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}
Date: 2008-09-18
Institutions: European Commission
Subjects: protection of animals, slaughter of animals, transport of animals, vocational training

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COMMISSION OF THE EUROPEAN 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} 

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TABLE OF CONTENTS 

1. 

1.1. 

1.2. 

1.3. 

1.4. 

1.5. 

1.6. 

1.7. 

1.8. 

2. 

Procedural issues and consultation of interested parties .............................................. 8 

EFSA opinions and guidelines of the World Organisation for Animal Health 
(OIE) ............................................................................................................................ 8 

External study (FCEC)................................................................................................. 8 

Consultations of interested parties ............................................................................... 8 

Food and Veterinary Office reports ............................................................................. 9 

Internet consultation..................................................................................................... 9 

Consultation of the Member States .............................................................................. 9 

Inter-Service steering group on the impact assessment ............................................. 10 

Follow-up to Impact Assessment Board recommendations....................................... 10 

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. 

2.3. 

A new context ............................................................................................................ 11 

Specific problems arising from this new context and the application of Directive ... 13 

2.3.1.  Different approaches taken by the Member 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 increasing animal welfare concerns ..................................... 15 

2.3.4.  Religious slaughter..................................................................................................... 15 

2.4. 

Subsidiarity ................................................................................................................ 16 

3. 

3.1. 

3.2. 

3.3. 

4. 

Objectives................................................................................................................... 17 

General objectives...................................................................................................... 17 

Specific objectives ..................................................................................................... 17 

Relationship between objectives and with other EU initiatives................................. 17 

Policy options............................................................................................................. 19 

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 

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5. 

5.1. 

5.2. 

Impacts analysis ......................................................................................................... 21 

Identifying the impact/General remarks..................................................................... 21 

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: non-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: reorganising 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....................................................................................................... 45 

6. 

6.1. 

6.2. 

6.3. 

7. 

8. 

Comparing the options ............................................................................................... 49 

Main policy options ................................................................................................... 49 

Comparing the components of option 3 "amending the directive" ............................ 50 

Comparing the components of option 4 "Reorganising the legislation".................... 51 

Monitoring and evaluation ......................................................................................... 54 

Conclusion ................................................................................................................. 55 

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 

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ANNEX IV - Main outcomes from the Member States consultation ...................................... 65 

ANNEX V – EU sectors affected by Directive 93/119/EC ..................................................... 66 

ANNEX VI - Current Stunning and bleeding techniques 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 Regulation 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 atmosphere stunning of poultry............................................................ 81 

ANNEX XIV – Complementary questionnaire to the Member States .................................... 82 

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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  animals  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/EC1 on the 
protection of animals at the time of slaughter or killing. The directive has never 
been  amended.  The  present  impact  assessment  will  therefore  mainly  focus  on 
whether the problems have changed and whether the original objectives are still 
valid. 

The starting point of the Commission proposal 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  Directive.  In  parallel  the  World 
Organisation for Animal Health adopted in 2005 two guidelines on the welfare of 
animals at slaughter and killing leading to similar conclusions. As a consequence 
the Commission mandated an external consultant in 2006 to carry out a study on 
stunning/killing  practices  in  slaughterhouses  and  their  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  slaughterhouses,  fur  farming,  hatcheries  and 
killing  performed  for  disease  control  purposes.  The  meat  industry  is  the  most 
concerned sector since it kills the largest 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 scientific 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  chain.  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 killing during large animal epidemics have 
also  raised  questions  on  our  way  to  ensure  humane  killing  of  animals.  In  2006 
the Commission adopted the first Community Action Plan on the Protection and 
Welfare of Animals, introducing new concepts 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. 

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Specific problems have also been identified with the present EU legislation such 
as  the  lack  of  harmonised  methodology  for  new  stunning  methods,  the  lack  of 
clear responsibilities for operators on animal welfare, the insufficient competence 
of  personnel  handling  animals,  or  insufficient  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  reinforced  in  1993.  Consultations  from 
stakeholders and Member States confirm the relevance of Community initiative 
in this domain. This legislation affects the meat industry, the sector of equipment 
manufacturers  and  some  farmers'  activities.  All  of  them  are  working  at 
international level and ask for an EU framework. 

The  general  objectives  of  the  initiative  attached  to  this  impact  assessment  is  to 
improve  the  protection  of  animals  at  the  time  of  slaughter  or  killing,  while 
ensuring a level playing field for all business 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  encourage  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  nothing  (=baseline=  option  1),  non-biding 
recommendations  (option  2),  amending  the  directive  (option  3)  through  its 
technical annexes and reorganising the legislation (option 4).  

Slaughtering  costs  represent  a  limited  part  of  the  total  costs  of  slaughterhouses 
activities (20%) but could affect their competitiveness. However changes in costs 
for  slaughtering  animals  are  unlikely  to  affect  the  final  price  of  meat. 
Slaughterhouses  are  already  submitted  to  permanent  official  inspection  through 
food safety legislation. The current animal welfare legislation does not introduce 
additional  requirements  for  official  inspections.  Animal  welfare  has  a  positive 
impact on meat quality and occupational safety. It also represents positive market 
values. No significant environmental impacts have been identified. 

From the comparison of the options it appears that doing nothing (option 1) have 
a number of negative impacts on the objective pursued. None of them is likely to 
be  achieved  by  this  option.  Animal  welfare  on  many  aspects  is  likely  to  be 
worsened  while  businesses  will  have  to  operate  in  an  increasingly  different 
environment from Member State to another. 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  detrimental  effects  on  meat  quality,  public 
perception  and  occupational  safety  could  have  long  term  negative  economic 
impacts on the meat sector. 

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The  comparison  between  the  other  options  in  the  light  of  the  objectives  makes 
clearly  more  advantageous  to  reorganise  the  legislation  (option  4)  while 
amending the directive (option 3) would bring some benefits 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  considered  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 businesses 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  benefits  than  amending  the 
directive (option 3) as regards animal protection. It is also the option that is likely 
to bring the most positive impacts in terms of meat quality, public perception and 
better working conditions 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  possible  transitional 
periods or exemption in specific cases.  

Environmental impacts are considered to be neutral for all options as there was 
no  evidence  during  the  collection  of  data  of  substantial  and/or  direct  effects  on 
environment. 

The  general  monitoring  of  the  legislation  on  animal  welfare  is  included  in  the 
Regulation 882/2004  on  official  controls  of  food  and  feed2  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. 

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1. 

1.1. 

PROCEDURAL ISSUES AND CONSULTATION OF INTERESTED PARTIES 

EFSA opinions and guidelines of the World Organisation for Animal Health 
(OIE) 

Following  a  Commission  request,  the  European  Food  Safety  Authority  adopted 
two scientific opinions in 20043 and 20064 on the different stunning and killing 
methods  to  be  used  for  main  farm  species  either  for  slaughter  for  human 
consumption or for disease control purposes. 

In  parallel,  the  OIE  provided  two  guidelines  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 year5. They 
contain detailed technical requirements for the different aspects of the slaughter 
or killing of animals. OIE guidelines are 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 
consequences6. The study was finalised in July 2007. 

In  the  framework  of  the  study,  major  stakeholders  such  as  meat  industry 
associations,  competent  authorities  and  animal  welfare  associations  were 
Individual 
consulted  at  European  and  national 
slaughterhouses,  consulting  firms,  farmers'  organisations  and  equipment 
manufacturers were also contacted for that purpose. 

(see  Annex 

level 

I). 

For all  species studied, there was a  global  perception  among  most  stakeholders 
that animal welfare was progressively integrated as one of the key dimensions to 
continue  their  business  in  Europe.  In  particular  this  evolution  explained  the 
success  and  the  development  of  new  methods  of  stunning  considered  more 
humane  like  the  use  of  modified  atmosphere  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 legal 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 

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The EFSA Journal (2004), 45, 1-29, Welfare aspects of the main systems of stunning and killing 
the main commercial species of animals. 
The  EFSA  Journal  (2006)  326,  1-18,  ”The  welfare  aspects  of  the  main  systems  of  stunning  and 
killing applied to commercially farmed deer, goats, rabbits, ostriches, ducks, geese and quail. 
See http://www.oie.int/eng/normes/mcode/en_titre_3.7.htm 
http://ec.europa.eu/food/animal/welfare/slaughter/slaughter_econostudy_en.htm 
Main organisations and companies consulted on bilateral basis are listed in Annex I. 

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The  initiative  was  also  publicised8  through  regular  presentations  at  industry 
forums  and  at  the  Commission  relevant  advisory  committees  of  the  Directorate 
General for Agriculture 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 Group9 contains 36 European organisations 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 

1.5. 

Commission  experts  from  the  Food  and  Veterinary  Office  (FVO)  performed 
regular  inspections  in  order  to  verify  that  Member  States  take  the  necessary 
implementing measures to ensure compliance with Community rules. As regards 
Directive 93/119/EC, FVO experts have regularly 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  missions10  and  important 
information  on  the  effectiveness  of  the  supervision  by  Member  States  on  the 
enforcement  of  animal  welfare  requirements.  Annex  III  provides  the  list  of 
missions performed on slaughter since 2003. 

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  the  proposal,  terms  of  reference  of  the 
socio-economic  study,  details  of  the  consultant  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  stakeholders  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 reflection 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. Afterwards some Member States provided 
specific contributions (see Annex IV). An additional questionnaire was sent to all 
Member  States  for  collecting  complementary  data  from  which  the  Commission 
received 11 replies (see complementary questionnaire in Annex XIV). 

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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. 
The list of members was published in OJ C 97, 21.4.2005, p. 2. 
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. 
http://ec.europa.eu/food/animal/welfare/slaughter/slaughter_directive_en.htm 

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1.7. 

Inter-Service steering group on the impact assessment 

Two  Commission  inter-service  steering  groups  took  place,  one  at  a  very  early 
stage of the IA draft (in February 2008) and one at the final stage of the draft (in 
April 2008). Were invited DG AGRI, TRADE, 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  June.  In  its  opinion,  the  Board  made  the 
recommendations and the document was accordingly redrafted. This includes: 

• 

• 

• 

• 

• 

merging  the  information  of  the  status  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. 

PROBLEM 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  billions  of  poultry  every  year12.  Slaughter  for  human 
consumption  may  also  take  place  outside  slaughterhouses  in  certain  cases 
(farmed game, derogations, etc.). In addition 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 also  require the killing of thousands to 
millions  of  animals.  Details  on  the  different  sectors  affected  are  provided  in 
Annex V. Stunning and bleeding methods differ according to species. Details on 
the current stunning/bleeding techniques used 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 

13 

Based on 2007 statistics, 258 millions pigs, 72 millions sheep and goats and 29 millions bovines 
are  slaughtered  in  the  EU  yearly.  Based  on  partial  2007  data  there  are  at  least  4  billions  poultry 
slaughtered every year in the EU. 
Based on 2006 data. 

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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 considerations 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 believe animal welfare and protection do 
not  receive  enough  importance  in  their  country's  agricultural  policy.  This 
concern has been enshrined in the Treaty with the adoption of the Protocol 
on the Protection and Welfare of Animals15 in the EC Treaty of Amsterdam 
in 1997.  

