COMMISSION STAFF WORKING DOCUMENT EVALUATION of the European Union Strategy for the Protection and Welfare of Animals 2012-2015
Date: 2021-03-31
Institutions: Directorate-General for Health and Food Safety, European Commission
Subjects: EU Member State, EU strategy, animal welfare, application of EU law, international cooperation, live animal, protection of animals, slaughter of animals, transport of animals, veterinary legislation

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 31.3.2021  SWD(2021) 76 final  COMMISSION STAFF WORKING DOCUMENT  EVALUATION  of the European Union Strategy for the Protection and Welfare of Animals 2012-2015 {SWD(2021) 77 final}  
 
 
Table of contents 

1. 

INTRODUCTION ....................................................................................................... 4 

1.1 

Purpose and scope ................................................................................................ 4 

2.  BACKGROUND TO THE INTERVENTION ........................................................... 6 

3. 

IMPLEMENTATION / STATE OF PLAY .............................................................. 11 

3.1 Description of the current situation ........................................................................ 11 

3.2 Ongoing Commission activities on animal welfare ................................................ 14 

4.  METHOD .................................................................................................................. 17 

4.1 Short description of methodology........................................................................... 17 

4.2 Limitations and robustness of findings ................................................................... 20 

5.  ANALYSIS AND ANSWERS TO THE EVALUATION QUESTIONS ................ 21 

5.1 RELEVANCE ............................................................................................................. 21 

5.2 COHERENCE ............................................................................................................. 30 

5.3 EFFECTIVENESS ...................................................................................................... 36 

5.4. EFFICIENCY ............................................................................................................. 57 

5.5. EU ADDED VALUE ................................................................................................. 68 

6.  CONCLUSIONS ....................................................................................................... 70 

ANNEX 1: PROCEDURAL INFORMATION ................................................................ 77 

ANNEX 2: STAKEHOLDER CONSULTATIONS ......................................................... 79 

ANNEX 3: METHODS AND ANALYTICAL MODELS ............................................... 90 

ANNEX 4: LIST OF ACTIONS UNDER THE STRATEGY AND OVERVIEW 

TABLE ...................................................................................................................... 92 

ANNEX  5:  OVERVIEW  OF  COSTS  –  BENEFITS  IDENTIFIED  IN  THE 

EVALUATION ......................................................................................................... 95 

ANNEX 6:  SUMMARY OF COSTS ............................................................................. 100 

1 

 
 
 
Term or acronym 

Meaning or definition 

Glossary 

ABM 

AAC 

AHL 

AW 

Animal-Based Measure 

Aquaculture Advisory Council 

Animal Health Law 

Animal Welfare 

BBFAW 

Business Benchmark on Farm Animal Welfare 

BTSF 

CAP 

CETA 

CIWF 

CS 

CVO 

Better Training for Safer Food 

Common Agricultural Policy 

Comprehensive Economic and Trade Agreement 

Compassion in World Farming 

Case study 

Chief Veterinary Officer 

DG AGRI 

Directorate-General for Agriculture and Rural Development 

DG DEVCO 

Directorate-General for International Cooperation and 
Development 

DG MARE 

Directorate-General for Maritime Affairs and Fisheries 

DG NEAR 

Directorate-General for Neighbourhood and Enlargement 
Negotiations 

DGs 

EAFRD 

EAGF 

EARDF 

EC 

ECA 

EEA 

Directorates-General 

European Agricultural Fund for Rural Development 

European Agricultural Guarantee Fund 

European Agricultural Fund for Rural Development 

European Commission 

European Court of Auditors 

European Economic Area 

2 

 
 
EFSA 

EU 

European Food Safety Authority 

European Union 

EURCAW 

EU reference centres for Animal Welfare 

FAO 

FAS 

FAWC 

FVO 

GAEC 

GATT 

HAPO 

Food and Agricultural Organization 

Farm Advisory System 

Farm Animal Welfare Committee 

Food and Veterinary Office 

Good Agricultural and Environmental Conditions  

General Agreement on Tariffs and Trade 

Hellenic Aquaculture Producers Organisation 

JACUMAR 

National Advisory Board for Marine Aquaculture 

JEEPA 

Japan EU Economic Partnership Agreement 

Kg 

NGO 

OCR 

Kilogram 

Non-Governmental Organisation 

Official Controls Regulation 

OECD 

Organisation for Economic Co-operation and Development 

OIE 

RDP 

SMR 

SOPs 

World Organization for Animal Health 

Rural Development Plan 

Statutory Management Requirement 

Standard operating procedures 

TAIEX 

Technical Assistance and Information Exchange 

ToR 

WTO 

Terms of Reference 

World Trade Organization 

3 

 
1. 

INTRODUCTION 

1.1 Purpose and scope 

Animal welfare is an issue of growing importance with a potential  to attract the public1 
and  media  interest.  The  European  Parliament  is  very  active  in  engaging  with  different 
animal  welfare  dossiers2.  It  has  adopted  several  resolutions  and  closely  monitors 
Commission’s activities in this policy area by sending regularly questions and petitions, 
also  from  the  civil  society.  Similarly,  the  Council  of  the  EU  adopted  conclusions  on 
animal  welfare3  and  followed  up  on  specific  subjects4  (e.g.  animal  transport,  animal 
welfare labelling etc.).  

The first EU legislation on the welfare of animals was adopted in 1974. It dealt with the 
protection of animals at slaughter5. Since then, animal welfare legislation has developed 
and expanded its coverage in response to political, market and citizens’ demand as well 
as scientific developments.  

Article  13  of  the  Treaty  on  the  Functioning  of  the  European  Union  (TFEU)  recognises 
animals  as  sentient  beings  and  requires  that  full  regard  be  given  to  the  welfare 
requirements of animals while formulating and enforcing some EU policies. This article 
does not provide a legal basis for protecting animals. However, it creates the obligation 
of the Member States and of the Union to ensure that the welfare requirements of animals 
are  considered  within  the  framework  of  certain  EU  policies,  such  as  agriculture,  the 
internal market and research6. Responsibility for enforcing animal welfare legislation is 
shared between the European Commission and the Member States.  

1   Special  Eurobarometer  442,  Attitudes  of  Europeans  towards  Animal  Welfare  of  March  2016: 
https://ec.europa.eu/commfrontoffice/publicopinion/index.cfm/ResultDoc/download/DocumentKy/713
48  

2   https://www.europarl.europa.eu/news/en/headlines/priorities/animal-welfare-and-protection 

3   Council conclusions on animal welfare, 16 December 2019  

4   https://www.consilium.europa.eu/en/council-eu/configurations/agrifish/# 

5   Council Directive 74/577/EEC of 18 November 1974 on stunning of animals before slaughter 

6   Article 13 of the Treaty on the Functioning of the EU states that “In formulating and implementing the 
Union's agriculture, fisheries, transport, internal market, research and technological development and 
space  policies,  the  Union  and  the  Member  States  shall,  since  animals  are  sentient  beings,  pay  full 
regard  to  the  welfare  requirements  of  animals,  while  respecting  the  legislative  or  administrative 
provisions  and  customs  of  the  Member  States  relating  in  particular  to  religious  rites,  cultural 
traditions and regional heritage.” 

4 

 
 
                                                           
The  EU  policy  on  animal  welfare  builds  on  legislative  and  non-legislative  tools.  The 
main body of EU legislation on animal welfare applies to food producing animals7 and to 
animals used for scientific purposes8.   

The Commission adopted a Communication with an EU strategy for protection and welfare 
of animals (2012-2015), in February 2012 (“the strategy”). It presented key strategic lines 
and a list of 20 specific actions.  

In November 2018, the European Court of Auditors (ECA) made a detailed assessment of 
the strategy for the first time and published a Special report No 31/2018: Animal welfare in 
the  EU:  closing  the  gap  between  ambitious  goals  and  practical  implementation.  In 
particular,  ECA’s  recommendations  aimed  at  improving  the  management  of  the  animal 
welfare policy, calling upon the development of a strategic framework for animal welfare, 
more effective enforcement and guidance to achieve compliance, actions to strengthen the 
links between the cross-compliance system and animal welfare and action to better address 
animal welfare objectives through the rural development policy. 

The ECA recommended9 the Commission to carry out an evaluation of the strategy by the 
end of 2020 in order to identify to what extent its objectives have been achieved and if the 
guidance it has issued is being applied.  

Following  the  ECA’s  recommendations,  DG  SANTE  launched  an  evaluation  of  the 
strategy in early 2019. 

In line with the principles of Better Regulation, the evaluation’s scope covers all stages of 
the  strategy  i.e.  its  design  (e.g.  choice  of  strategic  objectives,  priorities  and  actions),  its 
implementation (e.g. mode of implementation, division of tasks between stakeholders), its 
monitoring arrangements and its  follow-up. While the strategy  relates to the  years  2012-
2015,  the  evaluation  covers  the  period  2012-2018  in  consideration  of  the  fact  that  the 

7   Council  Directive  98/58/EC  of  20  July  1998  concerning  the  protection  of  animals  kept  for  farming 

purposes; 
Council Directive 1999/74/EC of 19 July 1999 laying down minimum standards for the protection of 
laying hens; 
Council  Directive  2007/43/EC  of  28  June  2007  laying  down  minimum  rules  for  the  protection  of 
chickens kept for meat production; 
Council  Directive  2008/120/EC  of  18  December  2008  laying  down  minimum  standards  for  the 
protection of pigs; 
Council  Directive  2008/119/EC  of  18  December  2008  laying  down  minimum  standards  for  the 
protection of calves; 
Council  Regulation  (EC)  No  1/2005  of  22  December  2004  on  the  protection  of  animals  during 
transport; 
Council Regulation (EC) No 1099/2009 of 24 September 2009 on the protection of animals at the time 
of killing. 

8   Directive  2010/63/EU  of  the  European  Parliament  and  of  the  Council  of  22 September  2010  on  the 

protection of animals used for scientific purposes; 

9   Recommendation 1(a) from ECA  Special report No 31/2018: Animal  welfare  in  the EU: closing the 

gap between ambitious goals and practical implementation 

5 

 
                                                           
 
implementation  of  some  of  the  actions  of  the  strategy  has  been  delayed.  It  also  analyses 
whether the strategy remained relevant and coherent up until today (2019), considering the 
most  recent  economic,  scientific,  social  and  environmental  developments  in  the  area  of 
animal  welfare.  The  geographical  scope  encompasses  the  27  EU  Member  States  and  the 
UK, as well as international organisations and third countries concerned by the strategy.   

The  evaluation  consists  of  an  evidence-based  assessment  of  the  strategy’s  overall 
relevance, coherence, effectiveness, efficiency and EU added value. More specifically, the 
evaluation  assesses  whether  the  strategy  achieved  its  objectives  and  delivered  the 
(expected) results. In addition, it has also focused on identifying remaining animal welfare 
risk  areas,  notably  according  to  Member  States’  degree  of  compliance  (ECA’s 
recommendation10), and areas of improvement.  

In May 2020, animal welfare has been included in the Farm to Fork strategy and adopted in 
the context of the European Green Deal. Hereby, as better animal welfare improves animal 
health  and  food  safety  and  quality,  reducing  the  need  for  medication  and  supporting  to 
preserve biodiversity. The Covid-19 pandemic has reminded us of the strong links between 
animal  health  and  human  health,  and  of  the  need  to  consider  animal  health  and  welfare 
under  a  One-Health  approach.  Animal  welfare  measures  can  also  have  considerable  co-
benefits and synergies with climate and environmental objectives, notably for reducing air 
and water pollution  (e.g. dry, clean animal housing  and  good manure management). The 
Farm  to  Fork  strategy  proposed  an  ambitious  agenda  in  the  area  of  animal  welfare, 
including an evaluation (“fitness check”) of the EU animal welfare acquis11 with a view to 
revise  the  legislation,  including  the  slaughter  and  transport  regulations,  in  order  to  align 
them with the latest scientific evidence, broaden their scopes, make them easier to enforce 
and ultimately ensure a higher level of animal welfare. This evaluation does not cover the 
EU animal welfare legislation. However, its findings will feed into the fitness check, and 
be considered for possible future actions in the animal welfare area to be taken in line with 
the “One Health” approach. 

