REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL on the possibility of introducing certain requirements regarding the protection of fish at the time of killing (Text with EEA relevance)
Date: 2018-03-06
Institutions: Directorate-General for Health and Food Safety, European Commission
Subjects: animal welfare, fish, fish farming, protection of animals, slaughter of animals, technical standard, veterinary inspection

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 6.3.2018 COM(2018) 87 final  REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL on the possibility of introducing certain requirements regarding the protection of fish at the time of killing    (Text with EEA relevance)  
 
 
1. 

Introduction 

Farmed  fish  are  covered  by  Council  Regulation  (EC)  No  1099/2009  on  the  protection  of 
animals  at  the  time  of  killing  (‘the  Regulation”)1.  However,  only  the  general  provision  in 
Article  3(1)  is  applicable  to  farmed  fish,  i.e.  "animals  shall  be  spared  any  avoidable  pain, 
distress or suffering during their killing and related operations".  

In addition Article 27(1) of the Regulation requires that "the Commission shall submit to the 
European  Parliament  and  the  Council  a  report  on  the  possibility  of  introducing  certain 
requirements regarding the protection of fish at the time of killing taking into account animal 
welfare aspects as well as the socio-economic and environmental impacts". 

The  purpose  of  this  report  is  to  comply  with  Article  27(1)  of  the  Regulation.  The  report 
includes analysis of socio-economic impacts at the time of slaughter. However the potential 
environmental  effects  were  not  considered  in  this  report  as  their  impact  was  considered 
negligible at the time of killing2.  

The report also constitutes one of the actions listed in the EU strategy for the protection and 
welfare of animals 2012-20153. 

The World Organisation for Animal Health (OIE) has adopted guidelines concerning welfare 
aspects of stunning and killing of farmed fish for human consumption4. These guidelines are 
also relevant within the EU since all EU Member States are OIE member countries.  

For the main fish species farmed in the EU the European Food Safety Authority (EFSA) in 
2009 published several opinions on the welfare aspects of the main systems of stunning and 
killing5.  These  opinions  demonstrated  that  challenges  exist  in  the  aquaculture  industry  with 
regard to maintaining good fish welfare at the time of killing. Using a risk based approach, the 
main hazards identified were:  

1) handling or handling related procedures (e.g. crowding, pumping, time out of water) 

2) water quality in holding tank/pen  

1 
2 

3 

4 

5 

OJ L 303, 18.11.2009, p. 1. 
In more general terms, environmental impacts from aquaculture production are important and 
consequently have been identified as one of the four priority areas in the Commission strategic guidelines 
for the sustainable development of EU aquaculture:  
http://ec.europa.eu/fisheries/cfp/aquaculture/index_en.htm  
Communication  from  the  Commission  to  the  European  Parliament,  the  Council  and  the  European 
Economic  and  Social  Committee  on  the  European  Union  Strategy  for  the  Protection  and  Welfare  of 
Animals 2012-2015, COM(2012) 6 final/2.  
Aquatic  Animal  Health  Code,  Chapter  7.3  Welfare  aspects  of  stunning  and  killing  of  farmed  fish  for 
human 
consumption. 
http://www.oie.int/index.php?id=171&L=0&htmfile=chapitre_welfare_stunning_killing.htm  
Scientific  Opinions  of  the  Panel  on  Animal  Health  and  Welfare  on  a  request  from  the  European 
Commission on Species-specific welfare aspects of the main systems of stunning and killing of farmed 
fish 
Farmed Carp http://www.efsa.europa.eu/en/efsajournal/pub/1013 
Farmed Rainbow Trout http://www.efsa.europa.eu/en/efsajournal/pub/1012 
Farmed Sea Bream and Sea Bass  http://www.efsa.europa.eu/en/efsajournal/pub/1010 
Farmed Atlantic Salmon http://www.efsa.europa.eu/en/efsajournal/pub/1011 

1 

 
 
                                                            
3) stunning and killing methods.  

EFSA concluded that many of the methods and much of the equipment in use then resulted in 
poor fish welfare. For this reason EFSA proposed certain recommendations, both for the pre-
slaughter  and  the  stunning  and  killing  operations.  It  was  also  emphasised  that  opportunities 
for development of new methods for stunning or killing, for all of the fish species assessed, 
were considerable.  