However, when consultation was carried out concerning a possible grading 
system for slaughterhouses according to different levels of animal welfare 
standards  applied,  there  was  a  unanimous  opinion  from  organisations  of 
animal  protection  as  well  as  from  the  meat  industry  that  animal  welfare 
standards at slaughter were not negotiable and should be determined by the 
legislation.  According  to  them,  there  is  a  strong  expectation  amongst 
consumers  that  animals  are  slaughtered  correctly  but  they  would  be  very 
reluctant,  when  buying  meat,  to  get  information  on  the  details  of 
stunning/killing methods used in order to make their choice. 

legislation  adopted 

(3)  Changes in the EU legislative context applicable to slaughterhouses: The 
EU  legislative  context  applicable  to  slaughterhouses  operators  has  been 
substantially  changed by the introduction of the general food law and the 
subsequent 
(the  so-called  "Hygiene 
package")16.  One  of  the  key  changes  of  this  set  of  legislation  was  to 
increase the responsibility of food business operators regarding food safety. 
Officials'  role  is  mainly  to  ensure  that  operators  develop  and  implement 
adequate measures to meet this objective. 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. 

in  2004 

14 

15 
16 

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. 
Protocol on the Protection and Welfare of Animals (OJ C 340, 10.11.1997, p. 110). 
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). 

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(4)  The  EU  has  faced  in  recent  years  major  animal  epizooties  involving 
massive  culling  of  animals  for  controlling  the  spread  of  animal  diseases 
(Foot and Mouth Disease in 2001, Avian 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 
11 millions pigs 

in 

the  Netherlands: 

1999-2000 

Avian Influenza in Italy: 14 millions birds18 

2001 

2003 

Foot  and  Mouth  Disease  in  the  UK  (mainly): 
10 millions  animals  (mainly  sheep,  but  also  cattle 
and pigs) 

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 Community in this field. Two concepts are 
particularly relevant: 

(a) 

(b) 

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. 

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 

18 

19 
20 

21 

Figures  on  Classical  Swine  Fever  and  Foot  and  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.  
Commission Staff Working Document SANCO/10613/2004 Rev. 4 Impact Assessment of the new 
Community measures for the control of Avian Influenza, in accordance with the draft Commission 
proposals  for  a  new  Council  Directive  on  the  control  of  Avian  Influenza  and  for  a  Council 
Decision amending Council Decision 90/424/EEC as regards Community compensation for Avian 
Influenza control measures. 
COM(2006) 13. 
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). 
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 

12 

   EN 

 
 
                                                 
(6) 

International  developments:  The  World  Organisation  for  Animal  Health 
(OIE)  adopted  in  2005  two  international  guidelines22  on  the  subject, 
demonstrating  the  interest  of  the  world  community  in  providing  better 
information and guidance for slaughtering and killing farmed animals.  

that 

food  manufacturers 

(7)  Market-driven  developments:  the  development  of  private  standards  by 
retailers/major 
include  animal  welfare 
requirements have led to the application of higher animal welfare standards 
in several cases. For example, the FCEC study confirms that in the case of 
the 
poultry  retail,  demands  often  exceed  national 
development of gas stunning has been mainly motivated by client demands 
despite  higher  costs.  This  has  been  also  observed  in  the  case  of  pigs.  In 
order  to  reflect  consumer  concerns  on  animal  welfare,  retailers  have 
progressively integrated this dimension in their requirements including for 
slaughterhouses  within  and  outside  the  EU,  indirectly  affecting  third 
countries exporting meat to the EU. 

legislation  and 

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 welfare conditions and impeding innovation 

Directive  93/119/EC  lacks  technical  details  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  stunning  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  development  of  Controlled  Atmosphere 
Stunning  (see  Annexes  VIII  and  X).  Similarly  the  development  of  water  bath 
stunners  using  high  frequency  currents  without  precise  indications  in  the  EU 
legislation  has  led  in  some  Member  States  to  improper  welfare  conditions  as 
highlighted by inspections performed by Commission' experts23. 

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  fixed  equipments  for  restraining  and 
stunning  animals  are  not  always  designed  and  built  in  order  to  take  into 
account the welfare needs of animals, resulting in useless suffering during 

22 
23 

See http://www.oie.int/eng/normes/mcode/en_titre_3.7.htm  
Final report of a mission carried out in France in February 2007 (DG (SANCO)/2007/7330-MR-
final). 

EN 

13 

   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  introduce  a  system  of  pre-approval  of 
slaughterhouses. 

According  to  the  FCEC  study  officials  tend  to  check  welfare  standards 
related  to  the  design  and  facilities  of  slaughterhouses  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 for sick animals, larger passageways 
for sheep and pigs, water supply in lairage facilities, recording device for 
electrical  stunning  apparatus  or  gas  stunning  systems,  constant  current 
stunners and a number of improvements in shackling lines for poultry. 

• 

Responsibilities for animal welfare are not clearly defined 

Operators killing animals have not systematically integrated animal welfare 
as  part  of  their  operational  objectives.  Many  operators  still  rely  on  the 
implement  animal  welfare  standards  with 
official  veterinarians 
unreliable  results.  A  comparable  problem  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 (HACCP24). 

to 

• 

Lack of knowledge of officials and slaughterhouse personnel 

Despite the fact that training on animal 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,  officials  in  slaughterhouses,  mainly  in 
charge  of  controlling  food  safety,  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  little  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 

14 

   EN 

 
 
 
 
 
                                                 
As  regards  slaughterhouses'  staff,  the  study  performed  by  the  external 
consultant  indicates  even  though  the  EU  legislation  requires  training, 
implementation is in practice far from uniform as the text does not specify 
the way it should be done. Meat and 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  supervised  by  the  competent  authorities  (56%  of 
respondents  for  the  red  meat  sector  and  52%  for  poultry).  In  most  of  the 
Member  States  there  is  no  compulsory  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  methods  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 welfare of animals is properly addressed. 

(2)  The  current  legislation  does  not  contain  provisions  for  farmed  fish. 
Scientists  consider  that  many  methods  of  killing  commonly  practiced  are 
not  acceptable  from  a  welfare  point  of  view.  However,  this  problem  will 
not  be  addressed  with  the  present  proposal  for  technical  reasons.  Fish 
present  substantial  physiological  differences  compared  to  terrestrial 
animals.  In  addition  technical  processes  and  economic  organisation  for 
slaughtering  fish  can  not  be  assimilated  to  the  ones  used  for  terrestrial 
animals25. Fish species will be dealt with in a separate initiative later on. 

2.3.4.  Religious slaughter 

The  current  Directive  provides  a  derogation  to  perform  slaughter  without 
stunning  in  case  of  religious  slaughter  (Jewish  and  Muslim  rites)  when  it  takes 
place in slaughterhouses. However Sweden, Lithuania, Latvia and some regions 
of Austria require prior stunning for religious slaughter26. 

25 

26 

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. 
Outside the EU, Norway and Switzerland have not authorised slaughter without stunning. 

EN 

15 

   EN 

 
 
                                                 
NGOs claim that the derogation is abused by some slaughterhouse operators who 
slaughter without stunning in excess to the religious 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 concerns are presently dealt by a specific 
Community Research project called DIAREL28 not yet finalised. Animal welfare 
labelling is also subject to a separate ongoing Commission initiative to determine 
its feasibility. 

As the main objective of the proposal is to take into account the new context and 
technological  developments,  religious  slaughter  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  the  scope  of  the  current  EU  legislation 
adopted  in  1993.  The  principle  of  subsidiarity  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  confirmed  that  further  harmonisation  is 
preferred rather than more subsidiarity. 

Directive  93/119/EC  is  based  on  Article  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 legislation directly affects competition between 
in  particular 
the  different  operators  within 
slaughterhouses  within  the  Community.  It  also  affects  Community  trade  policy 
since  the  measures  apply  to  slaughterhouses  of  third  countries  which  intend  to 
export to the EU.  

internal  market  and 

the 

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 fragmentation of the market concerning the 
equipment used for stunning the animals (see example in Annex X). 

27 

28 
29 

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  requirements  make  the  use  of  hindquarters  practically 
difficult (need to extract the sciatic nerve). In addition some slaughterhouses operators may see the 
slaughtering  of  lambs  without  stunning  faster  to  perform  increasing  their  productivity  and  the 
possible future markets. 
http://www.dialrel.eu/ 
"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 

16 

   EN 

 
                                                 
3. 

OBJECTIVES 

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 uptake of new technological developments 

in relation to stunning and 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/simplification 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 approach to encourage innovation for 

stunning/killing animals;  

(2)  Ensure  a  better  integration  of  animal  welfare  concerns  in  the  production 

process; 

(3)  Ensure  that  the  design  of  slaughterhouses  facilities  or  infrastructures 

respecting the welfare of animals;  

(4) 

(5) 

Increase  the  level  of  competence  of  operators  as  well  as  facilitate  the 
access to technical and scientific information on animal welfare; 

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 general objectives. First of all it improves 
innovation (general objective 2) and simplification by making 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  objective  3)  by  establishing  a  common 
methodology for putting such goods on the EU markets. Finally it by setting up 

30 

31 

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;" 
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 development of production and to facilitate the completion of the internal market in 
animals and animal products;" 

EN 

17 

   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 the EU policy to develop animal welfare 
standards based on sound scientific basis and to encourage innovation. However, 
this  objective  should  avoid  the  possible  increase  in  administrative  costs  and 
favour the principle of subsidiarity as much as possible. 

Specific  objective  2  derives  from  general  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 killing animals (general objective 3). 

Specific  objective  2  is  in  line  with  the  EU  policy  on  food  safety  towards  a 
simplified legislative framework that has been developed in the recent years with 
the adoption of the so-called "hygiene package". Emphasis has been given on the 
responsibilities  of  food  business  operators 
improved  operating 
procedures,  better  training  and  pre-approval  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. 

through 

Specific  objective  3  also  derives  from  general  objective  1  (improving  animal 
protection) since good practices can not performed easily in badly conceived or 
constructed  premises.  But  most  importantly  this  objective  is  important  for 
achieving general objective 3 since upgrading slaughterhouses infrastructures has 
an impact on investments and therefore on establishing a level-playing field for 
slaughterhouse operators. 

Specific objective 3 is consistent with the EU approach of the Hygiene Package. 
This  objective  should  avoid  the  possible  increase  in  administrative  costs, 
especially for small facilities32. 

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  role  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  the  strategy  developed  in  the  Community 
Action  Plan  on  the  Protection  and  Welfare  of  Animals,  which  underlines  the 
importance of better awareness and technical 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 

18 

   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 meeting 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 
Health33. 

4. 

POLICY OPTIONS 

4.1. 

The main policy options 

4.1.1.  The baseline = Do-nothing 

The  do-nothing  option  would  simply  leave  the  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 recognition of possible guidelines 
or self-regulatory codes by the industry and market players. These are no binding 
instruments and provide higher flexibility to operators. Providing guidelines is an 
attractive option as it does not complicate the legal framework. 
Guidelines have been developed at the international level by the OIE34 but their 
practical effects are not assessed. The FCEC study revealed that several retailers 
or  catering  chains  have  been  using  code  of  practices  on  animal  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 slaughterhouses are referring to. 

More specifically this option includes the following sub-options: 

(1)  Voluntary operational standards for slaughterhouses (specific objective 2). 
This option would imply providing a great number of technical parameters 
so  that  nearly  all  types  of  processes  and  techniques  would  be  covered  by 
the guidelines.  

