COMMISSION STAFF WORKING DOCUMENT IMPACT ASSESSMENT Accompanying the document Proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL laying down general provisions for the management of expenditure in the field of food chain, animal health and welfare, and on plant health and plant reproductive material ("feed and food expenditure")
Date: 2013-06-07
Institutions: European Commission
Subjects: EU financing, administrative check, animal nutrition, animal welfare, food safety, health control, marketing standard, plant health control, plant propagation, public expenditure, veterinary inspection

EUROPEAN 
COMMISSION 

Brussels, 7.6.2013  
SWD(2013) 195 final 

COMMISSION STAFF WORKING DOCUMENT 

IMPACT ASSESSMENT 

Accompanying the document 

Proposal for a 
REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL 

laying down general provisions for the management of expenditure in the field of food 
chain, animal health and welfare, and on plant health and plant reproductive material 
("feed and food expenditure") 

{COM(2013) 327 final} 
{SWD(2013) 194 final} 

EN 

   EN 

 
 
 
 
  
 
 
Contents 

Section 1: Procedural issues and consultation of interested parties 

1.1: Background 
1.2: Supporting Impact Assessments and Consultations 
1.3: Steering Groups 
1.4: Impact Assessment Board 

Section 2: Problem Definition 

2.1: Current policy and financial framework 
2.2: Problem Identification 
2.3 Who is affected by the current policy? 
2.4 How would the problems evolve, all things being equal? 
2.5 International dimension  
2.6: The Right and Justification for EU Action 

Section 3: Objectives 

3.1: General Objectives 
3.2: Specific Objectives 
3.3: Operational Objectives 
3.4: Consistency with other EU policies 

Section 4: Policy Options 
Section 5: Assessment of Impacts 

5.1: Option 1 
5.2: Option 2 
5.3: Option 3 (a) 
5.4: Option 3 (b) 
5.5: Option 4 

Section 6: Comparing the options 
Section 7: Monitoring and Evaluation 
7.1. Evaluation Report 
7.2. Ex-post Evaluation 
7.3. Indicators 
7.4: Communication 

Annex 1: Food Safety Budget 2007-2011 
Annex 2: Added Value from EU co-financing: example case studies 
Annex 3: Objectives of individual policy areas 
Annex 4: Costs and Responsibility Sharing Scheme  

Annex 5: References 

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Glossary 

AHL  
AHS 
AI 
BSE 
BTB 
BTSF 
BTV 
CA 
CAHP 
CAP 
CRSS 
CSF 
CVO 
DG 
EFSA 
EURLs 
FAOSTAT 
FCEC 
FMD 
GNI 
HPAI 
IA 
IASG 
IPPC 
LPAI 
MFF 
MS 
NGO 
OECD 
OIE 
PHL 
PHR 
PPP 
PRM 
SBV 
SMEs 
SPS 
TFEU 
TSE 
vCJD 
WHO 
WTO 

Animal Health Law 
EU Animal Health Strategy 2007-2013 
Avian Influenza 
Bovine Spongiform Encephalopathy 
Bovine Tuberculosis 
Better Training for Safer Food 
Bluetongue Virus 
Competent Authority 
Community Animal Health Policy 
Common Agricultural Policy 
Cost and Responsibility Sharing Scheme 
Classical Swine Fever 
Chief Veterinary Officer 
Directorate General (of the European Commission) 
European Food Safety Authority 
EU Reference Laboratories 
Food and Agricultural Organisation, United Nations, Statistics Division 
Food Chain Evaluation Consortium 
Foot and Mouth Disease 
Gross National Income 
High Pathogenic Avian Influenza 
Impact Assessment 
Impact Assessment Steering Group 
International Plant Protection Convention 
Low Pathogenic Avian Influenza 
Multiannual Financial Framework (2014-2020) 
EU Member State 
Non-Governmental Organisation 
Organisation for Economic Co-operation and Development 
World Organisation for Animal Health 
Plant Health Law 
Plant Health Regime 
Public-Private Partnership 
Plant Reproductive Material 
Schmallenberg Virus 
Small and Medium Sized Enterprises 
Sanitary and Phytosanitary Measures agreement 
Treaty on the Functioning of the European Union 
Transmissible Spongiform Encephalopathy 
variant Creutzfeldt-Jakob Disease 
World Health Organisation 
World Trade Organisation 

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Section 1: Procedural issues and consultation of interested parties 

1.1 Background 

For  some  years,  the  Commission,  specifically  DG  Health  and  Consumers,  has  been  working  on  the 
revision of EU policy for animal health, animal welfare, plant health, plant reproductive material, feed 
and  food  safety, and the  official controls that underpin the effective implementation of these policies 
(hereinafter together referred to as "food safety policy"). This overall revision is intended to drive EU 
policy  more  strategically,  making  it  more  effective,  and  allowing  more  flexibility  when  new  changes 
arise. This assessment evaluates the impacts of options to modernise the financial framework for the 
food safety policy areas.  

The  overall  budget  of  €1.891bn  from  2014  to  2020  (i n  current  prices)  for  the  food  safety  financial 
framework  has  already  been  proposed  by  the  Commission  within  the  context  of  the  Multiannual 
Financial Framework (MFF), published in June 2011 (budget line named 'food safety' under Heading 3 
'Security and Citizenship')1. Therefore, this impact assessment for the financial measures is intended 
to  consider  the  likely  impacts  of  the  options  available  for  the  legislative  proposal  establishing  the 
financial  framework  related  to  food  safety,  including  plant  health,  animal  health  and  official  controls, 
within this existing context. It brings together relevant work carried out for the impact assessments of 
the  individual  policies,  along  with  other  recent  relevant  evidence,  such  as  audit  reports  and 
consultation results.  

This  is  intended  to  be  a  "proportionate"  level  of  analysis  in  line  with  the  Commission  guidelines  on 
Impact Assessment. 

As the budget has already been developed and proposed in the context of the Multiannual Financial 
Framework,  and  the  policies  are  at  an  advanced  stage  of  development  with  significant  analysis  of 
impacts  already  behind  them,  and  also  considering  the  limited  timescale  to  meet  the  Secretary 
General's request, this assessment concentrates on the best ways in which the budget can be spent 
to support the policies in question. Moreover, no specific tools to demonstrate the cost-effectiveness of 
the  food  and  feed  spending  have  been  implemented  within  the  current  monitoring  and  evaluation 
system  so  far.  Therefore  this  assessment  will  take  a  light-touch  proportionate  approach  to 
demonstrate the importance of EU funding in this area and considers some alternative options. 
Within the food safety policies under consideration, rules governing expenditure are already in place. 
In  particular,  this  proposal  precedes  the  'Healthier  Animals  and  Plants  for  a  Safer  Food  Chain 
Package' which includes proposals for: 
• 

the animal health policy, which aims to protect and raise the health status and condition of animals 
in  the  EU,  in  particular  food-producing  animals,  whilst  permitting  intra-EU  trade  and  imports  of 
animals and animal products in accordance with the appropriate health standards and international 
obligations; 
the  plant  health  regime  (PHR),  whose  objective  is  to  protect  EU  agriculture  and  forestry  by 
preventing  the  entry  and  spread  of  non-native  harmful  organisms  (pests  and  pathogenic  micro-
organisms affecting plants); 
the  marketing  of  seed  and  propagating  material  of  agricultural,  vegetable,  forest,  fruit  and 
ornamental  species  and  vines  ("plant  reproductive  material"),  which  ensures  that  EU  criteria  for 
health and quality are met; 

• 

• 

•  a  legislative  framework  for  the  organisation  of  official  controls  concerning  food  and  feed  safety, 
animal health and welfare, plant health and plant reproductive material, established to ensure that 
the sectorial rules are enforced by Member States (MS) across the EU in a harmonised manner. 

1.2 Supporting Impact Assessments and Consultations 

Because all four policies have been under revision for some time, they are individually supported by 
their  own  impact  assessments,  and  details  of  these  policies  have  been  extensively  discussed  with 
stakeholders in various consultation fora. There are four relevant impact assessments and regulations 
under  consideration,  in  the  areas  of:  animal  health;  plant  health;  plant  reproductive  material;  and 

1 http://ec.europa.eu/health/programme/docs/maff-2020_en.pdf (see page 25) 

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official controls. This package, aimed at modernising and integrating the EU policies in these sectors, 
has  been  developed  as  a  result  of  a  long  series  of  studies,  analyses  and  evaluations.  The  most 
relevant ones, as well as their main conclusions and recommendations, are listed below. 

Animal Health 
In  2004,  the  Commission  launched  an  independent  evaluation  to  assess  the  performance  of  the 
Community Animal Health Policy (CAHP) over the previous decade and its coherence with other EU 
policy  interventions.  The  evaluation  recommended  -  among  other  things  -  the  adoption  of  a  single 
regulatory  framework  defining  and  integrating  common  principles  and  requirements  of  existing 
legislation for animal health. 
The  resulting  EU  Animal  Health  Strategy  2007-2013  (AHS)  "Prevention  is  better  than  cure"  and  its 
subsequent  Action  Plan  identified  the  main  objective  of  the  Strategy  in  the  development  of  an  EU 
Animal Health Law (AHL). 
The  Impact  Assessment  for  the  Animal  Health  Law  therefore  looked  at  ways  in  which  the  strategy 
could be best implemented, including making improvements to existing measures, as well as the main 
objective of consolidating and simplifying the legislation.  
The  new  AHL  will  replace  the  current  animal  health  legislative  framework,  which  involves  almost  60 
basic directives and regulations, some of them adopted as early as 1964, and is expected to affect the 
veterinary acquis communautaire, which covers now more than 400 acts. 

Plant Health 
Based  on  the  conclusions  of  the  Council  of  November  2008,  the  Commission  initiated  a 
comprehensive  evaluation  of  the  EU  plant  health  regime  (PHR)  from  the  introduction  of  the  internal 
market (1993) and contracted the necessary study out to an external consultant.  
The consultation concerned  changes  to  the  EU  plant  health  regime  itself as  well  as  elements  of  the 
regime to be transferred to or from the PRM regime and the future EU regime on official controls on 
food and feed, animal health and welfare, plant health and plant reproductive material. 
The internal process to develop the IA was further supported by a second contract with the consultant 
for a study on the quantification of costs and benefits of amendments to the regime, supplementary to 
the  data  that  had  been  collected  during  the  evaluation.  The  IA  recommended  that  an  increase  in 
certain aspects of plant health spending would have significant benefits that outweighed the costs.  
The  impact  assessment,  approved  by  the  Impact  Assessment  Board  in  2011,  explores  substantially 
increasing  the  Union's  financial  support  for  plant  health,  in  particular  to  expand  the  scope  of  Union 
financial  support  to  surveillance  programmes  for  speedy  detection  of  harmful  organisms,  and  to 
compensation to operators for the value of plant material destroyed during eradication. It furthermore 
outlines the extension of the scope of the EU reference laboratories system, financially supported by 
the EU to plant health and the provision of transitional EU financial support for the accreditation of the 
corresponding  national  reference  laboratories.  The  Commission's  proposal  for  the  2014-2020  MFF 
itself also underlines the need for an increased budget for plant health.  
The  new  Plant  Health  Law  (PHL)  will  replace  the  main  instrument  of  the  PHR,  which  is  Council 
Directive  2000/29/EC  on  protective  measures  against  the  introduction  into  the  Community  of 
organisms  harmful  to  plants  or  plant  products  and  against  their  spread  within  the  Community.  It  will 
also  replace  six  Council  Directives  for  the  control  of  specific  harmful  organisms,  and  will  affect  the 
phytosanitary acquis communautaire, covering at present more than 60 acts. 

Plant Reproductive Material (PRM) 
Based on the results of the evaluation of the European Union legislation on the marketing of seed and 
plant propagating material (PRM) conducted in 2007/2008 by the Food Chain Evaluation Consortium 
(FCEC), the Commission services developed a PRM Action Plan which was presented in 2009. They 
were followed by a study on variety registration conducted by the same consortium in 2010 and by a 
PRM certification study conducted by the Commission's services. 
The Impact Assessment on PRM was built on the results of these preparatory works, and focused on 
the simplification of the basic legal acts, on improving the effectiveness and efficiency of the system, 
and on horizontal coordination with recent, already adopted EU policies. 
In  particular,  the  current  legal  framework,  which  consists  of  a  horizontal  Council  Directive  on  the 
Common Catalogue of varieties of agricultural plant species and 11 vertical Council Directives on the 
marketing of commodities of seed and propagating material, is to be replaced by one single piece of 
legislation. 

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Official Controls for Feed and Food 
Regulation (EC) No. 882/2004 on Official Controls provides a harmonised framework of general rules 
for  the  official  controls  performed  to  ensure  the  verification  of  compliance  with  feed  and  food  law, 
animal health and animal welfare rules. 
In  September  2011,  a  report  examining  the  impacts  of  potential  revisions  to  this  Regulation  was 
published.  This  external  study  presents  results  of  the  research  conducted  and  impact  analysis  on 
options proposed by the Directorate-General for Health and Consumers to change the current system 
in order to improve shortcomings identified in an evaluation of the Regulation conducted in 2008. 
In July 2009 the Commission issued a report for the European Parliament and the Council to review 
the  experience  gained  throughout  the  first  years  of  application  of  Regulation  (EC)  No  882/2004.  It 
indicated  that  improvements  could  be  made  to  meet  the  Commission’s  Smart  Regulation  Agenda 
objective  of  simplifying  regulation.  This  would  also  address  the  issues  of  administrative  burden 
reduction and fostering competitiveness. 
 In addition, DG Health and Consumers has conducted further analysis on the alignment of other EU 
sectorial  legislation  on  official  controls  (animal  health,  plant  health,  plant  reproductive  material)  with 
the overarching principles established in the Regulation. 
These  works  led  to  the  development  of  an  Impact  Assessment,  addressing  shortcomings  stemming 
from  the  incomplete  implementation/achievement  of  certain  principles/objectives,  and  from  the  fact 
that the integrated approach to official controls is only partly consolidated. 
From the very start of the processes accompanying the package, key stakeholders, Member States' 
competent authorities, international organisations and trading partners have been closely involved and 
have  played  a  crucial  role  in  the  discussions.  In  addition,  in  accordance  with  the  Commission’s 
standards for consultation, economic and social stakeholders such as European associations with an 
interest in food and feed and the interested public have been consulted on a number of occasions. 

1.2.1 Multiannual Financial Framework 

On  29  June  2011,  the  European  Commission  presented  its  proposal  for  the  multi-annual  budget  for 
2014-2020  which  will  start  in  2014.  "A  Budget  for  Europe  2020"  is  aimed  to  respond  to  today's 
concerns  and  tomorrow's  needs,  and  focuses  on  priority  funding  at  the  EU  level  that  provides  true 
added  value.  This  upcoming  EU  budget  remains  focused:  the  overall  amount  proposed  for  the  next 
seven  years  is  €1,025  billion  in  commitments  (1.05%   of  the  EU  GNI)  and  €972.2  billion  (1%  of  EU 
GNI) in payments. The overall food safety budget €1.891bn from 2014 to 2020 (in current prices) has 
been proposed by the Commission as part of the overall MFF.  
As was made clear in a letter of 26 November 2010 to the President of the European Parliament and 
the President in office of the Council, the Commission indicated that it considers that:   
"European  added  value  is  a  key  test  to  justify  spending  at  EU  level  even  if  the  added  value  of  a 
political project cannot be reduced to a balance sheet".  
Therefore the general objectives of the initiative also include those laid out in the Commission working 
paper  discussing  the  necessity  for  added  value  in  the  new  Multiannual  Financial  Framework.  These 
concentrate on the necessity of added value in EU financial contributions2:  

•  The EU budget should focus on EU added value, meaning the delivery of objectives that can 
be  achieved  better  through  spending  at  EU  level  rather  than  at  the  level  of  the  individual 
Member  States.  The  design  of  both  the  Multiannual  Financial  Framework  and  the  sectorial 
instruments  and  programmes  should  be  such  that  the  contribution  of  the  expenditure  at  EU 
level is made obvious.  

•  EU added value should be prominent in areas of spending linked to the EU core competences 
(for example, agriculture, where more than 70% of total spending is at the EU level), or closing 
missing  links  (for  example,  key  cross  border  infrastructures  in  energy,  transport  and  ICT)  or 
because  the  issues  at  stake  are  of  such  a  magnitude  that  individual  actions  by  the  Member 
States would not meet the objectives (for example, large-scale research infrastructures or the 
combatting the consequences of climate change).  

•  Pooling resources at EU level should also generate economies of scale and better results than 
the same amounts separately spent at national levels (for example, in the areas of research or 
education mobility).  

2http://ec.europa.eu/budget/library/biblio/documents/fin_fwk1420/working_paper_added_value_EU_budget_SEC-
867_en.pdf  

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1.2.2 Consultations 

Due  to  the  limited  timescale  within  which  the  present  impact  assessment  has  been  developed,  no 
specific consultation was carried out to involve the stakeholders in the process. 
Nevertheless,  no  radical  changes  can  be  envisaged  at  this  stage,  in  keeping  with  the  formal 
consultations already conducted in the frame of the proposals of the "Healthier Animals and Plants for 
a  Safer  Food  Chain  Package".  These  are  considered  to  provide  sufficient  evidence  of  the  support 
expected by the interested parties. 
Moreover,  broad  discussions  carried  out  within  different  fora  (such  as  CVOs'  meetings,  Advisory 
Groups  and  Working  Groups  involving  both  representatives  of  national  authorities  and  experts  from 
the  private  sector)  also  demonstrate  the  overall  satisfaction  with  the  current  funding  policy  of  both 
public  authorities  and  the  private  sector,  therefore  any  major  change  to  the  current  approach  is  not 
considered necessary.  

1.3 Steering Groups 

This  impact  assessment  was  guided  by  an  internal  DG  Health  and  Consumers  steering  group.  An 
Impact  Assessment  Steering  Group  (IASG)  was  also  convened,  which  DG  Health  and  Consumers 
(SANCO)  chaired,  and  to  which  the  Secretariat-General  (SG),  Legal  Service  (SJ),  and  Directorate-
Generals for Budget (BUDG) and Agriculture and Rural Development (AGRI) were invited. The group 
met twice in September 2012.  

The  first  meeting  of  the  IASG  was  held  on  the  6th  September  2012  in  Brussels.    The  following  DGs 
participated  in  the  meeting:  SG,  SJ,  BUDG,  AGRI,  and  SANCO.  A  preliminary  discussion  on 
procedural  issues,  IA  objectives  and  policy  options  proposed  took  place;  particular  emphasis  was 
given  to  data  collection  needs.  Attendees  agreed  on  the  need  to  focus  the  further  assessment  on 
policy options 3(a) and 3(b), which are illustrated in Section 4. 
The  second  meeting  was  held  on  the  20th  September  in  Brussels.  DG  SANCO  chaired  the  meeting 
and  SG  and  DG  AGRI  participated.  A  draft  of  the  IA  was  discussed.  The  approach  was  broadly 
endorsed,  with  some  changes  requested,  particularly  the  better  alignment  of  objectives  with  the 
individual policy objectives. 
No third meeting was arranged, in agreement with the participants, as it was not considered necessary 
in the light of both the limited timescale available and the proportionate approach required to develop 
the present impact assessment. 

 1.4 Impact Assessment Board 

The  meeting  with  the  Impact  Assessment  Board  took  place  on  7th  November  2012.  Following  this 
discussion,  an  opinion  on  the  draft  IA  was  issued.  The  Board  stressed  the  need  to  strengthen  the 
report  by  focusing  on  five  main  recommendations  for  improvement.  The  main  comments  and  main 
changes made following the meeting are outlined in the table below: 

 (1) Identify the existing evaluation gaps. 

Describe in detailed how the 
existing budget is allocated and 
managed. 

Sections: 
-  2.1 
-  5.3.1 
Annex 1 

•  Overview of budget 

allocations per MSs and 
their evolution over time 
•  Examples of less successful 
interventions and lessons 
learnt 

•  Current eligibility conditions 

and funding rate 
mechanism 

Clarify which of the available 
(feasibility) studies, evaluations 
or audits providing adequate 
information about the cost-
effectiveness of past EU food 

•  Works indicating the added 
value of EU (co-)funding 

•  No cost-effectiveness 

analysis conducted so far 

•  Way forward towards a 

Sections: 
-  1.2 
-  1.2.1 
-  1.2.2 
-  1.3 

7 

 
 
 
 
 
 
 
 
 
 
 
 
and feed expenditure. 

systematic approach to 
monitoring and evaluation 

(2) Better explain the problems. 

More clearly spell out the need 
to reprioritise and re-allocate 
resources between the animal 
and plant health areas/activities 
in order to better address the 
major risks. 

Demonstrate the need for a 
separate food and feed 
emergency fund on top of the 
envisaged Global Agricultural 
Risk Management Fund and to 
finance training activities for 
third countries. 