To assist with the preparation of this report an independent study report by a selected external 
contractor  was  commissioned  in  20166.  The  aim  of  the  commissioned  study  was  to  gather 
information  on  current  animal  welfare  practices  in  European  aquaculture  in  particular  as 
regards the slaughter of farmed fish, and to analyse the extent that fish welfare issues remain 
unresolved. The  costs  of  adhering to  good  welfare  practices,  the  economic  situation,  effects 
on competitiveness and other factors were taken into account. The study focused on the five 
main farmed fish species in a number of selected EEA countries in order to provide a general 
presentation  of  the  current  situation  in  European  aquaculture:  Atlantic  salmon  (cold-water 
marine);  common  carp  and  rainbow  trout  (freshwater),  and  European  sea  bass  and  gilthead 
sea bream (Mediterranean marine) as outlined in Table 1 below.  

The international standards of the OIE on animal welfare during transport and stunning and 
killing  of  farmed  fish  for  human  consumption  were  used  as  a  benchmark  for  assessment  of 
welfare  practices.  EFSA  recommendations  on  slaughter  were  also  taken  into  account.  The 
study covered the period 2009 - 20137 so as to enable an assessment of any change or shift 
towards  handling,  transport  and  stunning/killing  methods  required  by  the  OIE  standards  or 
recommended  by  EFSA.  To  ensure  a  broad  and  reliable  collection  of  data  all  relevant 
stakeholders  e.g.  Member  States,  industry,  scientists,  equipment  manufacturers  and  animal 
welfare organisations were contacted and contributed via open and targeted consultations. 

This report was based on the following sources of information: 

1.  The above mentioned study report on the welfare of farmed fish, which included:  

-  Desk  research:  literature  review  and  database  searches  using  data  from  the 
Scientific,  Technical  and  Economic  Committee  for  fisheries  (STECF)8  and 
Eurostat; data originating from other sources including sector organisations at 
EU, EEA (European Economic Area) and national levels; 

-  Consultation:  data  collected  by  on-line  survey; 

targeted  stakeholders' 
interviews,  and  focus  groups,  such  as  representatives  of  aquaculture 
associations, national and regional administrations, producer groups and other 

Welfare of farmed fish: Common practices during transport and at slaughter final (2017) 
https://publications.europa.eu/en/publication-detail/-/publication/facddd32-cda6-11e7-a5d5-
01aa75ed71a1/language-en/format-PDF/source-49981830 
These  are  the  most  recent  years  for  which  Eurostat  and  STECF  (Scientific,  Technical,  Economic 
Committee for fisheries) figures on production and economic performance of the sector are available. 

6 

7 

8 

http://ec.europa.eu/fisheries/partners/stecf/index_en.htm  

2 

 
 
                                                            
  
relevant stakeholders, as appropriate in the different countries covered by the 
study;  

2.  Commission's overview report on implementation of the rules on finfish aquaculture9.  

Table 1. EEA States included in the study10  

Fish species** 

Country in study 

European 
rank by 
production 

Production 
(tonnes) in 
2014* 

Production 
type 

Atlantic salmon 

Common carp 

Norway (NO) 
United  Kingdom 
(UK) 
Ireland (IE) 

Poland (PL) 
Czech 
(CZ) 
Germany (DE) 

Republic 

1 
2 
4 

1 
2 
4 

Rainbow trout  
(Large (L) and Portion (P)) 

Denmark (DK) 
France (FR) 
Italy (IT) 
Poland 

(L4 and P3) 
(L3 and P4) 
(L9 and P2) 
(P5) 

European sea bass 

Gilthead sea bream 

Greece (GR) 
Spain (ES) 
Italy 

Greece 
Spain 
Italy 

2 
3 
4 

1 
3 
4 

1,290,000 
163,347 
10,000 

Cold-water 
marine 

18,000 
17,833 
5,285 

38,091 
34,000 
38,800 
17,500 

42,000 
17,376 
6,500 

71,000 
16,230 
8,200 

Fresh water 

Fresh water 

Mediterranean 
(warm water) 

Mediterranean 
(warm water) 

* Source FEAP 201511; ** Pictures from: https://ec.europa.eu/fisheries/marine_species_en 

9 

10 

11 

Overview report on the implementation of the rules on finfish aquaculture (2015) 
http://ec.europa.eu/food/audits-analysis/overview_reports/details.cfm?rep_id=95 
Tables  and  figures  adapted  from  published  study  report  “Welfare  of  farmed  fish:  common  practices 
https://publications.europa.eu/en/publication-detail/-
during 
/publication/facddd32-cda6-11e7-a5d5-01aa75ed71a1/language-en/format-PDF/source-49981830 
FEAP, 
www.feap.info/shortcut.asp?FILE=1402 