(2)  Voluntary standards for slaughterhouses infrastructures (specific objective 
3).  This  sub-option  will  aim  at  providing  recommendations  related  to  the 
design  of  the  facilities  and  the  equipments  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 killing (specific objective 5). This option 
would  consist  in  providing  specific  technical  recommendations  on  the 
methods that could be acceptable for massive killing. 

33 
34 

The new strategy is available at: http://ec.europa.eu/food/animal/diseases/strategy/index_en.htm 
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 

19 

   EN 

 
                                                 
4.1.3.  Main option 3: Amending the Directive 

This  option  would  consider  revising  the  annexes  without  modifying  the  main 
legal  framework.  The  general  approach  and  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 slaughterhouses (specific objective 2).  

(2) 

(3) 

standards for slaughterhouses infrastructures (specific objective 3). 

standards for massive killing (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  transformations  than  the  previous  option. 
In  particular,  this  option  would  include  modifying  the  legal  nature  of  the  text 
(regulation  vs.  directive)  and  introducing  new  concepts  such  as  welfare 
indicators  or  national  networks  of  reference  for  animal  welfare  (for  discussion 
between Directive and Regulation 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 task, such option would imply a number of 
structural  changes  on  this  approach  (e.g.  establishment  of  a  specific 
administrative  body  or  use  of  an  existing  agency  such  as  the  European 
Food and Safety Authority). An intermediate option would be to authorise 
the European Commission to lay down common rules for the methodology 
while leaving Member States to implement it with more transparency than 
today. 

(2) 

Improving integration of animal welfare in the production process (specific 
objective 2) by the requirement for 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 competent authorities, while leaving more flexibility to 
the  operators  in  the  way  they  could  achieve  those  objectives  (with  the 
possibility for them to adopt guidelines). 

EN 

20 

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(3) 

(4) 

Improving integration of animal welfare in the production process (specific 
objective 2) by the appointment of an animal welfare officer (AWO). This 
measure  consists  of  introducing  an  obligation  for  operators  to  assign  to  a 
specific employee the responsibility for supervising the welfare of animals 
during  the  production  process  (so-called  "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 slaughterhouses employ a quality manager 
for the daily running of their quality system. 

Increase the level of competence of operators (specific objective 4) through 
the  introduction  of  a  requirement  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 animal 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 Member States to set up a national 
centre/network  of  reference  where  officials  and  operators  could  refer  to 
when they need specific technical back 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  the  introduction  of  a  harmonised 
methodology.  This  option  would  introduce  general  principles  to  enhance 
logistical preparedness, animal welfare supervision and transparency on the 
animal welfare performance during killing operations. 

5. 

IMPACTS ANALYSIS 

5.1. 

Identifying the impact/General remarks 

As previously presented the scope of the current legislation covers a wide range 
of activities where slaughterhouses represent the main amount of animals killed. 
Other  activities  are  also  affected  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 sources as presented in the first section 
of this impact assessment (procedural issues). In particular it takes into account 
opinions  expressed  by  stakeholders  and  Member  States  which  have  been 
consulted on various occasions and through a complementary questionnaire at a 
later stage of this work. 

EN 

21 

   EN 

 
The main impacts that have been identified 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 options, in particular (1) introduction of 
an  animal  welfare  officer  in  slaughterhouses  (2)  increased  training 
requirements for slaughterhouse employees (3) adaptation to infrastructure 
of  slaughterhouses  (4)  new  authorisation  process  for  new  stunning/killing 
methods  (5)  setting  up  Standard  Operating  procedures  and  monitoring 
requirements 

Costs  for  authorities  related  to  the  authorisation  of  new  stunning/killing 
methods, establishing and running a system of certificate of competence for 
personnel handling animals at slaughterhouses; setting up national centres 
of  reference;  producing  a  report  on  animal  welfare  results  during 
operations of massive killings (for disease control). 

Indirect  impacts  on  the  retail  price  of  meat  products  -  based  on  the 
conclusions of the FCEC study, no significant impact on price 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  limited  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 analysed 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 

22 

   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  delivered  only  limited  information  on  financial 
impacts.  Generally  stakeholders  (both  industry  and  competent  authorities) 
claimed that estimation was very difficult or even impossible for them. 

The  costs  to  comply  with  the  Regulation  are  perceived  by  industries  as  much 
higher  than  administrative  costs,  and  therefore  some  of  them  focused  their 
answers on assessing compliance 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  current  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 experience at national level and/or from 
similar  policy  areas  and  by  basing  calculations  on  a  number  of  assumptions 
where appropriate.  

5.2. 

Analysis of the baseline scenario 

5.2.1.  General remarks on the baseline scenario / qualitative 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; New slaughterhouses are often approved by 
the  authorities  without  consideration  for  the  welfare  of  the  animals;  Personnel 
slaughtering animals are not always qualified for their tasks and the efficiency of 
stunning  is  not  regularly  assessed  on  the  animals.  Officials  in  charge  of 
controlling animal welfare in slaughterhouses have not enough time and limited 
skills  to  perform  adequately  their  responsibilities.  Research  and  innovation  on 
animal  welfare  at  slaughter  is  sometimes  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 encouraged by maintaining the status quo. 

Differences  in  welfare  standards  between  Member  States  have  been  noticed, 
creating distortion of competition between operators. 

EN 

23 

   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 individually 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  Directive.  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  Member  States  grant  authorisation  for 
new stunning methods. However this situation has up to now delivered unequal 
welfare  outcomes 
the 
commercialisation of positive innovations for the welfare of animals. 

the  EU  while  creating 

technical  barriers 

to 

in 

This could be illustrated by the emergence of the use of high frequency electrical 
stunning  for  poultry  where,  some  Member  States  have  established  clear 
indications  while  other  competent  authorities  have  left  local  inspectors  without 
instructions. Annex XIII provides an illustration of the impacts on innovation of 
the  baseline  scenario  in  the  specific  case  of  controlled  atmosphere  stunning  of 
poultry (CAS). 

Concerning  a  better  integration  of  animal  welfare  concerns  in  the  production 
process, the current rules require 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  operators  to  develop 
their  own  knowledge  and  operational  procedures  with  the  present  legislation. 
Despite  voluntary  approaches,  this  makes  outcomes  heavily  dependant  on  the 
level  of  initiatives  and  resources  of  the  slaughterhouses  and  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 Member 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  the  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. farms for fur animals, hatcheries, etc.). 

Regarding the design of slaughterhouses, the present EU legislation provides for 
certain  requirements  that  are  not  in  line  with  new  knowledge  and  upgrading  is 
necessary.  In  addition  the  readability  of  the  Directive  is  presently  poor  on  this 
aspect: structural requirements are disseminated among operational ones making 
the implementation by the competent authorities uneven. 

EN 

24 

   EN 

 
Staff competence in slaughterhouses is critical for the welfare of live animals and 
there  is  little  evidence  that  market  pressure  will  increase  alone  the  training  of 
employees  handling  and  killing  animals.  Nowadays  those  tasks  are  physically 
demanding  and  often  performed  by  staff  with  little  educational  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 initiative 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 welfare 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 means to perform tasks with little regard to 
animal  welfare  issues.  Commission  experts  have  found  that  in  some  Member 
States,  some  methods  of  killing  have  been  widely  used  without  being 
scientifically  assessed  from  a  welfare  point  of  view.  This  does  not  necessarily 
mean that those methods should be rejected but questions the approach taken by 
each  Member  State.  Killing  for  disease  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  situation  where  massive  killing  could  be 
performed without necessarily enough consideration for the welfare of animals. 
This  in  return  could  lead  to  serious  resistance  on  certain  aspects  of  the  animal 
health Community policy (eradication of animal disease through 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  the  part  represented  by  the  process  where 
live animals are treated in a slaughterhouse is currently limited. 

As  regards  the  red  meat  industry,  costs  related  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  stunning  techniques  (see  Table  1).  As 
indicated, costs were relatively evenly spread between the reception of animals in 
lairage,  and  the  operations  of  restraining,  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 

25 

   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 duties, 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 any event, the welfare requirements for 
animals  at  slaughter  equally  apply  to  slaughterhouses  in  third  countries  which 
guarantee a level-playing field. 

Table 1: Allocation of costs in the slaughterhouse 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  and  installation  costs  are 
significantly  different  between  waterbath  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  costs  between  these  two  major  stunning 
techniques.  While  running  costs  for  electrical  stunning  are  considered  as 
negligible by the industry (1€/1000 birds) , it is more expensive 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 are partly compensated by a number of 
direct or indirect benefits (greater throughput, increased meat quality and yield, 
less labour and better working conditions). 

EN 

26 

   EN 

 
 
Table 2: Allocation of costs in the slaughterhouse 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  main  threats  that  are  higher  domestic 
production costs (feed) and compliance costs with the EU legislation. There is a 
perception  within  the  industry  that  slaughterhouses  in  some  third  countries  are 
less likely to invest in controlled atmosphere stunning due to a lack of access to 
credit  and  a  relatively  uncertain  economic  environment.  However  it  should  be 
noted that up to now progress towards better welfare standards in this sector has 
been significant and due to market pressure. 

Indirect costs: relationship 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 negligible compared to the wholesale value 
of  the  meat  and  it  is  estimated  that  gas  stunning  would  only  contribute  to  an 
additional 0.1% of this value. Those figures do not take into account the fact that 
the wholesale price does not include other costs (further processing, distribution, 
and retailers' margins) which can constitute 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 figures previously mentioned. The same would 
apply for poultry meat. The total costs related to the slaughterhouses represented 
approximately  1/3  of  the  final  costs  (ranging  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 
37 

Figures of this paragraph come from the FCEC study. 
Based  on  a  specific  estimate,  the  consultant  calculated  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 

27 

   EN 

 
 
                                                 
Comparison of meat price indices level in 200638 does not indicate that there is a 
visible  correlation  between  welfare  stunning  techniques/standards  and  meat 
prices.  France,  Italy,  Germany  and  the  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  only  imposes  compliance  costs.  There  are  no 
administrative costs as there is no information obligation listed in the Directive. 
Private operators only have to comply with technical rules without the need for 
registration, reporting or paperwork of any kind. 

However,  as  the  present  text  is  a  Directive,  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 the food safety legislation which causes 
administrative costs both for the private and public sectors (see box below on the 
Hygiene  package).  Furthermore  in  several  Member  States,  the  programmes  for 
internal  audits39,  as  required  by  Regulation  (EC)  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  into  the  hygiene  package,  a  number  of 
administrative  requirements  are  applicable 
to  slaughterhouses.  They  are 
described  in  Regulations  (EC)  No  852/2004  and  No  853/2004.  From  an 
administrative  point  of  view  they  imply  for  slaughterhouses  the  following 
obligations40: 

– 

– 

– 

being registered and approved by the competent authorities, 

establishing HACCP procedures, 

providing 
information), 

information  on 

the  origin  of 

the  animals  (food  chain 

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 

39 
40 

Statistics  in  focus  Economy  and  Finance  90/2007,  Comparative  price  levels  in  37  European 
countries for 2006. 
Article 4 (6) of the Regulation requires competent authorities to perform internal audits. 
We  have  listed  here  only  the  administrative  requirements  that  relate  to  live  animals  in  a 
slaughterhouse. 

