Opinion of the European Economic and Social Committee on the ‘Communication from the Commission to the European Parliament, the Council and the European Economic and Social Committee on the European Union Strategy for the Protection and Welfare of Animals 2012-2015’ COM(2012) 6 final
Date: 2012-05-23
Institutions: European Economic and Social Committee
Subjects: animal welfare, competitiveness, farming sector, food safety, international cooperation, production cost, quality standard








C_2012229EN.01010801.xml










31.7.2012   


EN


Official Journal of the European Union


C 229/108





Opinion of the European Economic and Social Committee on the ‘Communication from the Commission to the European Parliament, the Council and the European Economic and Social Committee on the European Union Strategy for the Protection and Welfare of Animals 2012-2015’
COM(2012) 6 final
2012/C 229/20
Rapporteur: José María ESPUNY MOYANO

On 19 January 2012 the European Commission decided to consult the European Economic and Social Committee, under Article 304 of the Treaty on the Functioning of the European Union, on the

Communication from the Commission to the European Parliament, the Council and the European Economic and Social Committee on the European Union Strategy for the Protection and Welfare of Animals 2012-2015

COM(2012) 6 final.
The Section for Agriculture, Rural Development and the Environment, which was responsible for preparing the Committee's work on the subject, adopted its opinion on 11 May 2012.
At its 481st plenary session, held on 23 and 24 May 2012 (meeting of 23 May), the European Economic and Social Committee adopted the following opinion by 146 votes to three with nine abstentions.
1.   Conclusions

1.1   In general terms, the EESC agrees with the animal welfare strategy presented by the Commission, thereby supporting consumers' legitimate aspiration for food safety and a European production strategy geared towards quality.
1.2   The EESC notes that there are difficulties in the implementation of the existing legislation due to lack of support for their application and the loss of competitiveness suffered by EU products.
1.2.1   Instruments are needed to compensate for the loss of competitiveness faced by EU livestock production, since the additional costs resulting from the EU's animal welfare policy (EUPAW) are not absorbed by the market. There are reasons to fear an even greater loss of market share in both the internal market and export markets. There has been no consideration of the labour market or of working conditions.
1.2.2   The EESC would again insist that all imported products should meet the same production standards as EU products, taking a reciprocity approach in trade agreements.
1.3   On-going animal welfare training for operators, workers and authorities is a crucial element of the strategy. The EESC would also draw attention to the importance of allocating a proportion of cooperation funds to the training of third-country authorities, employers and workers regarding welfare in animal production.
1.4   The implementation of EU regulations requires adjustment of financial resources so that producers can make the necessary investments and in order to compensate for additional costs. The CAP must complement this strategy, attaching the necessary importance to it.
1.5   A communication strategy must be drawn up to address society's concerns, taking account of scientific studies and progress in this field and the various points of view of producers, workers and consumers. Communication must not be based solely on obligatory labelling. There must be coherent consumer information programmes, which help consumers to make decisions based on the greatest possible number of factors. Funds to promote agri-food products have a key role to play, ensuring that production sectors play an active part in this work.
1.6   The EESC believes that all social actors and consumers must participate in the European network of reference centres, and that it has a crucial role to play in the development of the animal welfare strategy:






a.


coordinating the various research centres in the EU,










b.


facilitating the implementation of the legislation (the development of practical indicators, training of operators, workers and authorities),










c.


helping to assess the impact of the regulations in socioeconomic and competitiveness terms,










d.


supporting information and communication activities.




1.7   Strengthening the weakest links in the food chain will lead to a fairer distribution of the additional costs resulting from the implementation of animal welfare standards, thereby maintaining the productive fabric and the development of rural areas.
1.8   The Commission's laudable efforts towards simplification are at odds with the Commission's intention to extend the scope of application to more species and further develop existing provisions.
2.   Gist of the Communication

2.1   The purpose of this Communication from the Commission is to set out lines for advancing the EUPAW, in continuation of the 2006-2010 Action Plan.
2.2   The document states that the EU has made significant efforts to support animal welfare. It points out that the EUPAW is not applied uniformly in all Member States and that the mandatory requirements have not been established within the set timeframes. Nevertheless, we need to reflect on whether a ‘one size fits all’ approach can lead to better animal welfare.
2.3   The evaluation of EU animal welfare policy concludes that welfare standards have imposed additional costs on the livestock and experimental sectors.
2.4   It also notes that consumer decisions are driven mainly by price and that animal welfare is only one of the factors affecting consumer choice.
2.5   The Communication mentions the need to simplify legislation, but also the need to look at the competence requirements for animal handlers for specific species or production systems and the training of inspectors and technicians in Member States. It also notes that welfare requirements cover some species but not others.
2.6   In view of the above, it puts forward two strands of strategic actions, namely to:






—


simplify legislation and facilitate its application; and to










—


strengthen actions the Commission has already taken.