2.  BACKGROUND TO THE INTERVENTION 

Description of the intervention and its objectives 

The strategy was a continuation of the Community action plan 2006-2010 which grouped 
defined areas where actions on animal welfare were mainly needed, while also announcing 
the  upcoming  development  of  the  European  Union  strategy  on  animal  welfare  and  other 
planned initiatives in this field12.  

10   Recommendation 1(b) from  ECA Special report No 31/2018: Animal  welfare in  the EU: closing the 

gap between ambitious goals and practical implementation 

11   https://ec.europa.eu/food/sites/food/files/animals/docs/aw_fitness-check_roadmap.pdf  

12   In  particular,  the  Communication  mentioned  that  “a  European  strategy  to  communicate  on  animal 
welfare  in  Europe  and  abroad  will  be  developed  to  explain  to  citizens  the  variations  in  animal 
production systems and the costs and benefits of  higher animal  welfare  standards. This strategy  will 
also include analysis of  the potential impact on trade (positive or negative) in Developing  Countries 

6 

 
                                                           
 
The design of the strategy was based on an Impact Assessment conducted in 2012, which 
identified key problems at EU level, their drivers, objectives to be met, and several policy 
options to reach such objectives13.  

The  impact  assessment  drew  on  an  external  Evaluation  of  the  EU  Policy  on  Animal 
Welfare and Possible Policy Options for the Future, published in 2010.   

The Impact assessment study identified a number of common drivers like: 

     Lack of enforcement by the Member States of the EU legislation on animal welfare 

in a number of areas (e.g. laying hens, the grouping of sows and other); 

     Business operators’ lack of knowledge in respect to animals’ welfare requirements 

and about possible alternative solutions;  

     Consumers' lack of appropriate information on animal welfare;  
     Lack of specific EU legislation and guidance for some categories of animals such 

as dairy cows, beef cattle, rabbits and other.  

In  addition,  the  evaluation  conducted  in  2010  also  highlighted  the  following  issues  and 
trends at EU level, which were considered in the Impact assessment: 

 

  A distortion of competition for EU business operators within the EU in the light of 
the different level of compliance with animal welfare legislation in the different MS 
accompanied  by  a  lack  of  enforcement  (battery  cages/grouping  of  sows)  and  on 
global  markets  (lack  of  equivalent  animal  welfare  standards  for  slaughterhouses 
exporting from third countries to the EU);  
Insufficient  uptake of opportunities by Member  States  and farmers in exploiting 
the  potential  of  the  Common  Agricultural  Policy  (CAP)  in  terms  of  support  to 
animal welfare measures. The European Agricultural Fund for Rural Development 
(EAFRD)  offers  to  Member  States  possibilities  to  co-finance  animal  welfare 
measures  within  their  rural  development  programmes  (RDPs).  This  mechanism 
constitutes  the  most  important  source  of  financial  funding  for  animal  welfare 
activities in the EU;  

  Growing  societal  concerns  over  animal  welfare  across  the  EU  (as  shown  e.g.  in 

Eurobarometer surveys in 2006);  

intending  to  export  to  the  EU.  Specific  tools  will  be  elaborated  to  better  inform  consumers  and  the 
general public of modern animal husbandry techniques and animal welfare considerations. There will 
be  a  continued  use  of  stakeholder  consultation  and  public  internet  surveys  to  receive  input  from  the 
public at an early stage of the policy formulation process. This activity for animal welfare will also be 
integrated with other forms of communication already developed by the Community in the agri-food 
sector.” 

13   In  the  IA  it  was  highlighted  that  the  preferred  option  was  a  policy  mix,  including  some  of  the 
components  of  several  options  considered.    Such  a  policy  mix  consisted  of  the  following  specific 
measures: 1. To explore the possibility of a simplified EU legislative framework 2. Develop tools for 
strengthening  Member  States'  compliance  with  EU  rules;  3.  Support  international  cooperation;  4. 
Provide  consumers  and  the  public  with  appropriate  information;  5.  Investigate  on  the  welfare  of 
animals not covered by specific EU rules. 

7 

 
 
                                                                                                                                                                            
 

Interest from EU consumers in receiving information on the handling of animals in 
order to make informed purchase choices; 

  Uneven yet progressive integration of animal welfare issues in research, education 

and training across the EU.   

The  impact  assessment  highlighted  that  animal  welfare  was  still  at  risk  across  EU 
Member States  back in  2012. This  conclusion was based on Commission  audit reports, 
EFSA scientific opinions and Member States reports. 

Broadly,  the  strategy  aimed  to  ensure  that  existing  animal  welfare  legislation  is 
consistently  applied  and  enforced  across  the  EU  and  that  animal  welfare  policy  is 
properly integrated with the CAP. The guiding principle behind the development of the 
strategy was that “Everyone is responsible”, meaning that in the area of animal welfare 
there are many stakeholders involved at different levels of the chain and each of them has 
an  important  role  to  play.  More  specifically,  the  strategy  set  up  the  following  six 
(specific) objectives, accompanied by a set of actions to achieve these objectives: 

  Consider the feasibility of introducing a simplified EU legislative framework 
(objective 1). The idea behind this objective was to ensure the respect of animal 
welfare  principles  for  all  animals  kept  in  the  context  of  an  economic  activity 
including, where appropriate, pet animals.  

  Support  Member  States  to  improve  compliance  (objective  2)  by  educating, 
training,  advising  and  auditing  the  competent  authorities  to  strengthen  the 
compliance  with  the  EU  animal  welfare  legislation,  sharing  of  best  practices, 
guidance and raising awareness amongst business operators;  

  Develop EU level knowledge of certain issues, e.g. the welfare of farmed fish 
(objective  3),  by  producing  new  EU-level  knowledge  and  evidence  and  taking 
decisions on that basis; 

  Promote  EU  animal  welfare  standards  globally  (objective  4),  notably  via 
bilateral  &  multilateral  international  cooperation  activities,  including  within  the 
European Neighbourhood Policy and the World Organization for Animal Health 
(OIE) and FAO; 

i.e.  funding  under 

  Optimise  synergies  with  the  Common  Agricultural  Policy  (CAP)  and 
components  of  relevance  (objective  5); 
the  Rural 
Development  Programme  for  animal  welfare  payments  which  compensate 
farmers  for  costs  or  income  losses  associated  with  commitments  going  beyond 
mandatory  requirements,  to  support  farmers  investing  in  animal  welfare,  cross 
compliance  linking  some  CAP  support  to  the  respect  of  animal  welfare  rules, 
organic  farming  which  requires  a  higher  level  of  animal  welfare,  marketing 
standards for eggs and production standards for broilers fattened for poultry meat 
requiring  compliance  with  animal  welfare  legislation,  promotional  measures, 
quality policy (requiring compliance with higher animal welfare standards); 

  Provide  consumers  and  the  public  with  appropriate  information  on  animal 
welfare  (objective  6),  e.g.  via  EU  communication  and  education  activities  (e.g. 

8 

 
 
 
   
Farmland designed for children and teachers in primary schools). 

To  achieve  its  objectives,  the  strategy  included  20  actions.  (see  a  detailed  overview  in 
Annex 4) which can be grouped as follows: 

  Studies,  research  projects,  and  scientific  advice  were  envisaged  as  means  to 
explore the various components of a potential animal welfare law (objective 1 - 
action 20). 

  Member  State  support  activities  envisaged  included  training  activities  targeting 
competent  authorities  (e.g.  via  the  Better  Training  for  Safer  Food  programme), 
implementing  plans,  as  well  as  guidelines  (e.g.  slaughter,  transport,  etc.) 
developed  for  competent  authorities  (objective  2  -  actions  1,  2,  3,  6,  9,  14), 
business operators and stakeholders (actions 4, 13, 16). The strategy also included 
enforcement actions, audits, and infringement proceedings at EU level to enhance 
further  progress  on  compliance  with  animal  welfare  legislation  (e.g.  welfare  of 
laying hens, pigs, slaughter etc.). 

  Scientific  advice  and  studies  on  fish  welfare  and  other  issues  (e.g.  welfare  of 
broilers,  stunning  of  poultry  etc.)  were  expected  to  address  knowledge  gaps  in 
specific areas (objective 3 - actions 5, 7, 8, 10, 11, 12, 17, 18, 19). 

  Bilateral and multilateral international cooperation activities aimed to enhance the 
competitiveness of European livestock producers in a globalised world (objective 
4 - action 15). 

  A  dedicated  cooperation  structure  was  to  be  set  up  to  assess  how  to  optimise 
synergistic effects of the current mechanisms of the CAP in particular relating to 
cross-compliance,  rural  development,  promotional  measures,  quality  policy, 
organic  farming,  etc.  at  the  farm  (objective  5  -  no  link  to  actions  listed  in  the 
Annex to the Strategy). 

  Communication and education activities targeting the general public & consumers 

were also anticipated (objective 6 - actions 8 and 12). 

By  means  of  those  actions  the  strategy  aimed  to  contribute  to  the  achievement  of  the 
following results:  

 

  A more comprehensive and uniform protection of animals (as a result of progress 
towards  a  simplified  legislative  framework,  and  training  and  other  support  to 
Member States to improve enforcement of existing legislation) (objective 1). 
Improved  awareness  and  changes  in  practices  from  industry  (following  the 
received guidance and training) (objective 2). 
Improved  enforcement  and  compliance  on  behalf  of  the  Member  States  (as  a 
result  of  EU  support  to  MS  enforcement,  training,  infringement  proceedings, 
audits and other support) (objective 2). 

 

  Policy  decisions  to  be  taken  based  on  new  evidence  (as  a  result  of  studies 

completed, notably on fish welfare) (objective 3). 

9 

 
 
 
 
 

 

Increased EU influence on global organisations and third countries (as a result of 
multilateral and bilateral international activities) (objective 4). 
Improved  use  by  Member  States  of  cross-compliance  checks  under  the  CAP  to 
encourage farmers to  comply with  EU animal  welfare standards (by linking full 
CAP  payments  to  farmers  among  others  to  animal  welfare  requirements);  and 
improved use by Member States of co-financing possibilities for animal welfare 
measures within their RDPs (objective 5). 

  Consumers making decisions based on animal welfare considerations (as a result 
of initiatives to better inform consumers on matters of animal welfare) (objective 
6). 

These results were expected to lead to four main types of impacts:  

  Better treatment of animals. 
  Open and fairer competition (both within and outside the EU). 
 
 

Increased consumer empowerment. 
Improved business opportunities. 

Several factors were identified as having different levels of influence on the impacts of 
the Strategy (details on the role of the factors can be found in section 5.3. Effectiveness).  

The intervention logic diagram presented below provides a visual representation of how 
the strategy was originally expected to work.   

10 

 
 
 
 
 
 
3. 

IMPLEMENTATION / STATE OF PLAY 

3.1 Description of the current situation  

The EU has a substantial population of livestock including at present 88 million bovine 
animals,  148  million  pigs,  and  around100  million  sheep  and  goats14.  Chickens,  egg-
laying hens and turkeys in the EU are estimated to be around 4.5 billion15. 

Following  a  Commission’s  study  on  the  welfare  of  dogs  and  cats16  it  was  estimated  in 
2012 that in the European Union there were 60.8 million dogs and 66.5 million cats. 

14https://ec.europa.eu/eurostat/search?p_auth=8TujuEo7&p_p_id=estatsearchportlet_WAR_estatsearchport
let&p_p_lifecycle=1&p_p_state=maximized&p_p_mode=view&_estatsearchportlet_WAR_estatsearc
hportlet_action=search&text=animal+population  

15   European  Parliament’s  Policy  Department  for  Citizens’  Rights  and  Constitutional  Affairs,  “Animal 

Welfare in the European Union”, Brussels, 2017  

16 

https://ec.europa.eu/food/sites/food/files/animals/docs/aw_eu-strategy_study_dogs-cats-commercial-

practices_en.pdf  

11 

 
  
 
 
                                                           
In 2017, the agricultural industry of the EU produced a total output value of 427 billion 
Euro (up from 400 billion Euro in 2016). 39.6% of this output value came from animals 
and animal products (with milk accounting for the greatest share of output value)17.  

