REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL on systems restraining bovine animals by inversion or any unnatural position
Date: 2016-02-08
Institutions: Directorate-General for Health and Food Safety, European Commission
Subjects: animal welfare, professional qualifications, protection of animals, slaughter of animals, technical standard, veterinary inspection

EUROPEAN 
COMMISSION 

Brussels, 8.2.2016  
COM(2016) 48 final 

REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND 
THE COUNCIL 

on systems restraining bovine animals by inversion or any unnatural position 

EN 

   EN 

 
 
 
 
  
 
REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND 
THE COUNCIL 

on systems restraining bovine animals by inversion or any unnatural position 

1. 

BACKGROUND 

Article 27(2) of Council Regulation (EC) No 1099/2009 on the protection of animals 
at  the  time  of  killing1  provides  that  the  "  No  later  than  8  December  2012,  the 
Commission shall submit to the European Parliament and to the Council a report on 
systems  restraining  bovine  animals  by  inversion  or  any  unnatural  position.  This 
report shall be based on the results of a scientific study comparing these systems to 
the  ones  maintaining  bovines  in  the  upright  position  and  shall  take  into  account 
animal  welfare  aspects  as  well  as  the  socioeconomic  implications,  including  their 
acceptability  by  the  religious  communities  and  the  safety  of  operators.  This  report 
shall,  if  appropriate,  be  accompanied  by  legislative  proposals  with  a  view  to 
amending  this  Regulation  concerning  the  systems  restraining  bovine  animals  by 
inversion or any unnatural position." 

To  prepare  this  report  the  Commission  commissioned  a  study  (later  called  the 
"BoRest study"2). 

Due  to  the  specificity  and  the  complexity  of  this  study  (in  particular  collecting 
technical and scientific data in slaugherthouses), its preparation and realisation took 
much more time than expected, hence a delay in adopting this report. 

2. 

RESTRAINING SYSTEMS FOR BOVINE ANIMALS SLAUGHTERED WITHOUT STUNNING 

2.1. 

The issue 

In slaughterhouses, bovine animals3 are restrained in upright position in a restraining 
pen before being stunned, usually using a penetrating captive bolt. 

Article  4(4)  of  Regulation  (EC)  No  1099/2009  provides  that  the  stunning 
requirements set out in Article 4(1) and in Annex I to this regulation do not apply if 
slaughter is subject to particular methods prescribed by religious rites, provided that 
the slaughter takes place in a slaughterhouse. Under these conditions EU legislation 

1 
2 

3 

OJ L 303, 18.11.2009, p. 1. 
Restraining  systems  for  bovine  animals  slaughtered  without  stunning/  Welfare  and  socio-economic 
implications – BOREST - by Institut de l'Elevage (as coordinator). June 2015. 
(http://ec.europa.eu/food/animals/welfare/practice/slaughter/index_en.htm). 
In the context of this report the word "animals" only refers to bovine animals (adult cattle and calves). 

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exceptionally  allows  slaughter  methods  without  stunning  such  as  bleeding  animals 
without prior stunning, which include ritual slaughter described by Jewish or Muslim 
rites. For that purpose, specific restraining systems have been designed to reverse the 
bovine  animal  upside  down  or  on  its  side  (rotating  pen)  in  order  to  facilitate  the 
cutting by  the  slaughterman. Such restraining  systems  may  only  be  used  if  animals 
are slaughtered without stunning4. 

In  a  2004  report  on  the  welfare  aspects  of  animal  stunning  and  killing  methods, 
scientists  of  the  European  Food  Safety  Authority  (EFSA)  favoured  restraining 
animals in an upright position in case of slaughter without stunning5. Their opinion  
was  based  on  a  publication  from  1990  comparing  two  types  of  pens  (upright  vs. 
rotating). 

However, during the process of adoption of Regulation (EC) No 1099/2009, it was 
argued  that  rotating  pens  used  in  Europe  are  now  substantially  different  from  the 
model  described  in  the  1990  publication.  In  addition  some  religious  communities 
expressed  concerns  that  an  upright  position  might  not  be  compatible  with  their 
religious rites. 

2.2. 

General situation 

In 2012, in total 25 million bovine animals were slaughtered in the EU6 from which 
around  2.1  million7  (8,5%)  were  slaughtered  without  stunning,  nearly  all  of  them 
(97%) in six Member States8.  

From these 2.1 million animals, more than 1.6 million are slaughtered in a rotating 
device (78 % of the animals slaughtered without stunning) while the rest (22 %) are 
slaughtered in an upright device. 