•  Need for a flexible approach 
in planning the food safety 
expenditure 

•  Analysis conducted within 

other works of the "Healthier 
Animals and Plants for a 
Safer Food Chain Package" 
(e.g. more investments in 
preventions, increased 
attention to plant health) 
•  No major risks due to the 

current framework 
•  Need to access a "crisis 
reserve" to be recurred 
when ordinary emergency 
measures (e.g. "Veterinary 
emergency fund" for animal 
diseases) are not sufficient 
to deal with the emergency 

•  Need to prevent the 

entrance into or the spread 
within the EU borders of 
diseases and pests from 
neighbours countries. 

-  2.1 
-  2.2.2 
-  7 

Sections: 
-  2 

Sections: 
-  2.1 
-  2.2.1 
-  2.5 

Provide a detailed analysis of 
problems and issues related to 
the EU expenditure 
management, including high 
error rates. 

Better describe all the direct and 
indirect  beneficiaries  of  the  EU 
support and explain how and to 
what extent they are affected by 
the identified problems. 

•  No major problems affecting 
the current framework 

Sections: 
-  2 

•  No high error rates 
identified within this 
assessment or previous 
works 

•  Outline of indirect 

beneficiaries of the EU 
measures 

•  Further details already spelt 
out in the individual IAs of 
the package 

Sections: 
-  2.3 

(3) Better explain policy options and consider additional ones. 

Clearly  indicate  how  priorities 
will  be  set  and  how  the  budget 
will be allocated. 

•  Flexibility of the food safety 
expenditure: prioritising 
annually adjusted 
•  Nature of budgetary 

allocations per macro area 

Sections: 
-  2.1 

Annex 1 
Annex 2 

•  Overview of budgetary 
allocations since 2005 

•  Focus on Veterinary 

programmes 

Better explain the content of the 
envisaged Cost and 
Responsibility Sharing Schemes 

•  Overview of the assessment 
conducted only in the field 
of veterinary emergency 

Sections: 
-  4.3 
-  5.3.1 

8 

 
 
 
 
 
 
 
 
 
 
 
 
Annex 4 

Sections: 
-  1 
-  4 

and justify why the current 
standard co-financing rate 
should be increased. 

Present other, more realistic 
and diversified, policy options 
that would duly reflect the 
identified problems and their 
drivers and would imply re-
prioritisation and spending less 
on certain activities. 

Consider alternative delivery 
mechanisms related, for 
example, to the institutional set-
up, eligibility criteria such as the 
minimum size of the co-funded 
programmes, payment methods, 
fraud prevention, controls, etc. 

measures 

•  More consistency among 
funding rates across the 
funding areas 

•  Contribution to economic 

recovery 

•  Reformulation of the options 
proposed in the previous 
draft IA and their link to the 
problems/drivers identified 

•  No need to develop 

additional policy options in 
the light of the minor 
problems identified 

•  Limited timescale available 
since the request for the 
present IA 

•  No need to further develop 
the analysis given the 
absence of any major 
problem affecting the 
present framework 

(4) Improve the assessment and comparison of options. 

Assess and present the benefits 
of EU intervention with more 
caution, particularly in view of 
the lack of evidence on the cost-
effectiveness and added value 
of past food and feed 
expenditure. 

Indicate the budgetary impact 
on individual Member States 
and assess the economic 
impacts for different sectors and 
on SMEs in greater detail. 
Clarify when methodological 
tools to assess the impacts of 
EU intervention will become 
available and to what extent 
they might have an impact on 
the foreseen budgetary 
allocation, or result in different 
spending per Member State. 
Compare a wider set of 
alternative policy options in 
terms of effectiveness, 
efficiency as well as coherence. 

Sections: 
-  2.1 
-  2.2 

Sections: 
-  5.3.1 

Sections: 
-  7 

Sections: 
-  1 
-  2.2 

•  Clarification of the available 
information (notably internal 
and external works, 
consultations) providing 
evidence of the added value 
of the current food safety 
expenditure, given the 
absence of a cost-
effectiveness analysis  

•  Quantitative analysis 
conducted in terms of 
macro areas of expenditure 

•  New methodological tool 
available in the upcoming 
months: continuous and 
analytical evaluation of the 
cost-effectiveness of all 
actions implemented under 
the food and feed 
expenditure  

•  No need to develop and 
compare a wider set of 
policy alternatives in the 
light of the minor problems 
identified 

•  Limited timescale available 
since the request for the 
present IA 

9 

 
 
 
 
 
 
 
 
 
 
 
 
 
(5) Strengthen monitoring and evaluation. 

Sections: 
-  3 
-  4 
-  5 
-  7 

•  Outline of the ongoing work 
within DG Health and 
Consumers to develop and 
implement, with the 
cooperation of national 
public authorities, a 
systematic approach to 
monitor and evaluate the 
performance of all actions 
implemented in the frame of 
the food and feed 
expenditure. 

Set out concrete arrangements 
for monitoring, reporting and 
evaluation, taking due account 
of the respective responsibilities 
of all levels of government and 
actors involved. 
Re-define policy objectives in 
sufficiently concrete terms and 
define reliable monitoring 
indicators, including the 
benchmark against which their 
performance will be measured. 
Explain how data will be 
collected, by whom and at what 
point of time. 

Section 2: Problem definition 

EU  financial  support  for  food  safety,  animal  health,  plant  health  and  official  controls  has  been 
examined in a number of audits, studies and analyses. In light of the extensive consultation conducted 
within these tasks, the current system is generally considered to add monetary value over and above 
the amounts contributed and to work fairly well in its existing format. Nevertheless, it is acknowledged 
that the current financial framework in the food and feed area is not always supported by a systematic 
approach  to  carry  out  ad  hoc  evaluations,  so  a  cost-effectiveness  analysis  allowing  the  overall 
performance of the related expenditure to be assessed has not so far been implemented. Therefore, 
the revision of the overall Multiannual Financial Framework and of the individual policies presents an 
opportunity  to  assess  the  current  situation  and  look  at  how  it  could  be  improved  further,  as  well  as 
tying  it  more effectively  to the  objectives  of  the Commission and  the  EU,  including  the  Europe 2020 
goals. 
It is also important to recognise that there are a number of problems, reflected in the various sectorial 
impact assessments, some of which the financial support for the sectors can help to solve. These are 
outlined further below and must be borne in mind when developing objectives and solutions.  

2.1 Current policy and financial framework 

The 2011 food safety budget was just under €314.6m . The overwhelming majority of the EU co-funded 
activities have their legal basis in one of the three following pieces of legislation: 

• Council Decision 2009/470/EC (e.g. Veterinary Eradication Programmes, Veterinary Emergency 

measures) 

• Directive 2000/29/EC (e.g. Plant Health measures) 
• Regulation 882/2004 (e.g. EU Reference laboratories, Better Training for Safer Food) 

The  budget  is  split  between  several  different  budget  lines.  A  short  overview  of  spending  in  2011  is 
presented below in Table 1, and a breakdown of the budget over the period 2007-2011 is presented in 
Annex 1. 

As a snapshot of the EU food and feed expenditure, the amount executed in 2011 are given in Table 
1.  The  distribution  presented  above  reflects  the  latest  prioritisation  of  the  funding,  which  is  decided 
and adjusted  on  an  annual  basis  to  ensure  that  it  is  fully  appropriate  to  the prevailing situation.  The 
Commission,  with  the  Member  States,  regularly  assesses  the  changing  external  environment  to 
evaluate  the  need  to  adapt  the  budget  to  respond  better  to  coming  challenges;  and  priorities  are 
sometimes shifted accordingly. 

10 

 
 
 
 
 
 
 
 
 
 
 
 
 
Table 1: Food safety expenditure 2011 

Measures 
Veterinary Eradication, Monitoring and 
Control Programmes 
Veterinary Emergency Fund to MSs 
Plant Health Measures 

EU Reference Laboratories 
Better Training for Safer Food 
Other operational measures 

Administrative measures and 
miscellaneous 

Total 

Amount executed (€) 
238.0 m 

Legal basis 

Dec. 2009/470/EC 

10.0 m 
19.2 m 

14.3 m 
14.4 m 
16.0 m 

1.7 m 

314.6 m 

Dec. 2009/470/EC 
Dir. 2000/29/EC 
Reg. 882/2004 
Reg. 882/2004 
Reg. 882/2004 
Dec. 2009/470/EC 
Reg. 882/2004 
Various sectorial legal bases 

Nevertheless,  the  distribution  of  financial  allocations  to  the  macro-areas  presented  in  Table  1  have 
broadly  been  consistent  from  year  to  year,  as  confirmed  by  the  evolution  of  the  annual  budgets 
executed  since  2007  which  is  shown  in  Annex  1.  A  more  detailed  planning  of  these  items  far  in 
advance is not practical. Indeed, the expenditure within these areas is by its nature variable, as it has 
to be adjusted in keeping with a number of factors (not necessarily consisting in large emergencies); 
notably the epidemiological evolution, which is not easily predictable. Therefore, some inherent room 
for flexibility is considered essential when drafting a minute provisional multiannual budget. 

A focus on the total budget for Food and Feed executed in the year 2011 reveals that some 75% of 
the total budget for Food and Feed executed in the year 2011 was allocated to programmes for the 
eradication,  control  and  surveillance  of  animal  diseases  and  zoonoses,  henceforth  referred  to  as 
Veterinary  Programmes.  These  programmes  aim  to  progressively  eliminate  a  number  of  listed 
animal  diseases  which  are  endemic  in  certain  areas  of  the  Union,  by  means  of  a  wide  range  of 
measures including vaccination, testing of animals, and compensation for slaughtering or culling. EU 
funding  to  support  these  measures  is  allocated  according  to  priority,  whereby  the  greatest  weight  is 
given  to  diseases  of  public  health  importance  and  those  that  have  major  economic  impacts  due  to 
trade implications and income losses for farmers, for the wider livestock industry, as well as adjacent 
sectors (rural economy etc.). The rationale for intervention is therefore directly linked to the protection 
of animal health, human health in the case of zoonoses and, also, to the importance of the livestock 
sector in the EU.  

EU  co-funding  for  monitoring,  eradication  and  control  activities  for  some  animal  diseases  has  been 
available  and  distributed  to  Member  States  for  some  time.  This  is  the  case  for  the  monitoring 
programmes for classical swine fever (CSF), and the eradication measures for bovine brucellosis and 
bovine tuberculosis, and ovine and caprine brucellosis.  

During the 1990s, the co-funding of eradication and monitoring measures of these diseases made up 
more  than  80%  of  the  overall  EU  funding  on  the  programmes  and  the  financial  contribution  was 
distributed  among  roughly  ten  Member  States,  mainly  those  in  the  Mediterranean  area  (Spain,  Italy, 
Portugal, France) where most of these diseases were traditionally endemic.  

In  recent  years,  diseases such  as  avian  influenza  and  bluetongue  have  emerged,  or re-emerged,  in 
EU  territory. The  EU  has,  therefore,  extended  its financial contributions  to combat  and  monitor such 
diseases  and  an  increased  number  of  Member  States  have  benefited  from  this  co-funding.  At  the 
same time, EU policy to combat certain diseases  has evolved significantly with increasingly focused 
and targeted measures following new scientific insights into the epidemiology of each disease and the 
risks  of  introduction,  spread  and  transmission  to  humans  (e.g.  in  the  case  of  enzootic  salmonellosis 
and  Transmissible  Spongiform  Encephalopathy  (TSE)  programmes).  Current  ongoing  eradication, 
monitoring  and  control  programmes  involve  10  of  the  25  diseases  covered  by  EU  co-financing3, 

3 Council Decision 2009/470/EC - Annex I 

11 

 
 
 
 
 
 
 
 
 
 
 
 
                                                            
notably:  Brucellosis  (bovine,  ovine  and  caprine),  bovine  Tuberculosis,  Bluetongue,  Salmonellosis, 
African Swine Fever, Classical Swine Fever, Swine Vesicular Disease, Avian Influenza, Transmissible 
Spongiform Encephalopathies and Rabies. Examples of positive case studies regarding some of these 
diseases are presented in Annex 2, while the main reasons behind less successful stories are outlined 
in the next section (Added Value from EU co-financing). 

Almost  3.2%  of  the  Food  and  Feed  expenditure  was  allocated  through  EU  co-financing  to  Member 
States under animal health emergency measures in the event of outbreaks of certain listed epidemic 
livestock diseases. The current EU rules provide for co-financing (or complete funding) of the actual 
direct  costs  incurred  for  eligible  expenditure.  The  eligible  expenditure  comprises:  compensation  to 
owners for the market value of compulsorily slaughtered animals or destroyed eggs; the compulsory 
slaughter  of  animals;  the  destruction  of  carcasses  and/or  eggs;  the  cleaning  and  disinfection  of 
holdings;  the  destruction  of  contaminated  feed  stuffs  and/or  milk;  the  destruction  of  contaminated 
equipment; the purchase of vaccines; and vaccination. 

The  expenditure  for  Plant  Health  measures  represented  the  second  largest  item  funded  in  2011, 
amounting  to  6.1%  of  the  overall  allocation  for  Food  and  Feed.  It  mostly  relates  to  eradication 
measures,  and  to  the  containment  of  outbreaks  of  plant  pests  and  diseases.  The  EU  plant  health 
regime (PHR) is mainly aimed at protecting European agriculture and forestry by preventing the entry 
and  spread  of  non-native  harmful  organisms  (pests  and  pathogenic  micro-organisms),  by  securing 
safe  trade  by  the  establishment  of  EU  import  requirements  and  intra-EU  movement  conditions  for 
plants  and  plant  products.  Outbreaks  of  the  listed  organisms  have  to  be  eradicated  or,  if  that  is 
impossible,  contained  to  protect  the  rest  of  the  EU  territory.  A  second  objective  of  the  regime  is  to 
ensure  the  availability  and  use  of  healthy  plant  material  at  the  beginning  of  the  chain  of  plant 
production  by  preventing  the  spread  of  harmful  organisms  with  seeds  and  planting  material.  This 
objective  is  shared  with  the  EU  regime  for  plant  reproductive  (planting)  material,  whose  health  is 
critical to tackle organisms (e.g. viruses) against which no pesticides are available. 

More  than  4.5%  of  the  budget  considered  was  spent  to  finance  the  Commission  training  initiative 
Better  Training  for  Safer  Food.  It  is  focused  on  ensuring  harmonised  and  efficient  controls  by 
training national authorities in Member States, and in some cases, candidate countries, keeping them 
updated on EU law, with a view to ensuring and maintaining a high level of consumer protection and of 
animal health, animal welfare and plant health. It comprises programmes on different subjects related 
to  the  verification  of  compliance  with  food  and  feed  law,  animal  health  and  welfare  rules  and  plant 
health rules. In 2011, 151 training activities took place, involving some 6,100 participants. Moreover, 
29  thematic  programmes  were  carried  out,  8  of  which  took  place  in  targeted  third  Countries.  The 
number of training sessions, participants and thematic programmes has progressively increased in the 
last few years. Between 2006 and 2011, almost 25,000 people took part in the training. 

In  the  frame  of  official  controls,  another  4.5%  was  allocated  to  the  network  of  EU  Reference 
Laboratories (EURLs). The 47 EURLs have their tasks designated in EU legislation, and contribute to 
all  aspects  of  food  safety  by  providing  information  on  analysis  methods  and  organising  comparative 
tests  with  the  national  reference  laboratories,  coordinating  the  application  of  the  methods  and 
research into new analysis methods, organising training and advanced courses for national reference 
laboratory staff and providing scientific and technical assistance to the Commission.  
A  breakdown  of  the  last  5  years  of  the  food  safety  budget,  including  details  about  allocation  per 
Member State and their evolution over time, is available in Annex 1. An overview of how much is spent 
on prevention, surveillance, eradication and containment is also given. 

Added Value from EU co-financing: example case studies 
Most of the EU food safety budget is spent on veterinary programmes, which represent about 78% of 
recent spend. Case studies of seven of the ten diseases which are currently funded are presented in 
Annex  2.  These  have  been  partially  or  wholly  successfully  tackled  with  the  help  of  EU  veterinary 
programmes  and  co-financing.  In  the  first  case  study,  rabies  is  examined.  This  disease  has  been 
largely eliminated in Europe through a successful wildlife vaccination programme, virtually wiping out a 
significant public health risk. Salmonella is the subject of the second case study, demonstrating that 
the  compulsory  co-financed  control  programmes  implemented  since  2004  have  almost  halved  the 
number of human cases in the EU. BSE was a new and poorly understood disease in the 1980s, but 
since  then,  concerted  EU  action  has  almost  eradicated  it  in  Europe.  Trade  in  live  cattle,  beef  and 
12 

 
 
 
 
 
 
 
 
 
bovine  products  from  countries  most  affected  has  been  restored,  and  consumer  confidence  has 
returned. The fourth case study looks at bovine tuberculosis, a challenging disease to control because 
of its slow development and, in certain areas, wildlife reservoirs. Nevertheless, success has come in 
some areas: we concentrate on Spain, where the possibility of obtaining officially free status is close. 
Classical swine fever used to be endemic in the EU but has been virtually wiped out with the help of 
EU  co-financed  programmes.  Bovine  brucellosis  has  also  been  totally  eradicated  in  most  EU 
countries:  how  Ireland  gained  officially free  status  with  the  help  of  an  EU  co-financed  programme  is 
examined. Lastly, avian influenza, which has made increasing incursions into the EU in recent years 
through  wild  bird  spread,  has  been  successfully  contained  through  monitoring  and  surveillance; 
reducing  the  risk  of  both  economic  losses  to  farmers,  and  also  the  emergence  of  a  zoonotic  strain 
dangerous to humans. 
These are examples of virtuous cases providing evidence of the positive value for money offered by 
the implementation of EU veterinary programmes. 
On the other hand, as already anticipated, one deficiency affecting the current framework is the lack of 
a  systematic  approach  to  the  monitoring  and  evaluation  of  the  performance  of  the  measures 
implemented  in  the  frame  of  the  food  safety  expenditure,  including  the  veterinary  programmes. 
Therefore, as will be further explained in Section 2.2, the ability to demonstrate the effectiveness of the 
financial management is sometimes limited. 
Taking into account this lack of cost-effectiveness tools, a continuous evaluation of the programmes 
co-financed at EU level is nevertheless possible, and has been conducted in the last few years. This 
evaluation  has  been  based  on  tangible  results  of  EU  action  to  support  the  MSs  in  eradicating, 
controlling and monitoring certain animal diseases. These studies have shown the overall success of 
the  veterinary  programmes  but  also  highlighted  some  less  virtuous  stories  where  particular 
implementation issues adversely affected the performance of the programme. 
Many veterinary programmes, especially eradication activities, are by their nature long-term, therefore 
results are often achieved a long time after the implementation of specific measures. For example, the 
eradication of tuberculosis, which cannot be tackled by means of a large-scale vaccination campaign, 
is likely to require a period exceeding ten years to be completed. Therefore, a proper evaluation can 
only be carried out in the medium to long term. 
Unfortunately,  there  are  also  stories  of  lower  performance  of  programmes  co-financed  by  the  EU; 
these cases are almost always due to problems with implementation at national level. 
The  Member  States  affected  often  face  structural  difficulties  such  as  budgetary  problems  or  staffing 
issues  (insufficient  staff  or  inappropriate  allocation  of  staff)  which,  despite  all  efforts,  hamper  the 
proper implementation of the defined actions. From the EU point of view, it is opportune to recognise 
that  these  difficulties  at  national  level  can  be  accentuated  by  the  ungainliness  of  the  co-funding 
system, which sometimes takes some time to reimburse programmes already implemented. 
It  can  also  be  that  these  failures  are  attributable  to  socio-cultural  issues,  such  as  inadequate 
coordination between national and regional/local players, or lack of dialogue (communication) between 
public and private sector. An improved commitment by the Member States is essential to resolve these 
issues. 
It  is  also  important  to  note  that,  where  programmes  have  failed  to  perform  due  to  poor  or  incorrect 
implementation  at  Member  State  level  (central,  regional  or  local  level),  the  Commission  has  taken 
effective corrective action or imposed penalties in terms of not approving the programme or reducing 
the funding in subsequent years. 
An  example  of  this  is  the  eradication  of  brucellosis  in  sheep  and  goats  in  Greece:  the  Commission 
approved  programmes  during  the  period  2005-2007  and  in  2009  (in  2008  and  2010  Greece  did  not 
submit a brucellosis eradication programme for sheep and goats).  Due to the poor implementation of 
the programme a 100% penalty was applied subsequently and no payments were made. 
In  the  light  of  this  unsuccessful  experience,  the  recent  decision  of  the  Commission  to  reapprove  a 
programme for 2011, 2012 and 2013, was only possible on the condition of a clear commitment from 
Greece  to  cooperate  in  implementing  the  action  agreed,  but  also  thanks  to  the  EU  engagement  to 
meet  Greece  halfway  by  providing  it  with  additional  staff  (only  for  2013)  to  make  up  for  the  lack  of 
human resources at national level. 