In  2014  and  2015,  EU  finfish  aquaculture  industry  produced  almost  700,000  tonnes  of 
finfish,  and,  together  with  other  EFTA  countries,  produced  over  2  million  tonnes18. 
According 
for 
Fisheries (STECF)  report19,  the  performance  of  the  aquaculture  sector  had  reached  1.4 
million tonnes in sales volume and  4.9 billion Euro in sales value in 2016. 

latest  Scientific,  Technical  and  Economic  Committee 

the 

to 

Estimates for the number of persons involved in agricultural activities reach 22.2 million 
for  2013,  many  of  whom  are  working  part-time.  Converted  into  full-time  equivalents, 
this comes to somewhere between 8.7 and 9.5 million20. 

Over the years, the EU invested significant efforts to make sure that its rules achieve the 
right balance between the need to protect the welfare of animals, while also supporting 
the competitiveness of the EU farming and agricultural industry.  

Implementation of the strategy 

All the actions  under  the  strategy  (listed in  Annex 4) have been implemented, with  the 
exception  of  the  one  requiring  to  assess  the  feasibility  of  introducing  a  simplified 
legislative framework. While the project concerning animal welfare law was not pursued, 
however  several  EU  Reference  Centres  for  animal  welfare  were  established,  and  the 
development of standardised animal welfare indicators was initiated.  

A  set  of  training  activities  for  Member  States  have  been  put  in  place  under  the  Better 
Training  for  Safer  Food  (BTSF)21  to  support  them  in  enforcing  the  legislation  on  the 
welfare  at  farm,  during  transport  and  at  slaughter.  Various  guidelines  and/or 
implementing  plans  on  the  welfare  of  pigs,  slaughter  and  transport  were  developed  for 
competent authorities, business operators and stakeholders, to assist the various actors in 
complying with animal welfare rules. 

Enforcement  is  primarily  under  the  responsibility  of  the  Member  States.  The 
Commission' role in improving enforcement is to stimulate and facilitate the work of the 

17 

DG 

AGRI, 

Agricultural 

and 

farm 

income 

report:  

https://ec.europa.eu/agriculture/sites/agriculture/files/statistics/facts-figures/agricultural-farm-
income.pdf  

18     Commission overview report of a series of fact-finding missions carried out in 2014 and 2015 on the 
implementation 
aquaculture: 
rules 
file:///C:/Users/ralchst/AppData/Local/Packages/Microsoft.MicrosoftEdge_8wekyb3d8bbwe/TempStat
e/Downloads/Overview%20report%20for%20publication.pdf  

finfish 

the 

on 

of 

19      Economic Report of the EU Aquaculture sector (STECF-18-19)  

20    DG AGRI, Farm structures report: https://ec.europa.eu/agriculture/sites/agriculture/files/statistics/facts-

figures/farm-structures.pdf  

21   https://ec.europa.eu/food/safety/btsf_en 

12 

 
                                                           
Member  States  competent  authorities.  For  this  reason,  Member  States  are  regularly 
audited  by  the  Commission.  Audits  are  carried  out  for  all  specific  EU  legislation 
applicable to farm animals and their reports are made public on the internet22.  

As part of the enforcement actions, infringement proceedings were launched against 13 
Member States for non-compliance with the requirement on group housing of sows after 
the  end  of  the  transitional  period  in  2013.  The  strategy  launched  ‘EU  pilot  dialogue 
schemes’, including 18 EU pilots23 on laying hens and pigs, and 5 pilots in other areas, 
mostly relating to transport.  

Studies  on  the  welfare  of  farmed  fish  (i.e.  common  practices  during  transport  and 
slaughter)24 and on the welfare of dogs and cats involved in commercial practices25 were 
carried out to address knowledge gaps in specific areas. 

EU  producers  have  to  comply  with  EU  animal  welfare  legislation  for  products  they 
export. Products imported into the Union do not have to comply with EU animal welfare 
standards  (except  for  slaughter)  and  EU  producers  perceive  this  as  a  limitation  to  their 
competiveness (see 5.4.4 Competitiveness and the economic sustainability). Overall EU 
and  third  countries  operators  seem  to  have  a  different  perception  also  on  the  impact  of 
animal welfare standards on productivity. However, they both consider that compliance 
with animal welfare legislation has a positive impact on product quality. 

The inclusion of animal welfare in bilateral trade agreements has always been at the EU 
request.  Within  or  outside  trade  agreements,  the  bilateral  cooperation  has  achieved 
concrete results over the years such as the creation of working groups with partners (e.g. 
Chile and New Zealand) with annual work plans and corresponding actions. This was for 
example  a  trigger  for  Chile  to  develop  a  full  body  of  national  legislation  on  animal 
welfare  and  for  New  Zealand  and  Canada  to  set  up  equivalence  on  animal  welfare  at 
slaughter. The EU-Brazil Sectorial Dialogue Instrument in the context of a Memorandum 
of  Understanding  on  animal  welfare  has  also  made  progress26.  In  parallel,  the 
Commission and the EU Member States have also been active on a multilateral level by 
contributing  to  the  process  of  development,  adoption  and  implementation  of  the  OIE 

22   https://ec.europa.eu/food/audits-analysis/audit_reports/index.cfm 

23   EU Pilot is a mechanism for informal dialogue between the Commission and the Member State before 

launching a formal infringement procedure. 

24   https://op.europa.eu/en/publication-detail/-/publication/facddd32-cda6-11e7-a5d5-

01aa75ed71a1/language-en/format-PDF/source-49981830  

25   https://ec.europa.eu/food/sites/food/files/animals/docs/aw_eu-strategy_study_dogs-cats-commercial-

practices_en.pdf  

26   Study  on  the  impact  of  animal  welfare  international  activities:  https://op.europa.eu/en/publication-

detail/-/publication/dc039353-ca9c-11e7-8e69-01aa75ed71a1  

13 

 
                                                           
international standards on animal welfare27 and cooperating with the FAO. 

The  CAP  has  encouraged  farmers  through  the  European  Agricultural  Fund  for  Rural 
Development  (EAFRD)  to  implement  animal  welfare  standards  that  go  beyond  the 
minimum legislative requirements.  These animal welfare payments compensate farmers 
for income loss and/or additional costs stemming from carrying out commitments  going 
beyond  the  minimum  requirements  set  out  in  the  legislation.  However,  this  measure  is 
optional  and  only  a  limited  number  of  Member  States  has  used  this  possibility  in  their 
RDPs.28 

Apart  from  table  eggs29,  there  are  no  compulsory  EU  marketing  standards30  to  allow 
consumers  to  choose  animal  welfare  friendly  products.  Voluntary  animal  welfare 
labelling schemes31 exist in few Member States.  

The  level  of  understanding  of  animal  welfare  issues  within  diverse  groups  such  as 
general  public,  students,  consumers  and  professionals  working  with  animals  were  also 
assessed during the strategy32. The aim was to identify where deficiencies still persist and 
to  suggest  means  of 
the 
dissemination of information.  

through  education  and 

improving  knowledge 

levels 

3.2 Ongoing Commission activities on animal welfare  

For the last years until the launching of the strategy evaluation in 2019, the work on animal 
welfare  focussed  on  better  enforcement,  stakeholders’  dialogue  and  promotion  of  animal 
welfare  globally. These  were areas for which, despite the progress made  by the strategy, 
the  Commission  aimed  to  do  more.  In  terms  of  enforcement,  the  two  key  Commission 
priorities were  and remain the protection of  animals  during  transport  and  the  welfare  of 
pigs  with  particular  focus  on  tail  docking.  Tail  docking  should  only  to  be  carried  out 
under  strictly  defined  circumstances,  however  it  is  still  routinely  practiced  by  many 
Member States. 

Regarding  the  transport  of  animals,  the  Commission  focussed  its  work  on  addressing 

27   Section  7  of  the  Terrestrial  Animal  Health  Code  (https://www.oie.int/en/standard-setting/terrestrial-
Code 

code/access-online/) 
(https://www.oie.int/en/standard-setting/aquatic-code/access-online/)  

Aquatic 

Section 

Animal 

Health 

and 

the 

of 

7 

28     https://www.eca.europa.eu/Lists/ECADocuments/SR18_31/SR_ANIMAL_WELFARE_EN.pdf    

29   https://ec.europa.eu/food/animals/welfare/other_aspects/labelling_en 

30   Regulation (EU) No 1308/2013 of the European Parliament and of the Council of 17 December 2013 

establishing a common organisation of the markets in agricultural products  

31   Private sector initiatives (e.g. pig sector in Finland), voluntary labelling schemes (e.g. Spain or Danish 
‘Better Animal Welfare’ label31) and high welfare barn systems introduced by producers (e.g. Kipster, 
Rondeel)  

32   Study  on  animal  welfare  education  and  on  information  activities  directed  to  the  general  public  and 
https://ec.europa.eu/food/sites/food/files/animals/docs/aw_eu-strategy_study_edu-info-

consumers: 
activ.pdf  

14 

 
                                                           
challenges related to  long journeys33. To ensure that the legislation is  correctly applied, 
the Commission audited several Member States within a three-year project (2017-2019). 
This project focused exclusively on the welfare of animals exported to third countries by 
road and by sea. Other activities carried out include the Commission's Project on Animal 
Transport  Guides,  the  organisation  of  regular  meetings  for  the  EU  National  Contact 
Points  for  animal  transport  and  communication  between  the  Commission  and  Member 
States  on  relevant  issues  such  as  transportations/exports  at  extreme  temperatures. 
Furthermore,  the  Commission  supports  financially  the  implementation  of  the  OIE 
Platform  on  Animal  Welfare  for  Europe  and  the  OIE  animal  welfare  action  plan  for 
Middle  East  countries  for  2016-2019,  which  included  targeted  training  activities  on 
transport and slaughter of animals. Nevertheless, there are still some challenging issues 
requiring  further  efforts  like  high  temperatures  during  transport/export  by  road  and  by 
sea.  Animal  welfare  NGOs  regularly  approach  the  Commission  with  reports  and 
complaints  against  national  competent  authorities  concerning  welfare  during  transport, 
with  a  particular  focus  on  animal  exports  to  the  Middle  East  or  Northern  African 
countries and the export of animals by sea.  

On 19 June 2020, the European Parliament set up a committee of inquiry to investigate 
alleged contraventions and maladministration in the application of Union law in relation 
to the protection of animals during transport within and outside the Union.34 

As regards the welfare of pigs, the Commission developed activities to support Member 
States to improve their level of compliance. In March 2016, the Commission adopted a 
Recommendation  on  the  application  of  Directive  2008/120/EC  laying  down  minimum 
standards  for  the  protection  of  pigs  as  regards  measures  to  reduce  the  need  for  tail 
docking. It is accompanied by a Staff Working Document, which provides the technical 
tools  to  improve  implementation  and  enforcement  of  the  legislation.  Furthermore,  the 
Commission carried out study visits, produced overview reports, analysed and supported 
the implementation of Member States action plans (i.e. peer-to-peer support, organisation 
of technical meetings and fora).  

In addition to the strategy, the Commission performed audits35 in the Member States to 
evaluate  how  they  have  used  this  Recommendation  to  improve  compliance  with  EU 
legislation. 

The  Commission  has  also  developed  extensive  communication  materials  to  help  pig 
farmers and to encourage them, with different approaches to avoid routine tail-docking.  