In 2012, rotating devices were not in use in Latvia, Portugal, Romania, Slovakia and 
the UK. The upright position was mandatory in the UK9. 

The breakup between upright and rotating pen varies considerably between Member 
States  from  100%  upright  (in  the  UK  due  to  legislation)  to  90%  rotating  (France), 
with various intermediate figures. 

There  is  a  wide  range  of  practice  in  the  way  rotating  pens  are  used.  Most  of 
slaughterhouse  operators  (80%)  using  the  inverted  position  of  180°  (upside  down), 
while the rest put the animal in a partial rotation at 90° (on the side). 

4 
5 
6 
7 
8 
9 

Article 15(2) of Regulation (EC) No 1099/2009. 
http://www.efsa.europa.eu/EFSA/efsa_locale-1178620753812_1178620775454.htm, see page 25. 
For details: see in particular section 4 of the Borest study. 
The precise figure is 2 147 300 bovine animals based on a 2012 survey from the competent authorities. 
Belgium, France Italy, the Netherlands, Spain and the UK. 
The upright position was also mandatory in Estonia but no slaughter without stunning was performed 
during the survey. 

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2.3. 

Rotating devices 

There are many types of equipment used (32 models identified by the BoRest study) 
with various manufacturers. Three main manufacturers share 50% of the market, the 
other half being supplied by local ones. 

According  to  the  BoRest  study,  more  than  90%  of  the  French  slaughterhouses  are 
equipped  with  modern  designed  rotating  device,  independently  of  the  size  of  the 
slaughterhouses. These devices are also used in other countries like the Netherlands, 
Spain  and  Belgium  (with  France,  these  Member  States  representing  85%  of  the 
animals slaughtered without stunning). 

Based on these data, the BoRest study estimates that more than 85% of the animals 
are slaughtered with modern designed rotating device. This is coherent with the fact 
that 67% of the slaughterhouses are equipped with devices of less than 10 years and 
that investment anterior to 1990 represents less than 15% of the slaughterhouses. 

3. 

ANIMAL-WELFARE CONSIDERATIONS 

3.1. 

Litterature review 

In the 2004 EFSA report, scientists refer to a study performed in 1990 comparing a 
type  of  pen  where  animals  are  restrained  in  an  upright  position  (Cincinnati  pen  or 
ASCPA) and a pen where animals are turned on their side or back (Weinberg pen). 
From this study it appears that there is a welfare advantage in restraining animals in 
an upright position. 

Since the introduction of the Weinberg pen, there have been significant alterations to 
the original design of rotating restraints. 

Inverting  the  animals  generates  a  series  of  animal  welfare  concerns:  the  animal  is 
exposed in a unnatural posture, generating abdominal pressure and stress due to the 
inversion especially if the animal is kept for a long time. 

On  the  other  hand  restraining  in  upright  position  for  slaughter  without  stunning 
makes the cutting more difficult for the slaughterman (from down to up) and possibly 
creates impaired working conditions.  

3.2. 

Data collected from the BoRest study 

In the BoRest study, animal welfare issues were studied on 1113 bovine animals with 
different samples of categories of animals, restraint devices or practices collected in 
18  slaughterhouses  in  six  Member  States10  from  July  to  December  2013.  Several 

10 

Belgium, France Italy, the Netherlands, Spain and the UK. These six Member States represented 97% 
of the bovine animals slaughtered without stunning at the time of study. 

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animal  welfare  parameters  were  observed  concerning  the  restraint  duration,  cutting 
and bleeding procedures as well as the loss of consciousness. 

For most of the variables, the ranges of the averages obtained in the three positions 
(inverted,  lateral,  upright)  were  similar.  The  results  showed  some  differences  but 
most  of  them  could  be  associated  with  some  particularities  of  the  design  of  the 
device, the quality of the head restraint and the skill of the operators.  

Due  to  the  large  variability  of  the  design  of  the  slaughterhouses  (layout  of  the 
corridor, layout of the restraining and bleeding area, design of the restraining device, 
etc.)  and  skills  and  capabilities  of  the  slaughter  men  observed  during  this  study,  it 
was not possible to take into account and analyse all factors. 

However,  the  study  did  not  lead  to  conclusive  findings  establishing  significant 
differences  in  terms  of  animal  welfare  outcomes  between  the  two  restraining 
systems. 

4. 

