere 
stunning. This legislation can no longer be amended, since the maximum number of 
amendments has been reached already. Therefor e, new legislation is needed. It has been 
expressed to us that the UK awaits th e revision of Council Directive 93/119/EC. 
For the Dutch situation, the Mi nistry of Agriculture conc luded in 2005 that applying 
controlled atmosphere stunning was covered alr eady by national as well as EU legislation 
(with reference to Di rective 93/119/EC). 
In Finland, the authorisation to apply multiphase has been laid down into legislation since the 
early 2000's. 
For other Member States equipment manufacturer s need to apply for a special derogation 
from the law. Such derogation is usually given on a temporary basis, subject to future law. 
Carbon dioxide stunning at high co ncentration (without the additi on of inert gasses) is only 
applied in Italy. In Germany, hypercapnic stunning of turkeys is allowed by law. There are 
however, currently no such sy stems operational in Germany. 
 
EN 79   EN ANNEX XI – Directive or Regulation in this case?  
As stated in the Commission Communicatio n on “Implementing the Community Lisbon 
programme: A strategy for the simplification of the regulatory environment”56, "Replacing 
directives with regulations c an under certain circumstances be conducive to simplification as 
regulations enable immediate application, guarantee that all actors are subject to the same 
rules at the same time, and focus attention on the concrete enforcement of EU rules."  
In this case, a Regulation would offer the following advantages: 
• it would provide a uniform and simultaneous  application of a measure in all the 
Member States and avoid the burden, both for the Member States and the 
Commission, of transposition. 
• as this area requires more detailed and precise provisions, wher e the results to be 
achieved are often quantifiable, if the Member  States are left with a too great margin 
of discretion, legal insecurity can arise.  
• the updating of a Regulation can be more  rapidly implemented. This would be 
particularly welcomed in this area which is subject to evolution, having regard to 
technical and scie ntific advances. 
                                                 
56 COM(2005) 535. 
 
EN 80   EN ANNEX XII – Comparative price level indices of the survey, EU 27=100  
From Statistics in focus, Econom y and finance, 90/2007, Eurostat 
 
 
EN 81   EN ANNEX XIII – Illustration of the impact of  the baseline scenario  on innovation: the 
example of controlled atmo sphere stunning of poultry  
The baseline scenario can be illustrated by the development of  the controlled atmosphere 
stunning of poultry (CAS)  where the current legislation does not contain requirement or 
common methodology to analyse/aut horise new methods of killing. We have previously seen 
in section on subsidiarity the various ways Member Stat es have dealt with CAS.  
All these differences between Member States have impacts on equipments manufacturers and 
at the end on innovation. They affect the cost of  the structure of production (direct effect) but 
they also affect the quality of  products (indirect effect).  
Regarding direct costs, the choice of gas mixtur e has an influence linked to the cost of gas 
(Argon or Nitrogen are more expensive than car bon dioxide) but linked to the fact that the 
different protocols can require slightly different time to stun or kill the animals. Under 
commercial conditions protocols used, the duration of exposure to gas mixture may vary 
between less than one minute of exposure to up to three minutes, affecting not only 
investment costs (design of the equipment) but  also the throughput of  the production line.  
Indirect effects are due to the constraints related to the effect  that the CAS protocols have on 
the final product. Meat quality may be affected by the use of some protocols. According to the 
FCEC study, the lack of harmonised legislati on on CAS has partly contributed to favour the 
prevalence of electrical stunning. 
Table 3: Use of controlled atmosp here system in the EU (poultry) 
 
 
EN 82   EN ANNEX XIV – Complementary questi onnaire to the Member States  
AS TO COMPLETE THE IMPACT ASSESSMENT ON THE REVISION OF THE EU LEGISLATION ON 
THE PROTECTION OF ANIMALS AT THE TIME OF SLAUGHTER OR KILLING  
The following questions do not preclude the final options taken by the Commission. They 
reflect demands expressed by st akeholders or/and scien tists which needs to be quantified in 
terms of economic costs as well as on othe r possible impacts. As information is not 
necessarily available and cases may vary de pending on each local situation, evaluation 
should be provided based on concrete data or exi sting studies which are directly relevant or 
which present similarities .  
For the purpose of this que stionnaire the word " stunning " should be understood as any 
method inducing unconsciousness and insensitivity, reversible or not (stunning or stunning/killing). 
Question 1 – Official controls  – The Commission may envisage requesting official controls 
and audits on animal welfare that we understa nd are already covered under inspection duties 
of officials in the framework of the hygien e package. Do we have any quantitative 
information regarding the costs generate d by the requested official controls? 
Question 2 – Administrative costs related to the authorisation of new stunning methods  – The 
Commission may envisage maintaining the possibility for Member States to initiate the 
process of authorisati on for new stunning methods. 
Q.2.1 – Based on previous experience, what w ould be the costs of processing such 
authorisations?  
Q.2.2 – What types of costs would a new authorisi ng scheme require from companies and/or 
Member States' authority?: 
ο Additional staff? If yes, please i ndicate how many more man-hours.  
ο Additional checks? If yes, please indi cate how costly this could be (in €). 
ο Data collection? If yes,  please indicate how costly this could be (in €). 
ο Data storing and processing? If yes, pleas e indicate how costly this could be (in 
€) 
ο Etc… 
Q.2.3  – To which extent these costs coul d be supported by the industry? 
Q2.4  – In the past years, how many authorisa tions for new stunning methods have been 
processed? 
Question 3 – Animal Welfare Officer (AWO)  – The Commission may envisage making 
compulsory for slaughterhouses to appoint a person who would be responsible for the 
implementation of the anim al welfare legislation.  
Based on the experience gained in your country  (if applicable) where a AWO is required, how 
this obligation is implemente d by operators? In particular, how many more man-hours are 
needed at company level to comply with the requirement?  
 