Aquaculture 

production 

2005-2014 

slaughter” 

European 

transport 

report 

2015, 

and 

at 

3 

 
 
 
 
 
 
 
 
 
 
 
 
 
                                                            
2.  Main findings 

2.1.  Welfare practices at slaughter 

The  slaughter  process  includes  the  following  stages;  handling,  restraining,  stunning  and  the 
final  killing  stage.  Stunning  should  cause  loss  of  consciousness  and  sensibility  without 
avoidable  stress,  discomfort  or  pain.  In  some  methods,  it  may  also  cause  death.  When  the 
stunning  method  is  reversible  or  does  not  cause  death,  it  should  be  followed  by  a  killing 
method.  Table  2  below  provides  an  overview  of  the  methods  used  for  stunning, 
stunning/killing and killing, their advantages and disadvantages. 

Table 2. Overview of methods used for stunning, stunning/killing and killing,  
their advantages and disadvantages 

Stunning or 
stunning/killing 

Electrical 
stunning 

Fish species 

Advantage 

Disadvantage 

Atlantic 
salmon 
Rainbow trout 
Common Carp 

-  An  immediate  stun  can 

be achieved;  

-  Effective 
needed; 

killing  method 

is 

-  Allows pre-rigor filleting. 

 -  Carcass damage can occur 
-  Product  quality  can  be  affected, 
mis-stuns*  may  occur  due  to 
varying resistance between fish; 

-  Very stressful 

Carbon  dioxide 
(CO2) stunning 

Rainbow trout 

Percussion 

Atlantic 
salmon 

-  An  immediate  stun  can 

-  Mis-stuns  due  to  variation  in 

be achieved; 

size; 

-  When  applied  correctly, 

 -  Damage to the head can occur. 

no recovery; 

-  Allows pre-rigor filleting. 

-  When  applied  correctly, 

-  Manual  application  can  lead  to 

Common carp 

no recovery. 

mis-stuns;  

-  Damage to the head can occur  

Rainbow trout 

-  When  applied  correctly, 

-  Manual  application  can  lead  to 

no recovery. 

mis-stuns. 

chilling 

Live 
with CO2 

Atlantic 
salmon 

-  Slow onset of rigor mortis 
allows pre-rigor filleting. 

-  Fish are not stunned.  
-  Method is stressful. 

Asphyxia  in  ice 
or ice water 

Sea bass 
Sea bream 
Rainbow trout 

-  Easy to use; 
-  Food quality and safety. 

-  Stress  in  fish  due  to  steep  drop 

in temperature. 

*  A mis-stun occurs when the application of a stunning method is not effective.  For electrical and percussive 

stunning this implies that consciousness is not lost immediately. 

The  OIE  advises  the  use  of  electrical  or  mechanical  (e.g.  percussive  stunning)  methods  for 
killing farmed fish. Other methods, including live chilling with CO2, CO2 stunning, chilling in 
ice water followed by electrical stunning, and asphyxia in ice, do not meet OIE standards. The 

4 

 
 
 
 
study  report  found  that  the  achievement  of  OIE  standards  at  slaughter  was  very  much 
dependent on the species and methods used as outlined in the following paragraphs.  

In the case of Atlantic salmon OIE standards are met when percussion is used for slaughter, 
which is the main slaughter method in Norway, the United Kingdom and Ireland. However, 
less so for electrical stunning where fish are frequently not orientated correctly, resulting in 
poor  stunning.  Live  chilling  with  CO2,  which  does  not  meet  OIE  standards,  is  still  used  in 
Norway and in Ireland though to a very limited extent and was reported that the practice will 
be phased out in 2018. 

OIE  standards  are  only  partly  achieved  for  the  slaughter  of  common  carp  in  Poland,  Czech 
Republic and Germany. The most common method is manual percussion (a blow to the head). 
However, in Poland carp species are exposed to the air for a maximum of 10 minutes, which 
causes  stress.  Electrical  stunning  is  also  used  in  Poland,  Czech  Republic  and  Germany,  but 
there is a lack of information on the effectiveness of the equipment for this method. 