2.2 Problem identification 

As  already  mentioned,  the  present  revision  mostly  addresses  the  need  to  adjust  the  legal  current 
framework  to  the  financial  requirements  of  the  new  MFF  2014-2020  (Driver  1).  In  addition,  it 

13 

 
 
 
 
 
 
represents  an  opportunity  to  introduce  some  improvements  to  cope  with  a  few  minor  drawbacks 
affecting the current financial management tools (Driver 2). 
The  problems  of  the  current  financial  framework  are  partly  due  to  the  changed  sectorial  needs 
identified in the respective policy reviews, which are about to be set out in new Commission proposals. 
Those needs should be reflected in the future financial legislation and in its implementing tools. The 
justification for those changes has been extensively provided in the sectorial impact assessments and 
is simply summarised here (Driver 3). 

2.2.1.  Driver  1  –  Legislative  framework:  The  current  legal  framework  is  over-complex  and 
sometimes out of date 

Problems: 

•  Lack of alignment with the newly proposed MFF 2014-2020 
•  Potential  administrative  burdens  for  MSs  in  keeping  up  to  date  and  fully  complying  with 

administrative and funding requirements. 

a)  The  current  revision  of  the  financial  framework  through  the  introduction  of  the  new  Multiannual 
Financial Framework will remove the 'food safety' budget lines (which cover all the animal health, 
plant  health  and  official  controls  spending  in  question)  from  Heading  2  of  the  overall  EU  budget 
'Preservation  and  Management  of  Natural  Resources',  which  includes  the  Common  Agricultural 
Policy  budgets.  They  will  be  moved  into  Heading  3,  to  be  called  'Security  and  Citizenship'.  This 
means  that  the  current  legal  base  for  financial  controls  and  management  of  funding  (Regulation 
1205/2005) will no longer cover food and feed spending. 

-  Therefore  a  new  legal  basis  would  be  needed  to  ensure  that  the  new  proposed  budget  of 

€1.891bn  over  seven  years  is  managed  and  audited  in  line  with  legal  requirements  and  good 
practice. 

b)  Moreover, the move from Heading 2 to Heading 3 will mean that should severe emergencies arise 
requiring  EU  financial  support,  there  will  legally  be  no  access  to  the  'Reserve  for  crises  in  the 
agricultural sector'. This access would be crucial to support MSs in the case of a large-scale crisis 
- such as that on the scale of the Foot and Mouth Disease crisis in 2001 – in which the Veterinary 
emergency measures (as concerns animal diseases) would not provide the countries concerned 
with enough financial support to face the situation. It is important to note that the "crisis reserve" 
under consideration, whose activation requires a complex procedure involving both the European 
Parliament and the Council, does not offer as much flexibility as the reimbursements allocated to 
the  MSs  under  the  emergency  fund,  which  can  be  speedily  and  straightforwardly  approved  as 
soon as the outbreak is reported. Therefore, the reserve is not suitable as a replacement for the 
emergency measures - which  ensure  prompt  intervention  when  an  outbreak  occurs -  but  should 
be  resorted  to  in  order  to  supplement  the  emergency  measures  when  they  are  not  sufficient  to 
deal with a very large crisis.  

-  Both the Commission and the Member States would suffer from the lack of certainty about access 

to the crisis reserve in a large crisis, especially in the current economic climate. 

c)  The  current  legislative  framework  is  not  fully  compliant  with  the  Financial  Regulation  and 

implementing rules applicable to the general budget of the European Communities. 

−  Therefore  an  alignment  to  the  provision  of  Title  VI  (grants)  by  means  of  the  proposed  financial 

regulation covering the food and feed spending is needed.  

d)  The provisions regarding the various financial provisions supporting food and feed safety, animal 
health,  plant  health  and  official  controls  are  currently  found  in  a  number  of  different  legislative 
instruments, some having a very old legal base, such as Council Decision 2009/470/EC, which is 
a re-cast of Council Decision 90/424/EEC. 

-  This  in  itself  can  be  confusing  and  unwieldy  for  MSs  seeking  to  understand  the  legislation,  with 

associated administrative burden.  

e)  Aside  from  the  context  of  the  MFF  and  the  current  disparate  legal  framework,  there  is  also  the 
problem  of  the  changing  sectorial  legislation.  The  current  package  being  worked  on  will  make 

14 

 
 
 
 
 
 
 
  
 
 
 
certain changes to animal health, plant health, PRM and official controls legislation, some of them 
very significant. 

-  Without the according changes to the financial provisions, they will remain unaligned to the new 

objectives and measures in the policy legislation.  

2.2.2.  Driver  2  –  Operational  framework:  The  existing  financial  management  tools  are  not 
optimal 

Problems: 

•  Lack of clarity in eligible measures for funding and their costs 
•  Complex administrative arrangements 
• 

Inefficient allocation of available resources 

a)  Current standards expect the Commission to be able to explain clearly and transparently what the 
EU  budget  is  for  and  how  it  will  be  used,  and  the  current  legislation  does  not  fully  meet  this 
criteria. Following the revision of the MFF, all budgets should be better aligned with it in order that 
they can be better managed using programme methods. 

-  The food and feed financial budgets are not currently time limited and would not sufficiently align 

with these new requirements.  

b)  At present, many of the administrative arrangements for gaining programme approval and funding 
reimbursement  are  overly  complex.  For  example,  there  are  around  140  Commission  decisions 
the  veterinary 
required  annually 
programmes. In addition, several of the programmes are worth very little, many less than €50,000. 

to  approve  reimbursement  decisions  associated  with 

-  This  takes  a significant  amount  of  time,  effort  and bureaucracy.  Moreover,  it  is  doubtful whether 
the time and effort put into administering tiny programmes outweighs the benefits gained from co-
financing. 

c)  The  financial  provisions  at  present  do  not  set  the  most  clear  and  consistent  objectives  and 
performance indicators to evaluate the cost-effectiveness of EU measures implemented within the 
food and feed policy. 

-  This means that the food and feed spending cannot always be consistently assessed, prioritised 

and improved. 

d)  The definition of eligible measures and associated costs are not as clear and simple as they could 
be.  In  particular,  eligible  measures  and  funding  rates  are  scattered  across  different  regulations. 
For  example,  for  the  Plant  Health  Emergency  measures  and  the  Emergency  Veterinary  Fund,  a 
2012 internal audit report recommended that they be clarified and simplified. 

-  These factors contribute to the over-complexity of the system  

e)  The  current  lack  of  consistency  in  funding  rates  presents  Member  States  with  a  great  deal  of 
uncertainty  when  planning  programmes.  For  example,  for  the  veterinary  and  emergency 
programmes, the compensation rate for slaughtered animals was 50% for most diseases, 60% for 
FMD, whereas other measures had no fixed rate and varied over time. Plant health measures had 
a  basic  rate  of  50%  but  with  the  possibility  of  derogation  which  meant  that  certain  procedures 
could  be  funded  at  higher  rates.  For  example,  the  pinewood  nematode  programme  in  Portugal 
was funded at 75%. 

−  This  situation  is  unsettling  and  difficult  to  deal  with,  and  is  likely  to  create  an  additional 
administrative  burden  for  MSs;  therefore  it  could  be  rationalised  by  means  of  a  harmonised 
approach. 

f)  A  recent  survey  of  MSs  representatives  found  that  the  multiannual  and  annual  programme 
planning framework is regarded as burdensome. The annual cycle of plan preparation, appraisal, 
approval, adoption and reporting is resource-intensive and involves a high degree of year-on-year 
repetition.  In  addition,  there  is  a  general  lack  of  visibility  and  clarity  in  Member  States’  medium 
term programme objectives, and some perceived imprecision in the criteria used to evaluate plans 
at EU level. 

15 

 
 
 
 
 
 
 
 
 
 
 
 
 
2.2.3. Driver 3 – Policy framework: Current tools are not sufficiently focused to guarantee the 
achievement of food safety objectives 

Problems: 

•  Sub-optimal implementation of individual policies and risk of not fully achieving overall policy 

objectives 

DG Health and Consumers internal audits and reports, as well as the impact assessments carried out 
for the individual policy areas, have identified a few issues relating to the existing framework that could 
be improved to better support policy objectives.  
The  plant  health  law  impact  assessment  identified  that  an  increased  EU  financial  support  for  plant 
health would pay back several times over in wider economic benefits. This included direct support for 
surveillance  and  associated  measures;  and  the  expansion  of  the  scope  of  the  EU  Reference 
Laboratories  to  include  plant  health  work.  In  addition,  the  official  controls  impact  assessment 
concluded that there was a similar case to be made for expanding the scope of the Better Training for 
Safer Food initiative.  
While at an aggregate level, the EU programmes have offered good value for money, the Commission 
could  better  formalise  the  process  of  evaluating  and  approving  MS  programme  plans  (which  has 
already started to happen but could be improved further). Member States themselves when consulted 
stated  that  funding  criteria,  data  management  and  payment  processing  were  the  three  areas  where 
they most wanted to see changes to the current model of veterinary programmes. By their very nature, 
veterinary programmes are long term investments.  
All  of  these  factors  link  to  problems  listed  under  the  financial  driver  (2.2.2),  and  ought  to  be 
consistently  reflected  in  the  legislation.  For  instance,  the  lack  of  a  clear  and  consistent  set  of 
objectives and indicators means that the programmes which benefit from EU co-financing are at risk of 
under-achieving  compared  to  the  objectives  which  are  set  out  for  the  policy  areas,  and  resources 
being spent in a sub-optimal way. 

2.3 Who is affected by the current policy? 

The  current  financial  framework  primarily  affects  Member  States  and  their  competent  authorities,  as 
they are the direct beneficiaries of the financial support. As thoroughly presented within each IA of the 
"Healthier Animals and Plants for a Safer Food Chain Package", there is also a wide range of indirect 
impacts linked to the EU measures implemented under the food safety policy, affecting the following 
categories of stakeholders: 
• 

stakeholders  involved  in  keeping  live  animals  and  in  the  production  of,  trade  in,  and  import  or 
export  of  live  animals,  animal  products  and  products  of  animal  origin,  non-commercial  animal 
keepers and holdings such as pet owners, zoos, backyard farmers, and hobby farmers; 
farmers, growers, traders in agriculture, horticulture, forestry, the wood industries, wood packaging 
material industries, logistics industries and industry and trade at large; 

• 

•  breeders of plant varieties, PRM suppliers and users; 
•  business operators within the food chain; 
• 

landscape  managers,  citizens,  environmental  NGOs  and  other  parties  interested  in  the 
conservation of the natural environment, landscape and public and private green; 
trading partners and competent authorities in third countries as they have to comply with the EU's 
import  conditions  for  live  animals,  animal  products  and  products  of  animal  origin,  the  EU 
provisions  and  pay  for  export  controls  and  issuance  of  phytosanitary  certificates,  and  have  to 
perform controls prior to export to the EU; 
veterinarians,  both  official  (state)  or  private,  other  veterinary  professionals,  technicians  and  the 
wider veterinary industries; 
consumers both in the EU and outside the EU, as they are the ultimate beneficiaries of measures 
to ensure the safety and quality of the food chain. 

• 

• 

• 

2.4 How would the problems evolve, all things being equal? 

The current financial framework would become problematic to manage by the start of 2014 because of 
the following factors. 

16 

 
 
 
 
 
 
 
 
 
 
Linked to the first set of problems, the primary difficulty would be the absence of a legal base covering 
the  food  and  feed  expenditure  after  its  move  from  Heading  2  to  Heading  3,  and  allowing  it  to  be 
controlled and managed. In addition, there would be no legal base for access to the 'reserve for crisis 
in the agricultural sector' in the case of large crises. In addition, the financial framework will not be fully 
compliant with the Financial Regulation, notably with Title VI (grants).  
As  concerns  the  second  set  of  problems,  the  lack  of  clarity  regarding  eligible  measures  and  the 
objectives  and  indicators  for  the  framework  would  continue  to  jeopardise  the  correct  monitoring  and 
evaluation of the measures implemented and hamper the effective prioritisation and planning of future 
expenditure. 
Linked to the third set, other minor problems identified through various evaluations, including those in 
the impact assessments, will continue.  

2.5 International dimension  

International governance 
EU membership of international bodies and its commitment to international agreements, such as the 
OIE Health Code, the International Plant Protection Convention, the WTO Sanitary and Phytosanitary 
Agreement and the OECD seed scheme, also ensures that the EU is responsible for maintaining an 
adequate legal framework consistent with international standards, guidelines and recommendations. 

Third Countries 
Another international dimension is the possibility of spending limited and targeted EU feed and food 
budgets in programmes in third countries. This has been done in the past, where a clear case can be 
made that the programmes would not be otherwise developed, and there is a clear benefit for the EU. 
This  should  continue  to  be  the  case  in  the  new  MFF.  For  example,  rabies  control  in  bordering 
countries to the EU is usually managed by the neighbouring EU MS in order to ensure compliance with 
the overall rabies measures, and ensure a buffer zone between the remaining infected areas and EU 
territory, and so reduce the risk of incursions.  

The Importance of Trade 
However, the most important international dimension is undoubtedly the value of the EU's production 
and the importance of trade. The production value at basic price for crop output in the Union in 2011 
was €205 billion and for animal output €156 billion. 
The  EU  is  the  world's  largest  exporter and  importer of  food  and drink  products.  In  2010,  EU27  food 
and beverages imports were worth € 78 billion, and exports €73 billion. 
The EU27 imported 79.3 million tonnes of food and live animals and 3.4 million tonnes of beverages in 
2010,  with  a  trade  deficit  of  14  million  tonnes  for  food  and  live  animals,  but  a  surplus  of  6  million 
tonnes  for  beverages.  These  figures  explain  how  important  it  is  for  the  EU  economy  to  encourage 
certain importing countries to meet the EU safety standards for food and feed, notably by means of the 
BTSF programme.  
The  EU  is  the  world's  largest  exporter  of  PRM  with  an  estimated  export  value  of  €4.4  billion 
representing roughly 60% of the total worldwide PRM export value of €7.7 billion.  
Included  in  these  overall figures,  in  2010  the  EU  exported  €1.5  billi on  of  live  animals,  €6.6 billion  of 
meat, €8 billion of dairy produ cts and birds' eggs, €2.9 billion of fish , €9.5 billion of cereals, €8.8 billion 
of vegetables and fruit and €2.9 of feeding stuff for animals.  
The  EU's  ability  to  export  to  third  countries  relies  on  its  continued  reputation  of  high  production 
standards  and  added  value  in  EU  goods  compared  to  those  produced  outside  Europe.  As  regards 
imports, it is essential that all products on the EU market covered by Union food safety legislation are 
safe. This can only be achieved by a reliable and trusted official controls system which ensures that 
the  relevant  EU  safety  and  quality  standards  are  consistently  enforced  and  corresponding 
expectations from trade partners met (for EU exports) and that goods arriving from third countries offer 
adequate guarantees of meeting equivalent safety levels (for EU imports).  
The  various  EU  initiatives  under  the  auspices  of  the  food  safety  budget  contribute  to  ensuring  that 
MSs  can  continue  to  trade  animals  and  animal  products  effectively  and  with  as  few  restrictions  as 
possible. This is an important contribution to the EU's economic recovery.  

The impact on trade in the case of disease outbreaks is demonstrated by a couple of very recent case 
studies:  

17 

 
 
 
 
 
 
 
 
 
 
Schmallenberg virus

The  Schmallenberg  virus  (SBV)  is  an  example  of  how  the  appearance  of  an  "unknown"  virus  and  diseased 
animals have the potential to greatly impact on trade and how a quick reaction from the EU was needed to 
minimise this impact. 

In November 2011 Germany isolated (for the first time in the EU) a new virus that was identified as belonging 
to the family Orthobunyavirus, serogroup Simbu. It was given the name "Schmallenberg", after the first place 
where  it  was  found.  Later,  the  virus  was  also  confirmed  in  the  Netherlands,  Belgium,  Germany,  United 
Kingdom,  France,  Luxembourg,  Italy,  Spain,  Denmark,  Poland  and  Austria.  From  early  February,  several 
trading  partners (e.g.  US  and  Russian  Federation)  started  taking  temporary  protective  measures  including 
trade restrictions and requested additional guarantees for certain commodities (i.e. live animals, semen and 
embryos,) awaiting further scientific knowledge before resuming trade. 

The Commission together with the MS identified the priorities and areas for which additional information was 
urgently needed to establish disease control measures. Some of the affected MS started to carry out scientific 
studies to improve knowledge about this virus and requested EU financial support. The Commission was able 
to very quickly allocate almost €3m to support 7 Member States to carry out 14 scientific studies to gather 
further information on the virus. (Commission Decision 2012/349/EU). 

As a result of this, it has been confirmed that SBV has a very minor impact on livestock production, the risk of 
infection  to  humans  from  direct  contact  or  products  is  negligible.  Since  then,  some  countries  have  already 
lifted trade restrictions, and the EU is in the process of agreeing with others to do the same.  

E-Coli

The 2011 outbreak of e-coli, primarily in Germany, demonstrates the impact of a loss of consumer confidence 
and trade restrictions when an outbreak occurs. Although not a direct animal disease or plant disease or pest, 
the direct parallels with a possible outbreak in one of those areas are evident, especially those with serious 
effects on humans.  

From  May  to  July  2011,  a  major  outbreak  due  to  the  contamination  of  sprouted  seeds  by  Shiga  toxin-
producing Escherichia coli (STEC) O104:H4 occurred in clusters in the north of Germany and in the Bordeaux 
region in France. The outbreak started in Germany at the beginning of May and reached a peak on 22 May 
2011. It ultimately led to 4010 cases, including 55 deaths. 

As  soon  as  the  first  cases  were  notified  by  Germany,  the  Commission  launched  appropriate  emergency 
procedures. The European Commission coordinated the response to the outbreak at EU level and was assisted 
by  the  ECDC,  and  the  European  Food  Safety  Authority  (EFSA).  The  EU  reference  laboratory  (EURL)  for 
Escherichia coli (E. coli) played a crucial role in the identification and management of the outbreak; providing 
risk assessment, advice in preventative measures, exchange of best practice in treatment, the development of 
a much quicker method for detection, and other epidemiological assistance.  

The losses for farmers in the fruit & vegetable sector were estimated to be at least €812m in the first 2 weeks 
alone  (source:  Copa-Cogeca).  In  addition  a  temporary  export  ban  of  vegetables  to  Russia  occurred, 
constituting an annual value of €600m. The Commission supported the sector with exceptional measures on 
market intervention with a total value of €227m. This was a previously unforeseen burden on the EU budget. 
Such measures concerned the products most directly affected by the crisis, i.e. tomatoes, cucumbers, lettuces 
and certain endives, courgettes and sweet peppers. Sales dropped significantly as consumers stopped buying 
these  vegetables  because  of  uncertainty  as  to  the  source  of  the  outbreak,  and  recommendations  not  to 
18 
consume these products raw. 

Following the confirmation of the source of the outbreak and its control, trade restrictions were subsequently 
lifted and consumer confidence has largely been restored.  

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
2.6 The right and justification for EU action 

The EU has the right to act in all of these areas, but not exclusive competence. MSs are also free to 
take their own measures regarding the financial support of animal health, plant health, official controls 
or  feed  and  food  objectives,  provided  that  they  do  not  interfere  with  other  EU  regulations,  such  as 
those governing the internal market and State Aid.  

2.6.1. Treaty basis 

There are a number of relevant treaty articles:   
•  Article 43 provides the basis for the EU legislative measures on the Common Agricultural Policy. 
The objectives of that policy are to increase agricultural productivity, to ensure a fair standard of 
living for the agricultural community, to stabilise markets, to assure the availability of supplies and 
to  ensure  that  supplies  reach  consumers  at  reasonable  prices.  The  Lisbon  Treaty  qualifies 
agriculture as shared competence between the EU and its Member States. It is obvious, however, 
that to a very large extent all fields of agricultural activity as well as ancillary activities upstream 
and  downstream,  have  been  regulated  at  the  EU  level.  This  means  that  legislation  is 
predominantly a role for the institutions of the European Union. 

•  Article 114 provides the legal basis for the establishment and functioning of the internal market 
and the approximation of provisions laid down by the law, regulation or administrative actions in 
this respect. 

•  Article 168 on health protection refers to the protection of human health from all causes that may 
damage it, including those related to animal health. The legal basis for veterinary and plant health 
measures  directly  aimed  at  protecting  public  health  were  adopted  under  the  co-decision 
procedure as a result of this article.  

•  Article  191  states  as  the  objectives  of  EU  environment  policy  the  preservation  of  the 
environment, the prudent and rational use of natural resources as well as promoting measures at 
international level to deal with environmental problems. 