33   Journey that exceed 8 hours  

34https://www.europarl.europa.eu/news/en/press-room/20200619IPR81604/protection-of-transported-

animals-parliament-establishes-inquiry-committee  

35   https://ec.europa.eu/food/audits-analysis/audit_reports/index.cfm  

15 

 
                                                           
In 2017, the European Commission established the EU Platform on animal welfare36, an 
expert group of the Commission serving as a forum to exchange good practices, promote 
non-binding  activities  and  advise  the  Commission  on  animal  welfare  matters37.  The 
Commission, through the Platform, aimed to show that non-legislative initiatives have the 
potential  to  improve  the  welfare  of  animals,  and  that  these  improvements  depend  on 
Member States’ and stakeholders' commitments. 

to  establish  dedicated  sub-groups  focusing 

Given the priority given tolive animal transport and the welfare of pigs, the Commission 
topics. 
decided 
Commission’s  sub-groups  on  transport38  and  the  welfare  of  pigs39  take  into  account  all 
existing work in these areas and assist the Platform in its work by fostering the exchange of 
information,  experience,  good  practices  and  facilitating  cooperation.  In  2020,  the 
Commission set up a new sub-group on animal welfare labelling.  

their  work  on  both 

In addition, several members of the Platform have decided to work on a voluntary basis on 
five  initiatives  that  deal  with  the  welfare  of  horses  and  alike,  welfare  of  pets,  welfare  of 
farmed fish, welfare of pullets (i.e. young hens before they lay eggs) and the castration of 
piglets. 

The Official Controls Regulation (EU) 2017/625 (OCR), which replaced Regulation (EC) 
No 882/2004 on official controls performed to ensure the verification of compliance with 
feed  and  food  law,  animal  health  and  animal  welfare  rules,  aimed  to  introduce  a  more 
harmonised and coherent approach to official controls and enforcement actions along the 
agri-food  chain40.  In  May  2019,  the  Commission  adopted  an  Implementing  Regulation 
2019/723 establishing the standard model form for the information and data, including on 
controls  on  animal  welfare,  to  be  included  in  the  annual  report  submitted  by  Member 
States. This was an important step forward to unify data collection , including on animal 
welfare implementation and streamline risk based controls at farm, during transport and 
at slaughter.  

Under  the  framework  of  the  OCR,  the  Commission  designated  in  2018  the  first  EU 
Reference Centre for Animal Welfare41 focusing on the welfare of pigs. Another centre 
on  the  welfare  of  poultry  and  other  small  farm  animals  was  designated  in  2019  and  a 
third  one  on  ruminants  and  equids  has  been  announced  in  June  2020.  The  centres  will 

36   https://ec.europa.eu/food/animals/welfare/eu-platform-animal-welfare_en  

37    The  activities  of  the  Platform  include  two  plenary  meetings  per  year,  the  work  of  two  subgroups,  on 
transport  and  on  pigs,  established  and  managed  by  the  Commission  from  Grange  as  well  as  five 
voluntary initiatives created by members. 

38https://ec.europa.eu/food/animals/welfare/eu-platform-animal-welfare/thematic-sub-groups/animal-

transport_en  

39 https://ec.europa.eu/food/animals/welfare/eu-platform-animal-welfare/thematic-sub-groups/pigs_en  

40 https://ec.europa.eu/food/safety/official_controls/legislation_en  

41 https://ec.europa.eu/food/animals/welfare/eu-ref-centre_en  

16 

 
                                                           
provide scientific and technical expertise to perform official controls.   

Approximately one and half million citizens have signed a European Citizens’ Initiative 
(ECI) calling for an end to the use of cages for farm animals. This initiative was launched 
by  Compassion  in  World  Farming  in  Sept  2018  in  partnership  with  Eurogroup  for 
Animals and approximately 170 other animal welfare and environmental organisations. 

4.  METHOD 

4.1 Short description of methodology 

For the purposes of the evaluation, the Commission published a roadmap42 in May 2019 
for  a  period  of  four  weeks,  presenting  the  scope,  the  key  evaluation  questions  and  a 
consultation  strategy  to  ensure  stakeholders'  engagement  in  the  process.  Feedback  was 
received  by  a  range  of  stakeholders  including  public  authorities,  business  associations, 
organisations, NGOs, citizens, academia, research and other.   

An  inter-service  steering  group  including  all  the  relevant  Commission  services 
accompanied  and  supported  the  evaluation,  by  providing  further  views  and  evidence 
which have been integrated in this document.  

An  extensive  one-year  study  (‘the  study’)  carried  out  by  a  Commission  external 
consultant  provided  the  main  evidence  base  for  this  evaluation.  This  study  –  which 
started  in  2019  -  applied  a  mixed-method  approach  in  order  to  address  the  evaluation 
questions.  The  methods  used  included  desk  research,  an  online  public  consultation, 
targeted  surveys  and  semi-structured  interviews.  In  addition,  eight  case  studies  using 
contribution analysis43, comparative analysis44 and an assessment of opportunity costs of 
partially  (or  not)  meeting  (some  of)  the  objectives  of  the  strategy  were  carried  out  to 
further  support  the  analysis.  The  findings  were  validated  during  a  stakeholders’ 
workshop.  

Furthermore,  to  ensure  objectiveness  of  findings,  the  study  applied  a  systematic 
categorisation of the evidence and used triangulation methods for qualitative research in 
weighing the different sources. 

4.1.1 Desk research  

42 

https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/2140-Evaluation-of-the-EU-

Animal-Welfare-Strategy-2012-2015-  

43   To identify the contribution the strategy has made to a change or set of changes. 

44   An assessment in which two things are compared and contrasted. 

17 

 
 
 
 
 
 
 
                                                           
The desk research included a review of all existing quantitative and qualitative data and 
evidence.  It  focused  primarily  on:  EU  policy  and  legislative  documents,    reports  and 
communications;  national  reports  and  other  relevant  documents,  audit  reports,  national 
action plans, international reports on animal welfare standards and policies, various web-
based  sources  from  relevant  stakeholders,  academic  publications,  scientific  opinions, 
consumer opinions on animal welfare, and competitiveness in the farmed animal sector, 
among others.  

4.1.2 Consultation activities  

The consultation was based on primary data collected from three different sources: 

a)  Public consultation targeting all stakeholders; and 
b)  Targeted consultations addressed to specific stakeholder groups, which involved:  
  surveys and  
  semi-structured interviews addressed to specific stakeholder groups. 

All  stakeholder  groups  (with  the  exception  of  consumer  organisations,  who  did  not 
contribute  to  surveys/interviews)  were  reached  in  the  context  of  the  consultation 
activities.  All  feedback  received  has  been  analysed  and  taken  into  account  for  the 
purpose  of  the  evaluation.  To  the  extent  possible  the  number  and  the  percentage  of 
stakeholders  who  took  part  in  specific  consultation  activities  were  indicated  in  the 
analysis.  More  details  on  the  representativeness  of  the  findings  can  be  found  in  the 
synopsis report (see annex 2) and in the study. 

a)  Public consultation 

The goal of the public consultation was to gather information and perspectives from all 
stakeholders, including the public at large. For this purpose, an online questionnaire was 
designed  around  the  five  objectives  of  the  strategy,  and  included  questions  relating  to 
each of the five evaluation criteria as well as future challenges.  

The  public  consultation  was  launched  on  23  March  and  ran  for  13  weeks.  A  total  of 
3,375  respondents  contributed  to  the  consultation,  of  which  2,704  were  identified  to 
come from a coordinated response.  

Of  the  remaining  671  responses,  410  came  from  EU  citizens,  and  55  from  non-EU 
citizens.  The  other  207  respondents  were  30  academics/researchers,  34  were  business 
associations, 31 companies, 49 NGOs, 8 organisations (2 consumer organisations and 6 
environmental organisations), 19 public authorities, 4 trade unions and 31 self-identified 
as ‘other’.   

b)  Targeted surveys 

18 

 
 
 
 
 
 
 
 
 
 
The  online  survey,  tailored  to  the  different  stakeholder  groups,  complemented  the 
information  collected  through  the  public  consultation  and  interviews,  and  focuses  on 
questions about effectiveness, coherence, relevance and EU added value. The survey was 
conducted in English and targeted the following stakeholders:  
  national competent authorities in Member States;  
  business organisations; trade/professional organisations;  
  non-governmental organisation (NGOs);  
  consumer organisations;  
  national Member States in non-EU countries;  
  and international organisations. 

The  survey  was  launched  on  1  April  2020  and  ran  for  five  weeks.  The  survey  was 
disseminated  through  several  channels,  including  348-targeted  emails  and  via  the  EU 
Animal  Welfare  Platform,  with  75-targeted  members  representing  the  different 
stakeholder groups.  

c)  Semi-structured interviews 

The interviews explored in detail specific aspects, such as the contribution of the strategy 
actions to the achievement of its objectives, coherence among policies and the strategy’s 
costs and benefits. The study team completed 102 telephone interviews from the initially 
planned 130 with a sample of key stakeholders at national, EU and international level.  

4.1.3 Validation workshop 

An online validation workshop was organised on 9 July 2020. The event enabled various 
stakeholders  and  experts  to  share  their  perspectives  and  insights  on  the  preliminary 
findings of the study.  It  served as an additional source of information  and as a tool for 
validating all data gathered from the desk research, stakeholder interviews, surveys, and 
the  public  consultation. The  stakeholders  invited  to  this  event  were  the  75  members  of 
the EU Animal Welfare Platform since they represent various types of stakeholders.  

4.1.4 Case studies 

In  support  to  the  data  collected  through  desk  research  and  the  set  of  consultation 
activities eight case studies aimed to assess the extent to which the actions of the strategy 
contributed  to  its  planned  objectives.  Each  case  study  explored  the  impact  for  each 
delivery model (i.e. tools used to deliver on specific actions) of the strategy in order to 
understand the processes and what contributed to the outcomes.  

A  synopsis  report  summarising  all  activities  carried  out  as  part  of  stakeholder 
consultations, and their results, is provided in Annex 2. 

19 

 
 
 
 
 
 
 
 
 
 
4.2 Limitations and robustness of findings 

Overall,  the  Commission  agreed  with  the  conclusions  of  the  study  despite  the 
methodological  limitations and lack of robust quantitative data (especially  affecting the 
effectiveness and efficiency analysis), as described below. 

With  respect  to  the  data  collection  activities,  the  following  key  limitations  have  been 
identified:  

4.2.1 Lack of longitudinal data45 

The lack of sufficient quantitative longitudinal data has been identified as an obstacle to 
develop  the  baseline  provided  in  the  Impact  Assessment  of  2012.  As  an  alternative,  a 
‘snapshot’  data  (data  available  for  certain  periods  and  for  certain  states)  together  with 
qualitative  data  (collected  during  the  consultation  with  stakeholders)  was  used  by  the 
study. Due to limitations to  demonstrating the causal  link between the strategy and the 
impacts achieved, the study instead focused on assessing the extent to which the strategy 
may  have  contributed  to  outputs  and  any  outcomes  that  could  be  documented. In  the 
effectiveness section, it has not been possible to obtain impact level data for any of the 
objectives.  This  gap  was  filled  by  using  the  intervention  logic  to  assess  the  extent  to 
which  the  strategy’s  actions  and  activities  have  delivered  the  anticipated  outputs, 
outcomes,  results  and  ultimately  contributed  to  addressing  the  problems  identified. 
Further,  other  information  gaps  have  also  been  filled  through  qualitative  inputs  from 
stakeholders  consulted.  The  lack  of  baseline  data  that  correspond  with  the  specific 
strategy objectives and related actions was a major challenge for assessing the relevance 
analysis as well.   

4.2.2 Breakdown analysis of the public consultation and survey data  

An analysis of the results by production system and geography46 was not possible due to 
a small base of data for both categories (business representatives were n=38 in the survey 
and n=45 in the public consultation). For this reason, the responses were analysed taking 
these categories as a whole and not including evidence by geography or type of industry.  

4.2.3  Low  response  rate  on  some  specific  questions  and  limited  quantitative 
evidence available  

Efficiency  questions  were  difficult  for  many  stakeholders  to  answer  due  to  limited 
familiarity with the strategy. To address this issue the interview and survey data provided 
insights into some of the costs incurred by stakeholders. There was no dedicated budget 
for the strategy, nor any dedicated data collection to measure the strategy’s progress.  It 

45   This is a data on the same subjects over some period of time like in the particular case at the time of 

the adoption of the strategy and the time of its end of implementation.  