EN 

28 

   EN 

 
                                                 
– 

– 

– 

management of the registration and approval procedures of slaughterhouses 
(among other food producing establishments), 

audits of HACCP procedures and good hygiene practices, 

performance of specific official controls including on animal welfare, food 
chain information and ante-mortem inspection. 

Although the Hygiene package is relatively new and started to apply from 2006, 
it should be underlined that some administrative 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 quality 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  total  238.9  million  pigs  were  slaughtered  in 
2005, these figures suggest total 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  muscle  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 purely due to better handling in the 
slaughterhouses. 

Similar gains can be had for the beef industry. US data indicates 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 slaughtered 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  increase  bruising;  bruising  can  occur  at  all 
phases of production, including after 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 meat originates from Brazil 
and Argentina. The EU has become a net importer  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 nearly no importations of pig meat with only 
14.000 tonnes in 2005 representing less than 0.1% of the EU production. 

41 

PSE stands for Pale Soft Exsudative and DFD for Dark Firm Dry. 

EN 

29 

   EN 

 
                                                 
Concerning  poultry,  the  import  data  show  that  the  EU  has  been  increasingly 
importing cuts and prepared poultry meat (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 standards 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 authorities signing the veterinary export 
certificates 
these 
slaughterhouses  are  regularly  visited  by  Commission's  experts  who  verified  the 
implementation  of  the  different  Community  rules  applicable  to  them  including 
welfare ones. 

(Article  15  of  Directive  93/119/EC). 

In  addition 

In  practice,  in  third  countries  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  legislation  on  animal  welfare  at  slaughter.  Equally, 
South  American  main  beef  meat  exporters  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  have  been  increasingly 
sensitive to animal welfare issues and they  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 affect 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 gas stunning of poultry 
is increasing welfare (no shackling of live birds) while providing better working 
conditions  for  employees.  Better  training  on  animal  welfare  is  likely  to  lead  to 
calmer animals, more efficient stunning and lower number of work accidents. 

5.2.4.  Environmental impacts 

No  major  direct  impact  of  the  baseline  scenario  was  identified  on  the 
environment  (in  terms  of  air  quality,  energy  use  or  CO2  emissions)  in  relation 

42 

EN 

This was recently the case in the 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 
schools.  See 
supplying 
http://www.hsus.org/farm/news/ournews/undercover_investigation.html 

federal  program 

food 

firm 

the 

for 

for 

30 

   EN 

 
                                                 
with the different stunning and bleeding techniques. However, there are possible 
minor  indirect  negative  impacts  on  the  environment  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  between  environmental  aspects  and  the 
improvement of meat quality due to better animal welfare, which may affect the 
quality  and  durability  of  meat.  Slaughterhouses  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  contribute 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 particular 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 practice by the operators. 

Providing  EU  recommendations  could  therefore  fill  this  gap  and  in  particular 
contribute to partially achieve the following main objectives: 

(1) 

(2) 

improving animal protection at slaughter (main objective 1), 

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 factors (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  recommendations  could  improve  the  following 
technical dimensions: 

(1) 

(2) 

animal welfare operational standards (specific objective 2); 

structural design of slaughterhouses (specific objective 3); 

43 

Chambers,  P.,  Grandin,  T.,  (2001)  Guidelines  for  humane  handling,  transport  and  slaughter  of 
livestock. FAO publication, page 5. 

EN 

31 

   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  unaddressed  (approval  of  new  stunning  methods, 
competence of staff). The level of achievement 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  slaughterhouses  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-playing field for the different operators. 

However  since  it  will  make  available  a  number  of  technical  references  for 
improving  welfare,  it  could  certainly  contribute  to  improve  the  situation  in 
particular  as  regards  animal  welfare  and  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  increased  harmonisation  is  necessary  as 
regards the protection of animals at slaughter. Killing animals is a non-negotiable 
matter  where  a  minimum  should  be  provided  and  guaranteed.  Providing  non-
biding  instruments  would  therefore  be  well  perceived  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,  difficulty  in  recruiting  people,  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 operators 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 (main 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 

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would  be  easy  and  straightforward  to  implement  for  officials  and  would  be 
legally secure, defining precisely which methods are in compliance or not. 

However,  this  approach  would  also  bring  drawbacks  as  it  will  increase  the 
complexity  of  the  legal  text.  Many  species  are  concerned  (six  main  farmed 
species) and for each species different methods 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  specific  process.  In  some  situations, 
different combinations of parameters44 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  comprehensive  set  of  technical  rules,  it  will 
ensure a level playing field for the operators (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) 

(2) 

(3) 

It would contribute to a better integration of animal welfare in the process 
of production (specific objective 2); 

It would improve the design of slaughterhouses (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 approval 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. 

It would improve the protection during 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 personnel or in equipment, etc.). 

Therefore this option "Amending the directive" will not address innovation (main 
objective  2)  and  will  not  contribute  to  simplification.  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  compliance  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 requirements 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. 

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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  operational  standards  were  not  possible  to 
evaluate  precisely  since  they  will  depend  on  the  final  parameters  adopted.  But 
due  to  the  diversity  of  parameters  observed  in  certain  techniques,  establishing 
precise  operational  standards  would  certainly  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.  Changes  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  compulsory  through  more  restrictive  national 
legislation. 

According  to  the  FCEC  study  those  measures  are  considered  by  most 
respondents of the red meat sector to be slightly to fairly 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  significant  compared  to  the  overall  investment 
cost  for  a  slaughterhouse,  especially  if  implemented  at  the  construction  phase. 
Impact on competitiveness was also discussed and most respondents considered 
that those investments were positive for their competitiveness since they expect 
economic  returns  because  of  improved  meat  quality  and  better  adequation  with 
customers' demand.  

Regarding the poultry sector, the FCEC study 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). 

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Figure 2 – Additional technologies implemented 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 consider 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  appropriate  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  chain45.  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  technical  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 expensive 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. 

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Following a specific questionnaire to the Member States on the issue, only seven 
provided responses. Most of them declared to use only authorised methods. On 
the  other  hand,  the  ones  that  have  used  other  methods  consider  that  a  lack  of 
flexibility  in  the  legislation  would  have  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 eradication of diseases outbreaks. 

5.4.3. 

Social impacts 

Detailed  and  prescriptive  legislation  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 welfare 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: reorganising the EU legislation 

5.5.1.  Achieving the objectives 

This option would address all the main and specific objectives 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  encourage  innovation  (main  objective  2)  and 
create  the  opportunity  for  establishing  a  level-playing  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 food safety legislation ("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  encourage  innovation  could  be  developed 
(specific objective 1) 

A  better  integration  of  animal  welfare  in  the  production  process  (specific 
objective  2)  could  be  envisaged  through  the  introduction  of  standards 
operating  procedures  (SOPs)  and  the  requirement  of  an  animal  welfare 
officer (AWO). 

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• 

• 

• 

Design of slaughterhouses could be also improved (specific objective 3) by 
a more traditional approach (as for amending the Directive); 

Competence of personnel in slaughterhouses could be ascertained through 
the requirement of a certificate of competence (specific objective 4) as well 
as  by  the  establishment  of  national  centres  of  reference  as  to  provide 
technical support for officials. 

A  methodological  approach  could  be  established  for  massive  killing 
(specific objective 5). 

More  specifically  here  are  how  some  specific  measures  attached  to  this  option 
could affect the completion 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 and within a species, different types of 
animals are slaughtered. Parameters to stun them depend on their 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  limited  compared  to  the  overall  duration  of 
the production process. Therefore it is better to ensure that operators design and 
put  in  place  their  own  quality  system  instead  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  objectives  set  up  by  the  legislation,  while 
providing  official  authorities  a  way  to  supervise  and  audit  operators  quality 
system  instead  of  focusing  on  technical  details.  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 some 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  level  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  would  be  to  ensure  that  competence  is 
assessed  independently  and  that  any  person  having  a  certificate  possesses  a 
common technical knowledge to carry out his/her tasks properly. In addition this 
would simplify the task of inspection performed by officials at slaughterhouses. 
This measure is already implemented in the UK in red-meat slaughterhouses with 
success. 

EN 

37 

   EN 

 
It  creates  a  level-playing  field  for  all  slaughterhouse  employees  (main 
objective 3)  contrary  to  the  present  situation  where  national  requirements  on 
training is far from being uniformly implemented 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. Indeed 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 back-up in their inspections tasks. 

A national centre of reference would have the advantages of providing support to 
slaughterhouse inspectors for any technical or scientific aspects on the welfare of 
animals at slaughter. In particular this would include the assessment of complex 
restraining  or  stunning  equipments  or  technical  parameters,  as  well  as  other 
possible related tasks such as ensuring the accreditation of bodies delivering the 
certificate of competence. 

It can be concluded that this measure will contribute to improve animal welfare 
(main objective 1) and encourage innovation (main objective 2). 

Methodology for massive killing 

This measure would emphasize legal requirements on a number of principles to 
be  respected  rather  than  precise  technical  figures.  For  example  at  present, 
contingency plan to eradicate disease do not require any information on animal 
welfare  consideration  at  killing 
(stunning  methods,  etc.).  Harmonised 
methodology  would  imply  better  transparency  on  the  preparedness  of  the 
authorities to control outbreaks 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  authorities  while  ensuring  a  better  level  of 
supervision  on  animal  welfare.  Another  advantage  of  requiring  a  reporting  on 
animal welfare would be to promote good initiatives in this domain. Outbreaks of 
contagious diseases are relatively unusual events within the Community and not 
all  Member  States  have  gained  practical  experience  in  killing  large  number  of 
animals. Therefore better reporting on animal welfare on those occasions would 
also help in promoting solutions for future outbreaks taking place 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 

38 

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Scientific  assessment  on  animal  welfare  at  slaughter  already  exists  through  the 
EFSA  opinions.  However,  the  current  work  of  the  EFSA  on  animal  welfare 
consists  in  gathering  information  already  published  on  specific  questions.  A 
centralised  approach  would  therefore  require  a  different  type  of  work  which 
would be the examination of specific application like the ones presented for food 
additives or medical drugs. This option would 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  allowed  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  authorities  could  assess  whether 
the  methodology used  is  sufficiently robust and reliable and during this period, 
the applicant could gain experience and refine its method on a commercial scale. 
After an adequate period the method would 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 for the design of slaughterhouses (see 
option 3)  

Requirement  for  Standard  Operating  Procedures  and  Animal  Welfare 
Officer 

From  the  external  FCEC  study,  it  appears  that  in  the  red  meat  sector,  the  large 
majority  of  slaughterhouses  respondents  had  put  in  place  animal  welfare 
procedures  through  client  requirements  (70%)  and  had  their  own  code  of  good 
practice  (61%).  In  particular  this  includes  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 responsible for animal welfare (see below 
animal  welfare  officer).  Those  two  initiatives  were  perceived  as  the  most 
beneficial  for  animal  welfare  by  the  respondents.  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 plan and an animal 
welfare officer were not considered costly and even considered by the majority 
of  respondents  as  having  a  fairly  or  significant  positive  impact  on  the 
competitiveness of their operations. 

EN 

39 

   EN 

 
The  FCEC  study  revealed  similar  figures  for  the  poultry  sector  (69%  of  the 
respondents  had  their  own  code  of  practice  on  animal  welfare)  but  a  higher 
proportion of respondents have implemented animal welfare procedures. Quality 
assurance plan for animal welfare and animal 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 respondents considered quality assurance plan as no costly or 
slightly costly (80%). 

