Opinion of the European Economic and Social Committee on "Proposal for a Council Directive amending Directive 88/407/EEC laying down the animal health requirements applicable to intra-Community trade in and imports of semen of domestic animals of the bovine species"

(COM(2002) 527 final - 2002/0229 (CNS))

(2003/C 85/12)

On 9 October 2002 the Council decided to consult the European Economic and Social Committee, under Article 37 of the Treaty establishing the European Community, on the above-mentioned proposal.

The Section for Agriculture, Rural Development and the Environment, which was responsible for preparing the Committee's work on the subject, adopted its opinion on 13 November 2002. The rapporteur was Leif E. Nielsen.

At its 395th plenary session on 11 and 12 December 2002 (meeting of 11 December), the European Economic and Social Committee adopted the following opinion by 103 votes in favour and two abstentions.

1. Gist of the Commission proposal

1.1. Council Directive 88/407/EEC lays down a series of detailed animal health requirements applicable to trade in, and imports of, semen of domestic animals of the bovine species.

The purpose of the Commission's proposed amendment is:

- to permit the storage of bovine semen at semen storage centres on premises other than the artificial insemination (AI) centre where semen was collected;

- to amend, in the light of the new scientific data available and the new provisions laid down by the Office International des Epizooties (OIE), the animal health conditions applicable to entry of bulls into AI centres, in particular concerning infectious bovine rhinothracheitis (IBR/IPV) and bovine viral diarrhoea (BVD/MD);

- to simplify the Community procedure for the approval of AI centres in third countries. These lists of approved AI centres are frequently modified on formal grounds on the basis of the information sent by the competent authorities of third countries (address, name, new establishment etc);

- to allow the Commission to amend, following the comitology procedure, the annexes to Directive 88/407/EEC as they cover technical points relating to approval of centres and conditions of admission of bulls into centres.

2. General comments

2.1. In the EU, bovine semen and embryos have, up to now, been produced and sold in association with approved semen collection centres under the auspices of cooperatives and organisations closely tied to local farming. Although semen and embryos from other Member States and non-EU countries may be distributed freely through this marketing chain, it is possible, by means of selection, to meet a series of specific requirements in the breeding programmes (e.g. as regards health or the prevention of unwanted genetic features, or the adjustments required to take account of regional or local conditions). At the same time, sales of bovine semen are the economic mainstay of AI associations' breeding work. The existing arrangements with approved semen collection centres ensure an appropriate reliability and product guarantee in the event of problems or damage; this would no longer be possible if the system were changed as radically as proposed.

2.2. Facilitating the establishment of semen storage centres separate from semen collection centres(1) is designed to liberalise the market and thus promote a more international "insemination industry" that distributes bovine semen and embryos through local stores. This involves a serious risk of undermining the system in place to date and of increasing centralisation in the selection, production and distribution of breeding material. It may result in a gradual change in breeding aims and a lack of versatility in the breeding material, with greater streamlining of productive livestock. Consequently, future stock breeding may become more one-sided and there may also be an impact on efforts to promote sustainable development and multifunctional agriculture in the EU. The restriction of genetic diversity can be seen also from the example of the Holstein-Friesian breed, for which the world stock of breeding animals might already total fewer than 40. The Commission proposal could encourage a further reduction in diversity.

2.3. Though, under the proposal, the same animal health requirements apply to semen storage centres as they currently do to the storage of bovine semen in association with semen collection centres, the distribution from storage centres to the herd is subject to national animal heath requirements alone. Liberalised distribution from local semen storage centres to the herd with no supervision, monitoring or expert back-up from the A1 associations, may increase the risk of spreading infectious diseases and genetic defects.

2.4. The spread of infectious animal diseases in the EU can have serious consequences. The recent foot-and-mouth epidemic in the UK clearly demonstrated the disease's potential social and economic impact. The same goes for a series of other infectious bovine diseases such as tuberculosis, brucellosis, IBR, BVD etc. The greatest possible vigilance must therefore be exercised in relation to all risk factors, including, not least, contact with the individual herds.

2.5. The single market - which involves, in principle, the free movement of livestock over longer distances, larger herds and a greater concentration of domestic animals in certain regions - also increases the risk of spreading infectious diseases and aggravating the social and economic impact of any possible outbreaks.

2.6. The collection, storage, importation, distribution and use of semen and embryos thus constitute a serious risk of infection, warranting the strictest monitoring. One dose of semen from a single ejaculation may, for instance, be used for up to 2000 inseminations and any potential infection can be spread to a corresponding number of herds in several Member States.

2.7. The above comments will apply all the more after enlargement, not least in respect of breeding trends and the potential dominance of "insemination industry interests" in the new Member States. Further, a precedent may be set for future parallel sets of rules, for instance in the pig sector. For these reasons, more thorough consideration must be given to the proposal's potential impact.

3. Specific comments

3.1. Under the proposed rules, a semen storage centre may import and export semen and embryos. It is vital therefore to lay down clear procedures for the local official veterinarian to check compliance with the rules. The current provisions on the marketing of semen give a sufficient guarantee of the necessary certainty of high standards both for the veterinarian concerned and for the breeder; this could not be fully guaranteed by semen storage centres in individual cases.

3.2. Registration of bovine semen producers is essential in order to ensure traceability in the marketing chains from collection to use in the herds. It must be an absolute requirement that trade may only be conducted "one way", i.e. from the producer to the store and from the store to the livestock holding, with no possibility of return.

3.3. Reliable monitoring arrangements must be in place for semen and embryo imports from collection or storage centres outside the EU, and traceability must be guaranteed in case of the risk of any outbreak of infectious animal diseases. Among other things, it is vital to ensure the registration and monitoring of third-country collection centres which export bovine semen to storage centres in the EU so that the veterinary authorities in the Member State concerned can immediately take the requisite precautions in case of any subsequent concerns about disease.

3.4. To streamline the admission of bulls into approved semen collection centres, the following additions are proposed:

- Where the tests mentioned in Annex B, chapter I, points 1(d) and (e) are carried out in the quarantine or isolation facility of the semen collection centre, the quarantine period must be deemed to start from the date the samples are collected for the tests under (d), not the date on which the results are received, which may be up to two weeks later. The interval between the tests mentioned under points (d) and (e) will thus be twenty-one days, in line with the international OIE standard.

- The tests for campylobacter and trichomonas, which require a bacteriological as opposed to a serological diagnosis, should be carried out after seven days' quarantine, and not twenty-one as proposed. This will enable infected animals to be identified at an early stage and, in case of infection, will make it possible to carry out all the tests within the quarantine period.

3.5. Under Article 3 of the proposal, trade in and imports of semen certified according to the rules formerly in force are to be accepted for a period of six months after the directive enters into force. The wording used here is unclear in certain language versions, and it also raises important questions about existing stocks which, under current practice, are normally used over a longer period.

4. Conclusion

4.1. Despite the fact that, for several years, proposed amendments have been on hold pending an OIE standard on issues such as IBR vaccination, the Committee feels that the proposed amendment for semen storage centres cannot be accepted in its present form. The Committee does, however, endorse the other three proposed amendments.

Brussels, 11 December 2002.

The President

of the European Economic and Social Committee

Roger Briesch

(1) The existing rules provide only for the establishment of "satellite stores" associated with a semen collection centre.