46   Public consultation responses Belgium, n=17; France, n=16; Germany, n=13; Ireland, n=10; Italy, n=24 and Spain, n=31 

20 

 
 
 
 
 
 
                                                           
has not  been therefore possible to  quantify  accurately all  costs  of the strategy, so  some 
estimates  were  used  instead.  Given  the  lack  of  information,  it  was  not  possible  to 
establish  proper  and  complete  costs  and  benefits  analysis  and  to  establish  the 
distributions among stakeholders, both in terms of differences by Member State and over 
time. Instead, a qualitative approach to assess the study questions on efficiency has been 
used.  

The  efficiency  analysis  has  been  based  on  data  gathered  from  Commission  documents, 
desk  research,  interviews,  targeted  survey  and  the  public  consultation.  Even  when  cost 
information related to the strategy was gathered, it was challenging to identify the share 
of it that directly pertains to the strategy and would not be incurred in its absence.  

4.2.4 Covid-19 crisis  

Some of the data collection activities encountered additional delay due to the Covid-19 
crisis in the mid of the study. An additional week was granted to contribute to the public 
consultation,  to  ensure  wider  participation  of  stakeholders.  While  the  Covid-19  crisis 
contributed to the delay of the process it did not hampered any of the findings. 

5.  ANALYSIS AND ANSWERS TO THE EVALUATION QUESTIONS 

5.1 RELEVANCE   

To assess the relevance of the strategy, the evaluation looked at the relationship between 
the  needs  and  problems  in  society  and  the  objectives  of  the  strategy.  In  particular,  the 
analysis aims to reply to the following evaluation questions: 

  The extent to which the objectives of the strategy, its actions and other activities, 
properly  addressed animal  welfare needs at EU-level  at the time of its  adoption 
(2012)? 

  The  extent  to  which  each  of  the  objectives  and  actions  remained  relevant  to 
animal welfare problems and drivers, as well as the context, at EU-level over time 
and up until today ( 2019)? 

Main findings:  

The  strategy  was  an  appropriate  response  to  the  animal  welfare  needs  and 
challenges at the time of its adoption in 2012. The key problems, drivers and objectives 
have  been  well  identified  and  incorporated  into  one  document.  The  majority  of 
stakeholders consulted perceived the strategy as a positive attempt by the Commission to 
coordinate actions around animal welfare in the EU. 

The delivery model of the strategy was appropriate for around half of the objectives 
in  2012.  For  example,  enforcement  actions  to  support  Member  States  were  well 
designed and specific enough. For the other half like for example optimising synergies 
with  the  CAP,  supporting  international  cooperation  and  providing  consumers  with 

21 

 
 
 
appropriate information, actions were perceived either as not ambitious enough or as not 
being sufficiently concrete in their formulation.  

The  enforcement  actions  were  the  most  appropriate.  The  development  of  guidelines 
were also appropriate but would have needed more dissemination efforts. The production 
of studies and reports were also appropriate but concrete follow up actions would have 
been required. 

Most of the problems and drivers identified in the strategy remain relevant today. 
Despite the progress made the need to improve compliance across Member States in 
some  legislative  areas,  enforcement  remains  a  key  challenge.  Considering  the 
increasing  EU  citizens  concerns  towards  animal  welfare,  the  adequate  information  to 
consumers makes the objective even more relevant today than it was in 2012.  

Although  the  strategy  objectives  have  evolved  over  time,  a  majority  of  them 
continue to be relevant today.  

5.1.1 Relevance in 2012 

The strategy properly identified common problems and drivers affecting animal welfare 
in the EU and set out six objectives for addressing them. The objectives were all relevant 
at the time of the adoption of the strategy. An analysis of the relevance for each objective 
in 2012 is provided below. 

Objective  1:  Consider  the  feasibility  of  introducing  a  simplified  EU  legislative 
framework for animal welfare  

With  this  objective,  the  strategy  targeted  two  problems.  The  first  was  to  simplify  the 
legislative  framework.  The  wording  “simplification”  led  to  different  perceptions 
amongst  stakeholders.  In  general,  NGOs  believed  a  simplification  of  the  legislative 
framework would dilute the existing requirements, while others such as industry thought 
it could create additional burden.  

The  second  element  relates  to  achieving  a  more  comprehensive  protection  of  animals 
across the EU, by including welfare principles for all animals. Evidence suggests that the 
relevance  of  this  element  was  high  since  only  farm  animals  were  covered  by  EU 
legislation and not all farmed species were protected by species-specific legislation. 

Overall,  while  the  problem  identified  was  relevant,  the  objective  and  the  strategy’s 
response lacked specificity. The action for possible legislative proposal for a simplified 
EU legislative framework for animal welfare was not pursued, however, the new Official 
Controls  Regulation47  empowers  the  Commission  to  set  up  EU  reference  centres  on 

47   Regulation  (EU)  2017/625  of  the  European  Parliament  and  of  the  Council  of  15  March  2017  on 
official controls and other official activities performed to ensure the application of food and feed law, 
rules on animal health and welfare, plant health and plant protection products 

22 

 
                                                           
animal  welfare  and  introduce  animal  welfare  indicators,  and  to  adopt  requirements  for 
control of compliance.  

Objective 2: Develop tools, including where relevant implementing plans, to strengthen 
Member States' compliance  

This  objective was highly  relevant  in  2012 due to  the uneven  level  of compliance with 
EU  legislation  on  animal  welfare  across  the  EU.  The  Impact  assessment  of  2012, 
Commission  audit  reports48,  Parliament49,  NGOs50  and  various  stakeholders  largely 
support these findings by pointing at concrete issues related to the  protection of calves, 
pigs, broilers, laying hens and animal transport. 

The strategy included a wide spectrum of measures targeting Member States and industry 
to  improve  compliance  with  EU  legislation.  For  Member  States,  the  strategy  designed 
enforcement actions, implementing plans and reports targeting low enforcement areas of 
the  EU  legislation  (e.g.  welfare  of  laying  hens  and  pigs).  For  industry,  the  strategy 
proposed  the  creation  of  guidelines  targeting  specific  areas  of  EU  legislation  that  were 
often seen as complex. The study and Commission audit reports from the time of strategy 
highlight that these measures were appropriate in addressing the identified challenges. 

Commission audit reports on the protection of animals on slaughter from the period 
2016-2017 confirm the need for further support, supervision and guidance. Objective 3: 
Investigate on the welfare of farmed fish 

According to the Impact Assessment of 2012, the lack of knowledge about the welfare of 
farmed fish was a relevant issue in 2012. A report on the future of European aquaculture 
from 2012 also identified aquatic animal health and welfare as one of eight priority areas 
and contained a goal to ‘develop and improve existing welfare/stress indices’ (European 
Aquaculture Technology and Innovation Platform, 2012).  To address this objective, the 
strategy included two actions: a study on the welfare of farmed fish assessing common 
practices during transport and at slaughter51 and a report to the European Parliament and 
the  Council  on  the  possibility  of  introducing  certain  requirements  regarding  the 

48   https://ec.europa.eu/food/audits-analysis/audit_reports/index.cfm 

49   Interview 

with 

MEP 

Marit 

Paulsen 

of 

2012:  

https://www.europarl.europa.eu/news/en/headlines/society/20120628STO47902/name-and-shame-
member-states-dragging-their-feet-over-animal-welfare 

50    “EUROPEAN  UNION  LEGISLATION  ON  THE  WELFARE  OF  FARM  ANIMALS”  by  Peter 
Stevenson,  January  2012:  https://www.ciwf.org.uk/media/3818623/eu-law-on-the-welfare-of-farm-
animals.pdf 

51https://op.europa.eu/en/publication-detail/-/publication/facddd32-cda6-11e7-a5d5-

01aa75ed71a1/language-en/format-PDF/source-49981830  

23 

 
                                                           
protection of fish at the time of killing52. Given the need for more knowledge about fish 
welfare, these actions were appropriate.  

Objective 4: Support international cooperation 

The  Commission  worked  to  support  international  cooperation  on  animal  welfare  far 
before  the  adoption  of  the  strategy53.  However,  this  objective  remained  also  relevant  in 
2012  because  the  international  cooperation  require  long  term  vision  and  action.  The 
strategy built on previous work done in this domain and contributed by further promoting 
the need to include animal welfare in trade agreements or cooperation fora. Inter alia, this 
was  done  by  exploring  better  integration  of  animal  welfare  in  the  European 
neighbourhood  policy  framework  and  organising  international  events  promoting  EU 
views  on  animal  welfare.  Additionally,  the  Commission  had  collaborated  with  inter-
governmental organisations such as the Food and Agriculture Organisation of the United 
Nations (FAO) and the World Organisation for Animal Health (OIE), providing financial 
support to the OIE and being actively involved in the development and implementation 
of international welfare standards. A report on the impact of animal welfare international 
activities on the competitiveness of European livestock producers in a globalised world54 
has been published by the Commission under the strategy.  

Overall,  activities  foreseen  under  the  strategy  were  appropriate  and  relevant  to  support 
the  international  cooperation  on  animal  welfare.  However,  the  lack  of  specificity  in 
formulating this objective posed a challenge to evaluate the impact of its activities. 

Objective 5: Optimise synergistic effects from current Common Agriculture Policy (CAP) 

The 2010 Evaluation of the EU Policy on Animal Welfare concluded that EAFRD animal 
welfare payments were under-utilised by Member States at the time. Despite the fact that 
there were already some tools in place (e.g. CAP Farm Advisory System (FAS), Cross-
compliance measures and EAFRD), this objective was relevant considering the perceived 
insufficient integration between animal welfare policy and the CAP in 2012.  

The  CAP  provided  opportunities  for  improving  the  awareness  of  farmers  on  the 
compliance  requirements  with  animal  welfare  rules.  Cross-compliance  linked  the 
payments of the CAP with the compliance of basic standards including animal welfare55 . 
In  addition,  the  EAFRD  offered  Member  States  the  possibility  of  co-financing  support 
for  animal  welfare,  via  specific  animal  welfare  payments  (i.e.  voluntary  management 

52   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, COM/2018/087 final  

53 https://ec.europa.eu/food/sites/food/files/animals/docs/aw_international_2002_0626_en.pdf  

54 https://ec.europa.eu/food/sites/food/files/animals/docs/aw_international_publication-report_en.pdf  

55   Directive 2008/119/EC, Directive 2008/120/EC and Directive 98/58/EC 

24 

 
                                                           
commitments  going  beyond  the  legally  binding  requirements  or  commonly  used 
agricultural  practices,  which  compensated  farmers  for  additional  costs  incurred  and/or 
income  foregone)  or  other  measures  (e.g.  investments,  training  and  advice)  aimed  at 
improvements in animal welfare.  

The strategy planned to tackle problems in 2012 by establishing “a specific inter-services 
arrangement to assess how to optimise synergistic effects of the current mechanisms of 
the  CAP  in  particular  through  cross-compliance,  rural  development,  promotional 
measures, quality policy, organic farming, etc.”. No specific inter-service arrangements 
with  this  purpose  was  set-up  during  the  period  considered.  Inter-service  consultations 
took place on an ad hoc basis. The lack of specificity posed a challenge to assess whether 
the  objective  could  have  been  met  only  with  such  an  arrangement  or  not,  and  whether 
this  could  have  been  an  appropriate  tool  to  increase  synergies  between  the  two  policy 
areas.    

Objective 6: Provide consumers and the public with appropriate information  

The Community Action Plan on the protection and welfare of animals (2006-2010) states 
that  there  has  been  a  „clear  shift  of  public  attitudes  towards  animals  over  recent 
decades‟. Providing consumers and the public with appropriate information was another 
highly relevant objective in 2012, supported by evidence from the Evaluation of the EU 
animal  welfare  policy  of  201056  and  the  Impact  assessment  of  2012.  An  EU  wide 
Eurobarometer  survey  on  “Attitudes  of  EU  citizens  towards  Animal  Welfare”  showed 
that animal welfare was a concern for 64% of the population (March 2007).  