For rainbow trout, OIE standards are partly achieved in Denmark, France and Italy, but they 
are not achieved in Poland. Electrical stunning is used in Denmark and Italy. However, data 
on  the  construction  of  the  equipment  is  scarce  and  therefore  it  is  not  known  whether  OIE 
standards  for  electrical  stunning  are  met.  Manual  percussion  of  rainbow  trout  meets  OIE 
standards, provided it is carried out correctly. Asphyxia in ice is used in Denmark and Poland, 
and  does  not  meet  OIE  standards.  In  France,  chilling  in  ice  water  followed  by  electrical 
stunning,  and  CO2  stunning  (to  a  limited  extent)  are  used,  neither  of  which  meet  OIE 
standards.  

Asphyxia  in  ice  of  sea bass  and  sea  bream  is  still the  main  practised  slaughter  technique  in 
Greece, Spain and Italy, though electrical stunning is being introduced in a limited number of 
farms on an experimental basis.  

Table 3: Summary of current slaughter methods indicating adherence to OIE standards 

Fish 
species 

Country 
in study 

Outcome 

Explanation 

Slaughter 

Atlantic 
salmon 

Common 
carp 

NO 

+/- 

UK 

IE 

PL 

CZ 

 

+/- 

+/- 

+/- 

Percussion (standards are met). 

Dry  electrical  stunning:  only  25-30%  oriented,  though 
increasing (standards are met for the 25-30%).  

Electrically  stunned  fish  killed  by  gill-cut  (standards  not 
met), or by percussion or decapitation (standards met).  
Live chilling with CO2 (standards not met). 

Standards are met 

Percussion. CO2 stunning for 7-8 % (standards not met). 

Manual percussion.  

Electrical stunner not from major producers 

Electrical stunner not from major producer and no killing 
method applied 

5 

 
 
 
Fish 
species 

Country 
in study 

Outcome 

Explanation 

Slaughter 

DE 

DK 

FR 

IT 

PL 

GR 

ES 

IT 

GR 

ES 

IT 

+/- 

+/- 

+/- 

+/- 

 

 

 

 

 

 

 

Manual percussion.  

Electrical stunner not from major producer 

Electrical stunner not from major producer 

Also asphyxia in ice 

Manual percussion. However, CO2 stunning and chilling in 
ice water followed by electrical stunning are also used. 

Electrical stunner not from major producer 

Asphyxia in ice slurry on a truck or at a farm or abattoir 

Asphyxia in ice or ice slurry 

Asphyxia in ice or ice slurry 

Asphyxia in ice or ice slurry 

Asphyxia in ice or ice slurry 

Asphyxia in ice or ice slurry 

Asphyxia in ice or ice slurry 

- likely that the OIE standards are achieved 

- likely that the OIE standards are not achieved 

- OIE standards may be achieved, depending on the method and the equipment used 

Rainbow 
trout  

European 
sea bass 

Gilthead 
sea bream 

 OIE  
 OIE  
+/- OIE  

With  regard  to  the  rules  concerning  slaughter  techniques  for  certified    organic  aquaculture 
production, the findings of the Commission report referred to in footnote nine confirm that the 
system  of  controls  related  to  slaughter,  as  outlined  in  Article  25(h)  5  of  Regulation  (EC) 
889/2008,  are complied with. 

2.2.  National legislation and guidelines 

Article 27(1) second paragraph of the Regulation allows Member States to maintain or adopt 
national rules regarding the protection of fish at the time of slaughter or killing in the absence 
of EU rules. The study found that while national legislation and guidelines were developed in 
the targeted Member States and EEA countries they were not as well developed as those for 
terrestrial farm animals, although the situation is improving due to growing awareness on fish 
welfare.  

For  the  five  species  covered  by  the  study,  private  standards  that  include  welfare  during 
transport and slaughter are predominately implemented in the salmon sector, to a lesser extent 
for rainbow trout, and on a limited scale for sea bass and sea bream. A very limited number of 
common  carp  farms  are  covered  by  private  welfare  standards.  Table  4  below  provides  a 
complete overview of national legislation, guidelines and private standards for the countries 
reviewed. 