ECONOMIC, SOCIAL AND SOCIETAL ASPECTS 

According  to  the  BoRest  study,  upright  restraining  systems  are  cheaper  than  the 
rotating  ones  on  all  the  economic  aspects:  total  investment,  maintenance  and  life 
time.  

The annual costs for an upright restraining device are estimated at about EUR 4,300 
per  year  (including  the  depreciation  costs  of  an  investment  of  EUR  50,000  , 
maintance  and  interest  costs)  and  for  a  rotating  restraining  device  at  EUR  12,600 
(including  the  depreciation  costs  of  an  investment  of  EUR  100,000  ,  maintenance 
and interest costs).  

However it should be remembered that costs in the restraining area are only a small 
part (less than 10%) of the total slaughtering costs. 

The  line  speed  at  a  slaughterhouse  is  the  one  of  the  most  critical  factors  of  the 
slaughter costs. In this regard, the study concluded that the line speed does not differ 
between  the  upright  and  rotated  system.  In  both  cases,  on  average,  about  28  to  30 
adult animals are slaughtered per hour.  

Compared  to  costs,  slaughterhouses'  directors  declared  that  considerations  on 
occupational safety of the personnel, animal welfare and religious acceptability play 
an equally important role for choosing the restraining system.  

In  the  context  of  the  BoRest  study  an  effort  has  been  made  to  collect  information 
from a wide range of religious representatives11. 

11 

See in particular Table 40 page 126 and page 249 of the study. 

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For  the  representatives  of  the  Jewish  communities,  inverted  position  was  always 
preferred.  

For the representatives of the Muslim communities, the use of rotating devices was 
often preferred, but the upright position was also considered acceptable if correctly 
adapted and if the staff operating the system was experienced.  

In  the  opinion  of  both  communities,  head  restraint,  whatever  the  position  of  the 
bovine  animals,  constitutes  a  concern  in  terms  of  welfare,  bleeding  efficiency  and 
practices. 

On  working  conditions,  no  comparison  could  be  made  between  the  two  restraining 
systems  because  limited  number  of  response  from  personnel  working  with  upright 
restraning  system.  The  main  risks  in  terms  of  work  safety  are  linked  with  possible 
unexpected  movements  of  the  animals  after  releasing  from  the  restraint  device  and 
while hoisting. 

5. 

TRADE 

No official information is available on the trade in Halal or Kosher meat.  

Based  on  2009-2013  Eurostat  data,  exports  of  beef  meat  from  EU  to  Muslim 
Mediterranean  countries  and  to  Israel  are  very  low  (less  than  15,000  tonnes  of 
carcasse weight equivalent) compared to the overall export to third countries (up to 
400,000  tonnes  per  year).  Furthermore,  they  are  highly  variable  from  one  year  to 
another. EU exports to Middle East increased significantly these last years, but still at 
a low level. 

6. 

CONCLUSIONS 

The restraining system of bovine animals slaughtered without stunning is chosen by 
the slaughterhouse operators to meet the religious requirements of the communities 
concerned.  In  addition,  the  operators  want  a  system  that  allows  a  quick  loss  of 
consciousness of the animals, ensures the work safety and is economically viable. 

Two main restraining systems are used in the EU: 

a) 

b) 

the  upright  system  where  animals  are  bled  in  upright  position  (also  used  for 
stunning animals with a captive bolt); 

the rotating system where animals are bled after being rotated in an inverted or 
lateral position (only authorised for slaughter without stunning). 

Both systems have advantages and disadvantages. The upright system was in the past 
considered  more  appropriate  for  the  perspective  of  animal  welfare  because  it  does 

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not put the animal in an unatural position. Data collected on more than one thousand 
animals  in  the  EU  show  that  from  an  animal  welfare  point  of  view  there  is  no 
conclusive  findings  indicating  that  one  system  is  better  than  the  other.  Due  to  the 
variety  of  the  situations  found  in  slaughterhouses,  the  animal  welfare  outcomes 
depend more on the way devices are designed and used than on the position of the 
animals (upright or inverted). 

The  same  applies  for  the  safety  of  the  operators  or  the  throughput  of  the 
slaughterline. 

Investment  and  operating  costs  are  substantially  higher  for  rotating  restraining 
systems than or upright ones. The first ones are however widely used in the EU (80% 
of bovine animals slaughtered without stunning). 

The vast majority of rotating restraining systems used in the EU have been recently 
designed. 

Information on best practices and training for proper use of such restraining systems 
contributes  to  improved  welfare  of  animals,  independent  of  the  restraining  system 
used. The BoRest study provides an overview in this regard. 

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