5.1.2 Relevance today 

According  to  the  evidence  gathered  in  the  study,  the  six  objectives  of  the  strategy 
continue  to  be  relevant  today.  Considering  the  fact  that  objectives  and  problems  have 
evolved with time there are some differences in the extent of their relevance.  

Objective 1: A simplified EU legislative framework for animal welfare  

The  objective  remains  relevant  because  the  existing  legal  framework  has  not  being 
updated  with  the  latest  scientific  evidence  and  does  not  contain  species  specific 
requirements for all animal species.   

The appropriateness of other measures included under this objective like the creation of 
common  requirements  for  personnel  handling  animals  remain  appropriate  and  are  still 
relevant.  The  establishment  of  EU  Reference  Centres  and  the  development  of  science-
based animal  welfare indicators were considered at  the time as very useful  tools for an 
improved  animal  welfare.  For  this  reason  the  ideas  were  retained  and  included  in  the 
Official Controls Regulation.  

56  Evaluation  of 

the  EU  Policy  on  Animal  Welfare  &  Possible  Options  for 

the  Future: 

https://ec.europa.eu/food/sites/food/files/animals/docs/aw_arch_122010_full_ev_report_en.pdf 

25 

 
                                                           
Changes and influencing factors:  

There were limited improvements in terms of the use of science-based welfare indicators. 
There  were  small  improvements  in  the  development  of  such  indicators  by  EFSA  (e.g. 
dairy cows, broilers and a statement on the use of animal-based measures which included 
recommendations around the development and use of such measures). The ECA report of 
2018 recommends57 the Commission to define baseline and target indicators to measure 
and compare the Member States’ degree of compliance in remaining risk areas identified 
by the evaluation of the strategy. 

Objective 2: Support Member States and take action to improve compliance  

This  objective  remains  highly  relevant  today  although  significant  progress  has  been 
made. Some areas of legislation have seen improved levels of compliance (e.g. banning 
of  non-enriched  cages  for  laying  hens58,  grouping  of  sows,  animal  transport  and 
slaughter), but non-compliance (e.g. use of enrichment materials and routine tail docking 
of pigs) is still perceived by stakeholders to be driven by a lack of knowledge of animal 
owners  and  handlers,  despite  guidelines  produced  under  the  strategy.  The  need  for 
continued  training  and  education  of  personnel  working  with  animals  remains  highly 
relevant. This is also supported by a survey of Chief Veterinary Officers (CVOs) under 
the Finish Presidency of the EU59, where both the attitude and insufficient knowledge of 
operators and farmers were highlighted as the main reasons for lack of compliance.  

Changes and influencing factors:  

Consumer awareness and citizens’ interest in animal welfare have increased with time as 
also  confirmed  by  Eurobarometer  on  the  “Attitudes  of  EU  citizens  towards  Animal 
Welfare”  made  in  2007  and  2016.  Expectations  and  behaviours  of  consumers  changed 
over time, resulting in  greater awareness overall (Cembalo et al., 2016) and therefore a 
greater commitment to act to make improvements. 

The lack of scientific and technological progress hampered the success of this objective 
in  some  legislative  areas.  For  example  an  IT  system  or  a  software  for  tracking  the 
transportation  vehicles,  their  journey  time,  outside  and  inside  temperature  and  other 
parameters could have improved compliance even further.  

NGO  initiatives  and  specific  campaigns  (e.g.  animal  transport,  pig’s  tail  docking  and 
other) also played a role in influencing enforcement and compliance. 

57   Recommendation 1(b) from ECA’s Special report No 31/2018: Animal welfare in the EU: closing the 

gap between ambitious goals and practical implementation 

58   Article 5(2) of Council Directive 1999/74/EC of 19 July 1999 laying down minimum standards for the 

protection of laying hens 

59   https://data.consilium.europa.eu/doc/document/ST-6007-2020-INIT/en/pdf  

26 

 
                                                           
Objective 3: Investigate on the welfare of farmed fish 

to 

this  objective  with 

Overall knowledge regarding the welfare of farmed fish has  improved as a result of the 
strategy,  which  has  contributed 
the 
aforementioned  study  and  a  Commission  report.  Considering  the  high  interest  to  this 
subject there is a need for follow-up actions based on the conclusions of the Commission 
report  (e.g.  scientific  and  technical  progress,  guidelines  etc.).  Stakeholders  from  across 
different  disciplines  believed  that  legislation  and  enforcement  related  to  fish  welfare 
needed to improve. The increased interest in fish welfare among consumers indicates that 
there  is  public  support  for  this.  While  progress  has  been  made  under  the  strategy,  this 
objective remains relevant today.  

the  production  of 

Objective 4: Support international cooperation  

Despite  the  progress  made,  the  need  to  support  international  cooperation  remains 
relevant.  The  Commission  study  and  report  on  the  impact  of  the  animal  welfare 
international  activities concluded that  “animal  welfare standards  have a limited impact 
overall on the competitiveness of EU producers on world markets”. Despite this, industry 
still perceives animal welfare improvements as costly. EU businesses and business/trade 
associations  expressed  high  degree  of  concern  in  relation  to  this  objective,  as  they 
perceive  that  higher  animal  welfare  standards  would  put  them  at  a  competitive 
disadvantage globally. This evidence was further supported also by the survey, where the 
majority (84%) agreed that further EU action was needed. 

All  the  actions  and  activities  were  appropriate  as  they  filled  a  knowledge  gap  but 
international cooperation is an ongoing objective and as such it remains relevant today. 
Stakeholders perceive that the strategy could have been more ambitious and concrete in 
the description of this objective.  

Changes and influencing factors:  

Consumer  awareness  is  again  considered  a  factor  affecting  the  relevance  of  this 
objective. Despite increases in awareness and interest in animal welfare in the EU, this is 
overall  lower  in  third  countries.  As  a  result,  the  demand  for  higher  animal  welfare 
products is still considerably lower in these countries following the Commission study on 
animal  welfare  international  activities.  This  in  turn  influences  exports  from  the  EU  as 
consumers in these countries may be less willing to pay for higher welfare products. The 
objective is also affected by trade of live animals. The level of trade between the EU and 
third countries has increased annually by 5%, with exports of agricultural products being 
higher  in  value  (€182  billion)  in  2019  than  imports  (€143  billion)  and  the  share  of 
agricultural products as a proportion of total trade reached 8% (Eurostat, 2020). 

Objective 5: Optimise synergies with the Common Agriculture Policy (CAP) 

The  CAP  supports  animal  welfare  by  improving  farmers’  awareness  of  their  legal 
obligations, and incentivising farmers to pursue higher standards.  

27 

 
This  objective  remains  relevant,  considering  the  need  for  higher  animal  welfare  is 
foreseen in the context of sustainable food production referred to under the Farm to Fork 
strategy.  Regular  coordination  between  the  CAP  and  animal  welfare  policies  existed 
before  and  continued  after  the  end  of  the  strategy.    However,  no  specific  actions  were 
carried out towards this objective under the strategy. 

Changes and influencing factors:  

Increased  consumer  awareness  on  animal  welfare  affected  (and  is  likely  continuing  to 
affect) this objective. The Eurobarometer survey conducted across all 28 Member States, 
found  that  respondents  perceived  the  CAP  was  fulfilling  its  objectives  of  supporting 
farmers  in  Member  States  in  achieving  higher  animal  welfare  standards  (Special 
Eurobarometer, 2018). The recent proposal for the CAP reform (2018) has taken a step in 
this  direction  by  explicitly  mentioning  animal  welfare,  and  linking  it  to  animal  and 
human health, as part of Specific Objective 9 “to improve the response of EU agriculture 
to societal demands on food and health, including safe, nutritious and sustainable food, 
reducing food waste, as well as animal welfare”. 

Objective 6: Provide consumers and the public with appropriate information  

This objective is even more relevant today than in 2012. This is due to a lack of progress 
on information available to EU consumers on animal welfare, despite perceived increases 
in  the level  of public interest  on the topic, and the commitment to  consider options for 
animal welfare labelling under the Farm to Fork Strategy.   

However, apart from the two studies to tackle the issue of consumer awareness (e.g. on 
the  stunning  of  animals  and  education  and  information  activities  directed  at  the  public 
and consumers), the strategy did not include more specific actions.  

There is also variation from one Member States to another supported by the findings  of 
different  surveys  on  consumers’  behaviours  and  willingness  to  pay  for  higher  welfare 
products6061.  Organisations  responding  to  the  public  consultation  supported  this  view, 
with  the  majority  (76%)62  considering  lack  of  information  among  consumers  to  be 
extremely or very relevant in 2020. Furthermore, a special Eurobarometer (March 2016) 
indicated significant increase in the interest of citizens to animal welfare by concluding 
that: “More than nine in ten EU citizens believe it is important to protect the welfare of 
farmed animals (94%).” 

60   “Consumer interest in environmental impact, safety, health and animal welfare aspects of modern pig 

production: Results of a cross-national choice experiment”, Grunert et al., 2018 

61   “Farm  Animal  Welfare,  Consumer  Willingness  to  Pay,  and  Trust:  Results  of  a  Cross-National 

Survey”, Nocella et al., 2010 

62   73%  of  academics,  76%  of  industry,  90%  of  NGOs,  and  63%  of  competent  authorities  in  Member 

States 

28 

 
                                                           
One  of  the  means  to  achieve  improvements  in  consumer  knowledge  on  the  topic  of 
animal  welfare  are  labelling  schemes.  This  is  supported  by  stakeholders  and  evidence 
from  the  evaluation63  of  EU  marketing  standards64  contained  in  the  Common  Market 
Organisation  (CMO)  Regulation,  the  ‘Breakfast  Directives’  and  CMO  secondary 
legislation, which found that rules for indicating the farming methods applied for laying 
hens had been  effective  in  promoting ‘animal  welfare-friendly’ production methods for 
eggs.  

There  are  also  EU  voluntary  marketing  standards  for  poultry  meat,  which  includes 
reference to types of farming. In addition, the EU organic farming rules encourage a high 
standard of animal welfare.  

Apart  from  EU  initiatives,  various  certification  schemes  have  been  developed  with 
animal welfare claims. In 2009, the Commission adopted a report on options for animal 
welfare labelling, based on a study. Already at that time several quality schemes were in 
place,  some  of  them  specifically  targeted  towards  animal  welfare,  others  had  animal 
welfare in their characteristics. 

This interest of the consumers to receive information on animal welfare is visible through 
the growing number of animal welfare claims among existing labels (like Label Rouge in 
France) but also with the emergence of new schemes where animal welfare is the sole or 
an  important  component.  In  absence  of  a  common  methodology,  the  proliferation  of 
claims increases the difficulty for consumers to really assess their reliability. 

Available evidence suggests that there is an increasing demand for an EU animal welfare 
labelling  scheme.  This  demand  has  been  recently  expressed  by  the  Agriculture  and 
Fisheries  Council  of  Ministers  who  adopted  in  December  2020  specific  conclusions  on 
animal welfare labelling65. 

As  announced  in  the  Farm  to  Fork  strategy,  the  Commission  will  consider  options  for 
animal welfare labelling to better transmit value through the food chain.  

Changes and influencing factors:  

Changes and influencing factors are similar to the one described in the previous objective 
(e.g. increased consumer and citizens awareness since 2012). Some initiatives by NGOs 
have  also  influenced  this  objective  through  awareness  raising  activities  during  the 
strategy  period.  The  2016  United  National  Committee  on  World  Food  Security 

63   COMMISSION STAFF WORKING DOCUMENT EVALUATION of marketing standards (contained 
in the CMO Regulation, the ‘Breakfast Directives’ and CMO secondary legislation) {SWD(2020) 231 
final} 

64   https://ec.europa.eu/info/news/eu-marketing-standards-contribute-high-quality-standards-eu-agri-food-

products-2020-oct-27_en 

65 https://data.consilium.europa.eu/doc/document/ST-13691-2020-INIT/en/pdf 

29 

 
                                                           
recommendations  to  improve  animal  welfare  were  initially  driven  by  NGO  initiatives 
and, as such, were praised by animal welfare NGOs (Buller et al., 2018). 