6 

 
 
 
Table 4: legislation and national guidelines or codes of practices that regulate welfare aspects of 
slaughter of farmed fish 

Country 

NO 

 Legislation 

National guidelines or private 
standards 

  Regulation 

(EC)  No  1099/2009  and  Norwegian 
Regulation  No  1250/2006  sets  rules  for  general  fish 
welfare requirements 

  A 

the 

comprehensive 

industry  by 
Food 

guidance 
document  has  been  prepared 
for 
the 
Safety 
Norwegian 
regarding 
Authority 
requirements 
good 
aquaculture 
animal  welfare 
during slaughter12 

(NFSA) 

for 

UK 

  Regulation (EC) No 1099/2009  

  Animal Welfare Act 2006  

  The Welfare of Animals at the Time of Killing (Scotland) 
Regulations 2012. Statutory Instrument 2012 No. 321 
  The Welfare of Animals (Transport) (England) Order 2006 

(and equivalent legislation in Scotland and Wales) 

IE 

  Regulation 1099/2009 

   Animal Health and Welfare Bill 2012 

  Opinion  on  welfare  of  farmed 
fish;  Farm  Animal  Welfare 
Committee; 2014 

  Code of good practices13 

  A  Fish  Health  Code  of  Practice 
for  Salmonid  Aquaculture 
in 
Ireland (2014)  

  The  Farmed  Salmonid  Health 

Handbook (2011)14   

PL 

CZ 

  Regulation (EC) No 1099/2009 Animal Protection Act, ( No 

  CODE  of  Good  Practice  (Kodeks 

111, Item 724; of 1998 No 106, Item 668) 

Dobrej Praktyki); 2014 

  Regulation (EC) No 1099/2009  

  Act No 246/1992 Coll. and following amendments on the 

protection of animals against cruelty  

  Decree No 245/1996 Coll. on stunning/killing methods 

  Decree No 382/2004 Coll. on stunning/killing methods 

  Act  No  99/2004  on  fish  pond  management,  incl  for  fish 

farming 

  Guideline  No.  5/2015  on  stall 

selling fish / sales places 

  DE 

  Regulation (EC) No 1099/2009  

(Verordnung  zum  Schutz  von  Tieren 

  Law  for  protection  of  animals  related  to  killing  and 
im 
slaughter 
Zusammenhang mit der Schlachtung oder Tötung und zur 
Durchführung  der  Verordnung  (EG)  Nr.  1099/2009  des 
Rates (Tierschutz-Schlachtverordnung -TierSchlV) 

  Good  Hygienic  practice  (1994) 
(Verordnung 
die 
hygienischen  Anforderungen  an 
Fischereierzeugnisse) 

über 

  Good  Practice  in  pond  farming 
(carp)  (gute fachliche Praxis der 
Teichwirtschaft in Brandenburg) 

   

12https://www.mattilsynet.no/om_mattilsynet/gjeldende_regelverk/veiledere/veileder_fiskevelferd_ved_slakteri_
for_akvakulturdyr_2014.9471/binary/Veileder%20fiskevelferd%20ved%20slakteri%20for%20akvakulturdyr%2
02014 

13http://thecodeofgoodpractice.co.uk/chapters/  
14http://www.fishhealth.ie/FHU/sites/default/files/FHU_Files/Documents/FarmedSalmonidHealthHandbookOcto

ber2011.pdf  

7 

 
 
                                                            
Country 

 Legislation 

National guidelines or private 
standards 

DK 

  Regulation (EC) No 1099/2009  

  None 

(Competent  Authority 

   

FR 

  Regulation (EC) No 1099/2009 

   Note de service 2007-8016 de la DGAL du 16 janvier 2007 

(DGAL/SDSPA/N2007-8192) 

survey) 

  (no 

Competent 
response received) 

Authority 

IT 

  Regulation (EC) No 1099/2009  

  None 

(Competent  Authority 

GR 

  Regulation (EC) No 1099/2009  

ES 

  Regulation (EC) No 1099/2009  

  ) 

3. 

 Socio-economic findings 

survey) 

  2 Circulars on welfare of farmed 

fish (23/3/2015; 9/6/2015) 

  Code of practice for killing of 
fish (Piscicultura; Guia de 
practica correctas para el 
sacrificio; 2016; AEONOR) 

Table 5 below shows the national production from aquaculture of fish, crustaceans, molluscs 
and other aquatic organisms in the 19 main aquaculture producing EEA States for the years 
2009 – 2013, which accounts for 99 % of EEA aquaculture production. Table 6 provides an 
overview of the average output of total farmed fish for the study target countries.  