Disadvantages  possibly  raised  by  this  option  have  been  pointed  out  during 
stakeholders'  consultation,  following  the  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  concerned  by  possible  excessive  bureaucratic 
requirements.  Therefore,  the  Commission  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 exempted from the requirement to report on 
it as this proofed disproportionately burdensome 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. Additional costs related to the extension of 
SOPs  for  animal  welfare  will  only  affect  slaughterhouses  that  have  not  yet 
implemented  such  policy  (the  FCEC  survey  indicated  that  between  60-70%  of 
the respondents had already implemented such policy anyway). This means that 
the 
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 development 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). 

responsibility  would  probably  affect 

increased 

less 

Figure  1:  Assessment  of  costs  of  operational  measures  and  procedures  by 
slaughterhouses operators (red meat) 

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40 

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Similar conclusions could be drawn as regards the impact related to the Animal 
Welfare Officer. 

According to the FCEC study, most respondents had implemented measures for 
having an "animal welfare officer" in their plant (61% in the red meat sector and 
more than 70% in the 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 additional costs are to be expected in those countries. 
For other countries, it should be highlighted that in practice this would not mean 
that a new person would have to be employed  as  the  additional  animal  welfare 
surveillance  could  be  covered  by  the  person  in  charge  of  general  quality  meat 
control.  Responses  from  Member  States  indicate  that  this  task  could  represent 
10 to 20% of the time of a full-time employee. 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  FCEC  study  has  indicated  that  most 
respondents  of  slaughterhouses  would  combine  AWO  with  SOPs.  It  is  in  fact 
logical  since  having  procedures  to  deal  with  animal  welfare  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  this  case  reference  to  common  guidelines 
could be a solution (as foreseen in the Hygiene package). 

– 

Certificate of competence 

Training  does  involve  costs.  For  example  in  Germany,  a  4-hour  external 
training  course  provided  by  specialists  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 from 126 to 630€ per participant. 

However,  the  majority  of  respondents  of  the  FCEC  study  considered  that 
the  cost  of  their  training  measures  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 (resulting 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 

41 

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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 
training  measures  and 
occupational safety; better trained personnel may lead to less stressed and 
calmer animals that are easier and safer to work with. 

likely  positive  correlation  between 

– 

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  were  essentially  related  to  research 
and  development  costs  and  no  distinction  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  included).  It  is  almost  impossible  to 
disentangle  which  parts  of  the  preparatory  work  for  authorisation  are 
research and developing costs that would have been done in any event by 
business  e.g.  for  marketing  purposes  and  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 for each technique are limited to three 
companies)  and 
techniques  will  be  relatively 
exceptional  (today's  methods  will  continue  to  be  authorised  without 
specific authorisation process).  

innovation  for  new 

It should be noted that in any case 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  slaughter  but  there  is  not  a  formalised 
organisation  that  could  be  compared  to  this  sub-option  at  the  moment.  It 
would  be  therefore  misleading  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 recognising the roles of already existing 
structures  and  experts.  Therefore  certain  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 

42 

   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  research  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 400.000 euros a year for a similar size 
Member State (UK) if nothing is in place. 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 advantage of providing a clear visibility 
to  officials  and  slaughterhouses  operators  on  where  to  refer  to  on  when 
questions  on  animal  welfare  at  slaughter  are  raised,  instead  on  relying  on 
informal network. Such centre would also provide higher legitimacy to the 
officials  working  in  the  field  while  ensuring  better  harmonisation  at 
national level. 

–  Massive killing methodology 

On  the  negative  side,  requesting  more  requirements  on  animal  welfare 
could be considered by certain Member States as additional technical and 
administrative  constraint  and  especially if  reporting  is  requested.  There  is 
no evidence that better animal welfare preparedness and supervision would 
entail higher costs. Good welfare measures relates mainly to good logistical 
preparedness and not necessarily to costly techniques. In addition, Member 
States  have  increasingly  integrated  animal  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 

43 

   EN 

 
 
 
 
                                                 
 
Administrative  costs  generated  by  such  measure  will  depend  to  a  large 
extent  to  the  current  practices  presently  in  place  in  the  Member  States. 
From  the  data  collected  by  the  Commission,  this  option  is  already 
implemented  in  some  Member  States  where  competent  authorities 
performed veterinary supervision and reporting on animal welfare for every 
cull47. It is the case for the UK, Netherlands, Czech Republic and is under 
development  in  Sweden  and  Germany.  Since  killing  animals  in  case  of 
outbreaks is not a regular activity, reporting costs may vary depending on 
the size of the killing performed. From data collected in one major Member 
State  this  would  require  the  development  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  controls  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 the UK, Germany and Lithuania. It is 
also required by the legislation on the welfare of animals during transport. 
The  main  disadvantage  of  such  measure  is  to  request  the  examination  of 
existing working staff, requesting an important administrative task for both 
the industry and the public sector during the first years of implementation 
of  the  legislation.  In  the  case  of  transport,  the  implementation  phase  was 
extended  to  three  years  but  according  to  the  data  collected  by  the 
Commission  a  longer  period  would  be  probably  more  appropriate  (i.e.  5 
years). 

Based  on  the  UK  experience  for  issuing  a  certificate  of  competence  for 
slaughterman, the administrative costs charged 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  expenses.  Despite  the  fact  that  up  to  now,  no 
formal  system  was  established  and  therefore  no  official  request  was 
processed, public authorities considered that main 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 

44 

   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 regarding purely administrative costs, as 
today  new  methods  are  very  often  evolving  from  research  programs  for 
which administrative costs have not been separated from R& D and other 
costs.  One  Member  State 
the  costs  are  currently 
indicated 
approximately between 6.000 and 15.000 Euros per authorisation48. These 
costs are recovered via fees to operators. 

that 

5.5.3. 

Social impacts 

Main  social  impacts  are  related  to  the  positive  public  perception  in  improving 
welfare standards. This perception would derive from all the measures included 
in  this  package  (such  as  SOPs,  AWO,  better  design  of  slaughterhouses, 
certificate  of  competence  for  personnel,  establishment  of  national  centre  of 
reference). 

However if the requirement for AWO was 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 animals, 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  measure  will  provide  employees  better 
skills for preventing them having accidents with animals; 

Animal  welfare  officer:  this  measure  will  increase  the  likelihood  to 
moderate the possible excess of cadence requested by the line managers; 

Standard  Operating  Procedures:  this  measure  will  increase  their  ability  to 
control  the  process  and  reduce  their  risk  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 States. In addition, we have calculated in 
some  cases 
for 
total  costs  of 
business/Member States.  

the  different  measures 

the  estimated 

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 

45 

   EN 

 
 
                                                 
These  calculations  are  based  on  estimates  from  the  FCEC  study  on  the 
percentage  of  market  operators  that  do  not  currently  comply  with  the  measures 
envisaged  and  would  therefore  need  to  adapt.  These  estimations  may  be 
underestimated  as  it  is  likely  that  the  respondents  to  the  FCEC  study  are  in 
majority operators with well-advanced practices on animal welfare.  

In addition, it should be reminded that there are important 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  uncertainty  behind  some  of  the 
figures provided in the questionnaires' responses. 

Additional  economic  figures  used  for  the  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 costs 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  estimated  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  one  fifth  of  these  employees  work  in 
slaughterhouses  and  are  in  charge  of  the  treatment  of  live  animals,  we  have 
considered roughly the figure of 120 000 employees to extrapolate and calculate 
training costs. 

EN 

46 

   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 
slaughterhouses 

in 

31-40%  of  slaughterhouses  i.e.  less 
than 6000 establishments (2/3 are small 
scale establishments)  

Monitoring  the  efficiency  of 
procedures 
killing/stunning 
(Standards 
Operating 
Procedures - SOPs) 

Increased 
slaughterhouse employees 

training 

of 

30-40%  of  slaughterhouses  concerned 
i.e.less than 6000 establishments in the 
EU 

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 

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  certainly  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)  

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.  

Approx.  200  Euros/participant/year  (high  estimation  based  on 
German  experience)  plus  costs  for  certificate  of  competence  (25 
Euros/application) i.e. a total of 225 Euros 

13.8-27.6 mio Euros per year 

20.7 mio Euros per year  
It  should be highlighted  that most of  these 
costs  are  already  included  in  the  costs  of 
AWO 

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 

slaughterhouses 
the 
20-50% 
depending on the type of infrastructure 

of 

Costs would be absorbed by the amortisement of equipment of 10-
15 years (transitional period in the legislation) 

- 

Authorisation 
stunning/killing methods  

of 

new 

are 

authorisations 

New 
relatively 
exceptional  –  between  2-5  per  year  – 
equipment 
and 
manufacturers 

apply 

only 

to 

6.000-15.000  Euros  per  authorisation  (fees 
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. 

to  be  paid 

savings 

12.000  –  75.000  euros  per  year  maximum 
for  submitting  applications.  This  figure 
for  operators  as 
represents 
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 

47 

EN 

 
  
Qualitative description 

Quantitative description 

Monetised value 

Estimated total costs in the EU 

FOR PUBLIC AUTHORITIES 

Setting  up  national  networks 
of reference 

Production  of  a  report  on 
conditions 
animal  welfare 
during  operations  of  massive 
killings 

Establishing  and  running  a 
of 
of 
system 
competence 

certificate 

Authorisation 
new 
stunning/killing  methods  (at 
EU level) 

of 

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 

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) 

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  costs  (partly  recovered  via  a  fee) 
estimated at 25 Euros/application 

2,5 mio Euros 

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.  

to 

are 

only 

apply 

authorisations 

New 
relatively 
exceptional  –  between  2-5  per  year  – 
and 
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. 

EN 

48 

EN 

 
  
 
6. 

COMPARING 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 

Encouraging innovation 

Level playing-field 

Simplification 

Economic impacts 

Costs for businesses 

Costs for SMEs 

Costs for authorities 

Meat quality 

Trade from third 
countries 

Meat retail prices 

Social impacts 

Public perception 

Occupational safety 

Environmental impacts 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0/+ 

0 

0/+ 

0 

0 

0 

0 

0/+ 

0 

0 

0 

0 

0 

+ 

0 

++ 

0 

- 

- 

0 

+ 

0 

0 

+ 

+ 

0 

++ 

+ 

+ 

+ 

- 

- 

- 

++ 

0 

0 

++ 

++ 

0 

(--) 

(+/-) 

very negative impact, (-) negative impact, (0) no impact, (+) positive impact, (++) very positive 
impact  
the situation will depend on the national context. 

The  comparison  between  the  different  options  in  the  light  of  the  different 
objectives  makes  clearly  more  advantageous  to  reorganise  the  legislation 
(option 4) while amending the directive  (option 3) would bring limited benefits 
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  considered  interesting  as  a 
complementary instrument. 

EN 

49 

   EN 

 
 
 
 
 
 
 
 
 
 
 
 
 
Option  2  would  in  particular  contribute  to  improve  animal  protection  and  meat 
quality.  It  could  also  contribute  to  establish  a  certain  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  benefits  than  amending  the 
directive (option 3) as regards 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  standards  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 likely 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 options 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 components) of option 3 indicates that the 
three components of this option have a different effect on each areas. 