3.   General comments

3.1   The EESC welcomes the strategy paper under consideration and the Commission's intention to improve factors liable to contribute to achieving the EU's objectives in this area.
3.2   The EESC supports consumers' legitimate aspiration for food safety and also supports a European production strategy geared towards quality. However, it would call upon the Commission to bear in mind that the increased cost for producers resulting from the animal welfare strategy is seldom offset by higher sale prices. Furthermore, the European livestock sector suffers from the lack of reciprocity in trade agreements with third countries.
3.3   The EESC regrets that the Commission's Communication does not explicitly mention the employment conditions of workers, the people who ultimately handle the animals. Significant emphasis must also be placed on ongoing training and the acquisition of the new skills required as a result of the changes proposed.
3.4   The EESC welcomes the objective of simplifying EU animal welfare legislation and enhancing the competitiveness of EU agriculture. However, the strategy does not adequately address a number of important points which are highlighted in the evaluation report on EU animal welfare policy, and which should be priorities for 2012-2015.
3.5   The Commission recognises a number of shortcomings in the outcomes of the action plan and the EUPAW, involving what it describes as ‘the main common drivers affecting the welfare status of animals in the Union’. Nevertheless, it does not analyse their causes in detail and, as a result, the strategy put forward does not offer adequate solutions to the problems identified.
3.5.1   It notes that the Member States do not fully enforce the provisions despite long transitional periods and support. However, there is no critical analysis of the socioeconomic and productive situation in the various EU Member States, but merely a reference to the ‘cultural appreciation of animal welfare aspects’ as a factor that sets Member States apart. The Commission fails to mention the differences in livestock production systems, consumer demand, and the commercial advantages of applying minimum animal welfare standards or support for adaptation, which are not uniform across the EU.
3.5.2   EU animal welfare policy should be much better geared towards the market as well as consumer safety. It is essential that producers are compensated for additional production costs and that consumers are aware of the improvements and efforts of producers, as well as the higher added value of food produced according to the EU model. There must also be a balance in the food chain, which is currently absent.
3.5.3   The Communication's stated intention of simplifying animal welfare legislation is at odds with the reference to the need to extend its scope of application to more species and for more detail in the existing legislation. The strategy does not include the EUPAW evaluation report's recommendation to explore non-legislative routes to complement existing legislation, such as agreements between sector bodies, parties in the value chain, social actors and consumer organisations and governmental bodies, which might achieve the intended objectives without resorting to further legislative burdens.
4.   Specific comments