8 

 
 
 
 
Table 5. Aquaculture production in 19 EEA States, 2009-2013 (1 000 tonnes live weight) 

EEA State 

2009 

2010 

2011 

2012 

2013 

Change 
2009-2013 

Share of EEA 
total, 2013 

Norway 
Spain 
United Kingdom 
France 
Italy 
Greece 
Netherlands 
Denmark 
Poland 
Ireland 
Germany 
Czech Republic 
Hungary 
Finland 
Sweden 
Bulgaria 
Croatia 
Romania 
Portugal 
Total 19 States 
Total EEA 
Source: FAO Global Fishery and Aquaculture Statistics, Version 2016.1.2. Figures in italics are forecasts 

29.7% 
-16.1% 
3.4% 
-14.2% 
0.1% 
-6.6% 
8.5% 
7.3% 
-3.6% 
-28.0% 
-35.0% 
-3.6% 
0.6% 
-0.1% 
56.5% 
80.8% 
-15.5% 
-16.2% 
49.6% 
8.7% 
8.9% 

50.5% 
9.0% 
8.2% 
8.1% 
6.6% 
4.6% 
2.4% 
1.5% 
1.4% 
1.4% 
1.0% 
0.8% 
0.6% 
0.6% 
0.5% 
0.5% 
0.5% 
0.4% 
0.4% 
99.1% 
100.0% 

1 020 
252 
201 
225 
153 
121 
67 
36 
31 
46 
41 
20 
14 
12 
11 
8 
14 
9 
8 
2 290 
2 306 

962 
267 
197 
234 
162 
122 
56 
35 
37 
48 
39 
20 
15 
14 
9 
7 
14 
13 
7 
2 255 
2 271 

1 144 
272 
199 
207 
164 
111 
44 
36 
29 
44 
39 
21 
16 
11 
13 
6 
13 
8 
9 
2 386 
2 403 

1 321 
264 
206 
205 
163 
111 
46 
35 
32 
36 
26 
21 
15 
13 
14 
6 
10 
10 
10 
2 544 
2 563 

1 248 
224 
203 
201 
163 
114 
60 
38 
35 
34 
25 
19 
15 
14 
13 
12 
12 
11 
10 
2 451 
2 473 

Table 6: Average output of fish per enterprise in the selected EU Member States  

National sales 
volume (tonnes) 

Number of 
enterprises 

Average output per 
enterprise (tonnes) 

GR (2014) 

UK (2013) 

DK (2013) 

IT (2013) 

IE (2013) 

ES (2013) 

FR (2013) 

PL (2013) 

DE (2016) 

118,080 

203,263 

46,297 

153,944 

34,667 

231,738 

227,601 

31,267 

20,936 

248 

548 

130 

587 

283 

3,023 

2,988 

846 

5,952 

476.1 

370.9 

356.1 

262.3 

122.5 

76.7 

76.2 

37.0 

3.5 

Source: STECF database, except for Germany (German Federal Statistical Office) 

9 

 
 
 
 
3.1.  Economic analysis of slaughter practice 

The socio-economic analysis of the study report considered the differences between the five 
species  studied  and  between  environments  (cold-water  marine,  Mediterranean  marine, 
freshwater).  The  variation  in  the  scale  of  enterprises  and  the  production  methods  were  also 
considered  in  this  analysis  as  they  are  relevant  factors  for  assessing  welfare.  Other  cost 
factors,  which  were  not  considered  in  the  study  report,  such  as  feed,  labour  and  operating 
costs, are responsible for most of the larger variations between enterprises and countries15. 

For  each  of  the  investigated  species  in  the  case  countries,  the  additional  investments  and 
annual costs of adhering to improved animal welfare practices since 2009 are calculated for 
the average aquaculture farm for the species under study. These included the additional cost 
related  to  improved  welfare  during  stunning,  killing  and  slaughter.  In  the  calculations  on 
additional  related  costs  it  is  assumed  that  every  aquaculture  farm  needs  to  possess  its  own 
primary processing and that the average enterprise has not implemented welfare practices.  

Atlantic salmon 

To meet the OIE standards (see section 2.1 of this report) the study assumed that every fish 
farm  requires  investment  costs  of  either  an  electric  stunner  or  a  mechanical  stunner,  plus  a 
decapitation robot and found that the additional costs for adopting improved welfare practices 
are  relatively  small  based  on  the  average  farm  size.  According  to  the  study,  the  cheapest 
additional cost would amount to 2 € cents/kg or 0.5 % of the sales price in UK, and the most 
expensive at 9 € cents/kg or less than 1.5 % of the sales price in Ireland. In slaughterhouses 
with high throughput and high labour costs the investment might even result in cost savings. 
However,  as  there  is  already  a  high  level  of implementation  of  fish  welfare  practices  in  the 
salmon  industry  in  Member  States  and    EEA  states,  relatively  few  enterprises  will  need  to 
invest to meet OIE standards, therefore the impact on competitiveness is likely to be small. 