2.6.2. Subsidiarity Test  

2.6.2.1. Necessity test - Why can the objectives not be achieved by MSs? 

In very general terms, good animal health, plant health, food safety and feed safety generates not only 
private benefits for the stakeholders concerned, but is a public good with wider societal benefits.  
This is particularly true for the spread of diseases and pests. Co-operation in management and control 
measures is virtually always essential to limiting and defeating the problem. Diseases and pests do not 
respect national borders, and can easily spread across them. Where there is a risk of this happening, 
or  a  case  of  it  having  happened,  MSs  must  act  together,  using  similar  or  identical  control  and 
management  measures,  in  order  to  have  an  impact  on  the  disease.  Reflecting  this  approach,  EU 
legislation has introduced harmonised rules which apply to all MSs.  
In addition, coordination at EU level allows for cheaper action on EU priorities, making it more effective 
and  less  expensive  than  actions  by  individual  MSs.  Both  animal  diseases  and  plant  pests  are 
independently  mobile  and  cross-border  effects  can  occur  not  only  through  intra-EU  movement  of 
commodities  but  also  via  natural  spread;  therefore  they  need  to  be  addressed  comprehensively. 
Inaction in one MS may result in spread to others. Third country trade partners might also implement 
restrictions on imports from the EU as a whole if an outbreak or safety problem in one of the MSs is 
not properly eradicated or resolved. 

2.6.2.2. Added value test - Can objectives be better achieved by the EU? 

The specific added value of EU financing or co-financing is that it provides incentives to MSs to put in 
place and support eradication and surveillance actions which are in the long-term interest of the Union 
as a whole. Large-scale eradication actions by MSs, including emergency measures could be difficult 
without EU support in view of the large costs incurred by the individual MS to the benefit of the EU, 
even  if  the  overall  cost/benefit  for  the  Union  as  a  whole  would  be  clearly  positive.  This  requires 
solidarity between MSs in sharing the costs and burden. If there were no measures at all at EU level, 
27 systems instead of one would be in place. This would pose significant obstacles to movement on 
the internal market and would likely increase the financial burden associated with controls on health 
and quality.  

19 

 
 
 
 
 
 
 
 
 
 
But why support eradication and emergency actions in the first place? There are a number of reasons 
why the EU intervenes to support better and safer food and feed, including reducing animal and plant 
disease.  For  example,  this  flow  diagram  (Figure  1)  shows  the  various  reasons  why  intervention  is 
considered relevant and important for animal diseases, and gives some idea of the possible impacts if 
they  are  left  alone.  Different  diseases  have  different  impacts  and  profiles,  and  there  are  different 
reasons why we might intervene. For example, although salmonella will cause some direct economic 
losses  for  operators,  the  primary  reasons  for  controlling  it  are  because  of  its  direct  threat  to  public 
health, and the indirect impact on trade if serious or prolonged outbreaks occur. On the other hand, a 
disease  like  Foot  and  Mouth  is  epidemic  by  nature,  spreading  extremely  quickly  and  requiring 
immediate  control  measures.  The  primary  reasons  for  controlling  it  are  that  it  causes  direct  and 
potentially  enormous  economic  loss  to the  farmer  through natural  losses  and culling  for control;  and 
lower  production  output  should  the  disease  be  uncontrolled  and  animals  recover.  Its  occurrence  will 
provoke serious and immediate trade embargos. 
The specific added value of the EU co-financing of the plant health regime is that it provides incentives 
to MS who put in place eradication and surveillance actions which are in the long-term interest of the 
Union as a whole. Large-scale eradication actions  by MS for outbreaks could be difficult without EU 
support in view of the large costs incurred by the individual MS to the benefit of the EU, even if the 
overall cost/benefit for the Union as a whole would be clearly positive. This requires solidarity between 
MS  in  sharing  the  costs  and  burden.  The  current  example  of  the  pine  wood  nematode  outbreaks  in 
Portugal and Spain demonstrates that EU plant health co-financing budget is crucial to implementing 
the eradication and containment measures which cause damage to Portuguese and Spanish forestry, 
however  are  essential  to  protect  forestry  in  the  other  25  MSs.  The  impact  assessment  for  the  plant 
health review specifically addressed the Union added value of expenditures in this area and concluded 
that  increased  investment  in  this  area  would  result  in  significant  overall  long-term  savings  for  the 
Union. 

Figure 1 

Why do we try 
to eradicate 
animal disease?

Compliance with 
international 
legal standards

Consequences of 
animal disease

Public health

Eg: salmonella

Direct economic 
losses

Eg: FMD

Environmental/ 
ecosystem 
impacts

Loss of consumer 
confidence

Eg: BSE

Impacts on trade

Direct

Indirect

Internal market

Eg: Blue Tongue

Export markets

Eg: Schmallenberg

The  benefits  of  EU  rules  for  the  prevention,  notification,  control  and  eradication  of  plant  pests  and 
animal  diseases  have  been  demonstrated,  respectively,  by  the  appearance  of  plant  pests  and 
occurrence  of  animal  disease  outbreaks  in  recent  times.  The  response  to  these  crises,  examples  of 
which are provided in the Animal Health Law and Plant Health Law impact assessments, showed the 
EU's capability to react quickly, limiting the spread of pests and diseases and minimising their impacts. 
This  was  largely  due  to  the  harmonised  approach  to  controls,  including  providing  financial 
compensation  for  losses  due  to  eradication  measures.  The  current  system  also  enables  the 
development of sustainable surveillance and monitoring programmes by providing co-financing at EU 
level. 

20 

 
 
 
 
 
 
 
 
For  example,  a  2011  report4  undertaken  by  the  Food  Chain  Evaluation  Consortium  (FCEC)  in 
conjunction  with  three  independent  consultants,  which  looked  at  the  outcome  of  the  EU  co-financed 
animal disease eradication and monitoring programmes, concluded that, "the programmes continue to 
play  a  crucial  role  in  the  effective  management  of  the  targeted  animal  diseases  […]  this  […]  offers 
clear  net  economic  benefits  to  the  relevant  sectors  and  stakeholders,  as  well  as  the  protection  of 
consumers and public health." 

The EURLs are also a key part of co-ordinated EU action. The shared resource enables MSs to rely 
on shared and consistent best practice being developed across MSs. This ensures that a consistent 
approach is taken to all aspects of the scientific support of food safety objectives. For example, during 
the e-coli outbreak in 2011 mentioned above, the EURL was crucial to developing a faster detection 
method, providing risk assessments, advice on preventative measures, and exchange of best practice 
in  treatment;  as  well  as  other  epidemiological  assistance.  Given  the  cross-border  nature  of  this 
outbreak, a co-ordinated approach was essential to both detecting and eliminating the outbreak, and 
to limiting the number of cases and loss of life. 

Overall,  the  approach  followed  at  EU  level  to  financially  support  activities  under  the  food  and  feed 
policy  meets  the  expectations  of  all  interested  parties  in  the  MSs.  The  satisfaction  of  the  public 
authorities and the private sector stakeholders with the current funding system in this area has been 
confirmed  through  the  dialogue  constantly  carried  out  at  EU  level,  both  formally  and  informally,  with 
these parties. 

Section 3: Objectives 

3.1 General Objectives 

Financial  instruments  should  be  part  of  EU  budget  interventions  in  internal  policies  pursuing  the 
following objectives, as set out in the Commission working paper accompanying the new Multiannual 
Financial Framework5, and with the EU 2020 priorities:  

Figure 2: EU2020 priorities for Health and Consumers (SANCO compilation) 

4http://ec.europa.eu/food/animal/diseases/eradication/docs/fcec_report_ah_eradication_and_monitoring_program
mes.pdf  
5 http://ec.europa.eu/budget/library/biblio/documents/fin_fwk1420/SEC-868_en.pdf  

21 

 
 
 
 
 
 
 
 
 
 
 
 
 
  
 
                                                            
The general objective of the regulation itself will be:  

•  Expenditure covered by this Regulation shall aim to ensure a high level of health for humans, 
animals and plants along the food chain and in related areas and a high level of protection for 
consumers  and  the  environment  while  enabling  the  EU  food  industry  to  operate  in  an 
environment favouring competitiveness and the creation of jobs. 

3.2 Specific objectives 

1.  To  establish  a  single,  clear  and  modern  legal  framework  fit  for  purpose  to  manage  the 
food  and  feed  expenditure  budget  lines,  including  animal  health,  plant  health  and  official 
controls.  

2.  To  optimise  the 

implementation  and  the  functioning  of  financial  management 

instruments. 

3.  To support the policy objectives laid out in feed and food legislation through the effective 

and efficient distribution of the budget.   

3.3 Operational Objectives 

1.  The modernisation and simplification of the present legal framework has to be achieved through: 

a.  defining a common legal basis, replacing the current multiple legal bases; 
b.  establishing a harmonised legal basis, to cope with the move of food and feed expenditure 
from Heading 2 (Agriculture) to Heading 3 (Security and Citizenship) of the EU budget; 
c.  ensuring continued access to the "Reserve for crisis in the agriculture sector", to resort to 

in case of large scale emergencies; 

d.  aligning EU financial instruments in the field of food and feed to the Financial Regulation. 

2.  The optimisation of the financial management tools will be pursued by: 

a.  simplifying  financial  management  structures  and  processes,  also  ensuring  that  the 

framework is time limited; 

b.  setting clear objectives and performance indicators; 
c.  clarifying actions eligible for funding or co-financing; 
d.  simplifying and standardising the funding rates, removing ad hoc rates; 

3.  The support for the policy objectives will be achieved through support in each of the policy areas: 

a.  contributing to a high level of safety of food and other products and of food production 
systems  which  may  affect  safety  of  food  while  improving  the  sustainability  of  food 
production; 

b.  contributing  to  a  higher  animal  health  status  in  the  Union  and  to  support  the 

improvement of the welfare of animals; 

c.  contributing to timely detection of plant pests and their eradication where these have 

entered into the Union; 

d.  contributing  to  improve  the  effectiveness,  efficiency  and  reliability  of  official  controls 
and  other  activities  carried  out  in  view  of  the  effective  implementation  of  and 
compliance with the Union rules. 

The  policy  objectives  of  the  individual  parts  of  the  food  and  feed  legislation,  as  identified  in  their 
individual impact assessments, are laid out in Annex 3.  

3.4 Consistency with other EU policies 

It  is  crucial  that  the  proposal  currently  under  consideration  also  remains  consistent  with  other  EU 
policies.  At  a  high  level,  this  means  supporting  the  objectives  of  EU  2020  and  the  Multiannual 
Financial Framework.  Perhaps most importantly, it is crucial that the financial framework supports the 
economic recovery through promotion of trade and other important economic activity. In other areas, it 
will be important to ensure that feed and food safety policy supports and complements, and does not 
overlap or undermine, other EU policies. This is particularly true in the areas of Agriculture and Trade. 
The new proposals for the Common Agricultural Policy support the same sorts of general objectives as 
22 

 
 
 
 
 
 
  
 
 
 
 
 
 
 
 
the current financial regulations in question, but different specific objectives and via different means. It 
is also crucial that the financial regulation continues to support European trade and is consistent with 
existing  and  future  trade  rules.  There  is  some  consideration  needed  of  marine  policy,  when  the 
financial framework supports the prevention or eradication of diseases affecting aquaculture animals, 
for example. And it is important to be mindful of the objectives of environmental policies. Lastly, there 
are strong links between other policies such as public health, animal welfare, and others, which must 
be co-ordinated with. 

Section 4: Policy options 

4.1. Option 1: Baseline scenario: No change 

No  change  would  involve  continuing  with  the  existing  set  of  legislative  instruments  governing  the 
financial framework. This would mean initially that programmes could continue as now, but from 2014, 
there  would  be  no  legal  base  for  the  management  and  control  of  the  expenditure.  If  the  existing 
scenario is kept as it is, the 'Reserve for crises in the agricultural sector', needed to cope with large-
scale crises for which the ordinary emergency measures are not sufficient, could no longer be resorted 
to after 2014. Moreover, none of the minor drawbacks identified within the present impact assessment 
are addressed. 

4.2. Option 2: Bring existing legislation into one legislative instrument 

Option 2 examines whether it would be possible to keep all existing measures from existing legislation, 
and bring them together into one regulation, as requested by DG Budget within the discussions on the 
MFF  2014-2020.  This  would  make  the  legal  provisions  consistent  with  and  workable  within  the  new 
MFF,  including  making  them  consistent  with  the  change  from  Heading  2  (preservation  and 
management  of  natural  resources)  to  Heading  3  (security  and  citizenship),  and  providing  the  legal 
basis for its control and management. 
However,  the  existing  provisions  for  financially  supporting  and  co-financing  programmes  would  not 
materially change.  

4.3. Option 3: Single coherent financial programme 

Sub-option  3(a):  Establish  a  single  coherent  financial  programme,  largely  using 
existing financial provisions, but with some improvements, particularly simplification. 

This option envisages, as for option 2, bringing all financial provisions for food and feed together into 
one regulation. However, rather than keeping all the existing provisions exactly as they are, this option 
takes  the  opportunity  to  ensure  that  the  revision  fully  meets  objectives  1  and  2  by  amending  the 
framework to ensure that it is time limited, that it sets clear objectives and indicators, that it identifies 
eligible actions as well as evaluation criteria, and establishes detailed financial rules. In addition, there 
are  a  number  of  improvements  to  the  current  system  which  would  be  introduced  in  this  option, 
including the simplification and harmonisation of co-financing rates, the expansion of certain financing 
measures  to  plant  health,  and  better  targeting  of  the  scope  of  the  Better  Training  for  Safer  Food 
Programme to also include PRM. In particular, the introduction of a systematic approach to monitoring 
and  evaluation  by  defining  clear  objectives  accompanied  by  performance  indicators,  as  mentioned 
above, would provide evidence on the drivers of cost-effectiveness and critical success factors for food 
and feed programmes and measures offering better value for money.  

Sub-option 3(b): As for sub-option (a) but including the introduction of aspects of Cost 
and Responsibility Sharing Schemes (CRSS)  

Option  3(b)  would  further  develop  Option  3(a)  by  introducing  an  element  of  cost  and  responsibility 
sharing  into  the  financial  regulation.  Both  the  upcoming  AHL  and PHL  put  emphasis  on  the need  to 
explore possibilities of distributing costs and responsibilities more fairly between the EU, the MSs and 
the  private  sector.  In  particular,  work  has  been  ongoing  for  some  time  in  the  animal  health  area  to 
identify  whether  there  are  ways  in  which  farmers,  animal  keepers  and  MSs  could  be  incentivised  to 
adequately  take  the  responsibility  for  prevention  and  best  practice  management  methods,  and  to 
23 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
share  the  costs  of  outbreaks  and  epidemics  when  they  do  occur.  However,  in  the  light  of  this 
investigation, there is not enough evidence to suggest that the benefits from introducing this system 
will  outweigh  the  costs,  especially  in  the  short  term.  The  introduction  of  a  CRSS,  as  assessed  with 
respect  to  the  emergency  veterinary  fund,  was  considered  not  viable  in  the  current  climate  and  not 
likely to be accepted by MSs and stakeholders for the following reasons:  

• 

• 

• 

introduce  some  administrative  complexity,  conflicting  with 

it  would 
simplification and harmonisation; 
it  would  require  an  additional  administrative  burden  to  set  up  the  elements  of  the  scheme 
especially in the start-up phase: 
the contribution required from the private sector risks being unsustainable, particularly in the 
challenging financial climate. 

the  objective  of 

More details about the investigations conducted in the animal health area are presented in ANNEX 4. 

4.4: Option 4: Stop all EU action 

It would in theory be possible to stop all EU financial provisions that contribute towards animal health, 
plant health and food and feed safety, and require MSs to fund their own programmes and activities. 

Veterinary programmes  
This  would  leave  Member  States  uncompensated  for  any  veterinary  programmes,  if  they  decided  to 
initiate  them  at  all.  It  is  entirely  possible  that  without  the  incentive  to  initiate  programmes,  Member 
States  may  stop  many  of  them.  It  would  also  provide  them  with  little  incentive  to  comply  with  EU 
standards or keep the EU informed.  

Emergency measures 
In addition, emergency measures would go uncompensated. This would mean that should a serious 
animal disease outbreak occur, Member States would have to bear management and control burdens 
themselves.  

Plant Health 
Plant  health  measures  would  also  go  uncompensated,  leaving  Member  States  with  no  financial 
contribution for surveillance programmes. There would be no support during periods of emergency.  

EU Reference Laboratories 
The  financing  for  the  EU  Reference  Laboratories  would  be  removed.  Alternative  measures  such  as 
entirely  relying  on  the  private  sector  to  fund  and  supervise  official  testing  and  research,  should  be 
taken. 

Better Training for Safer Food 
Removing  the  financing  for  Better  Training  for  Safer  Food  would  mean  that  there  would  be  no 
integrated Union-level training available for those working on the front line of official controls.  

Option progression logic 
The  graph  in  Figure  3  presents  the  logic  of  the  development  of  the  options  presented  above,  from 
least action (Option 4) to most action (Option 3.b): 
The  present  Impact  Assessment  is  primarily  aimed  at  exploring  possible  alternatives  in  response  to 
the formal requirement from the Secretary General to establish a new common legal basis to control 
the  EU  expenditure  in  the  food  safety  area  within  the  next  financial  framework.  Therefore,  neither  a 
scenario where this change to the existing legislation is not made (Option 1), nor a scenario where the 
entire food safety spend is stopped (Option 4), can be considered as realistic policy alternatives, since 
they do not address the main purpose of the proposal the present impact assessment examines, i.e. 
creating a new legal basis complying with the structure of the Budget 2014-2020. 
This means that Option 1 and Option 4 can be dismissed without further investigation. 
Options 2, 3.a and 3.b, all satisfy this formal requirement missing in Options 1 and 4, and also meet 
the  request  from  DG  Budget  to  move  the  existing  legislation  into  a  common  financial  framework 
covering all food and feed issues.  

24 

 
 
 
 
 
 
 
 
 
 
 
 
Moreover,  Options  3.a  and  3.b  introduce  a  few  changes  to  solve  a  number  of  minor  problems 
identified within the present assessment (section 2.2), aimed at modernising the current framework by 
making it more straightforward, effective and sound. 
In addition, Option 3.b envisages an advanced system where the EU, the MSs and the private sector 
share  both  the  costs  and  the  responsibilities  to  tackle  problems  due  to  animal  diseases  and  plant 
pests. 

Figure 3: Option progression logic 

Section 5: Assessment of impacts 

As this is strictly a financial regulation, each option will be analysed according to its impact related to 
the  main  problems  and  specific  objectives  identified  earlier  in  the  assessment,  which  are  largely 
financial or socio-economic impacts, rather than the policy-focused objectives of economic, social and 
environmental  impacts  which  are  traditionally  used  for  policy  legislation.  The  criteria  for  assessing 
impacts is broadly related to the achievement of the three specific objectives, and so divided into:  

•  Administrative and legal impacts 
•  Financial and management impacts 
Impacts on food safety objectives 
• 

5.1: Option 1: Baseline scenario: No change 

No change initially means that the current programmes would continue for the next year or so, or new 
ones be approved on the same basis. Funding for other aspects such as EURLs would continue as 
now. There is unlikely to be any significant impact on the ground during that time. However, as noted 
in section 2, the current financial framework risks becoming unmanageable by the start of 2014, as it 
will no longer be legally consistent with the new MFF which is due to be introduced then, and will have 
no legal basis for financial management or controls.  

5.1.1: Administrative and legal impacts 

The financial framework for food safety will no longer be legally supported, because of the move from 
heading  2  of  the  MFF  to  heading  3.  The  lack  of  management  and  audit  controls  means  that  the 
25 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
framework  risks  being  legally  non-compliant.  This  has  a  potentially  huge  impact  on  the  Commission 
and Member States who rely on the co-financing to help fund programmes and activities. 

Administrative burden 
At present, the complexity of the current system (e.g. lack of harmonisation, fragmentation of the legal 
basis) creates administrative burden for stakeholders to understand the legislation, and by the start of 
2014,  will  prove  very  burdensome  due  to  the  lack  of  legal  base  for  controls  and  management.  It  is 
extremely difficult to quantify this burden as some of the consequences of this legal issue are as yet 
unclear, but it has the potential to be large. 

Access to crisis reserve 
The  impact  of  the  move  of  the  food  safety  budget  lines  from  Heading  2  to  Heading  3  of  the  MFF 
leaves  a  number  of  legal  questions.  But  the  main  potential  problem  is  access  to  the  crisis  reserve. 
Although  there  has  not  been  a  serious  epidemic  outbreak  for  several  years,  there  is  always  the 
potential for MSs to be hit with a debilitating disease or pest, especially with climate change potentially 
bringing changing conditions for the nurture of vectors or diseases that have not been found in Europe 
before.  The  possibility  of  access  to  the  crisis  reserve  is  an  absolutely  essential  part  of  last-resort 
disease control. Without it, MSs would be left to fend for themselves in the face of serious economic 
losses, as well as the possible associated problems of food safety, public health and food security. In 
the current economic climate, MSs are likely to find this even harder than usual to bear.  