Upgrading  slaughterhouse  infrastructure  has  a  potentially  important  negative 
impact on businesses due to the need for certain operators for investing on new 
infrastructures  and  equipments.  However  this  effect  can  be  mitigated  by 
transitional period. 

Imposing  operational  standards  through  a  prescriptive  approach  has  mainly  the 
disadvantage of being complicated 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 simplification. 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 

50 

   EN 

 
Table 4 – Summarising the impacts of the components of the option "Amending the 
directive" 

Impacts/ Options 

Main objectives 

Animal protection 

Encouraging innovation 

Level playing-field 

Simplification 

Economic impacts 

Costs for businesses 

Costs for SMEs 

Costs for authorities 

Meat quality 

Trade from third 
countries 

Meat retail prices 

Social impacts 

Public perception 

Occupational safety 

Environmental impacts 

Upgrading 
slaughterhouses 
infrastructure 

Operational standards 
for slaughterhouses 

Standards for massive 
killing 

+ 

0 

++ 

0 

-- 

-- 

0 

+ 

0 

0 

+ 

++ 

0 

+ 

0 

++ 

-- 

- 

- 

0 

+ 

0 

0 

+ 

0 

0 

+ 

0 

0 

-- 

0 

0 

- 

0 

0 

0 

+ 

0 

0 

(--) 

(+/-) 

6.3. 

very negative impact, (-) negative impact, (0) no impact, (+) positive impact, (++) very positive 
impact.  
the situation will depend on the national context. 

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 authorising new stunning methods, is likely 
to  encourage  innovation  (objective  2).  The  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 

51 

   EN 

 
 
 
 
 
 
 
 
 
 
Most measures will also contribute to ensure 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  establishment  of  a  common  methodology  for 
new stunning methods. This last component will positively affect the conditions 
of competitions of manufacturers of stunning equipments. 

Most  measures  have  little  impact  on  simplification.  Certificate  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 beneficial in simplifying the 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  implemented  the  proposed  measures  (better 
infrastructures,  SOPs,  AWO  and  in  some  Member  States,  certificate  of 
competence) which will limit the negative effects 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  competence)  or  possible 
exemption justified by the size 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  requirements.  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  legislation  without  creating  substantial 
administrative  costs  for  the  authorities.  Therefore  there  is  no  reason  to  believe 
that those requirements would be bring heavy costs while 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  regards  the  public  perception  of  the  meat 
production. Positive image of the meat, has also positive economic effect for the 
sector. 

Occupational  safety  is  also  positively  affected  by  most  of  the  components 
presented. Better design of slaughterhouses, existence of SOPs and better trained 
personnel contribute significantly to ensure that slaughterhouses are a safe place 
for workers. 

EN 

52 

   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 

Level playing-field 

Simplification 

Economic impacts 

Costs for businesses 

Costs for authorities 

Meat quality 

Social impacts 

Public perception 

Occupational safety 

Environmental impacts 

+ 

++ 

++ 

+ 

+ 

- 

0 

0 

0 

0 

+ 

0 

++ 

0 

-- 

0 

+ 

+ 

++ 

0 

++ 

0 

+ 

+ 

0/- 

0 

++ 

0 

++ 

0 

++ 

0 

+ 

0 

0/- 

0 

+ 

++ 

+ 

0 

++ 

0 

++ 

- 

0/- 

+/- 

+ 

++ 

++ 

0 

++ 

++ 

0 

0 

0 

+/- 

+ 

++ 

0 

0 

++ 

+ 

0 

0 

0 

+/- 

0 

++ 

0 

0 

(--) very negative impact, (-) negative impact, (0) no impact, (+) positive impact, (++) very positive impact.  
(+/-) the situation will depend on the national context. 

EN 

53 

EN 

 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
7. 

MONITORING AND EVALUATION 

The  general  monitoring  of  the  legislation  on  animal  welfare  is  included  in  the 
Regulation  (EC)  No  882/2004  on  official  controls  of  food  and  feed49.  This 
the 
the  Member  States 
Regulation  foresees 
requirements  of  the  food  legislation  including  those  on  animal  welfare.  The 
Commission (Food and Veterinary Office) controls the correct implementation of 
EU legislation in the Member States.  

implement  efficiently 

that 

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 specific 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 animals51. 

However  from  experience  with  other  animal  welfare  legislation,  harmonising 
reporting  from  the  Member  States  is  a  complex  issue  and  comparability  of  the 
data  is  often  critical.  In  addition  it  generates  administrative  burden  for  the 
Member States while providing data that are 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 Commission experts remain the 
most reliable and specific source of information on the subject. In addition, the 
frequency  of  controls  is  relatively  high52  and  provides  adequate  indications  on 
the  level  of  compliance  with  the  legislation.  Finally  Commission  experts  have 
performed specific exploratory missions on animal welfare on subjects for which 
there were no detailed provisions in the current 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  regular  external  studies  as  to  evaluate 
every  five  years  not  only  the  welfare  dimension  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 issue 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 depending on the gravity of the issues to 
change.  This  evaluation  could  be  part  of  a  comprehensive  evaluation  of  the 
animal welfare policy. 

49 
50 

51 

52 

OJ L 165, 30.4.2004, p. 1–141. 
See the review published in 2004:   
http://www.defra.gov.uk/animalh/welfare/farmed/slaughter/awr03.pdf  
Report GAO 04-247 http://www.gao.gov/new.items/d04247.pdf and more recently GAO 08-686T 
http://www.gao.gov/new.items/d08686t.pdf  
Usually Commission's services would control Member States on animal welfare at slaughter at not 
less than every five years. 

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8. 

CONCLUSION 

From  the  comparison  of  the  main  policy  options  envisaged  it  appears  that 
reorganising  the  legislation  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 knowledge of officials etc.). 

Regarding  the  question  of  authorisation  of  new  stunning  methods,  the  present 
system is clearly not satisfactory. It gives 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  alternative  but  a  partially  decentralised 
system would have some benefits. Some Member States have invested resources 
to support innovation and good welfare standards while bringing other social and 
economic benefits. National structures are also more available and more reactive. 
A partially decentralised system should therefore be also considered. 

Better  integration  of  animal  welfare  in  the  process  of  production  brings  clear 
positive  outcomes  for  the  welfare  of  animals,  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  while  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 could be reduced if a reasonable transitional 
period is considered. 

Better  competence  of  personnel  killing  animals  as  well  as  setting  up  specific 
national structure for providing technical back-up on animal welfare for officials 
appear  to  be  two  complementary  approaches.  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  for  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  preparedness,  better  supervision  and  better  reporting 
would  also  increase  credibility  of  official  services  and  their  sub-contractors 
dealing with those issues.  

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55 

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ANNEX I - List of main organisations and companies consulted 

Name 

Type of organisation 

Geographical 
base 

Anglia-Autoflow 

Animals Angels 

AVEC 

Butina 

CIWF 

Equipment manufacturer 

EU/UK 

Animal welfare organisation 

Poultry meat industry 

EU 

EU 

Equipment manufacturer 

EU/Denmark 

Animal welfare organisation  

EU 

COMPACT EUROPE 

Equipment manufacturer 

Belgium 

COPA-COGECA 

Farmers 

EUROGROUP FOR ANIMALS 

Animal welfare organisation 

European Fur Breeders Association 

Fur industry 

Federation of Veterinarians of Europe 
(FVE) 

Veterinarians 

Finnish fur breeders association 

Fur industry 

FNICGV 

Red meat industry 

EU 

EU 

EU 

EU 

Finland 

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 

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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 protection 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 welfare organisation), AVEC (poultry 
industry),  EUROCOMMERCE,  COPA-COGECA, 
industry),  CLITRAVI 
EUROGROUP  FOR  ANIMALS  (animal  welfare  organisation),  FVE  (veterinarians), 
UEAPME  (small  businesses),  UECBV  (red  meat  slaughterhouses),  IBC  (butchers),  CIWF 
(animal welfare organisation), EFBA (fur breeders). 

(meat 

Main outcome: 

The Commission presented the main topics related to the proposal to revise Directive 93/119, 
already  available  on  the  website  of  the  Commission.  Paper  copies  of  the  website  and  other 
supporting documents were handed out to participants. 

The Commission received constructive support from all stakeholders 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). All participants also welcomed 
the proposal for a regulation rather than a directive. 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 industry and to officials and to ensure effective 
controls and sanctions across Member States. 

Stakeholders were informed of the possibility 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). 

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Specific outcomes (on slaughter) Presentation is annexed  

Increase the operators' responsibility 

All stakeholders were supportive of an increased responsibility of the industry. UECBV and 
FVE  strongly  supported  this  view  while  CIWF  was  concerned  about  too  much  flexibility 
being given to operators and insisted 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 regulation rather than a directive. 

A more specific scope for permitted 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  manufacturers  of  stunning/killing  equipment  should 
provide  the  necessary  instructions.  However  UECBV  was  concerned  that  some  equipment, 
already in use, could no longer be used. A transitional period should be foreseen in this case. 

The  Commission  representative  said  that  it  was  essential  to  provide  scientific  arguments  to 
support the authorisation or to ban specific methods of slaughter. 

issue. 
CIWF  and  EUROGROUP  welcomed 
EUROGROUP  also  asked  whether  farmed  fish  would  be  included  in  the  current  initiative. 
The  Commission  explained  that  this  was  not  immediately  foreseen  for  a  number  of  reasons 
(need for a specific impact assessment, different physiology, different inspection system etc.). 
However the Commission made clear that it intends to undertake a specific initiative on the 
issue later. 

the  Commission  suggestion  on 

this 

The  question  of  mobile  equipment  (e.g.  captive  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  the  need  for  a  better  knowledge  policy  on  this  issue  since  both 
official  inspectors  and  operators  sometimes  lacked  technical  assistance.  The  FVE  supported 
the  idea  of  a  centre.  The  industry  (CLITRAVI,  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  reference  could  be  dealt  with  separately,  in 
particular  by  establishing  an  EU  list  of  scientists  specialised  in  a  particular  area  of  animal 
welfare at slaughter. The FVE suggested that the existence of national networks of reference 
should be included as a part of the Official Feed and Food Control Regulation (incorporated 
in national control plans). 

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Improving the design of restraining/stunning/killing equipment 

The FVE agreed on the principle of integrating AW requirements in the process of the general 
approval  of  slaughterhouses.  The  Commission  explained  that  since  most  equipment  was  a 
fixture  of  the  slaughterhouse  itself,  only  a  local  assessment  would  be  relevant.  As  regards 
mobile equipment, the Commission suggested that the responsibility should remain with the 
slaughterhouse  operators  as  there  was  no  available  legal  and  practical  system  to  ensure  a 
harmonised  system  of  pre-approval  at  EU  level.  Therefore  it  would  be  up  to  the  Member 
States  to  possibly  develop  a  pre-approval  system  for  mobile  equipment.  Most  stakeholders 
accepted  the  views  presented  by  the  Commission.  However  CIWF  declared  that  all  new 
equipment  or  new  parameters  for  using  equipment  (such  as  new  electrical  stunning 
parameters  or  gas  stunning/killing  parameters)  should,  before  being  put  into  use,  require 
approval  from  the  competent  authority  that  they  are  capable  of  properly  fulfilling  their 
intended function. 