Common carp 

Economies  of  scale  in  slaughter  volume  have  a  substantial  effect  on  the  cost  of  welfare 
measures.  This  fact  was  evident  when  electrical  stunning  followed  by  decapitation  were 
evaluated  for  improved  welfare  at  slaughter  for  carp,  which  has  a  much  lower  slaughter 
volume  than  typical  salmonid  enterprises.  The  extra  costs  varied  considerably  between  the 
case-study  countries  with  the  lowest  being  6 €  cents/kg  in  Poland,  and  as  much  as  41  € 
cents/kg in Romania, and 58 € cents/kg in Germany. 

Common  carp  is  mainly  consumed  in  the  country  of  production  and  was  generally  not 
profitable  without  subsidies  between  2009  and  2013  in  typical  production  systems.  Small 
farms  are  likely  to  have  most  difficulty  in  investing  to  improve  animal  welfare  and  may 
experience  a  competitive  disadvantage.  As  export  (including  re-export)  accounts  for  only  a 
very  small  proportion  of  world  carp  production,  the  effects  of  welfare  measures  on 
international competitiveness are expected to  be limited (although the impacts on cost price 
can as shown in figure 1 be considerable). 

15  

These  cost  factors  were  dealt  with  more  extensively  and  comprehensively  in  the  STECF  reports  on 
production and economic performance of the sector. 

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Rainbow trout 

Regarding  the  investment  requirements  to  meet  OIE  standards  for  the  slaughter  of  rainbow 
trout  the  study  report  assumed:  1) electrical  stunning  before  dewatering,  and;  2)  percussive 
stunning after dewatering, both followed by manual gill cutting. As with carp the additional 
costs  impact  varied  significantly  depending  on  the  economies  of  scale  with  estimated 
additional costs ranging from just 4 € cents/kg in Denmark up to 24 € cents/kg in France. In 
Italy,  where  slaughterhouses  have  high  throughput  and  high  labour  cost,  savings  of  6  € 
cents/kg were reported. Percussive stunning is a more expensive option and the cost impact 
will be greater especially for small scale farms, such as in France. 

European sea bass and gilthead sea bream 

For both sea bass and sea bream the investments considered to improve welfare at slaughter 
are: 1) electrical stunning before dewatering, and; 2) electrical stunning after dewatering, both 
followed by chilling in a slurry of ice and sea water.  

The additional unit cost varies slightly between the methods, but it varies to a greater extent 
between countries according to the size of enterprises. In Spain – with the largest enterprises – 
the additional unit cost was 4 € cents/kg for both methods. In Greece, it was 5-6 € cents/kg 
depending  on  the  method,  and  in  Italy  –  with  the  smallest  enterprises  –  it  was  11-13  € 
cents/kg.  Although  the  cost  increase  is  quite  modest,  even  for  relatively  small  volume 
producers as in Italy, the profit margins on most of these farms might prevent producers from 
investing.  

Overall  the  study  report  found  that  the  production  of  sea  bass  and  sea  bream  was  also 
generally  not  profitable  without  subsidies  during  the  period  2009  and  2013  in  the  major 
producing Member States. It may therefore be difficult for producers to make the necessary 
investment to improve welfare standards.  

Figure 1 provides a summary overview on the impact of achieving improved animal welfare 
practices on the cost price of farmed fish in the case-study countries (€s/kg). 

11 

 
 
Figure 1: Impact of achieving improved animal welfare practices 
on the cost price of farmed fish in the case-study countries (€s/kg) 

4.  Limitations of the findings 

The economic analysis performed in the commissioned study report used the limited available 
information  for  the  cost  of  equipment  required  for  improving  welfare  at  slaughter.  The 
analysis  is  based  on  the  average  enterprise  for  each  species  in  each  of  the  case-study 
countries. However, it is assumed that enterprises with high throughput achieve economies of 
scale.  The  financial  return  on  the  investments  will  also  differ  substantially  between  fish 
species.  

For enterprises with lower annual production volumes, the investment costs are substantially 
higher than for larger scale operations. The capacity of the identified equipment is such that it 
might  be  idle  for  significant  periods  of  time.  It  may  be  that  alternative  –  lower  cost  – 
equipment  will  become  available  for  smaller-scale  facilities.  However,  no  information  on 
such alternatives was available at the time of the study.  