5.1.2: Financial and management impacts 

Management control 
Setting aside the problems that are inevitably going to arise when there is no legal basis for the control 
and management of the finances, the use of available resources will continue to be sub-optimal in the 
short term. The need for better management and evaluation of programmes, particularly the veterinary 
programmes (by far the largest amount of spend), has already been identified. This will enable MSs to 
better  identify  which  measures  work  most  effectively  against  which  diseases.  Continuing  with  the 
current system would mean not reforming the requirements for better evaluation and according ability 
to modify programmes to make them more effective, therefore inevitably continuing with sub-optimal 
and perhaps ineffective programmes.  
In  the  longer  term,  the  lack  of  any  legal  controls  and  management  after  the  adoption  of  the  MFF 
means  a  complete  lack  of  requirements  to  assess  and  monitor  programmes,  and  so  no  value  for 
money can be guaranteed (if indeed any programmes were able to be continued or approved). 

Impacts on/Sustainability of Public budgets 
Assuming that around the same rough scale of programmes continue to be co-financed as currently, 
initially there would be no change to public budgets. However, the legal and administrative uncertainty 
if the legislation is not reformed to align with the new MFF means that far fewer programmes would be 
able  to  be  funded.  While  this  might  initially  save  money  from  public  budgets,  the  expected  impacts 
from  removing  any  prevention  and  management  programmes  are  high.  And  if  more  pests  and 
diseases begin to develop due to the lack of preventative programmes, there would be no guaranteed 
finances  available  to  help  Member  States  cope  with  emergency  measures.  The  increase  in  both 
animal  and  plant  disease,  and  the  corresponding  impacts  on  food  safety,  public  health,  and  food 
security, is likely to ultimately cost much more to public budgets. However, this is extremely difficult to 
quantify in any meaningful way, as there is no available data assessing the impact of partially or totally 
removing prevention and control programmes.  
Nevertheless,  the  impact  of  a  serious  outbreak  can  be  devastating.  To  give  an  idea  of  the  possible 
scale, the Animal Health Law impact assessment quoted the costs of some recent major crises:  

•  BSE  (1996-1997):  for  UK  only,  GBP£3.5  billion  (0.5%  of  GDP).  The  disease  also  caused  a 
serious  fall  in  consumer  confidence  across  the  whole  EU  and  long-term  large-scale  trade 
embargos.  

•  FMD (2001-2002): for UK only, GBP£10-12 billion (1.2% of GDP) – i.e. between about €16bn 
and €19bn - mainly in agriculture / food chain (30%) and tourism (50%). For this outbreak, the 
EU  co-financed  €386.7m  under  the  emergency  meas ures  to  cover  part  of  the  direct  costs 
incurred, that is about 3.5% of the total estimated (direct and indirect) losses. 

26 

 
 
 
 
 
 
 
 
 
 
•  Avian flu in the Netherlands (2003): 30 million birds and direct economic costs of more than 

€150 million. 

In the Plant Health Law Impact Assessment, examples were given of major pest incursions which 
have already threatened agricultural and forestry production, as well as the natural environment.  

•  Xanthomonas axonopodis pv. citri (citrus canker): following its introduction into Florida, 

the US authorities have spent €800 million in thei r fight against the bacterium. The production 
value of citrus in the EU, where the pest could cause huge damage, is about €3.9 billion. 
•  Mortality of western Canada's pine forests due to the mountain pine beetle (Dendroctonus 
ponderosae) outbreaks currently approaches 80% and reversed these vast forests from 
carbon sink to carbon source. Scandinavian pine forests are still free from the pest but are 
equally susceptible (FCEC, 2011). 

5.1.3: Impacts on food safety objectives 

Plant and Animal Health 
For  plant  health,  the  impact  assessment  shows  that  the  increasing  influx  of  new  harmful  organisms 
cannot  be  adequately  stopped  without  expanding  the  scope  of  Union  financial  support  to  measures 
that  are  not  receiving  such  support  at  present  (surveys  for  new  organisms  and  priority  organisms; 
compensation  to  operators  for  losses  from  eradication  measures).  This  option  was  considered 
unacceptable by the majority of the stakeholders as well as by the Member States. 
In addition, should the animal disease veterinary programmes have funding reduced or removed due 
to  the  legal  problem  of  lack  of  controls  and  management,  the  frequency  and  seriousness  of  animal 
disease outbreaks may increase. This is particularly the case as the lack of co-financing programmes 
gives  little  incentives  for  MSs  to  finance  them  themselves.  The  potential  problems  with  then 
reimbursing MSs for emergency spend may also be extremely serious. Member States (and potentially 
farmers  or  other  individuals  and  businesses  affected)  may  well  have  to  bear  significant  and 
unanticipated financial burdens.  
In  the  long  term,  the  EU  will  have  no  legal  control  over  the  finances  granted  to  Member  States, 
seriously risking major falls in prevention activity, and therefore putting the whole EU at risk of more 
animal and plant disease outbreaks. In addition, in the case of an outbreak, there would be no legal 
recourse to the crisis reserve. This would mean that any serious outbreaks above the budget already 
reserved would not be reimbursed from EU funds. Therefore, incidents such as those quoted above 
would  be  dealt  with  by  Member  States  alone,  with  no  reimbursement,  at  a  time  when  many  are 
struggling with recession and budgetary deficit.  

5.2: Option 2: Bring existing legislation into one legislative instrument 

This  option  would  only  partially  achieve  objective  1  as  identified  in  section  3,  and  would  not  meet 
either of the other two objectives identified. From a formal point of view, the establishment of a new 
legal basis would ensure continuity of the food and feed expenditure after 2014, when the budget line 
named "food safety" will be implemented under Heading 3 of the EU budget. The coverage of all food 
and feed expenditure through one single piece of legislation would address, to some extent, objective 
1, by promoting simplicity and encouraging better understanding of the legislation. However, without 
further change to the existing measures, no harmonisation will be achieved and the specific changes 
envisaged within the sectorial legislation will not be implemented in the financial instrument. Moreover, 
it would not allow the financial programme to be planned and managed together comprehensively and 
consistently or set clear objectives and indicators, and it would not set clear and consistent criteria for 
evaluating eligible actions, or establish detailed financing rules. 

5.3:  Option  3  (a):  establish  a  single  coherent  financial  programme,  largely  using  existing 
financial provisions, but with some improvements 

5.3.1: Administrative and legal impacts 

The  simplification  of  the  system  and  the  harmonization  or  rates  is  expected  to  reduce  the 
administrative burden on the Commission and MSs. 

27 

 
 
 
 
 
 
 
 
 
 
 
 
  
Reducing administrative burden: simplification of funding rates 
Funding  rates  would  be  simplified  to  provide  only  three  different  standard  rates,  improving 
transparency and consistency.  

•  50% 

Where  Union  financial  aid  takes  the  form  of  a  grant,  the  amount  of  the  Union  financial  contribution 
would  be  up  to  50%  of  the  eligible  costs.  Until  2010,  this  used  to  be  the  standard  rate  for  funding 
veterinary programmes (representing about 75% of the total food and feed expenditure), and it is also 
commonly used to co-finance most of the other measures in this area.  

•  75% 

The standard rate above would be increased to 75% for cross-border activities coordinated by two or 
more  Member  States  in  order  to  eradicate  diseases  or  harmful  organisms  (as  co-operation  to 
overcome  the  technical  problems  of  working  together  in  harmony  is  essential  to  the  success  of  the 
programme),  or  for  Member  States  whose  2011  gross  national  income  per  inhabitant  based  on 
EUROSTAT  data  is  less  than  90%  of  the  Union  average  (to  encourage  the  development  of 
programmes by requiring less state funding from those MSs less able to contribute).  

•  100% 

Where the control of serious health risks for the Union is involved, where the activities benefitting from 
Union  contribution  are  specific  tasks  of  particular  importance  for  the  Union  or  when  the  activities 
funded  are  implemented  in  third  countries  (for  the  good  of  the  EU  as  well  as  those  countries,  and 
where they are unlikely to be otherwise funded), the grant may cover up to 100% of eligible costs (see 
below).  
The simplification of the rates would provide more simplicity, transparency and consistency across EU 
measures. This would enable simpler programme development and approvals processes and reduce 
administrative burden for both the Commission and Member States. 

Reducing administrative burden: removing low-value programmes 
Another  proposition  for  reducing  administrative  burden  is  to  remove  the  possibility  of  funding 
programmes with a value of less than €50,000. At  present, a number of very small payments are made 
to Member States for tiny contributions to veterinary programmes. These do not add up to a significant 
proportion  of  the  budget,  and  do  not  carry  great  importance  for  eradicating  animal  disease.  Yet  the 
processes  of  development  by  MSs  and  approval  and  payment  by  the  Commission  take  a  similar 
amount of time to a very large and significant programme worth millions of Euros. So, removing them 
introduces  the  possibility  of  eliminating  a  disproportionate  administrative  burden  for  both  the 
Commission and the MSs. 

Quantitative analysis 
The budgetary impact expected from this introduction of standardised rates and removal of low value 
programmes has been estimated by projecting the new rates onto recent spending.  
As above, three standard co-financing rates are envisaged: 

•  50% 

−  basic co-financing rate 

•  75% 

−  cross-border activities coordinated by two or more MSs to eradicate diseases or harmful 

organisms 

−  measures for MSs whose 2011 gross national income (GNI) per inhabitant based on 

EUROSTAT data is below 90% of the Union average 

•  100% 

−  measures involving the control of serious health risks for the Union. 

The  introduction  of  the  standard  co-financing  rate  of  50%  would  have  a  positive  impact  on  the  EU 
budget. 

•  The largest proportion of spend is on veterinary programmes, whose basic co-funding rate has 
been recently increased to 60%, at the request of Member States (on the basis of article 28.2 
of Council Decision 2009/470): therefore an appreciable reduction of the amounts funded can 
be envisaged. 

•  The  implementation  of  the  new  scheme  would  generate  an  expected  decrease  also  for 
compensations  under  the  emergency  veterinary  measures,  which  are  mostly  co-financed  at 
50% exception made for measures for Foot and Mouth disease, currently co-financed at 60%. 

28 

 
 
 
 
 
 
 
•  The  spending  on  plant  health  measures  would  be  limited  affected  as  their  current  rate  is 

between 40% and 50%. 

Further savings are expected thanks to the fact that any measure not exceeding would no longer be 
eligible for EU co-financing. 
On the other hand, an extra expenditure is expected for measures addressing MSs whose 2011 gross 
national  income  (GNI)  per  inhabitant  (in  current  prices)  is  below  90%  of  the  Union  average:  this  is 
likely  to  partly  counterbalance  the  reduction  in  the  food  safety  budget  due  to  the  introduction  of  a 
standard  rate  of  50%  and  to  the  non-eligibility  for  co-financing  for  measures  below  €50,000,  as 
presented above.  
Lastly,  measures  which  are  currently  totally  financed  or  co-financed  at  higher  rates,  such  as  the 
purchase of vaccines under emergency measures (100%) and the programmes for rabies (75%) and 
TSE (100%) would not be affected by the changes described above. 
Taking  all  this  into  account,  the  application  of  the  new  standardised  rates  to  the  profile  of  the 
expenditure committed in 2011 would have meant: 

• 
• 
• 

for the veterinary programmes, a decrease in expenditures amounting to 13million euro 
for the emergency veterinary measures, an extra-expenditure of about 350,000 euro 
for the plant health measures, an extra-expenditure of less than 7million euro 

Overall,  the  proposed  rate  system  -  applied  to  the  items  above  -  would  have  generated  annual 
budgetary savings on the food safety budget of more than 6million euro. 

Streamlining administration across different policies 
The  financial  support  for  plant  health  is  proposed  to  be  more  strongly  aligned  with  animal  health  as 
regards  procedures  and  processes.  This  introduces  the  possibility  of  streamlining  administration  in 
both  the  Commission  and  MSs.  This  impact  is  extremely  difficult  to  quantify  due  to  the  different 
arrangements in each MS and the very varied potential for any improvement, and the impact for the 
Commission is likely to be greater than for MSs.  

Reduction in Commission decisions 
One major expected change is that the legal requirements for the processes to approve and reimburse 
programmes  in  the  eradication,  monitoring  and  control  programmes  and  the  emergency  measures 
would be simplified. Commission decisions will not have to be taken for every single reimbursement in 
the  administrative  process,  as  now;  but  a  new  system  introduced  with  a  simpler  internal  approval 
process. The c.140 Commission decisions taken each year regarding the veterinary programmes will 
be reduced to a single decision approving the priorities for funding. The emergency programmes will 
also  be  reduced  to  one  decision  per  outbreak,  with  no  formal  reimbursement  decisions  necessary. 
This  will  significantly  reduce  administrative  burden  in  terms  of  staff  time  in  the  Commission  and  the 
Member States. This is also likely to speed up payments to Member States.  

5.3.2: Financial and Management Impacts 

Use of available resources  
Financial  management  tools  will  be  improved  under  this  reform.  By  setting  clearer  objectives  and 
indicators for programmes, and following up evaluations more thoroughly, the veterinary programmes 
in particular are likely to be much more effective, by tailoring the programme according to the findings 
of what the most effective actions are for tackling certain kinds of disease. In particular, the disease 
monitoring  and  evaluation  tool  provided  for  in  the  Animal  Health  Law  will  enable  a  scientific  and 
evidential base as the foundation for decision-making on the distribution of resources for the promotion 
of  animal  health.  It  is  extremely  difficult  to  quantify  the  impact  of  these  particular  changes  as  the 
impacts are indirect and their scale is very uncertain. Nevertheless, we can be sure that they will be 
positive compared to the baseline scenario. 

Impacts on/sustainability of public budgets 
The  overall  MFF  budget  has  already  been  proposed.  So,  there  is  virtually  no  impact  on  the 
Commission's  budget  compared  to  the  baseline  scenario.  For  the  financial  impact  on  MSs,  there  is 
also  little  change  envisaged.  If  anything,  there  will  be  a  reduction  in  their  financial  burden.  The 
changes  to  the  co-financing  rates  should  reduce  their  financial  burden.  The  other  administrative 
burden reductions are also likely to save them money.  

29 

 
 
 
 
 
 
 
 
 
 
5.3.3: Impacts on Food Safety Objectives 

Better training on and enforcement of food safety 
The review of the official food and feed controls Regulation will strengthen the legal base of the Better 
Training for Safer Food (BTSF) initiative, make its scope more coherent and improve its efficiency and 
effectiveness.  This  would  promote  further  a  better  understanding  of  all  kinds  of  plant  health,  animal 
health, official controls and food and feed safety legislation and enforcement in MSs and beyond the 
EU.  Very  preliminary  results  of  an  ongoing  general  evaluation  undertaken  with  training  participants 
and  competent  authorities  show  that  69%  of  participants  consider  the  programme  has  improved  the 
quality of their work, 41% consider it has improved their efficiency and 41% consider it has improved 
the guidance given to front line staff. The greatest impact was stated to have been on border controls 
and  the  management  of  border  control  posts.  The  changes  proposed  will  have  an  impact  that  is 
extremely difficult to quantify. The cost, however, is small, and the effects will undoubtedly be positive. 

Plant Health  
Option  3a  will  better  support  the  achievement  of  plant  health  objectives  compared  to  the  baseline 
option. The impacts of changing this situation were examined in the sector impact assessments and 
found  to  be  positive.  Thus,  the  plant  health  law  and  official  controls  proposals  will  put  forward  the 
possibility of setting up EURLs in the areas of plant health and supporting these financially from the 
EU budget; as well as the expansion of EU Reference Centres to PRM. In addition, financial support 
would  be  available  to  all  MSs  to  upgrade  plant  health  surveillance  and  to  reinforce  eradication  and 
containment. This would introduce incentives for MSs and operators to be more vigilant, immediately 
notifying  issues  and  taking  early  action.  This  would  substantially  limit  the  influx,  establishment  and 
spread  of  new  harmful  organisms  into  and  within  the  EU,  with  a  significant  positive  impact  on 
productivity and profit of growers and foresters and competitiveness with third countries. Risks of trade 
restrictions  from  third  countries  from  EU  outbreaks  of  internationally  regulated  harmful  organisms 
would be substantially mitigated. The annual costs of EU reference laboratories for plant health have 
been estimated in the PLH IA as €1.5m. It is anticipated that the benefits of this annual €1.5m will far 
outweigh the costs, but are extremely difficult to quantify.  

Animal Health  
The  better  and  more  efficient  use  of  resources  and  the  increased  consistency  between  animal  and 
plant health measures should lead to a reduction in the occurrence of animal diseases, and therefore 
a positive impact on animal health objectives. No major changes are proposed to the actual measures 
which are funded through veterinary programmes and emergency programmes, but simpler and more 
effective  administrative  processes  and  better  analysis  of  the  effectiveness  and  efficiency  of 
programmes should lead to improved animal health. This is almost impossible to quantify or measure 
as the impacts are indirect and scale uncertain, but a general tendency in the positive direction is self-
evident. 
More specifically, changes to be put forward in the new Animal Health Law proposal will promote more 
systematic  appraisal  of  animal  diseases,  allowing  them  to  be  listed  for  particular  measures  and 
prioritised  in  a  transparent  fashion,  supported  by  scientific  evidence  and  objective  risk  assessment. 
This will support the better implementation of financial support by ensuring that only diseases which 
are  of  relevance  to  the  EU  and  deserve  financial  support  actually  receive  it.  As  for  emergency 
measures, the list of animal diseases established may be amended in order to include also diseases 
which are likely to constitute a new threat for the Union in terms of impact on human health, animal 
health  or  welfare,  or  agricultural  or  aquaculture  productions.  The  established  list  of  animal  diseases 
and  zoonoses  under  the  veterinary  programmes  may  be  amended  too,  taking  into  account  the 
situation  of  animal  diseases  having  a  significant  impact  on  livestock  production  or  trade,  the 
development  of  zoonoses  which  pose  a  threat  to  humans,  or  new  scientific  or  epidemiological 
development. 

5.4: Option 3 (b): Introduction of aspects of Cost and Responsibility Sharing Schemes (CRSS)  

Being  a  development  of  Option  3(a),  impacts  already  described  as  for  that  policy  alternative  can  be 
mostly  kept  on  board  when  assessing  Option  3(b).  The  additional  CRSS  element  introduced  by  this 
option  either  entail  extra  impacts  or  modify  the  expected  outcomes  of  Option  3(a).  Therefore,  the 
assessment below is largely drawn with reference to impacts envisaged for Option 3(a). 

30 

 
 
 
 
 
 
 
 
 
 
5.4.1: Administrative and legal impacts 

Operating costs and conduct of and administrative burden on businesses, including SMEs 
The operating costs of and the administrative burden on businesses could be expected to rise in the 
short term as they will be required to comply with a more advanced system requiring the introduction 
of  additional  components  of  cost  and  responsibility  sharing.  There  is  likely  to  be  an  increase  in 
administrative complexity with the introduction of this system.  

Challenges of implementation 
The  implementation  of  a  CRSS  system  is  politically  controversial,  and  is  unlikely  to  be  easy  or 
straightforward to introduce.  

5.4.2: Financial and Management Impacts 

Use of available resources  
Option  3(b) envisages  a  participatory  approach  when  public  authorities,  at  both  EU  and  MSs  levels, 
share with the private sector the burden of losses incurred as well as the responsibilities of running the 
system.  This  involvement  of  the  private  sector  in  managing  the  financial  instruments  entails  an 
increased engagement towards efficiency which is expected, particularly in the long-term, to maximise 
the use of available resources. 

Impacts on/Sustainability of Public budgets 
Since  the  primary  sector  will  be  asked  to  contribute  to  the  system  by  sharing  costs  associated  with 
animal diseases and plant pests, there will be a direct reduction in the budgets of public authorities; 
moreover,  an  indirect  longer-term  reduction  in  budgets  is  also  expected,  through  reduced  disease 
outbreaks resulting from increased attention to prevention.  

5.4.3: Impacts on food safety objectives 

Public Health 
Because  of  the  expected reduction  in both size  and  occurrence  of  plant  pests  and animal  diseases, 
we  can  assert  that  the  only  impact  on  public  health  and  safety  is  the  likely  consequential  trend  of  a 
reduced risk to public health and safety. Therefore, its knock-on effects on the food chain, included the 
risk of loss of consumers’ confidence, would also be expected to reduce.  

Plant and Animal Health 
This Option envisages a system which will incentivise all players involved to reduce the occurrence of 
pests/diseases  as  much  as  possible:  since  public  and  private  parts  jointly  bear  the  losses,  they  all 
have an economic stake in preventing/early detecting crises; moreover, the CRSS provide them with 
specific  incentives  to  invest  in  the  implementation  of  preventive  measures  and  improving  and 
spreading best practice. Benefits deriving from this system are expected to consolidate in the mid-long 
run. 

Experience from Australia for plant health shows that the introduction of cost and responsibility sharing 
schemes  takes  a  long  period  to  introduce  (in  Australia,  10  years).  Short-term  introduction  is  likely 
therefore not to be feasible. 