The Commission also evoked the possibility in the 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)  expressed  their  support  in 
implementing  a  harmonised  system  of  certification  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 development of production. It was also 
mentioned that voluntary schemes in certain slaughter houses already existed and should be 
taken as examples. Some stakeholders 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 Procedures for animal welfare 

Although the industry was mostly supportive of the idea, the AVEC questioned the feasibility 
of  finding  measurable  objectives  in  all  cases.  UECBV  also  expressed  concern  about  the 
possible  risk  of  requesting  excessive  documentation  from  small  or  medium  size 
slaughterhouses  (creating  potential  additional  administrative  costs).  The  question  of 
proportionality  of  the  requirement  for  SOPs  was  also  raised  by  the  FVE.  Adaptability  for 
SMEs (possible transition period) was also mentioned.  

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Animal Welfare Officer (AWO) 

All  stakeholders  backed  the  idea  of  a  requirement  for  an  AWO  provided  that  she/he  has 
proper qualifications and responsibilities within the slaughterhouse (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 stunning/killing/bleeding 

Although all stakeholders agreed on the need for a system to monitor animal welfare at these 
particular stages of the process (stunning/killing/bleeding), UECBV expressed the view that 
the legislation should not set out specific welfare indicators taking into account that national 
laws have an impact on the conditions of competition and accordingly on the operation of the 
common  market.  UECBV  considered  that  it  should  be  up  to  operators  to  establish  welfare 
indicators  in  SOPs  and  with  a  recording  system  so  that  officials  could  perform  audit  and 
controls. FVE and EFBA also supported the opinion that a general requirement for monitoring 
outcomes  and  the  creation  of  SOPs  should  suffice.  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  (slaughter/killing/bleeding)  of  the  process  was  critical  for  the 
welfare of animals. 

Killing for disease control purposes 

Stakeholders  agreed  on  the  Commission’s  proposal  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  disease  control  purposes  in  order  to  facilitate 
exchange  of  information  and  good  practices  between  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 exempted from AW rules including stunning. 

CIWF declared that fur farming 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  carbon  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 chicks53 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 permitted under Article 12 of Directive 93/119/EC). 

53 

Male chicks of breeds used for producing eggs are systematically destroyed. 

EN 

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AVEC advocated authorisation of neck dislocation 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 organisations (CIWF and AA) who requested that 
slaughter without prior stunning should be stopped. 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 restraining always applied (cattle and sheep), it 
does  not  pose  any  particular  problem  from  an  animal  welfare  point  of  view.  UECBV 
underlined  its  wish  to  avoid  any  discrimination  between  Halal  and/or  Kosher  meat  because 
any interdiction might be translated in possibilities 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-labelled  as  religiously  slaughtered  meat)  and 
considered that such practice did not allow consumers to be properly informed.  

The  Commission  informed  stakeholders  of  the  ongoing  Community  research  project 
DIALREL and the fact that there were very few Member States (Sweden and some Länder in 
Austria) which had banned slaughter without stunning. The probability of a ban being adopted 
at EU level looked rather limited. In addition such a position would be in conflict with other 
EU policies such as the protection of fundamental rights. 

AW labelling 

AVEC asked if the Commission intended to introduce 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 stakeholders considered that slaughtering animals should be done 
correctly  and  that  the  legislation  should  not  introduce  a  grading  system  between 
slaughterhouses or slaughter methods. 

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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 

Member State 

Dates of mission 

Report reference 

Details of missions  

Portugal 

Luxembourg 

Italy 

Belgium 

Spain 

France 

Denmark 

Austria 

Ireland 

Greece 

Lithuania* 

Latvia* 

Hungary* 

Czech Republic* 

Germany 

Portugal 

Greece 

Finland 

Sweden 

14-21.5.01 

5-9.11.01 

DG(SANCO)/3311/2001 

DG(SANCO)/3343/2001 

25.2 to 1.3.02 

DG(SANCO)/8556/2002 

18-22.3.02 

2-11.4.02 

24-28.6.02 

9-13.9.02 

DG(SANCO)/8555/2002 

DG(SANCO)/8553/2002 

DG(SANCO)/8554/2002 

DG(SANCO)/8676/2002 

14-18.10.02 

DG(SANCO)/8677/2002 

25-29.11.02 

DG(SANCO)/8678/2002 

13-17.1.03 

27-31.1.03 

10-14.2.03 

3-7.3.03 

7-11.4.03 

DG(SANCO)/9002/2003 

DG(SANCO)/9020/2003 

DG(SANCO)/9053/2003 

DG(SANCO)/9052/2003 

DG(SANCO)/9051/2003 

19-23.5.03 

DG(SANCO)/9038/2003 

2-6.6.03 

DG(SANCO)/9039/2003 

15-19.9.03 

DG(SANCO)/9211/2003 

1-5.9.03 

DG(SANCO)/9212/2003 

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 

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Spain 

Poland * 

Italy  

Slovakia 

Lithuania 

Hungary 

Greece 

Czech Republic  

Estonia 

Latvia 

Cyprus 

Greece 

Bulgaria* 

Romania* 

Croatia* 

Hungary 

Poland 

9-17.12.03 

23-27.2.04 

10-14.5.04 

24-28.5.04 

21-25.6.04 

13-17.9.04 

4-8.10.04 

10-14.1.05 

5-9.9.05 

DG(SANCO)/9215/2003 

DG(SANCO)/7209/2004 

DG(SANCO)/7010/2004 

DG(SANCO)/7233/2004 

DG(SANCO)/7306/2004 

DG(SANCO)/7237/2004 

DG(SANCO)/7273/2004 

DG(SANCO)/7519/2005 

DG(SANCO)/7714/2005 

31.5 to 3.6.05 

DG(SANCO)/7367/2005 

9-13.1.06 

DG(SANCO)/8037/2006 

21.2 to 1.3.06 

DG(SANCO)/8042/2006 

6-10.11.06 

6-10.11.06 

4-8.12.06 

DG(SANCO)/8054/2006 

DG(SANCO)/8053/2006 

DG(SANCO)/8046/2006 

DG(SANCO)/8331/2006 

23-27.4.07 

DG(SANCO)/7331/2007 

22-26.10.07 

DG(SANCO)/7734/2007 

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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 

France 

Spain  

27.11 to 1.12.06 

DG(SANCO)/8038/2006 

12-16.2.07 

DG(SANCO)/7330/2007 

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  mission  number  in  the  search  engine  of  the 
SANCO web page: http://ec.europa.eu/food/fvo/ir_search_en.cfm 

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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,  France,  Germany,  Italy,  Netherlands,  Portugal, 
Sweden and the UK). 

From the meeting and the contributions received, the main reactions 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  were  more  divided  as  regards  if  the  most 
appropriate form should be a directive or a regulation, since some of them feared that it would 
be put into question stricter standards 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 guidelines, others would prefer a certain flexibility 
for the killing for disease control purposes. 

As  regards  new  methods  Member  Stats  agreed  that  new  methods  should  be  evaluated  with 
strict scientific methodology. But some of them would favour a centralised approach (through 
the EFSA) rather than a partially decentralised option. 

Standard Operating Procedures/ Animal Welfare Officer 

There  was  also  a  large  support  for  introducing  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  technical  parameters  and  were  doubtful  on  the  possibility  of  leaving 
animal welfare indicators in the legislation. Concerns were also expressed of requesting SOP 
and AWO for small size businesses. 

Certificate of competence 

Member  States  also  largely  supported  the  introduction  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,  despite  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 guidelines in this area, others would advocate for 
a certain level of flexibility as regards the list of killing methods to be used. 

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ANNEX V – EU sectors affected 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 meat 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  production),  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 total gross internal production of meat in the 
EU-25  (see  Figure  1  below).  The  major  sheep  and  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  increasingly  large  and  automated  within  the  EU.  Many  are 
specialised  and  only  slaughter  one  species,  though  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  slaughterhouses  increase  in  size.  Figure  2  and 
Table 2 provides more specific data on the sector in each Member State. 

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Figure 1: Gross internal EU production (2005) 

Figure 2: Slaughtering by Member States (2004) 

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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%). The EU is 106% self-sufficient 
in poultry meat. 

Chicken and turkey are the main poultry species produced, with chickens comprising around 
three quarters of total EU poultry production and 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 followed by Spain (13%), and France (12%). Among 
the New Member States, Poland is the biggest chicken producer supplying over 11% of EU 
broilers. As far as turkeys are concerned, the biggest producers are France (30%), Germany 
(18%),  Poland  (14%),  and  Italy  (14%).  Figure  3  provides  more  details  on  EU  poultry  meat 
production. 

The EU poultry meat processing sector is characterised by strong regional concentration and 
specialisation (driven by increased competition) and vertical integration, particularly between 
the animal feed industry, broiler producers, and the slaughtering and distribution sectors. As 
regards poultry meat imports, while imports of poultry alive and carcass are insignificant (less 
than 10 000 Tonnes in 2005), imports of poultry cuts and prepared have increased, reaching 
512,000 tonnes in 2002 and 400,000 tonnes in 2005. 

Figure 3 and Table 3 provide more details on the sector and capacity in Member States.  

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Figure 3: EU poultry meat production, by species 1995-2006 (‘000 tonnes) 

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Table 3: Number of poultry slaughterhouses 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  that  50%  of  fur  breeders  rely 
exclusively on fur farming for their incomes. 

Mink  and  foxes  constitute  the  main  species  farmed  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 sector are laid down in the table 4 below. 

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Table 4: Main figures of the EU fur sector (2006) 

Number of fur farms in the EU (2006) 

Number of mink pelt 

Number of fox pelt 

Estimated  employees 
(whole chain) 

Value of farmed fur 

in 

the  fur  sector 

164.000 full time + 174.000 part time 

1.500 millions euros 

6.000 

25.1 millions 

2.6 millions 

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 

185.000 

22 

13.420.309 

1.727 

12.000 

35 

1.465.000 

569 

2.120.000 

1.266 

1.200 

12  104.000 

234 

180.000 

400.000 

50.000 

17 

25 

20 

Belgium 

Denmark 

Finland 

France 

Germany 

Greece 

Netherlands 

3.500.000 

148 

Iceland 

Ireland 

Latvia 

Italy 

Lithuania 

Norway 

Poland 

Spain 

Sweden 

22 

6 

12 

21 

18 

1.500 

200 

17.700 

7.600 

4 

1 

7 

4 

170 

280.000 

480 

155.000 

175.000 

500.000 

130.000 

351.230 

530.000 

420.000 

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). 

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In  addition  hatcheries  for  the  meat  types  are  incidentally  killing  day  old  chicks  and  the 
number of killed chicks both male and female is rather low. 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 neck. 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  placed  on  the  farms  and  about  1  –  1.5  million  are 
estimated to be killed. 

Killing for disease control and other killing 

Outbreaks  of  contagious  diseases  can  sometimes  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 obviously extremely volatile since outbreaks are not 
part of a normal production activity. However in the last decade, two major outbreaks have 
affected  mammals  species  with  around  10  millions  animals  killed  in  each  case  (Classical 
Swine  Fever  in  the  Netherlands  and  Foot  and  Mouth  Disease  in  the  UK)  while  two  other 
major outbreaks have affected birds 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  contagious  diseases,  as  well  as  contamination  of  animals  by  feed 
may lead to the killing of entire farms. 