A further limitation of the findings concerns the quality of data that was obtained during the 
study  for  the  actual  costs  for  stunning  and  killing,  particularly  financial  and  commercially 
sensitive  information.  This  was  mainly  due to  a low response rate from industry or the fact 
that their accounting practices did not break down these costs. Where costs were insufficiently 
obtained  from  industry  estimates  were  obtained  from  equipment  manufacturers,  which  may 
not  reflect  true  operating  costs.  It  should  also  be  noted  that  the  study  focused  on  a  specific 
reference period, 2009-2013, which may not reflect trends over a longer period, or over the 
period since. 

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5. 

Conclusions 

Overall  the  general  requirements  contained  in  Regulation  (EC)  No  1099/2009  applicable  to 
the welfare of fish at slaughter have contributed to the development of a framework in terms 
of national legislation and guidance for the welfare of farmed fish in the EU particularly for 
Atlantic salmon. 

The level of achievement of OIE standards at slaughter varies with the species considered. For 
Atlantic salmon, best practices are mostly achieved, with a few exceptions, in the case-study 
countries.  For  common  carp  and  rainbow  trout,  the  level  of  achievement  varies  between 
methods used. For European sea bass and gilthead sea bream, OIE standards are not achieved 
in the case-study countries. 

The  economic  analysis  shows  that  differences  in  production  cost  are  mainly  caused  by  the 
structure of the industry, with particular benefits from economies of scale. Where such scale 
economies exist, improving welfare practices is likely to have only a small impact on the cost 
price, whereas for smaller farms the impact is likely to be much greater. Other factors, such as 
feed,  labour  and  operating  costs  are  responsible  for  most  of  the  larger  variations  between 
enterprises and countries. 

In  the  specific  case  of  larger  Atlantic  salmon  and  rainbow  trout  farms  it  was  found  that 
investment  in  improving  welfare  could  lead  to  labour  savings,  and  may  outweigh  the 
investment cost. 

The  commissioned  study  report  findings  have  also  shown  that  the  industry  as  a  whole  is 
gradually but continuously improving fish welfare as evidenced by the increasing use of more 
humane methods such as electrical stunning, the phasing out of others such as CO2 stunning16, 
and  the  adoption  of  private  standards.  However,  improvements  are  still  needed  in  order  to 
increase welfare of some fish species, such as the European sea bass and Gilthead sea bream. 
The findings of this study are also supported by the Commission's overview report which was 
undertaken during 2014-201517. 

At this stage, the Commission considers that the evidence suggests that it is not appropriate to 
propose  specific  requirements  on  the  protection  of  fish  at  the  time  of  killing,  taking  into 
account that the objectives of the Regulation may equally be achieved by voluntary measures, 
as evidenced by the improvements introduced by industry in recent years. It is also important 
to note that this is a comparatively new and very diverse sector compared to other traditional 
farmed  animal  production  systems,  and  technology  for  improved  welfare  is  currently 
progressing. In view of these ongoing developments the Commission concludes that if further 

16  

17 

the Dutch authorities notified the Commission on the 17-10-2017 concerning a new draft national 
regulation which will ban current traditional slaughter methods for European eels in favour of humane 
electrical stunning methods (notification 2017/0406/NL 

Overview report on the implementation of the rules on finfish aquaculture http://ec.europa.eu/food/audits-
analysis/overview_reports/details.cfm?rep_id=95 

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guidance  is  required  this  would  be  best  achieved  at  Member  State  level.  In  any  event  the 
Commission will continue to monitor progress in this area. 

However, it has also to be recognized that there is a need for further research aimed to tailor 
dedicated systems for those fish species where the development of more effective techniques 
is necessary. 

The  Commission  therefore  considers  it  essential  to  develop  further  stakeholder  dialogues  in 
order to favour specific initiatives and projects in this field that could be mutually beneficial 
both  from  an  economic  and  animal  welfare  point  of  view.  Against  this  background  the 
Commission has formulated a more systematic and visible format for this dialogue, through 
the  EU  Platform  on  Animal  Welfare18.  The  primary  objective  of  this  platform  is  to  allow 
interested  parties  (animal  welfare  organisations,  scientists,  veterinarians,  farmers,  food 
processors, food retailers, etc.) an opportunity to express their concerns, share knowledge and 
resources to build common activities. 

18 

Commission  Decision  of  24  January  2017  establishing  the  Commission  Expert  Group  ‘Platform  on 
Animal Welfare’ C/2017/0280, OJ C 31, 31.1.2017, p. 61. 

14