5.4.4: Final considerations on economic/social impacts 

The assessment conducted in the frame of emergency measures to make up for losses due to animal 
and plant disease does acknowledge that a CRSS system is complicated, and that the likelihood of its 
being  acceptable  to  MSs  and  to  stakeholders  is  small,  even  if  in  the  long  term,  it  may  reduce  the 
impacts  of  animal  diseases  and  plant  pests.  Therefore,  the  introduction  of  a  CRSS  system  would 
defeat the objectives of clarity and simplicity. In addition, the current financial climate makes it more 
difficult  politically  and  culturally  for  MSs  and  stakeholders  to  accept  a  larger  share  of  the  financial 
burden, even if the overall burden from outbreaks and pests reduces in the long term. As it is, there is 
not enough evidence to suggest that the benefits from introducing this system will outweigh the costs. 
It is possible that this area may be reviewed again in the future. 

31 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
5.5: Option 4: Stop all EU Action 

This option has been discarded without being analysed in great detail. It is self-evident that it would 
meet none of the objectives set out in Section 3. Rather than considering the impacts in terms of the 
objectives, as with the other options, the overall impact of stopping each main aspect of food safety 
funding has been assessed as follows: 

Veterinary programmes 
There would be two main impacts should funding for veterinary programmes be discontinued entirely. 
The  first  would  be  on  the  existing  programmes.  Discontinuing  existing  funding  risks  leaving  no 
programmes running which are aimed at tackling existing endemic diseases. Many of these are long-
term programmes that are aimed at eradicating diseases which are difficult or very slow to wipe out. 
For  example,  bovine  tuberculosis  is  a  slow-spreading  disease  which  may  lie  hidden  without  clinical 
symptoms in infected animals for a long period of time, but while that animal is still infectious. To stop 
a  veterinary  programme  and  therefore remove  all  testing  and  surveillance  in  an  infected area  would 
almost inevitably lead to slow but undetected spread throughout and between herds, both nationally 
and  internationally,  depending  on  trade  patterns.  It  is  unlikely  that  MSs  would  continue  to  fund 
programmes  by  themselves,  either  to  the  same  extent,  or  at  all;  especially  in  the  current  economic 
climate.  This  risks  jeopardising  the  achievements  of  the  investments  that  have  already  been  made 
(see case studies in Annex 2). In addition, there would be little incentive for MSs to inform the EU of 
the  health  situation  in  their  own  countries,  meaning  no  co-ordinated  information  or  action  would  be 
available or possible at trans-national level. The approaches taken to different diseases may diverge 
too far to tackle disease well.  
Ultimately this would have a major impact on economic losses and on trade restrictions. It affects both 
diseases which are still endemic in the EU, but also those which are now exotic. Once spread over a 
wider area, endemic disease is even harder to detect, control and eradicate; whereas diseases which 
have  already  been  eradicated,  or  which  are  new  and  emerging,  would  risk  being  reintroduced.  For 
example,  Bluetongue  has  been  a  great  success  story,  tackled  by  EU  co-financed  emergency 
measures and veterinary programmes. In 2007 BTV-8 appeared in northern Europe for the first time. 
In  2008,  there  were  over  45,000  cases.  Through  a  combination  of  measures,  including  widespread 
vaccination,  the  disease  has  not  appeared  at  all  in  2012.  However,  were  surveillance  to  stop  and 
vaccination  to  be  discontinued,  the  disease  could  re-emerge  given  the  right  climatic  conditions,  and 
spread again, causing serious economic losses and widespread trade disruption in the EU economy. 
This is particularly the case because of the global warming and the changing climate, which is slowly 
bringing conditions more favourable to certain diseases, like Bluetongue.  

Emergency measures 
Emergency  measures  are  the  other  side  of  the  same  coin.  In  the  current  economic  climate,  leaving 
MSs  with  no  EU-level  financial  support  for  veterinary  programmes  means  they  are  more  likely  to 
experience  incursions  and  outbreaks.  The  lack  of  financial  support  with  emergency  measures 
therefore  means  they  will  be  less  able  to  cope  with  them  well;  and  the  lack  of  reimbursement  in 
incursion or outbreak scenarios may well seriously damage a MS's economy. For example, the Foot 
and  Mouth  Disease  outbreak  in  Bulgaria  in  2011  was  quickly  identified  and  eradicated  with  co-
ordination and co-financing provided at EU level, and it is unlikely that it would have been eradicated 
as quickly should the EU-level support not have been available. In addition, leaving those individuals 
and businesses who are currently compensated with no compensation in a crisis scenario is likely to 
seriously  damage  the  rural  economy  in  emergencies,  putting  farmers  and  other  operators  out  of 
business. 

Plant Health Measures 
Plant  health  measures  are  not  currently  funded  to  the  same  extent  as  animal  health  measures. 
However, the plant health law impact assessment clearly demonstrated the justification for increased 
funding for plant health measures – the benefits of funding plant health measures clearly outweigh the 
costs  of  no  action  (or  maintaining  the baseline scenario).  Thus,  we  can  extrapolate  that  stopping  all 
action on plant health measures will have significant long-term costs.  

EU Reference Laboratories 
Stopping  any  funding  for  the  EU  Reference  Laboratories  would  have  serious  impacts.  We  must 
assume  that  all  of  the  food  safety  scientific  support  activities,  including  testing,  surveillance,  and 
32 

 
 
 
 
 
 
 
 
 
developing  new  techniques  and  best  practice  would still  go  ahead  in  some way  to  have  any  kind  of 
scientific  support  to  maintaining (or  improving)  food  safety,  including  animal health  and  plant  health. 
The EURLs are appointed by the Council and are a network of laboratories unique in the world. They 
develop  and  harmonise  standards  for  testing  across  the  EU,  ensuring  a  standardisation  and 
consistency  that  would  be  incredibly  difficult  to  obtain  through  contracting  to  the  private  sector.  The 
EURLs  also  provide  neutral  arbitration  in  the  case  of  disagreements  between  MSs,  which  would  be 
extremely difficult to establish fairly otherwise.  
The EU would also have to look carefully about whether penalties or legal fines would be applied for 
cancelling or not honouring existing contacts for provision with the EURLs.   
There  are  a  number  of  separate  reports  and  analyses  that  provide  evidence  that  the  EU's  financial 
provisions and joint ventures such as the EURLs and the training initiatives add value over and above 
what  MSs  can  achieve  acting  alone.  Joint  action  also  underpins  the  successful  functioning  of  the 
internal market, and prevents operators being unjustifiably discriminated against due to their location. 

Better Training for Safer Food 
In 2011 alone, 151 BTSF training activities took place, involving some 6,100 participants. Removing all 
training  in  this  sphere  would  not  have  the  dramatic  effects  predicted  for  the  removal  of  funding  for 
other  areas  such  as  the  veterinary  programmes  or  emergency  measures.  However,  for  a  relatively 
small  amount  of  spend,  BTSF  offers  an  easy  and  effective  way  to  disseminate  information  on  the 
enforcement  of  food  and  feed  safety  to  all  Member  States  and  to  third  countries.  To  remove  this 
funding would leave a gap in training which is highly unlikely to be filled elsewhere, and risks reducing 
the knowledge of enforcement officers over time, ultimately impacting negatively on the enforcement 
of  food  and  feed  controls.  Two  recent  evaluations  have  concluded  that  BTSF  offers  good  value  for 
money and should continue.  

Conclusion 
Stopping  all  EU  financial  provision  would  have  the  potential  to  seriously  threaten  food  safety,  food 
security, public health and the environment, as well as jeopardising the recovery of the EU economy 
by seriously damaging the EU's ability to trade in animals and animal products. It is not desirable from 
a  social,  economic,  political  or  environmental  point  of  view.  It  would  also  have  little  to  no  support 
amongst stakeholders, including MSs. The principle behind the revision of all of the current legislation 
is to ensure more coherence and simplicity across the board, and taking away any financial provisions 
to support EU action is simply unimaginable with the identified objectives in mind, and considering the 
conclusions of the policy IAs. While the methodological tools and models to explicitly quantify the costs 
and benefits do not (yet) exist, and some work will need to be done on developing them; it is clear that 
the risks to the EU of taking this action would undoubtedly be higher and the long-term costs would 
unquestionably outweigh any short-term savings.  

Section 6: Comparing the options 

It  is  clear  using  proportionate  impact  assessment  principles  that  Option  3(a)  is  the  preferred  way 
forward. It is the only option to meet all three objectives, and with very few (if any) negative impacts, 
assessed  in  the  table  below  in  terms  of  absolute  variations  against  Option  1,  i.e.  the  anticipated 
impacts over the budgetary period 2014-2020 if the current financial framework is not revised.  

Table 2: Comparative assessment of impacts 

Option 3(a) 

Option 3(b) 

Achievement of legal 
and administrative 
objectives 

 + 
Reduction of administrative 
burden on PA and private sector 

Optimising financial 
management tools 

+ 
Increased efficiency: 

•  clearer objectives and 

indicators 

- 
Additional administrative burden on 
MSs and private sector (in the short-
term) 
-/+ 
Short run – possible decreased 
efficiency: 
• 

time needed to familiarise with 

33 

 
 
 
 
 
 
 
 
 
 
 
 
 
• 

longer-term sustainability 

• 

the new system 
lack of acceptability in both 
MSs and private sector 

+ 
Long-run: Increased efficiency 

Support to achievement 
of food and feed 
objectives 

 + 
Increased effectiveness: 

++ 
Increased effectiveness: 

• 

improved consistency 
among EU policies and 
with international 
commitments 

•  Additional incentives towards 
prevention and eradication 

Option 3(b) has been dismissed for now – at present, its complicated nature outweighs any long-term 
positive  impacts  in  the  current  challenging  financial  climate.  However,  in  the  future,  with  a  changed 
environment,  it  may  well  offer  the  most  appropriate  solution  to  many  of  the  wider  and  changing 
problems facing animal and plant health, and could be re-examined.  

Section 7: Monitoring and evaluation 

7.1: Evaluation Report 

By the end of 2018, an evaluation report shall be established by the Commission on the achievement 
of  the  objectives  of  the  measures  (at  the  level  of  results  and  impacts),  the  efficiency  of  the  use  of 
resources  and  its  European  added  value,  in  view  of  a  decision  on  the  renewal,  modification  or 
suspension of the measures. The evaluation shall additionally address the scope for simplification, the 
continued relevance of all objectives, as well as the contribution of the measures to the Union priorities 
of  smart,  sustainable  and  inclusive  growth.  It  shall  take  into  account  evaluation  results  on  the  long-
term impact of the predecessor measures. 

7.2: Ex-post Evaluation 

No later than mid-2022 the Commission shall carry out an ex-post evaluation in close cooperation with 
the  Member  States  and  beneficiaries.  The  ex-post  evaluation  shall  examine  the  effectiveness  and 
efficiency of feed and food expenditure and its impact. 

Both  the  evaluation  report  and  the  ex-post  evaluations  shall  take  account  of  progress  against 
indicators  presented  in  section  7.3  below.  The  Commission  shall  communicate  the  conclusions  of 
these  evaluations  to  the  European  Parliament,  the  Council,  the  European  Economic  and  Social 
Committee and the Committee of the Regions. 

7.3: Indicators 

The evaluations referred to in paragraphs 1 and 2 shall take account of progress against indicators. As 
reiterated in the present impact assessment, one deficiency affecting the current framework is the lack 
of  a  systematic  approach  to  the  monitoring  and  evaluation  of  the  performance  of  the  measures 
implemented in the frame of the food safety expenditure.  
This  is  the  reason  why,  with  a  view  to  revising  the  current  framework,  the  preferred  alternative 
identified also aims at developing and implementing a sustainable set of objectives and indicators in 
order to redress this situation. 
Referring back to the operational objectives linked to the achievement of food safety objectives, these 
will be:  

a. 

to  contribute  to  a  high  level  of  safety  of  food  and  other  products  and  of  food  production 
systems which may affect safety of food while improving the sustainability of food production. 
Indicator: reduction of EU cases in humans, linked to food safety or zoonotic diseases. 

34 

 
 
 
 
 
  
 
 
 
 
 
 
 
 
 
 
b. 

c. 

d. 

to contribute to a higher animal health status in the Union and to support the improvement of 
the welfare of animals; 
Indicator:  increase  of  the  number  of  Member  States  or  region  thereof  free  from  the  animal 
diseases  for  which  financial  contribution  is  granted  over  time,  and  reduction  of  disease 
parameters such as incidence, prevalence, number of outbreaks. 
to contribute to timely detection of plant pests and their eradication where these have entered 
into the Union. 
Indicator:  coverage  of  the  Union  territory  by  survey  for  pests  in  those  parts  where  they  are 
considered not to occur, and time and success rate for the eradication of those pests. 
to contribute to improve the effectiveness, efficiency and reliability of official controls and other 
activities carried out in view of the effective implementation of and compliance with the Union 
rules.  
Indicators: favourable trend of the outcome of controls in particular areas of concern carried 
out and reported by Commission experts in the Member States. 

Based  on  the  initial  objectives  and  indicators  listed  above,  a  detailed  monitoring  system  shall  be 
developed  by  DG  Health  and  Consumers  in  the  first  months  of  2013,  with  a  view  to  optimising  the 
financial management tools. Its implementation would allow the assessment of the cost-effectiveness 
of  all  measures  implemented  and  provide,  consequently,  evidence  for  the  prioritisation  of  the  future 
spending in the frame of the food safety policy. 

The  pilot-system  of  performance  indicators  recently  created  in  the  context  of  the  Reference 
Laboratories will represent a starting point experience towards the development and implementation of 
a systematic approach to monitor and evaluate all food and feed expenditure. 

7.4: Communication 

The Commission shall communicate the conclusions of these evaluations to the European Parliament, 
the Council, the European Economic and Social Committee and the Committee of the Regions. 

35 

 
 
 
 
 
 
 
 
Food Safety Budget 2007-2011 

Measures

Eradication Programmes
Other measures in veterinary, animal welfare, public health
Emergency Fund
Preparatory Action
Plant Health - operational
Food and Feed Control - operational
International affairs
Plant Health - administrative
Food and Feed Expenditure - administrative
Pilot Project
Animal Disease Eradication and Emergency Fund - administrative
Administrative Assistance PHEA
Total

Annex 1: 

Execution of the Budget for Chapter 17 - Commitments 2007-2011
2010

2008

2007

2009

2011
€203.984.156,43 €184.452.356,70 €265.493.595,00 €274.082.000,00 €238.015.000,00
€18.116.450,32
€13.304.888,40
€14.095.235,31
€4.000.000,00
€16.849.399,94
€25.926.308,23
€166.225,60
€300.000,00
€674.930,37

€13.621.935,44
€9.460.383,57 €159.985.729,00
€4.000.000,00
€5.903.195,51
€21.022.256,19
€166.225,60

€12.528.635,44
€11.967.532,30
€2.000.000,00
€8.287.161,00
€30.954.730,80
€200.000,00
€150.160,00
€581.369,00

€1.457.063,19
€16.944.068,66
€167.022,67
€412.905,00
€453.750,00

€21.256.677,24
€29.539.222,00

€13.506.114,
€10.053.119,41

€441.068,44
€420.149,23

85

€951.478,10
€1.000.000,00

€211.283,00

€245.072,00
€1.100.000,00

2007-2011
€1.166.027.108,13
€71.078.024,45
€205.561.999,59
€10.000.000,00
€53.753.496,88
€124.386.585,88
€699.473,87
€1.304.133,44
€3.081.676,70
€1.000.000,00
€456.355,00
€1.100.000,00

€246.184.237,92 €391.103.176,54 €345.622.144,77 €340.962.871,54 €314.576.423,17 €1.638.448.853,94

36 

 
 
 
 
 
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
FOOD SAFETY BUDGET 2005-2011: allocations per MS and evolution over time 

Austria
Belgium
Bulgaria
Cyprus
Czech Republic
Denmark
Estonia
Finland
France
Germany
Greece
Hungary
Ireland
Italy
Latvia
Lithuania
Luxembourg
Malta
Netherlands
Poland
Portugal
Romania
Slovakia
Slovenia
Spain
Sweden
UK
TOTAL EU27

2005
€2.291.000,00
€4.639.000,00
€0,00
€5.863.000,00
€5.746.000,00
€2.621.000,00
€349.000,00
€1.615.000,00
€34.770.000,00
€19.240.000,00
€3.352.000,00
€2.154.000,00
€16.307.000,00
€20.242.000,00
€105.000,00
€1.081.000,00
€220.000,00
€406.000,00
€6.172.000,00
€3.615.000,00
€5.550.000,00
€0,00
€1.190.000,00
€14.569.000,00
€23.654.000,00
€5.700.000,00
€16.030.000,00
€197.481.000,00

2006

2007

2008

2009

2010

2011 TOTAL 2005-2011

€2.440.000,00
€4.435.000,00
€0,00
€4.074.000,00
€2.920.000,00
€2.640.000,00
€1.436.000,00
€1.251.000,00
€33.070.000,00
€18.200.000,00
€3.585.000,00
€2.170.000,00
€11.850.000,00
€18.660.000,00
€1.288.000,00
€890.000,00
€275.000,00
€794.000,00
€6.182.000,00
€11.833.000,00
€5.825.000,00
€0,00
€1.985.000,00
€12.917.000,00
€29.185.000,00
€7.706.000,00
€8.170.000,00
€193.781.000,00

€4.048.000,00
€3.199.000,00
€368.000,00
€2.005.000,00
€3.071.000,00
€2.811.000,00
€1.356.000,00
€1.064.000,00
€37.237.000,00
€14.419.000,00
€2.468.000,00
€2.305.000,00
€9.109.000,00
€18.995.000,00
€1.262.000,00
€1.277.000,00
€399.000,00
€1.445.000,00
€10.721.000,00
€8.236.000,00
€13.677.000,00
€1.506.000,00
€1.964.000,00
€13.373.000,00
€32.325.000,00
€8.112.000,00
€6.625.000,00
€203.377.000,00

€8.006.000,00
€4.383.000,00
€1.437.400,00
€1.898.000,00
€3.213.000,00
€2.037.000,00
€1.269.100,00
€860.000,00
€25.005.000,00
€11.800.000,00
€2.472.000,00
€2.537.000,00
€9.558.000,00
€19.520.000,00
€1.284.100,00
€1.521.000,00
€4.459.000,00
€3.162.000,00
€7.344.000,00
€14.541.000,00
€8.182.000,00
€550.000,00
€1.726.000,00
€12.899.000,00
€24.406.000,00
€5.990.000,00
€6.376.000,00
€186.435.600,00

€9.190.000,00
€6.050.000,00
€2.455.000,00
€3.517.000,00
€6.460.000,00
€610.000,00
€9.907.000,00
€625.000,00
€63.470.000,00
€20.875.000,00
€6.770.000,00
€1.624.000,00
€16.760.000,00
€18.450.000,00
€1.575.000,00
€686.000,00
€2.965.000,00
€5.527.000,00
€2.225.000,00
€10.340.000,00
€7.330.000,00
€1.655.000,00
€2.200.000,00
€10.860.000,00
€43.600.000,00
€3.160.000,00
€8.520.000,00
€267.406.000,00

€10.785.000,00
€6.285.000,00
€3.471.000,00
€4.630.000,00
€5.655.000,00
€950.000,00
€12.805.000,00
€205.000,00
€46.580.000,00
€7.650.000,00
€7.240.000,00
€2.010.000,00
€14.790.000,00
€15.830.000,00
€2.295.000,00
€715.000,00
€4.044.000,00
€7.525.000,00
€2.660.000,00
€11.875.000,00
€7.040.000,00
€2.182.000,00
€1.100.000,00
€12.210.000,00
€43.380.000,00
€2.320.000,00
€38.480.000,00
€274.712.000,00

€8.660.000,00
€2.040.000,00
€2.060.000,00
€665.000,00
€5.240.000,00
€750.000,00
€8.380.000,00
€335.000,00
€11.650.000,00
€5.700.000,00
€8.020.000,00
€2.685.000,00
€18.205.000,00
€19.890.000,00
€3.940.000,00
€2.855.000,00
€3.600.000,00
€7.500.000,00
€1.610.000,00
€11.115.000,00
€7.595.000,00
€3.125.000,00
€1.375.000,00
€20.610.000,00
€39.300.000,00
€1.080.000,00
€38.050.000,00
€236.035.000,00

€45.420.000,00
€31.031.000,00
€9.791.400,00
€22.652.000,00
€32.305.000,00
€12.419.000,00
€35.502.100,00
€5.955.000,00
€251.782.000,00
€97.884.000,00
€33.907.000,00
€15.485.000,00
€96.579.000,00
€131.587.000,00
€11.749.100,00
€9.025.000,00
€15.962.000,00
€26.359.000,00
€36.914.000,00
€71.555.000,00
€55.199.000,00
€9.018.000,00
€11.540.000,00
€97.438.000,00
€235.850.000,00
€34.068.000,00
€122.251.000,00

€1.559.227.6

00,00  

37 

 
 
 
 
 
 
 
 
FOOD SAFETY BUDGET 2005-2011: overall allocations per MS 

38 

 
 
 
 
 
 
 
 Annex 2: Added Value from EU co-financing: example case studies  

Taking  into  account  the  lack  of  a  cost-effectiveness  analysis,  a  continuous  evaluation  of  the 
programmes co-financed at EU level is nevertheless possible. This evaluation has been conducted in 
the last few years, based on tangible results of EU action to support the MSs in eradicating, controlling 
and  monitoring  certain  animal  diseases.  These  studies  have  shown  the  overall  success  of  the 
veterinary  programmes  but  also  highlighted  some 
less  virtuous  stories  where  particular 
implementation issues adversely affected the performance of the programme. 