Delivery model 

The  feedback  from  the  consultation  activities  confirms  that  the  strategy  was  largely 
perceived  by  stakeholders  as  a  positive  step  forward.  In  the  meantime,  it  was  also 
criticized for not being ambitious enough in its design. One of the reasons for this was 
that the strategy brought together some earlier planned work (i.e. international activities) 
and some actions that have been already foreseen under the legislation (e.g. enforcement 
activities under the laying hen and pig welfare directives and Commission reports to the 
Parliament and the Council).  

In  addition,  stakeholders  also  pointed  to  the  lack  of  outcome  indicators  and  follow-up 
actions as factors limiting the potential positive impact of the strategy.  

5.2 COHERENCE 

Under the coherence criterion, it has been assessed whether/to what extent the different 
components  of  the  strategy  operate  together  in  a  coherent  way  to  achieve  the  given 
objectives  (internal  coherence).    Also,  it  has  been  explored  whether  the  strategy  is 
coherent with other relevant EU/national legislation and policies, initiatives taken in third 
countries and international organisations (external coherence). The following evaluation 
questions were used to guide such assessment:  

  How well have the various components of the strategy operated together and led 
to  synergies  to  improve  overall  performance,  over  time  and  up  until  2019?  Or, 
conversely,  whether  gaps,  areas  of  tension  or  inconsistencies  existed?  Where 
there have been inconsistencies or gaps, what has caused these? What have been 
the impacts?  

  To what  extent has  the strategy been  coordinated with  animal  health policy  and 
initiatives, as well as with the CAP (as per one of its objectives) over time and up 
until  2019?  Where  there  have  been  inconsistencies  or  gaps,  what  has  caused 
these? What have been the impacts?  

  To what extent has the strategy been coordinated and complementary with other 
EU-level  policies  and  interventions  related  to  animal  welfare  over  time  and  up 
until  2019  (e.g.  environment,  trade,  single  market,  fisheries,  and  research)? 
Where  there  have  been  inconsistencies  or  gaps,  what  has  caused  these?  What 
have been the impacts?   

  To  what  extent  has  the  strategy  been  aligned  with  national  and  non-EU 
interventions with common objectives? Where there have been inconsistencies or 
gaps, what has caused these? What have been the impacts?  

Main findings:  

The objectives and actions of the strategy were internally coherent. They operated 
well together and led to synergies.  

30 

 
 
The strategy has been coherent and coordinated with the  animal health policy and 
the CAP. However, the strategy made only a limited contribution to the improvement of 
synergies with CAP and the strengthening of the existing level of coherence.  

There  is  no  evidence  of  contradiction  between  the  EU  policies  developed  during  the 
period of implementation of the strategy.  
The strategy was coherent with interventions in Member States. However, the extent 
to which the strategy was aligned with relevant national interventions varied by Member 
State due to different, mainly national, reasons. 

There was limited evidence to assess the coherence between the strategy and the non-EU 
actions and policies.  

However,  at  global  and  regional  level,  there  are  some  positive  examples  of 
coherence between the strategy and various OIE  initiatives on animal  welfare and 
as well as the FAO Gateway to Farm Animal Welfare. 

5.2.1 Internal coherence  

Overall,  the  objectives  of  the  strategy  were  internally  coherent.  For  example,  the 
objective to simplify the legal framework was coherent with that of supporting Member 
States  in  achieving  and  improving  compliance,  as  a  simpler  framework  with  common 
indicators and requirements would make enforcement easier for Member States. Further, 
this objective was also aligned with the objective of optimising synergies with the CAP, 
as it aimed to improve the support given to businesses to raise awareness on compliance. 
Additionally,  the  general  objective  of  addressing  key  gaps  in  knowledge  on  animal 
welfare issues supported all the other objectives, as improved knowledge helped promote 
animal welfare internationally and nationally. 

The  20  actions  elaborated  under  the  different  strategy  objectives  worked  well  together, 
complemented each other and established synergies. This is the case, for example, of the 
enforcement actions and the training activities, or the set-up of the EU Reference Centre 
for  Animal  Welfare  and  the  objective  to  support  Member  States.  These  findings  are 
largely supported by the outcomes of stakeholders’ interviews. 

While  overall  the  strategy  document  is  coherent  internally,  there  were  also  some 
inconsistencies to be noted, particularly when exploring the links between the objectives, 
the  actions,  their  expected  outputs  and  the  impacts.  For  example,  certain  actions  were 
standalone or not directly associated with other parts of the strategy such for example the 
action  requiring  a  report  with  recommendations  in  the  area  of  restraining  systems  used 
for bovine animals. Also, the strategy did not include references to expanding research or 
plans to improve the welfare of equines, shellfish, rabbits, fur animals other than cats and 
dogs,  and  turkeys,  contradicting  the  general  objective  of  achieving  welfare  for  all 
animals.  

5.2.2 External coherence with EU legislation/policies  

Animal Health and Official Controls policies 

31 

 
 
The strategy is coherent and coordinated with animal health policies and legislation.  For 
the purposes of the evaluation, it was assessed whether the strategy is coherent with two 
major  legislative  acts  which  are  relevant  to  animal  welfare,  i.e.  the  Official  Controls 
Regulation66  (OCR)  and  the  Animal  Health  Law67,  as  well  as  with  the  previous  EU 
animal welfare strategy (2007-2013). 

The  OCR  includes  welfare  requirements  for  animals  in  its  scope  and  encompasses  key 
animal welfare aspects, such as the establishment of reference centres or the potential use 
of  science-based  indicators.  Both  aspects  were  indicated  in  the  strategy  document  as 
possible  components  of  the  simplified  EU  legislative  framework  for  animal  welfare. 
Article 13 TFEU recognising that animals are sentient beings is part of the recitals of the 
OCR. 

The  animal  welfare  strategy  was  coherent  with  the  EU  animal  health  strategy  (2007-
2013).  Both  strategies  demonstrated  synergies  through  their  objectives,  whereby  the 
animal  health  strategy  goal  4  was  to  promote  farming  practices  and  animal  welfare  by 
making a reference to coherence with the Community Action Plan on the Protection and 
Welfare of Animals 2006-2010. 

Contrary to the OCR, the Animal Health Law does not include animal welfare within its 
scope.  Nevertheless,  the  strategy  and  the  AHL  share  similar  objectives,  by  promoting 
animal health and welfare. In its recitals, the AHL makes references to the link between 
animal health and animal welfare and to Article 13 of the TFEU.  

The  majority  of  consulted  stakeholders  perceive  both  the  Animal  Health  Law  and  the 
Official  Controls  Regulation  as  an  important  and  positive  animal  welfare  policy 
development.  While  both  legislative  acts  (OCR  and  AHL)  are  relatively  recent,  the 
coherence  with  the  animal  welfare  strategy  demonstrates  that  coordination  efforts  have 
been successful.    

Common Agricultural Policy and other EU policies  

The CAP provides support for farmers to pursue higher standards through animal welfare 
payments,  funded  under  the  EAFRD  as  part  of  the  CAP  (Pillar  II)68.  These  payments 
cover  the  income  foregone  and  the  costs  incurred  for  carrying  out  animal  welfare 
commitments  that  go  beyond  legal  requirements.  The  EAFRD  includes  also  other 
possibilities  to  support  animal  welfare  objectives,  such  as  investments  in  more  animal 

66    Regulation (EU) 2017/625 of the European Parliament and of the Council of 15 March 2017 on official 
controls and other official activities performed to ensure the application of food and feed law, rules on 
animal health and welfare, plant health and plant protection products, OJ L 95, 7.4.2017, p. 1–142 

67    Regulation  (EU)  2016/429  of  the  European  Parliament  and  of  the  Council  of  9  March  2016  on 
transmissible  animal  diseases  and  amending  and  repealing  certain  acts  in  the  area  of  animal  health 
(‘Animal Health Law’), OJ L 84, 31.3.2016, p. 1–208 

68   https://www.europarl.europa.eu/factsheets/en/sheet/110/second-pillar-of-the-cap-rural-development-

policy  

32 

 
                                                           
welfare  friendly  stables,  training  and  advice,  quality  schemes,  organic  farming  and 
support  for  innovation  through  the  European  Innovation  Partnership  for  Agricultural 
Productivity  and  Sustainability.  Farmers  can  receive  such  support  only  if  the  Member 
State  or  the  region  where  they  operate  has  incorporated  the  payments  in  their  Rural 
Development Programmes (RDPs).  

On  the  other  hand,  improving  farmers'  awareness  is  largely  done  through  cross-
compliance  under  Pillar  I  of  the  CAP,  which  is  financed  by  the  European  Agricultural 
Guarantee  Fund  (EAGF).  These  requirements  encompass  several  areas  concerning  the 
environment,  climate  change,  good  agricultural  and  environmental  condition  of  land, 
public health, animal health, plant health and animal welfare. 

Commission  Services  maintained  regular  exchanges  of  information  aiming  at  ensuring 
coordination in the area of animal welfare during the strategy period. However, there is 
limited  evidence  that  these  led  to  new  or  increased  synergies  with  the  CAP.  This 
cooperation will further improve and it would potentially lead to some new synergies as a 
result of the new CAP proposal of 2018, which explicitly recognises and includes animal 
welfare  together  with  animal  and  human  health  as  part  of  its  Specific  Objective  9  “to 
improve  the  response  of  EU  agriculture  to  societal  demands  on  food  and  health, 
including  safe, nutritious and sustainable food,  reducing  food  waste,  as  well as animal 
welfare”. 

There  are  other  EU  policies  that  impact  on  the  welfare  of  farmed  animals.    For  that 
reason,  there  were  well-established  processes  and  procedures  in  place  to  ensure 
coherence with other EU-level policies, such as the joint organisation of events, regular 
communication  on  animal  welfare,  and  collaboration  on  projects  during  the  strategy 
period.  For  example,  DG  SANTE  collaborated  with  other  DGs  on  animal  welfare 
activities  in  third  countries  through  technical  assistance  instruments  with  DG  NEAR69, 
cooperation  and  stakeholders’  forums  with  DG  AGRI70,  and  development  cooperation 
projects with DG DEVCO71.  

The  strategy  was  coherent  with  EU  policies  for  research  and  food  and  feed  safety. 
Coordination  with  research  policy  was  achieved  by  research  projects  funded  in  the  EU 
Framework  Programmes  for  Research  and  Technological  Development  that  focused  on 
animal welfare activities. For example, under FP7, the Animal Welfare Indicators Project 
(AWIN72)created science-based animal welfare indicators based on pain assessment and 

69   Study on animal welfare international activities (see section 4.3. TAIEX):  “Between 2004 and 2015, 

TAIEX funded over 60 workshops on animal welfare.” 

70   https://ec.europa.eu/info/food-farming-fisheries/key-policies/committees-and-advisory-councils/civil-

dialogue-groups/animal-products_en  

71   Study on animal  welfare international activities (see section 4.5 Development Cooperation Projects): 

“Animal welfare was included in over 30 development cooperation projects by DG DEVCO.”  

72   https://cordis.europa.eu/project/id/266213 

33 

 
                                                           
pain  recognition  for  individual  animals;  EconWelfare73  promoted  insight  on  the  impact 
for the animal, the production chain and society of upgrading animal welfare standards; 
and AWARE74 sought to improve the integration of farm  animal welfare research in an 
enlarged Europe. 

The European Food Safety Authority (EFSA) was mandated to provide scientific advice 
on farm animal welfare, which created synergies between the strategy and the EU-level 
policies  on  food  and  feed  safety.  EFSA’s  panel  on  animal  health  and  welfare  also 
examined  a  diversity  of  issues  that  affected  the  welfare  of  animals,  including  nutrition 
and  feeding  that  impacted  on  the  Commission’s  science-based  approach  to  animal 
welfare. For instance, the use of outcome-based animal welfare indicators in the strategy 
took into account EFSA’s Scientific Opinions.  