Animals are also killed on farms because they are not sufficiently productive. If animals are 
sometimes  transported  to  slaughterhouse,  many  such  animals  are  unsuitable  for  human 
consumption and are killed on farms. 

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ANNEX VI - Current Stunning and bleeding techniques used in slaughterhouses 

Table  1  summarises  the  different  techniques  for  stunning  and  bleeding  used  in  the  different 
species.  The  results  are  based  on  the  survey  of  EU  slaughterhouse  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/bleeding techniques used in slaughterhouses 

% of 
slaughterhouses 
who responded 

Stunning technique 

Bleeding techniques 

Cattle 

Penetrative  captive  bolt:  79%  on  cattle,  96% 
for calves 

Chest  sticking:  50%  for  cattle  and  56% 
for calves  

Non-penetrative  captive  bolt:  4%  for  claves 
and 7% for cattle  

1 carotid artery: 16% for cattle, 26% for 
calves 

Electrical  stunning:  0%  for  calves,  12%  for 
cattle 

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 

Chest  sticking:  86%  for  pigs  up  to  150 
kg , 100% for pigs more than 150 kg  

Gas stunning: 64% for pigs up to 150kg, 62% 
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 

2  carotid  arteries:  62  %  for  lamb,  54% 
for adult sheep 

Non-penetrating captive bolt: 7% of lamb 

Chickens 

Head only stunning: 10% 

Reversible water bath: 55% 

Irreversible water bath: 24% 

Neck  dislocation:  10%  (but  only  used  in 
emergency back-up) 

Turkeys 

Reversible water bath: 67% 

Irreversible water bath: 33% 

1 carotid artery: 38% for lamb, 46% for 
adult sheep 

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% 

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 slaughterhouse operators, consultants reports 

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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 requirements for stunning or killing of animals 

Specific requirements for: 

– 

– 

– 

unloading and keeping animals at slaughterhouses 

restraining animals 

bleeding animals 

General requirements on equipment and personnel to perform the slaughtering operations in a 
professional way respecting the welfare of the animals 

Outside slaughterhouses: 

General  animal  welfare  principles  but  possible  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 specific requirements for the killing of: 

– 

– 

fur animals 

surplus day-old-chick 

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ANNEX VIII - Main technological 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  and/or  pulsed  direct  current  for  water  bath 
stunning 

The first water bath stunners were using alternating current at a frequency of 50 Hz since this 
is  the  frequency  delivered  by  electricity  providers.  However  due  to  meat  quality  problems 
(blood  splashes,  broken  bones)  it  appears  that  some  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 frequency of alternative current or using pulsed direct current 
may  decrease  the  effectiveness  of  the  stunning  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 indicates that at least three different CAS methods are now used 
in the EU within around 25 slaughterhouses. CAS is used in the largest slaughterhouses and 
experts  estimate  that  between  20  to  25%  of  broilers  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  increasingly  used  higher  concentrations  up  to  90%  in  order  to 
shorten the time of exposure while ensuring a longer 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. 

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ANNEX IX - Hygiene package requirements in a nutshell 

Main requirements of the "Hygiene package" applicable to slaughterhouses 

The "Hygiene package" is a set of several regulations implementing the general principles of 
the  "Food  Law"  laid  down  in  Regulation  (EC)  No  178/2002.  The  relevant  regulations 
applicable to slaughterhouses 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) 

(2) 

(3) 

(4) 

(5) 

(6) 

(7) 

identification of food safety hazards, 

identification of critical control points CCP (i.e. the steps of the production process 
where you can prevent, reduce or eliminate the hazards), 

establishment of critical limits for each CCP (what is acceptable or not), 

establishment of monitoring procedures for each CCP, 

establishment of corrective actions when a CCP is not under control, 

establishment  of  verification  procedures  to  ensure  that  the  system  is  effectively 
working, 

establishment of documents and records commensurate 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  specific  hygiene  rules  for  food  of  animal 
origin 

This  regulation  requires  establishments  to  be  registered  and  approved  by  the  competent 
authority and laid down specific requirements for each type of establishments. 

For slaughterhouses, pre-approval is based on the inspection by the competent authority as to 
assess the compliance of requirements related 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. 

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Regulation (EC) No 854/2004 laying down specific rules for the organisation of official 
controls on products of animal origin intended for human consumption 

This regulation laid down the organisation of official control including in slaughterhouses. 

In  particular  the  process  of  approval  of  slaughterhouses  and  audit  of  HACCP  procedures  is 
specified. The regulation explicitly indicates that for slaughterhouses, 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 and the gravity of the problem encountered. 

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ANNEX X - Example of the discrepancies of situation in Europe concerning Controlled 
Atmosphere Stunning from information collected from manufacturers 

Current  UK  legislation  only  allows  anoxic  mixtures  to  be  applied  in  controlled  atmosphere 
stunning.  This  legislation  can  no  longer  be  amended,  since  the  maximum  number  of 
amendments  has  been  reached  already.  Therefore,  new  legislation  is  needed.  It  has  been 
expressed to us that the UK awaits the revision of Council Directive 93/119/EC. 

For  the  Dutch  situation,  the  Ministry  of  Agriculture  concluded  in  2005  that  applying 
controlled  atmosphere  stunning  was  covered  already  by  national  as  well  as  EU  legislation 
(with reference to Directive 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  manufacturers  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  concentration  (without  the  addition  of  inert  gasses)  is  only 
applied  in  Italy.  In  Germany,  hypercapnic  stunning  of  turkeys  is  allowed  by  law.  There  are 
however, currently no such systems operational in Germany. 

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ANNEX XI – Directive or Regulation in this case? 

As  stated  in  the  Commission  Communication  on  “Implementing  the  Community  Lisbon 
programme:  A  strategy  for  the  simplification  of  the  regulatory  environment”56,  "Replacing 
directives with regulations can 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,  where  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 scientific advances. 

56 

COM(2005) 535. 

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ANNEX XII – Comparative price level indices of the survey, EU 27=100 

From Statistics in focus, Economy and finance, 90/2007, Eurostat 

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ANNEX XIII – Illustration of the impact of the baseline scenario on innovation: the 
example of controlled atmosphere 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/authorise new methods of killing. We have previously seen 
in section on subsidiarity the various ways Member States 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  mixture  has  an  influence  linked  to  the  cost  of  gas 
(Argon  or  Nitrogen  are  more  expensive  than  carbon  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 legislation on CAS has partly contributed to favour the 
prevalence of electrical stunning. 

Table 3: Use of controlled atmosphere system in the EU (poultry) 

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ANNEX XIV – Complementary questionnaire 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 stakeholders or/and scientists which needs to be quantified in 
terms  of  economic  costs  as  well  as  on  other  possible  impacts.  As  information  is  not 
necessarily  available  and  cases  may  vary  depending  on  each  local  situation,  evaluation 
should be provided based on concrete data or existing studies which are directly relevant or 
which present similarities.  

For  the  purpose  of  this  questionnaire  the  word  "stunning"  should  be  understood  as  any 
method 
insensitivity,  reversible  or  not  (stunning  or 
stunning/killing). 

inducing  unconsciousness  and 

Question  1  –  Official  controls  –  The  Commission  may  envisage  requesting  official  controls 
and audits on animal welfare that we understand are already covered under inspection duties 
of  officials  in  the  framework  of  the  hygiene  package.  Do  we  have  any  quantitative 
information regarding the costs generated 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 authorisation for new stunning methods. 

Q.2.1 –  Based  on  previous  experience,  what  would  be  the  costs  of  processing  such 

authorisations?  

Q.2.2 –  What types of costs would a new authorising scheme require from companies and/or 

Member States' authority?: 

ο 

ο 

ο 

ο 

ο 

Additional staff? If yes, please indicate how many more man-hours.  

Additional checks? If yes, please indicate how costly this could be (in €). 

Data collection? If yes, please indicate how costly this could be (in €). 

Data storing and processing? If yes, please indicate how costly this could be (in 
€) 

Etc… 

Q.2.3 –  To which extent these costs could be supported by the industry? 

Q2.4 –  In  the  past  years,  how  many  authorisations  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 animal welfare legislation.  

Based on the experience gained in your country (if applicable) where a AWO is required, how 
this  obligation  is  implemented  by  operators?  In  particular,  how  many  more  man-hours  are 
needed at company level to comply with the requirement?  

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Question  4  –  Certificate  of  competence  –  The  Commission  may  envisage  establishing  a 
system of certificate of competence for personnel 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  would  a  new  certificate  of  competence  scheme 

require from companies and/or Member States' authority?: 

ο 

ο 

ο 

ο 

ο 

Additional staff? If yes, please indicate how many more man-hours.  

Additional checks? If yes, please indicate how costly this could be (in €). 

Data collection? If yes, please indicate how costly this could be (in €). 

Data storing and processing? If yes, please indicate how costly this could be (in 
€) 

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  slaughter  and  killing.  In 
particular  those  tasks  could  involve  inter  alia  the  provisions  of  technical  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 certificate 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  availability  of  existing  scientific  resources 
available  in  your  country,  what  types  of  costs  would  a  new  national  centre  of 
reference require from companies and/or Member States' authority?: 

♦  Additional staff? If yes, please indicate how many more man-hours.  

♦  Additional checks? If yes, please indicate how costly this could be (in €). 

♦  Data collection? If yes, please indicate how costly this could be (in €). 

♦  Data storing and processing? If yes, please indicate how costly this could be (in 

€) 

♦ 

Etc… 

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Question 6 – Killing for disease control purposes and other depopulation  cases – Directive 
93/119/EC  allows  the  competent  authority  to  use  other  methods  than  the  one  listed  in  the 
current EU legislation. The Commission may envisage using a stricter list of stunning/killing 
methods including for disease control purposes and requesting a better integration of animal 
welfare concerns when actual killing of animals takes place. 

Q.6.1 –  Could  you  identify  methods  of  killing  that  are  presently  not  listed  in  Directive 
93/119/EC or not recommended by the EFSA or the OIE guidelines that 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 

ο 

ο 

Buying new equipment? If yes, please indicate how costly. 

Hiring additional staff? If yes, please indicate how many more man-hours. 

Etc…. 

Q.6.3 – What are the current practices of your country in relation to the integration of animal 
welfare issues on the planning, the supervision and the reporting 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 depopulation? If so, how often? 

Q.6.5 –  If not, what types of additional costs would involve the production of an evaluation 

report on the animal welfare results 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 often performed without sufficient consideration to the welfare of 
the animals and suggest that permanent presence of officials would improve the situation. 

What types of costs would a presence of officials involve from Member States authority?  

ο 

ο 

ο 

ο 

ο 

Additional staff? If yes, please indicate how many more man-hours.  

Additional checks? If yes, please indicate how costly this could be (in €). 

Data collection? If yes, please indicate how costly this could be (in €). 

Data storing and processing? If yes, please indicate how costly this could be (in €) 

Etc… 

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Question 8 – Official controls on fur animals killing – Today's EU legislation provides 
specific requirements for the killing of fur animals which take place on farm during a specific 
period of the year. 

Q.8.1 –  How today official controls are performed to check the provisions applicable to the 

killing of fur animals?  

Q.8.2 –  What is the percentage of fur animals killed per year do you estimate to be checked? 

END OF THE QUESTIONNAIRE 

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