Case Study 1: Rabies 

Rabies  is  an  infectious  zoonosis  which  may  affect  all  mammalian  species.  In  Europe  the  main 
reservoirs  for  the  disease  are  populations  of  wild  red  foxes.  The  disease  is  passed  through  bites  or 
other  close  contact,  and  is  invariably  fatal  in  humans  unless  prophylactic  treatment  is  applied 
immediately  after  contact.  Worldwide  rabies  is  responsible  for  more  than  50,000  reported  deaths, 
mainly in children. Unofficial estimates suggest that including unreported cases, the real figure may be 
at  least  double  this.  Therefore,  it  is  primarily  a  public  health  worry  (although  can  also  cause  direct 
losses in kept livestock animals). The problem of controlling the disease at its origin (wild animals) has 
been tackled in recent decades through the spreading of baits containing oral vaccine. Co-ordinated 
efforts  across  national  borders  are essential  to  its  successful  eradication,  as  wild  animals  can  cross 
borders  and  re-introduce  the  disease  into  an  area  in  which  it  has  been  previously  eradicated  if  joint 
measures are not taken.  
The  EU  has  striven  to  eradicate  rabies  from  its  territory  since  the  1990s.  Rabies  was  previously 
common  across  much  of  Europe  (see  1992  map),  but  concentrated  and  co-ordinated  efforts,  co-
financed by the EU, led to certain areas, notably France, Belgium, Luxembourg, Austria and much of 
Germany,  being  free  from  rabies  by  2000.  Further  significant  progress  came  in  the  2000s,  as  new 
Member States from Eastern Europe gained access to EU funding that enabled them to put in place 
large  scale  oral  vaccination  campaigns.  This  and  the  importance  of  the  co-financed  funding  to 
incentivise  effective  vaccination  programmes  led  to  clearances  of  whole  swathes  of  central  and 
Eastern Europe by 2009.  

Figure 1: Wildlife-associated rabies cases 1992 - 2009 
                     1992      

                        2000 

2009 

There has been a sustained reduction in spending on rabies in the 1990s and up to 2003. This was 
thanks to the success of the vaccination campaigns in all the rabies affected then-Member States as 
oral  vaccination  was  discontinued  in  cleared  areas.  Spend  on  rabies  has  gone  up  considerably  in 
recent years, notably since accession of new Member States in 2004, and the increase in co-financing 
from 50% to 75% in 20106. The cost in real terms, however, is still relatively small. Between 2004 and 
2010, only €43m has been spent on EU co-financing.  

6  The  reason  for  increasing  to  75%  was  the  economic  difficulties  of  some  MS  in  securing  national  funds  to 
maintain  oral  vaccination  until  final  eradication.  Should  this  happen,  the  resources  spent  in  previous  years  are 
39 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
                                                            
Figure 2: Number of cases in wildlife and cats and dogs, EU Member States 1994-2009 

Figure 3: Rabies, EU co-funding (payments) 1992-2009 

*Note:  data  include  payments  for  countries  which  were  non-EU  MS  at  the  time:  Austria  (pre  1995) 
€255,662, Poland €1,043,832 (pre 2004), and Czech  Republic €22,466 (pre 2004); also, Switzerland 
€45,972 . 
Source: DG SANCO-based on financial decision 1992-2009 

wasted, as interruption of vaccination before eradication enables the disease to quickly spread again. A second 
reason was to further support MS in the final efforts to achieve eradication 

40 

 
 
 
 
 
 
 
                                                                                                                                                                                          
As rabies is primarily a risk in wild animals which can spread across borders unchecked, the EU also 
co-finances programmes which include some bordering 'buffer zones', where these are not currently 
funded  by  the  neighbouring  country  in  question.    So,  for  example,  the  Polish  veterinary  programme 
has  included  some  areas  of  Ukraine  and  the  Latvian  and  Lithuanian  programmes  include  bordering 
Belarusian territories. These are funded for the good of the EU as a whole to prevent re-incursions into 
European territory, threatening European citizens. The spend outside the EU is only a tiny part of the 
veterinary programmes as a whole.  
The effect of the application of oral rabies vaccination in the EU can be understood by the comparing 
the  number  of  indigenous  human  cases  (deaths)  reported  in  certain  neighbouring  European  third 
countries  with  those  in  the  EU  in  recent  decades  (Table  2).  It  is  important  to  note  that  the  two 
indigenous  cases  reported  in  the  EU  in  recent  years  are  both  located  in  Romania,  the  last  Member 
State to launch EU-funded vaccination campaigns (started in 2011). Most cases in the EU are in fact 
'imported' due to people contracting rabies abroad (generally on other continents) where the disease 
is endemic and only showing symptoms after having returned home.  

Table 2: Indigenous cases in the EU and certain other European countries 

Belarus 

Russian Federation 

Ukraine 

EU-27 
Source: WHO 

2004 

2005 2006 2007 2008 2009 2010 2011  2012  Total 

0 

12 

0 

0 

0

8

0

0

0

2

0

0

0

6

2

1

0

12

2

0

0

10

0

0

0

6

2

0

1 

10 

0 

0 

1 

1 

0 

1 

2

67

6

2

Thus, the EU co-financing is very small compared to the benefits of the eradication of a serious and 
fatal zoonosis. Apart from the prevented human deaths, a significant saving for a rabies-free country is 
the reduced need for post-exposure treatment for humans being bitten by animals, which is extremely 
expensive, and takes a significant period of time to recover (with associated economic losses). Much 
alternative  cost  has  been  saved  through  the  veterinary  programmes.  In  rabies-free  countries,  this 
treatment is limited to travellers attacked by animals in infected countries. 

Case Study 2: Salmonella 

One notable example of the catalytic impact of EU funding is in the tackling of salmonella outbreaks. 
In 2004, the implementation of mandatory control programmes was introduced. The salmonella control 
programmes  are  targeted  at  the  most  frequent  causes  of  human  infections,  notably  salmonella 
Enteriditis  and  salmonella  Thyphimurium,  which  are  responsible  for  about  75%  of  human  infections 
(2009  data).  EU  co-financing  is  given  at  the  rate  of  50%  for  certain  defined  measures,  and  totalled 
under €30m over the period 2004 – 2009.  
Epidemiological  data  since  that  date  clearly  shows  that  there  has  been  a  substantial  and  steady 
decline in the reported cases in humans across all 27 Member States. The drop is approximately 49% 
between 2004 and 2010, from 196,000 cases to 99,020. EFSA (the European Food Safety Authority) 
estimated in 2010 that the overall burden of human salmonellosis in the EU was up to €3bn per year in 
2008.  Making  a  simplistic  assumption  that  the  cost  per  case  has  remained  approximately  the  same 
over  this  period  (and  without  adjusting  for  inflation),  we  can  extrapolate  that  the  savings  to  the  EU 
economy between 2004 and 2010 have been between a wide range of €131m a nd €1.96bn. Therefore 
l  spend)  seems  a  small  price  to  pay  for  such  an 
€30m  of  EU  co-financing  (and  around  €60m  of  tota
enormous reduction in costs, and demonstrates a clear overall economic benefit, even if the scale is a 
wide  range.  And,  this  is  no  minor  achievement  –  leaving  aside  the  economic  impact  of  human 
salmonellosis,  which  is  usually  characterised  by  treatable  symptoms;  it  can  be  fatal,  and  so  have  a 
devastating personal impact. 

41 

 
 
 
 
 
 
 
 
 
 
  
 
 
 
 
 
Figure 4: Confirmed salmonella cases in humans, 2001-2010 

Start o f pro gram m es 

Note: From 2001-2004 data refer to total cases rather than confirmed cases 

*

Case Study 3: BSE 

Bovine Spongiform Encephalopathy (BSE) is the bovine form of the disease known as Transmissible 
Spongiform Encephalopathy (TSE). In Europe, it was first confirmed in the UK in 1987, and a serious 
epidemic subsequently developed.  
BSE  is  a  concern  because  the  balance  of  evidence  suggests  that  it  is  zoonosis  (leading  to  the 
invariably  fatal  human  disease  variant  Creutzfeldt–Jakob  disease  or  vCJD)  transmitted  by  the 
consumption of infected bovine products. At one time it was feared that BSE would lead to a serious 
vCJD epidemic. Although the scale of epidemic once anticipated has not arisen, there have been 173 
cases  in  the  UK  (as  of  August  2012),  all  fatal,  and  several  other  cases  in  the  EU;  most  notably  in 
France (27 cases, all fatal)7. 
Although the major concern is a public health risk, BSE in cattle causes serious and direct economic 
losses, and indirect losses through lack of ability to trade. Because the prions associated with BSE are 
not  routinely  destroyed  by  heat,  BSE  infected  cattle  products  are  not  safe  for  human  consumption 
even if cooked, and must be destroyed at high temperatures.  
Once the disease became a clear and serious concern, the EU took specific measures to manage and 
eradicate  BSE  across  its  territory.  In  the  UK,  the  export  of  beef  cattle  and  bovine  products  was 
completely banned, and the beef cattle trade was decimated. Before the ban, in 1995, annual exports 
of beef of 300,000 tonnes were worth almost GBP£600 million. There was also a substantial trade in 
live calves from the British dairy herd to the rest of Europe, worth some GBP£70 million per year. This 
trade completely collapsed when the European Union imposed a ban on all UK exports worldwide as a 
consequence of the BSE crisis (figures sourced from the Department for Environment, Food and Rural 
Affairs, UK).  
During the epidemic, more than 185,000 BSE cases in cattle were confirmed in the European Union. 
At the height of the crisis, consumer confidence in the food chain was at an all-time low. In response 
to this, the European Union implemented a new, comprehensive regulatory framework (the 'food law') 
to  improve  EU  food  safety,  ensure  a  high  level  of  consumer  protection  and  restore  and  maintain 
confidence  in  the  EU  food  supply.  In  addition,  the  EU  banned  the  use  of  animal  protein  for  feeding 
ruminants, measure that blocked the source of infection to animals. 

7 National CJD Research & Surveillance Unit (NCJDRSU), University of Edinburgh: 
http://www.cjd.ed.ac.uk/vcjdworld.htm  

42 

 
 
 
 
 
 
 
                                                            
The reaction of the EU to this crisis in terms of funding consisted of market measures (handled by DG 
AGRI)  and veterinary measures that included eradication measures (culling of infected or suspected 
animals)  and  stringent  monitoring  measures  (testing  of  all  bovines  dying  on-farm  and  all  bovines 
slaughtered, before releasing the meat for consumption). 
During  the period 2005-09,  the  EU co-financed TSE  monitoring and  eradication  programmes  across 
the  EU-27.  For  the  years  2005-2008,  the  majority  (over  80%)  of  funding  was  provided  for  TSE 
monitoring, a necessary measure to ensure that the disease continues to decline. Nevertheless, the 
monitoring rules have been significantly relaxed for bovines given the improving and now favourable 
situation,  and  the  number  of  tests  performed  is  now  significantly  lower  than  previously.  The  total 
amount of EU co-financing was €413m. 

Figure 5: Co-financing for TSEs 2007 - 2011 

Veterinary programmes on TSEs 
Budget committed 2007-2011

140,000,000 €

120,000,000 €

100,000,000 €

80,000,000 €

60,000,000 €

40,000,000 €

20,000,000 €

0 €

2007

2008

2009

Year

2010

2011

In the case of BSE, there has been a dramatic drop in the number of positive cases since the end of 
the 1990s. During the period 2002-2009, there was an average 35% year-on-year drop for the period; 
by 2009 only 67 positive cases were found from over 7 million performed tests; in 2010 45 cases from 
7.5  million  tests;  and  in  2011  28  cases  from  6.3  million  tests,  implying  the  disease  has  almost 
disappeared. 

The  key  success  from  the  reduction  in  BSE  cases  has  been  the  restoration  of  trade.  The  UK  is  a 
particularly good example, as it was severely hit by the trade ban in 1995. Figure 7 clearly shows the 
impact  of  the  ban,  and  the  subsequent  lifting  of  it  in  2005.  UK  beef  exports  since  then  have  grown 
steadily, since the UK could demonstrate that beef  posed negligible risk to humans and so restored 
consumer confidence.  

43 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Figure 6: BSE Cases in the EU 2001-2009 

Figure 7: UK fresh bovine meat exports, quantity and value 1985 - 2010 
900,000

800,000

700,000

600,000

500,000

400,000

300,000

200,000

100,000

0

5
8
9
1

6
8
9
1

7
8
9
1

8
8
9
1

9
8
9
1

0
9
9
1

1
9
9
1

2
9
9
1

3
9
9
1

4
9
9
1

5
9
9
1

6
9
9
1

7
9
9
1

8
9
9
1

9
9
9
1

0
0
0
2

1
0
0
2

2
0
0
2

3
0
0
2

4
0
0
2

5
0
0
2

6
0
0
2

7
0
0
2

8
0
0
2

9
0
0
2

0
1
0
2

Source: FAOSTAT 

Tonnes

Value ($1000)

44 

 
 
 
 
 
 
 
 
 
Case Study 4: Bovine Tuberculosis  

Bovine Tuberculosis is the bovine form of the tuberculosis family of bacteria. It can affect practically all 
mammals.  Until  the  1920s  when  control  measures  began  in  developed  countries,  it  was  one  of  the 
major diseases of domestic animals throughout the world. Today TB remains an important disease of 
cattle, wild animals, and is a zoonosis (an animal disease which can be transmitted to humans).  
BTB has a number of specific characteristics which make it a difficult disease to control without taking 
long-term  and  persistent  measures.  First,  the  disease  can  take  months  or  years  to  develop  clinical 
symptoms,  while  the  animal  is  nevertheless  infectious.  Therefore,  once  established,  it  can  spread 
through a population undetected if testing is not routinely applied. Second, the disease can often be 
found in populations of wild animals, which are much more difficult to control. Third, although vaccines 
are available to prevent BTB, their use is prohibited by EU law. This is primarily because vaccines can 
interfere with testing for the purposes of detection and elimination. Therefore, testing and culling are 
the most widely used control measures.  
The presence of BTB has a serious impact on trade, and the achievement of 'officially-free status' is a 
crucial  objective  of  BTB  control  measures,  as  this  status  allows  producers  to  trade  freely.  Officially-
free status can be applied to individual holdings in some cases, but can also be granted to regions or 
countries.  
Although cases are now rare, BTB can also infect humans through the consumption of unpasteurised 
milk,  and  very  rarely,  through  direct  contact  with  infected  animals  through  the  inhalation  of  infected 
droplets.  

Figure 8: BTB co-financing 2007-2011 

Veterinary Progremmes on Bovine Tubercolosis
Budget committed 2007-2011

80,000,000 €

70,000,000 €

60,000,000 €

50,000,000 €

40,000,000 €

30,000,000 €

20,000,000 €

10,000,000 €

0 €

2007

2008

2009

Years

2010

2011

BTB is a slow and difficult disease to tackle, but there are success stories where clear progress can 
be demonstrated, in part due to EU co-financing. 

BTB in Spain 
In  Spain,  the  first  actions  to  eradicate  bovine  TB  were  taken  in  the  1950s.  In  1965  the  government 
adopted  a  national  plan  to  combat  the  disease.  Since  accession  to  the  EU  (1986),  programmes  for 
eradication have been accelerated.  
Between 1993 and 2009, clear progress can be demonstrated in the reduction of the number of cases.   

45 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Figure 9: Bovine TB in Spain, herd prevalence and animal incidence 1993-2009 

Figure 10: EU co-financing on Bovine TB in Spain 2005-2011  

€20,000,000

€18,000,000

€16,000,000

€14,000,000

€12,000,000

€10,000,000

€8,000,000

€6,000,000

€4,000,000

€2,000,000

€0

2005

2006

2007

2008

2009

2010

2011

Of course, this success has come through the costs of eradication and control measures. The EU co-
financing for BTB in Spain in recent years has increased, although the disease has continued to fall. 
This  is  because  as  the  Spanish  authorities  are  winning  the  battle  against  TB  and  seeking  to 
completely  eradicate  the  disease  from  their  territory,  nevertheless,  there  are  fewer  efficiencies  of 
scale. Control costs therefore tend to rise as you make concerted efforts and get closer to eradication. 
Nevertheless,  once  eradicated  and  declared  officially  free,  measures  would  reduce  to  very  minimal-
cost surveillance in order simply to keep on top of any incursions. And a sense of perspective should 
be retained as to these costs. While millions of euros have been spent on tackling TB, the costs of not 
tackling it would be far higher. There would be costs in both direct losses to farmers through losses of 
animals; but also of the lack of ability to trade. Spain's export trade in live bovines, bovine meat, milk, 
cheese and butter was worth US$1.26bn in 2010 alone (equivalent to €947m at 2010 exchange rates) 
(FAOSTAT), and not tackling bovine TB would impact on this trade very seriously, even wiping it out 
altogether if the disease were once again to become widespread.  

46 

 
 
 
 
 
 
 
 
 
 
Case Study 5: CSF 

Classical swine fever (CSF) is an animal disease affecting domestic pigs and wild boar, of all breeds 
and ages. It is a highly contagious infection, easily transmitted by direct and indirect contact between 
pigs, and by materials, swill feeding, trucks, instruments, and humans carrying the virus. 
CSF does not infect humans. However, it can cause very significant losses to pig holdings, both due to 
morbidity and mortality, and because of trade restrictions. Indeed, it is a transboundary disease and 
the  epidemiological  situation  in  one  country  can  affect  neighbouring  countries,  therefore  national 
measures alone tend not to be sufficient to control its spread, especially when outbreaks occur near 
borders. 
CSF is an example of a highly contagious disease that has been eradicated from most of the EU MS 
due to stringent vaccination and subsequent prevention and control measures. 
Effective vaccines have been available for CSF since the 1980s. Attenuated live vaccines have proven 
to  be  the  most  effective  way  of  reducing  disease  prevalence  by  providing  quick,  long  lasting  and 
complete  protection.  Moreover,  vaccination  of  wild  boar  has  proven  to  be  a  tool  of  increasing 
importance to control CSF in the environment in Europe over the last 20 years.  
Movement control is also crucial in the control of CSF outbreaks, and forms an important element in 
the contingency plans that all EU Member States have prepared for use in the event of an outbreak.  

EU funding for the eradication of CSF over the period 1995-2009 has amounted to €30,207,724. The 
distribution of payments has been steady throughout the period considered, with the exception of 2007 
and  2009.  Thanks  to  the  eradication  measures  and  the  vaccination  policy,  by  2004,  CSF  was 
eradicated in the majority of EU15 Member States. The increases in 2007 and 2009 were due to the 
fact that, since 2007, (since their accession to the EU), veterinary programmes have been granted to 
the  new  MSs,  particularly  Romania,  where  the  disease  was  previously  widespread,  mainly  in  the 
backyard pig population.  

Figure 11: EU co-funding (payments) by MS and year, 2005-2009 

Epidemiological  data  for  these  countries  indicate  that,  since  2005,  CSF  (Belgium,  Czech  Republic, 
Slovenia and Luxembourg) incidence in domestic pigs and wild boar has disappeared, or decreased to 
almost  zero  (Bulgaria,  Germany,  France,  Hungary,  Luxembourg,  Romania  and  Slovakia).  The  only 
exceptions were unexpected outbreaks in Romania in 2006/7, but the country has remained free since 
then. 

47 

 
 
 
 
 
 
 
 
 
 
 
One of the main positive impacts of the eradication programmes has been the reduction of the CSF 
incidence  in  domestic  pigs,  making  it  possible  to  focus  on  the  wildlife  reservoir,  the  wild  boar,  as 
source of infection. 
The success of the eradication programmes in the EU can be clearly seen through these maps.  

Figure 12: Maps of Classical Swine Fever cases in the EU, 1984-2012 

1984 - 2001

2002 - 2008

2009 - 2010

2011 - 2012

Case Study 6: Bovine Brucellosis 

Bovine  brucellosis  is  a  disease  of  cattle  which  is  also  a  zoonosis.  If  untackled,  it  causes  direct 
economic losses through spontaneous abortions in cattle, and can be passed onto humans, where it is 
occasionally  fatal.  It  can  be  vaccinated  against,  and  there  are  several  success  stories  of  complete 
eradication to be found within the EU.  