EN 83   EN Question 4 – Certificate of competence  – The Commission may envisage establishing a 
system of certificate of competence for pers onnel handling animals at slaughterhouses and for 
personnel killing fur animals.  
Q.4.1 – Based on similar experiences, what would be  the costs for the public administration 
to introduce and run such system of certificates of competence? 
Q.4.2 – In particular, what types of costs woul d a new certificate of competence scheme 
require from companies and/or  Member States' authority?: 
ο Additional staff? If yes, please i ndicate how many more man-hours.  
ο Additional checks? If yes, please indi cate how costly this could be (in €). 
ο Data collection? If yes,  please indicate how costly this could be (in €). 
ο Data storing and processing? If yes, pleas e indicate how costly this could be (in 
€) 
ο Etc… 
Question 5 – National Centre of Reference  – The Commission may envisage requesting 
Member States to establish a national centre of reference to perform several scientific and technical tasks related to the welfare of animals at  the time of slaught er and killing. In 
particular those tasks could involve inter alia  the provisions of t echnical supports for the 
process of approval of new slaughterhouses, the examination of new stunning methods, the 
scientific advice on killing methods for disease control purposes and the accreditation of certification bodies (for ce rtificate of competence). 
Q.5.1 – Could you describe in your country how officials in slaughterhouses make use of 
scientific and/or technical expertise to assess the animal welfare aspects of new 
equipments, new establishments, new stunning or killing methods or the competence 
of personnel?  
Q.5.2 – What is the present costs of  the system you have described? 
Q.5.3 – Based on similar experience and the av ailability of existing scientific resources 
available in your country, what types of costs woul d a new national centre of 
reference require from companies an d/or Member States' authority?: 
♦ Additional staff? If yes, please i ndicate how many more man-hours.  
♦ Additional checks? If yes, please indi cate how costly this could be (in €). 
♦ Data collection? If yes,  please indicate how costly this could be (in €). 
♦ Data storing and processing? If yes, pleas e indicate how costly this could be (in 
€) 
♦ Etc… 
 
EN 84   EN Question 6 – Killing for disease contro l purposes and other depopulation cases  – Directive 
93/119/EC allows the competent authority to us e other methods than the one listed in the 
current EU legislation. The Commission may envisa ge using a stricter li st of stunning/killing 
methods including for disease control purposes a nd requesting a better integration of animal 
welfare concerns when actual ki lling of animals takes place. 
Q.6.1 – Could you identify methods of killing th at are presently not listed in Directive 
93/119/EC or not recommended by the EFSA or the OIE guidelines th at have been or 
would be used by your country  in case of outbreaks? 
Q.6.2 – What type of costs would the ban on these methods involve from your organisation? 
ο Buying new equipment? If yes,  please indicate how costly. 
ο Hiring additional staff? If yes, pleas e indicate how many more man-hours. 
ο Etc…. 
Q.6.3 – What are the current practic es of your country in relation to the integration of animal 
welfare issues on the planni ng, the supervision and the re porting during outbreaks or 
other massive on farm killing? 
Q.6.4 – Do you have the practice of producing an evaluation report on the animal welfare 
results during operations of de population? If so, how often? 
Q.6.5 – If not, what types of additional costs w ould involve the production of an evaluation 
report on the animal welfare result s during operations of depopulation? 
• Additional checks? If yes,  please indicate how costly 
• Additional drafting for producing report?  If yes, please indicate how many 
more man-hours 
Question 7 – Official supervision in case of religious slaughter  – Some stakeholders believe 
that religious slaughter is ofte n performed without sufficient consideration to the welfare of 
the animals and suggest that permanent presen ce of officials would improve the situation. 
What types of costs would a presence of offi cials involve from Memb er States authority?  
ο Additional staff? If yes, please i ndicate how many more man-hours.  
ο Additional checks? If yes, please indi cate how costly this could be (in €). 
ο Data collection? If yes,  please indicate how costly this could be (in €). 
ο Data storing and processing? If yes, please indicate how co stly this could be (in €) 
ο Etc… 
 
EN 85   EN Question 8 – Official controls on fur animals killing  – Today's EU legislation provides 
specific requirements for the killing of fur an imals which take place on farm during a specific 
period of the year. 
Q.8.1  – How today official controls are performed to check the pr ovisions applicable to the 
killing of fur animals?  
Q.8.2  – What is the percentage of fur animals k illed per year do you estimate to be checked? 
END OF THE QUESTIONNAIRE