4.1   The EU animal welfare budget (EUR 70 million per year) is in clear contrast to the investment required for its implementation, and all the more so if we add the livestock sector's legislative costs (EUR 2 800 million, according to the EUPAW evaluation). The strategy does not contain specific and realistic proposals for tackling the increased costs and the lack of support for implementation.
4.2   In order to improve the competitiveness of producers, synergies between the EUPAW and the common agricultural policy must be optimised. In the post-2013 CAP, the EU must adopt a balanced approach to welfare. Livestock farmers and operators must be guaranteed access to aid measures with a sufficient budget to apply the EUPAW. Account must be taken of the financial impact of additional costs on producers and sufficient income support must be provided through price and market policies and/or direct aid.
4.3   The EESC agrees that legislative simplification is needed. If appropriately deployed, it will contribute to the implementation of the EUPAW. To achieve this, the impact of measures developed to carry out future actions in the EUPAW framework will have to be studied, as will, where appropriate, the risks to the productive fabric entailed by each measure and the compensation needed if they are implemented, also influencing the value attached to consumer health and safety in the EU.
4.4   Introducing science-based indicators based on animal welfare outcomes and not on inputs will make the simplification and flexibility required to improve the competitiveness of EU livestock farmers possible, provided that the socioeconomic implications are taken into account and that it reflects the general situation in the livestock sector as opposed to specific cases. Measures have to be developed in cooperation with operators and should be straightforward, practical and easy to apply. They should not incur additional costs for livestock farmers. It should be possible to apply them to all species and production systems. They should be easy to interpret and replicate (not subjective human perceptions of animal welfare).
4.5   The work of the Welfare Quality project is an interesting reference point. However, the animal welfare indicators need to be improved and simplified before they can be applied to the livestock sector. The interpretation and application of criteria must be harmonised in the various Member States in order to ensure their validity and the viability of their application in all cases.
4.6   One challenge that this strategy must address is to improve coordination, traceability, transparency and communication in relation to animal welfare in the EU, allowing administrations, socioeconomic actors and consumers to participate. This would lead to better understanding, adequate information and the correct application of requirements. Reference centres could and should play a vital role in meeting this objective. In addition to the activities mentioned in the Communication (support for the authorities, training and dissemination), they should also coordinate, monitor and share information. They should make the most of existing structures to avoid additional costs.
4.7   Reference centres could also provide advice and carry out assessments regarding the practical application of welfare laws. Scientific research should be added to applied research with a view to making recommendations. In light of the work carried out by DG SANCO's scientific committee and the European Food Safety Authority's panel on Animal Health and Welfare (AHAW), this network should coordinate the testing of new techniques and assess the impact of animal welfare standards. The sector's operators make a great contribution to applied research. They should play a prominent role regarding the legislative and research priorities with EU funding for animal welfare.
4.8   The EUPAW evaluation report recommends: ‘Developing a stakeholder engagement plan for each aspect of EU animal welfare policy …’ and ‘in consultation with stakeholder groups, assessing the need to develop new modes of engagement over time …’. Roadmaps need to be agreed between the relevant authorities and affected operators, to ensure the gradual application of laws by the mandatory deadline and to facilitate ex-ante coordination and problem solving. Ex-post inspection and monitoring activities should also be included, as well as training and information for operators and the Member States' authorities to ensure the adequate implementation of legislation.
4.9   Support for international cooperation is crucial in terms of improving the competitiveness of EU production. To this end, concrete actions must be provided for within the 2012-2015 strategy in order to ensure that animal welfare is included in bilateral trade agreements negotiated by the EU and within the WTO. Meanwhile, the points mentioned below need to be taken into account.
4.9.1   The evaluation report points to the need to find ways to assist EU sectors which are most vulnerable to third-country imports or to likely loss of market share, in particular in the eggs and egg products sector. The strategy does not propose solutions for the loss of competitiveness in the face of third-country imports which do not meet EU production standards.
4.9.2   The EU must allocate a proportion of cooperation funds to the training of authorities, employers and workers regarding animal welfare.
4.10   A communication strategy covering the points raised in the EUPAW evaluation needs to be developed. It should include a serious and objective training, information and communication campaign, from school upwards, to ensure that current and future consumers are aware of the high animal welfare standards required by the EUPAW, starting with the existing legislation. This will allow them to make consumer choices based on accurate animal welfare information.
4.10.1   It is essential that rigorous and reputable sources (such as the network of reference centres) cooperate in this work in order to ensure that consumers understand and appreciate the advantages of the EUPAW, as well as the production costs under the European model.
4.10.2   Consumer information regarding animal welfare must not be restricted to labelling and product advertising, but must also be the subject of publicity campaigns by sectoral organisations and institutions with a view to communicating the efforts made and the impact on production costs. Mechanisms and funds for promoting agri-food products in the internal market are ideal ways to provide information regarding the EUPAW.
4.11   In addition to the measures mentioned in the Commission's proposal, we need to consider other equally important measures mentioned in the EUPAW evaluation report, which recommends: ‘Ensuring adequate growth in funding for the EUPAW over the next action plan period, in line with the growing needs of the policy, and in order to meet increasing needs identified in this evaluation. These include support for implementation and enforcement of new legislation’.
4.11.1   The animal welfare policy's negative impact on competitiveness is one of the major obstacles to the legislation's application, and to maintaining and creating jobs in rural areas, particularly given the difficulty faced by producers in transferring the additional production costs (and added value) to the subsequent links in the food chain. The strategy does not consider how to overcome the dysfunctions in the food chain, nor the anti-competitive impact of the legislation on channels and markets other than retail (catering, industry, export).
4.11.2   These are the key points concerning rural development funding:






—


more funding for animal welfare under rural development programmes (for investments as well as increased operating costs); and










—


facilitating support for the implementation of mandatory welfare requirements, with EU support under the CAP, and also binding on Member States.




4.11.3   Furthermore, there must be consistency between animal welfare policy and other areas such as the environment, animal health and sustainability, including competitiveness, which need to be strictly interrelated, as well as advantages for consumers, workers and employers. These points must be included in the strategy.
4.12   Since simplification is one of the 2012-2015 strategy's purported aims, as is the framing of a law that incorporates all animal welfare standards for all species and production systems, it is not appropriate to embark on new legislative strands or to further develop existing ones at a time when there is no decision on what course to take and on whether the established course should cover aquatic or other species.
4.13   With regard to the sensitive issue of ritual slaughter, the Committee wishes to take this opportunity to reiterate its view expressed in its opinion (1), which stated that a derogation on ritual slaughter is inconsistent with the overall objective [improving the protection of animals]. Innovative technology such as the stun assurance monitor allows those who wish to slaughter with prior electrical stunning in compliance with Halal rules to accurately monitor how much electrical charge is given to an animal. This ensures that it is properly stunned but still alive prior to slaughter. The monitor records each stun carried out and the voltage given to the animal. It has a real contribution to make to animal welfare. Furthermore the introduction of a labelling system indicating the method of slaughter would encourage the use of the stun assurance monitor. It is important for the Commission actively to support research into systems which would convince religious groups to make use of stunning.

Brussels, 23 May 2012.


The President of the European Economic and Social Committee

Staffan NILSSON




(1)  OJ C 218 du 11.09.2009. p. 65