From  an  economic  perspective,  these  success  stories  have  yielded  benefits  resulting  from  the 
avoidance of direct losses for farmers from the cost of morbidity and the cost of reduced production. In 
terms of the costs of the programmes, the improved health status of the herd has led to a reduction in 
number and the frequency of sampling as well as in the number of slaughtered animals. One of the 
main positive impacts of the eradication programmes has also been the removal of barriers to trade, 
and therefore, the avoidance of indirect losses for operators. As the percentage of accredited holdings 
increases,  the  commercial  potential  of  the  products  increases,  and  the  movement  of  animals  and 
animal products is facilitated. This is particularly relevant as regards the movement of animals for the 
purposes of intra-EU trade. 

Brucellosis in Ireland  
A  national  brucellosis  scheme  has  been  implemented  in  Ireland  since  1966.  At  the  beginning  a 
clearance area was designated, which included the areas of lowest incidence, and a compulsory blood 
testing programme was introduced, accompanied by a system of ring testing of milk. 

48 

 
 
 
 
 
 
 
 
 
 
 
Figure 13: Spending on Brucellosis 2007-2011 

Veterinary Programmes on Bovine Brucellosis
Budget committed 2007-2011

16,000,000 €

14,000,000 €

12,000,000 €

10,000,000 €

8,000,000 €

6,000,000 €

4,000,000 €

2,000,000 €

0 €

2007

2008

2009

Years

2010

2011

Figure 14: Bovine brucellosis in Ireland, herd and animal prevalence and incidence, 2000-2008 

Over the years the clearance area was extended at various stages until it covered the whole country 
and a general disease-free status was achieved throughout the country by 1986. Measures aimed at 
achieving eradication of the disease have been maintained since then and the incidence has declined 
below 0.2% in the period. In the mid-1990s, an increase of the disease incidence was observed, with 
this  being  attributed  to a  temporary  accelerated  movement  pattern of  cows, which was prompted  by 
keepers  changing  the  profile  of  their  suckler  herds  in  following  the  1992  reform  of  the  CAP.  An 
intensified eradication programme was therefore introduced in the country to deal with this increase in 
brucellosis levels and this has been improved and continued since then. Since 1998, brucellosis levels 
have continued to fall and in 2009 Ireland achieved 'Officially Free' status, following three years with 
no cases. 

49 

 
 
 
 
 
 
 
 
 
Since 2001, Irish bovine exports have undergone a good increase. This has undoubtedly been helped 
by the eradication of brucellosis. Particularly noticeable in Figure 15 is the growth of the export of live 
bovines,  more  than  a  fourfold  increase  between  2001  and  2010.    The  declaration  of  officially  free 
status in 2009 is likely to have been an important contributory factor to the rapid increase of export of 
live bovines in 2009 and 2010. 

Figure 15: Irish live bovine, bovine meat and milk exports 2001-2010 (source: FAOSTAT) 
400000

350000

300000

250000

200000

150000

100000

50000

0

Fresh bovine meat exports (tonnes)

Fresh milk exports (tonnes)

Live bovine animal exports (head)

2001

2002

2003

2004

2005

2006

2007

2008

2009

2010

Case Study 7: Avian Influenza 

Avian influenza is a form of the influenza virus, and the term as used here refers to the H5N1 strain. It 
is a zoonosis which can (relatively rarely) be caught through direct contact with birds, although it has 
little transmissible potential between humans in the H5N1 form. In October 2011, the WHO announced 
a total of 566 confirmed human cases which have resulted in the deaths of 332 people since 2003.  
One  of  the  main  motivations  for  carrying  out  surveillance  for  avian  influenza  is  the  possibility  of  an 
evolution  of  the  virus  into  a  more  virulent  and  dangerous  form  of  the  disease  for  humans,  and  the 
consequent fear of a pandemic. For example, the 2009 'swine flu' pandemic appears to have mutated 
from  an  influenza  virus  usually  affecting  pigs,  and  ultimately  led  to  over  7820  deaths  worldwide. 
However, even this pales in comparison to the 'Spanish flu' pandemic of 1918: a 2005 study estimated 
that  Spanish  flu  had  a  global  mortality  rate  of  50-100  million  people,  or  3-6%  of  the  entire  global 
population. One theory about the origin of the Spanish flu virus is that it originated in poultry (although 
a non-human mammalian species is also a possibility).  
Avian influenza can have significant economic impacts. Outbreaks themselves can be very costly, as 
demonstrated by the outbreaks in 2003 in Netherlands (€150m of direct economic costs). Outbreaks 
can  also  lead  to  trade  restrictions.  The  disease  can  affect  consumer  confidence,  and  hence  market 
stability of the poultry and egg sectors, as demonstrated by the 2005/06 loss of consumer confidence. 
The monitoring programmes can help avoid these negative economic impacts through early detection 
which  can  reduce  the  risk  of  large  outbreaks,  and  by  providing  assurance  to  trading  partners  and 
consumers.  
During the period 2006-09, the EU co-financed avian influenza surveillance programmes in all Member 
States.  The  total  EU  funding  over  the  period  amounted  to  just  over  €12m.  These  monitoring 
programmes were designed to detect AI in both wild and domestic birds.  
The  surveillance  programmes  also  allow  the  monitoring  of  low  pathogenic  strains  which  can  mutate 
into high pathogenic strains. For the period 2006-09, the number of wild birds testing positive for low 
pathogenic AI (LPAI) and other strains of AI has remained relatively steady, while the number of wild 
birds testing positive for high pathogenic AI (HPAI) has dropped significantly.  

50 

 
 
 
 
 
 
 
 
 
Figure 16: Avian influenza, outbreaks in wild birds, 2000-2009 

Figure 17: Number of infected wild birds found in surveys 2006-2009 

The number of detections does not represent an indicator of the effectiveness of the programme itself. 
However, the number of detected cases, resulting from the implementation of the survey, indicates the 
relevance of the programme in maintaining a sound alert system for the disease. This has proven to 
be an effective mechanism.  

51 

 
 
 
 
 
 
 
 
 
There are five main reasons for continuing to survey for avian influenza:  

1.  The improvement of overall animal health and welfare. While LPAI has a relatively low impact 

on morbidity and mortality, HPAI can have very dramatic effects.  

2.  Fewer  incidents  of  avian  influenza  in  birds  reduces  the  risk  of  the  disease  in  humans,  both 
amongst farmers and the overall population. This is both the case for the H5N1 virus directly 
infecting  humans,  but  also  reduces  the  possibility  of  a  mutation  creating  a  pandemic  in 
humans (or in other animals important for the food chain or wellbeing of humans).  

3.  Thirdly, there are strong economic benefits, again particularly from avoiding incidents of avian 
influenza  in  domestic  birds.  In  2003  there  was  an  outbreak  of  the  HPAI  H7N7  strain  in  the 
Netherlands. This outbreak resulted in the destruction of 30 million birds and direct economic 
costs  of  €150m  (European  Commission,  2006 8).  Similarly,  the  spread  of  H5N1  among 
domestic  and  wild  birds  in  Romania  during  2005  and  2006,  i.e.  prior  to  EU  accession,  has 
been  estimated  to  have  caused  losses  of  around  €200m  according  to  Romanian  authorities 
(USDA, 2006). In addition, 325 tonnes of poultry meat is believed to have been destroyed, and 
900,000 backyard birds culled. 

4.  Fourth,  the  control  of  avian  influenza  can  have  beneficial  effects  on  trade.  This  is  best 
demonstrated during the 2006 outbreaks of H5N1. Following outbreaks in the EU during 2006, 
until February 2007, some 73 third countries imposed bans on poultry and egg products from 
the  EU.  While  most  of  these  bans applied  to  specific  MS  with  outbreaks,  13  third  countries9 
imposed bans on all poultry meat and egg exports from the EU (independent of whether the 
Member  States  had  reported  an  outbreak  or  not).  In  2006  these  bans  caused  significant 
business  disruption  for  the  EU  exporting  producers.  The  export  value  of  poultry  meat  has 
decreased from €927 in 2005 to €806 in 2006. 

5.  Fifth,  the  surveillance  programme  provides  an  additional  assurance  for  the  public  that  the 

disease is being monitored, which has an impact on market stability in this sector. 

The effect on consumer confidence can be marked. Research has identified that consumer attitudes 
towards  poultry  meat  and  eggs  were  closely  related  to  the  development  of  the  avian  influenza 
epidemic (see European Commission, 2006; and Magdelaine et al., 200810). 
Although the majority of consumers had not changed their consumption habits, the survey found that 
demand  for  poultry  meat  was  affected  (more  than  the  demand  for  eggs).    Specifically,  18%  of 
respondents  had  reduced  consumption  of  poultry  meat,  compared  to  13%  of  respondents  having 
reduced  their  egg  consumption.  However,  the  consumption  response  varied  considerably  between 
MS.  

The  surveillance  programmes  have  played  an  important  role  in  the  fight  against  avian  influenza  by 
contributing  to  the  early  detection  of  the  disease.  Early  detection  allows  rapid  reaction  and  effective 
response  by  enabling  the  timely  adoption  emergency  measures  to  prevent  the  further  spread  of  the 
disease. In particular, protection zones can be established around the finding, and control measures 
can  be  strengthened.  These  actions  in  turn  ensure  that  one  incident  of  avian  influenza  does  not 
develop  into  a  large  scale  outbreak  which  may  eventually  affect  humans.  The  cross-EU  monitoring 
programmes are a small continued price to pay for this advance warning and security. 

8  European  Commission  2006.  Avian  Influenza.    Special  Eurobarometer  257  –  Wave  65.2  –TNS  Opinion  and 
Social.  June 2006. 
9 Angola, Azerbaijan, Cameroon, Chile, Egypt, India, Panama, Papua New Guinea, Senegal, Sierra Leone, Syria, 
Togo, and United Arab Emirates. 
10 Magdelaine, P., Spess, M.P. and Valceschini, E. 2008  Poultry meat consumption trends in Europe. World’s 
Poultry Science Journal. Volume 64, March 2008 

52 

 
 
 
 
 
 
 
                                                            
Figure 18: Attitudes to poultry meat and egg consumption, 2006 

53 

 
 
 
 
 
Annex 3: Objectives of individual policy areas 

Animal Health 

The general objectives of EU animal health policy are outlined in the EU AHS 2007-2013, and are:  
• 

to  ensure  a  high  level  of  public  health  and  food  safety  by  minimising  the  incidence  of  biological 
and chemical risks to humans; 
to promote animal health by preventing/reducing the incidence of animal diseases, and in this way 
to support farming and the rural economy; 
to  improve  economic  growth/cohesion/competitiveness  assuring  free  circulation  of  goods  and 
proportionate animal movements; 
to promote farming practices and animal welfare which prevent animal health related threats and 
minimise environmental impacts in support of the EU Sustainable Development Strategy.  

• 

• 

• 

These  general  objectives  demonstrate  that  the  basis  for  EU  action  is  wider  than  simply  preventing 
public or animal health problems from arising or ensuring the economic security of farmers. The scope 
of  any  new  measures  will  need  to  encompass  not  just  kept  animals  (including  production  animals, 
animals used for work, sport, recreation or display, companion animals and animals used in research); 
but  also,  to  an  extent,  wild  animals,  where  their  poor  health  has  the  potential  to  jeopardise  any  of 
these objectives.  

Plant Health 

The  overall  objectives  of  the  revision  of  the  plant  health  regime  are  to  ensure  an  EU  plant  health 
regime which:  
•  Supports the Union's agricultural policy (TFEU Art. 43) and environment policy (TFEU Art. 191) by 
protective  measures  against  harmful  organisms  of  plants,  with  prevention  at  the  source  as 
important principle; 

•  Allows  a smooth  functioning  of  the  Union's  internal  market  with  fair  competition  (TFEU  Art.  114, 
while respecting the need for a high level of protection of health and the environment, based on 
scientific facts); 

•  Contributes to the harmonious development of world trade (TFEU Art. 206, by adopting legislation 

which complies with the WTO-SPS Agreement). 

The intermediate objectives are:  
•  To ensure that the EU territory remains free from harmful organisms that are not yet present in the 

Union 

•  To ensure that the areas affected by harmful organisms with the most severe impacts to the Union 

(priority organisms) do not increase 

•  To modernise the regime in terms of governance and incentives  
•  To ensure adequate support for the regime 

Plant Reproductive Material 

The general and specific objectives of the PRM revisions are:  
•  To assure the health and high quality of PRM; 
•  To provide a single and harmonised regulatory framework which is supportive for innovation and 

the competitiveness of the European PRM industry; 

•  To  support  sustainable  agricultural  production,  biodiversity  protection,  adaptation  to  climate 

change and to contribute to food security and poverty alleviation. 

•  To  ensure  a  level  playing  field  across  the  EU  through  simplified,  clarified  and  harmonised  basic 

rules on fundamental principles presented in an improved legal form; 

•  To  reduce  unnecessary  costs  and  administrative  burden  and  to  increase  flexibility  for  operators 

without compromising the general policy objectives; 

•  To  align  PRM  legislation  with  other  recent  Union  strategies  (plant  health  law,  official  controls 

regulation, agriculture, biodiversity, food security, climate change, bio-based economy); 

•  To foster innovation in plant breeding, especially in SMEs, in order to improve PRM users’ choice 

and access to a wide diversity of plant varieties adapted to conditions in Europe. 

54 

 
 
 
 
 
 
 
 
 
 
 
Official Controls 

The  specific  objectives  for  the  revision  of  the  official  controls  legislation  were  set  with  the  aim  of 
eliminating  the  specific  obstacles  identified  during  the  official  controls  impact  assessment  which 
prevent  or  hamper  the  achievement  of  the  general  objectives  in  this  area.  The  specific  objectives 
address two sets of obstacles: those resulting from shortcomings in the design of the official controls' 
framework and those resulting from the difficulties and inequities in financing of official controls. 
Objectives related to the design of the official controls' framework 
•  Ensure a comprehensive and consistent approach to official controls along the food chain: 

- 

- 

- 

the  system  of  official  controls  should  be  consistent  across  all  food  chain  sectors  avoiding 
differences which are not justified by the peculiarities of a given sector; 
this  system  should  provide  for  all  tools  necessary  to  ensure  accountability,  soundness  and 
effectiveness of the enforcement activities performed in all food chain sectors; 
this  system  should  avoid  duplications  and  overlaps  which  result  in  divergent  interpretations 
and implementation. 

•  Allow for a more efficient use of national control resources: 

- 

the  system  of  official  controls  should  require  MS  to  allocate,  in  all  food  chain  sectors,  finite 
control resources on the basis of the actual risk in order to achieve the most efficient use of 
such resources. 

•  Reduce administrative burden and remove unnecessary requirements: 

-  unnecessary administrative burden, in particular on MS' CAs, should be eliminated; 
- 

the  system  should  allow  for  the  necessary  flexibility  so  that  important  requirements  (the 
accreditation of official laboratories) can be derogated where appropriate. 

•  Foster closer cooperation between MS to improve official control delivery:  

- 

the  system  of  official  controls  should  enable  swift  and  effective  cooperation,  and  synergies, 
among MS' competent authorities (including customs) which are tasked with controls over the 
food chain. 

• 

Improve transparency: 
- 

the system of official controls should provide MS with a clear guidance on how a 'high level of 
transparency'  should  be  ensured  so  that  the  European  citizens  can  benefit  from  the  same 
level of transparency across the EU.  

55 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Annex 4: Costs and Responsibility Sharing Scheme in the Animal Health Field (Emergency 
fund) 

CRSS Background 
DG Sanco has been going through a long process of analysing the possibility of introducing aspects of 
cost and responsibility sharing into animal health policy. This has included a 'pre-feasibility study' on 
options  for  harmonised  cost-sharing  schemes  in  advance  of  the  Animal  Health  Strategy  2007-2013 
published in 2005, a working party of Chief Veterinary Officers (CVOs) in 2008 and a Feasibility Study 
published in 2011, as well as many other consultations. All of these have been looking at the ways in 
which losses from animal disease could be financed. A possible option derived from exhaustive recent 
analysis includes the compulsory introduction of a harmonised cost and responsibility sharing scheme 
in the form of three complementary aspects.  

1.  A bonus-malus system to calculate direct losses which are at present compensated by 
the  EU.  This  envisages  changing  the  co-financing  rate  for  each  MS  according  to 
whether it had made claims from the emergency fund in the previous year.  

2.  A public-private partnership scheme to contribute to the compensation of direct losses 

not currently co-financed by the EU.  

3.  Coverage  of  indirect  losses  (such  as  loss  of  business  through  trade  restrictions) 
through the voluntary introduction of mutual funds or similar insurance-type schemes.  
Considering  these  three  aspects,  a  preferred  option  was  developed  which  centred  on  a  voluntary 
approach – no bonus-malus; a voluntary introduction of a public-private partnership; and the positive 
encouragement of schemes to cover consequential losses. This would be introduced with the door left 
open to introduce a bonus-malus and/or make the introduction of a public-private partnership scheme 
compulsory if it was shown to work well.  
However, the assessment does acknowledge that: 
-  this  three-part  system  is  complicated,  defeating  the  objectives  of  clarity  and  simplicity  which  are 
objectives for this IA 
- it creates an additional administrative burden for both authorities and operators 
-  the  likelihood  of  its  being  acceptable  to  MSs  (Bonus-Malus  system)  and  to  stakeholders (PPPs)  is 
small 
-  even  if  in  the  long  term,  it  may  reduce  the  impacts  of  animal  disease,  limited  advantages  can  be 
envisaged in the short term 
-  the  current  financial  climate  makes  it  even  more  difficult  politically  and  culturally  for  MSs  and 
stakeholders to accept a larger share of the financial burden, even if their overall net burden reduces 
in the long term.  

-  moreover,  the  assessment  is  not  complete  for  all  food  and  feed  expenditure,  as  it  was  only 
conducted in the animal health area. 
As  it  is,  there  is  not  enough  evidence  to  suggest  that  the  benefits  from  introducing  this  system  will 
outweigh the costs. 

56 

 
 
 
 
 
 
 
 
 
 
 
Annex 5: References 

Multiannual Financial Framework 

•  Communication from the Commission to the European Parliament, the Council, the European 
Economic and Social Committee and the Committee of the Regions: "A Budget for Europe 
2020": http://ec.europa.eu/health/programme/docs/maff-2020_en.pdf 

•  Commission working paper: A Budget for Europe 2020: The added value of the EU budget 

http://ec.europa.eu/budget/library/biblio/documents/fin_fwk1420/working_paper_added_value_
EU_budget_SEC-867_en.pdf 

•  Commission working paper: A Budget for Europe 2020: the current system of funding, the 

challenges ahead, the results of stakeholders' consultation and different options on the main 
horizontal and sectorial issues accompanying the new Multiannual Financial Framework. 
http://ec.europa.eu/budget/library/biblio/documents/fin_fwk1420/SEC-868_en.pdf  

Animal Health 

•  EU Animal Health Strategy 2007-2013 (AHS) "Prevention is better than cure" 

http://ec.europa.eu/food/animal/diseases/strategy/docs/animal_health_strategy_en.pdf  

•  EU Animal Health Strategy 2007-2013: Action Plan 

http://ec.europa.eu/food/animal/diseases/strategy/docs/COMM_PDF_COM_2008_0545_F_E
N_AUTRE_PROC_LEG_NOUVELLE.pdf  

•  Audit on the management of veterinary programmes in DG SANCO, DG SANCO, 2010 
•  Report on the outcome of the EU co-financed animal disease eradication and monitoring 

programmes in the MS and the EU as a whole: Food Chain Evaluation Consortium (FCEC), 
2011 
http://ec.europa.eu/food/animal/diseases/eradication/docs/fcec_report_ah_eradication_and_m
onitoring_programmes.pdf 

•  Audit on the veterinary emergency fund and plant health measures in DG SANCO, DG 

SANCO, 2012 

•  Evaluation of the Eradication, Monitoring and Control Programmes for Animal Diseases, GHK 

(interim report)  
Impact Assessment for the Animal Health Law (yet to be published) 

• 

Plant Health and PRM 

•  Evaluation of the Community Plant Health Regime, FCEC, 2010 

http://ec.europa.eu/food/plant/plant_health_biosafety/rules/docs/final_report_eval_en.pdf  
•  Evaluation of the Community acquis on the marketing of seed and plant propagating material 

(S&PM), FCEC, 2008: 
http://ec.europa.eu/food/plant/plant_propagation_material/review_eu_rules/docs/s_pm_evalua
tion_finalreport_en.pdf  
Impact Assessment for the Plant Health Law (yet to be published) 
Impact Assessment on PRM (yet to be published) 

• 
• 

Better Training for Safer Foods  

•  Evaluation of the benefits of the Better Training for Safer Foods Programme, GHK (interim 

report)  

European Union Reference Laboratories 

•  Evaluation of the EU-RLs in the field of food and feed safety and animal health and live 

animals, FCEC, 2011: 
http://ec.europa.eu/food/food/controls/reference_laboratories/evaluation_en.htm  

Most Relevant Legislation:  

•  Council Directive 2000/29/EC 
•  Regulation (EC) No. 882/2004 
•  Council Decision 2009/470/EC (Council Decision 90/424/EEC) 
•  Regulation 1205/2005 

57