The  creation  of  EU  Reference  Centres  for  Animal  Welfare  (EURCAWs)75  under  the 
strategy was also designed with an aim to complement the role of EFSA and the EU Joint 
Research Centre  and not  to  overlap with  their activities. These Centres aim  to  improve 
the  enforcement  of  animal  welfare  legislation,  and  provide  technical  support  and 
coordinated  assistance  to  EU  countries  in  carrying  out  official  controls  in  the  area  of 
animal welfare. The first one was created in 201876 and the second one in 201977. 

The  strategy  was  moderately  coherent  with  the  EU  single  market78,  sustainability  and 
environmental policies. Concerning the single market, there is still no harmonised system 
at EU-level for marketing and labelling of animal welfare standards. 

Under  the  Farm  to  Fork  strategy,  the  possibility  to  introduce/use  EU-wide  labelling 
schemes  for  animal  welfare  will  be  considered.  For  this  purpose,  the  Commission  will 
conduct  an  external  study  foreseen  to  start  first  half  2021.  In  parallel,  the  Commission 
has  established  a  sub-group  on  animal  welfare  labelling  under  the EU  Platform  on 
Animal Welfare which will assist the Commission in its related work.  

The coherence between the strategy and the need for more sustainable food production is 
expected to be strengthened with the Farm to Fork strategy, as the latter makes explicit 
reference  to  the  integration  of  animal  welfare  and  sustainability  policy.  This  issue  has 

73   https://cordis.europa.eu/project/id/213095 

74   https://cordis.europa.eu/project/id/265686 

75   https://ec.europa.eu/food/animals/welfare/eu-ref-centre_en  

76   Commission Implementing Regulation (EU) 2018/329 of 5 March 2018 designating a European Union 

Reference Centre for Animal Welfare 

77   Commission  Implementing  Regulation  (EU)  2019/1685  of  4  October  2019  designating  a  European 

Union Reference Centre for Animal Welfare for poultry and other small farmed animals 

78   Half  of  the  survey  respondents  (50%  of  n=87)  agreed  that  the  Strategy  was  moderately  or  quite 

coordinated and complementary with the Strategy and EU’s single market policies 

34 

 
                                                           
 
been  mentioned  in  the  roadmap  of  the  ongoing  fitness  check79  of  animal  welfare 
legislation, and will be further explored in that context.  

Concerning  environmental  policy,  some  areas  under  the  strategy  demonstrate  limited 
levels  of  coherence.  For  example,  the  laying  hen  practices  enforced  under  the  strategy 
required  alternative  caging  systems  for  laying  hens80,  which  have  higher  ammonia 
emissions and carbon footprints than traditional systems81.  

There  were  also  some  shortcomings  in  terms  of  coherence  between  the  strategy  and 
international  trade, transport, and fisheries policy. The issue of coherence with the trade 
policy  has  been  addressed  by  consistently  including  commitments  on  animal  welfare 
cooperation in Free Trade Agreements to which the strategy had also contributed.  

While  some  progress  was  made  on  animal  transport  (through,  for  instance,  the  animal 
welfare transport guidelines), evidence shows that there was a lack of coherence between 
animal welfare policy and transport in terms of implementation and enforcement of rules 
covering temperatures and journey times82.  

5.2.3 External coherence with national policies 

The strategy achieved coherence with interventions in Member States. More than half of 
EU  Member  States  directly  transposed  the  Directives  on  the  protection  of  animals  into 
their national  legislation. Member States, such as Denmark, the  Netherlands, Germany, 
and Sweden, had more  ambitious animal  welfare interventions than the strategy, which 
are considered to be consistent with the strategy.83  

Coherence was also achieved with EU-level interventions for Member States. Evidence 
gathered from the review of several reports of projects relevant to animal welfare funded 
under  the  European  Network  for  Rural  Development  suggests  that  coherence  has  been 
training, 
achieved  between  animal  welfare, 
environment, economics, and animal health. 

technological  and  farm  upgrades, 

The  identified  lack  of  coherence  between  the  EU  and  national  policies  in  some  cases 
were associated with the different sets of national rules and policies, cultural traditions, 
challenges faced by new Member States in adopting animal welfare legislation, as well as 
lack  of  resources  to  work  on  animal  welfare.  The  presence  of  public-private  initiatives 
also  seem  to  have  shaped  the  extent  to  which  synergies  were  achieved.  The  level  of 

79   The  Fitness  Check  roadmap  specifies:  ‘stricter  animal  welfare  policy  standards  are  among  the 
sustainable agricultural practices necessary to achieve the objectives of the Farm to Fork Strategy’.  

80   Article 4 of Directive 1999/74/EC 

81   Environmental impacts and sustainability of egg production systems, Xin et al. 2011 

82   See section 4.2.3 of the Study. 

83  

I.e. Austria will phase out farrowing crates by 2033 (Animal Protection Index 2012a), and Germany has national rules that are 
stricter and more detailed than the Strategy (Miele et al. 2015). 

35 

 
                                                           
coherence  between  the  strategy  and  national  interventions  therefore  varied  by  Member 
State. 

5.2.4 External coherence with non-EU interventions 

The  strategy  was  coherent  with  non-EU  level  interventions  with  common  objectives, 
recognising the importance of science underpinning standards for animal welfare.  

The OIE and the strategy  had objectives that were coherent  and complementary. OIE’s 
Global strategy on animal welfare, like the EU strategy on animal welfare, promote the 
implementation  of  OIE  international  animal  welfare  standards,  capacity-building  and 
education, communication with stakeholders, and the implementation of animal welfare 
standards and policies. Some regional OIE activities like for example the OIE Platform 
on animal welfare for Europe84 has also shared common objectives with the strategy for 
improving animal welfare and identified the need for raising awareness. The EU remains 
the  main  donor  of  the  OIE  Platform  on  animal  welfare  for  Europe85  and  other  OIE 
initiatives on animal welfare at regional and global level. 

Synergies  were  also  achieved  with  FAO’s  work  through  the  EU’s  contribution  to  the 
Gateway to Farm Animal Welfare86. The Commission was a key strategic partner to the 
FAO ‘Gateway’ and provided links to diverse resources on animal welfare for farm and 
working animals.  

Finally,  the  strategy  contributed  to  improving  coherence  in  relation  to  some  trade 
agreements.  Provisions  to  strengthen  cooperation  on  animal  welfare  were  included  in 
trade  agreements  with  third  countries,  such  as  the  trade  agreement  signed  between  the 
EU  and  Mercosur  states87  -  Argentina,  Brazil  Paraguay  and  Uruguay.  This  has  been 
explored under the relevant the case studies available in Annex 9 of the study report.  

5.3 EFFECTIVENESS  

The  analysis  of  effectiveness  focusses  on  how  successful  the  strategy  has  been  in 
achieving  or  progressing  towards  its  objectives.  For  objectives  that  were  only  partially 
met, the assessment reveals the extent to which progress has fall short and why they have 
not  been  achieved.  The  following  evaluation  questions  were  used  to  guide  such 
assessment: 

  To what extent has the strategy contributed to a more comprehensive and uniform 

protection of animals across species in the EU? 

84     https://rpawe.oie.int/  

85  Evaluation  Report  of 

the  OIE  Platform  on  Animal  Welfare  for  Europe  on  June  2019: 

https://rpawe.oie.int/fileadmin/upload-activities/governance/final_report_-_oie_awp_evaluation.pdf 

86   http://www.fao.org/ag/againfo/themes/animal-welfare/aw-abthegat/en/ 

87   https://ec.europa.eu/trade/policy/in-focus/eu-mercosur-association-agreement/ 

36 

 
                                                           
  To what extent has the strategy contributed to improvements in the enforcement 
of  and  compliance  with  EU  law  at  national  level  (including  compliance  risk 
areas)? 

  To what extent has the strategy contributed to the functioning of the EU market 

and a level playing field in the EU and at global level?  

  To  what  extent  has  the  strategy  improved  awareness  about  animal  welfare 
amongst animal owners/handlers, consumers and the general public (e.g. the link 
with the sustainable production methods)? 

  To what extent has the EU strategy produced knowledge and evidence which, in 

turn, contributed to policy and decision-making?  

  To  what  extent  has  the  strategy  contributed  to  the  EU’s  influence  on  animal 
welfare  standards,  policies  and  practices  at  global  level  and  in  relevant  Third 
countries?  

  To  what  extent  has the  strategy  contributed  to  Member  States’  improved  use  of 

the CAP to comply with EU rules and go beyond? 
  To what extent have the 20 actions been achieved? 
  Regarding  the  objectives  partially  met  or  unmet,  which  factors  hindered  the 

achievement of the objectives? 

Main findings:  

The strategy was overall effective as an initiative that set common goals and helped 
to improve key issues on animal welfare at EU level.  

All  strategy  actions  were  implemented  except  one  (i.e.  a  simplified  EU  legislative 
framework).  Although  progress  has  been  made  on  all  objectives,  there  were  different 
levels of success. However, none of them has been fully achieved. There is a complex 
set  of  internal  factors  (e.g.  delivery  model,  resources,  political  agenda  etc.)  and 
external  factors  (e.g.  differences  across  MS,  stakeholders  support,  differences  in 
interpreting the legislation etc.) that contributed to this.  

Overall, the strategy actions on enforcement and guidelines were the most effective 
ones.  The  strategy’s  main  contribution  is  associated  with  the  enforcement  of  the 
prohibition of non-enriched cage systems for hens and the group housing of sows.  The 
strategy has contributed to a medium extent to the protection of chickens kept for 
meat  production,  protection  of  animals  during  transport  and  slaughter,  and 
indirectly  to  protection  of  animals  kept  for  farming  purposes.    Commission  audits 
revealed the use of risk-based systems  for selecting sites for inspection  and continuous 
efforts to address non-compliance. 

Despite  some  improvements  the  analysis  identified  some  remaining  compliance  risks 
related  to  animal  transport  and  the  welfare  of  pigs.  More  concretely,  compliance 
challenges on transport are associated with long journeys, especially those to third 
countries  in  combination  with  issues  related  to  high  summer  temperatures.  In  the 

37 

 
area  of  pig  welfare,  the  main  challenge  remains  the  largely  practiced  routine  pig’s 
tail docking.   

Stakeholders  see  the  strategy  as  playing  a  key  role  influencing  the  creation  of  the 
EU Animal Welfare Platform. The EU Platform further contributed to some of the 
actions  and  objectives  of  the  strategy  in  terms  of  improving  dialogue  with 
stakeholders,  sharing  knowledge,  exchanges  of  best  practices  and  development  of 
guidance.   

The strategy did not contribute to extending protection of animals to species which 
were not previously protected, nor did it contribute to the development of common 
requirements  for  competence  of  personnel  handling  animals  which  were 
components of the simplified framework. 

At  a  global  level,  the  strategy  contributed  to  some  extent  towards  a  global  level 
playing  field  through  its  international  activities.  The  strategy  further  contributed  to 
promoting animal welfare in international fora and establishing synergies with the 
other international organisations active on animal welfare like OIE, FAO and other.  

Overall,  the  awareness  of  animal  welfare  among  industry  stakeholders  has 
improved since 2012.  

Actions to improve awareness of consumers and the public through communication 
and education were not so effective mainly because they were not pursued further on 
and there were no follow-up actions and dissemination activities.  

The strategy played a limited role for improving synergies with the CAP and in particular 
for  encouraging  Member  States  to  make  better  use  of  the  possibilities  offered  by  the 
EAFRD to support animal welfare measures through their RDPs.   

Certain  actions  and  objectives  such  as  those  targeting  international  cooperation, 
increased synergies with CAP, and the feasibility of an EU legislative framework - 
were not specific enough. This was a key factor to limit their impact.  

The strategy lacked a monitoring mechanism to effectively measure the progress or the 
impact of its activities. 

Some internal factors such as changes in political agenda and insufficient resourcing led 
to delays in the implementation of the strategy.  

In  the  absence  of  quantitative  data  to  assess  the  extent  to  which  the  strategy  has  been 
successful in achieving the set objectives, the effectiveness analysis is mainly based on a 
qualitative analysis.  

5.3.1  Comprehensive  and  uniform  protection  of  animals  (simplified 

legislative framework) 

38 

 
The  strategy  contributed  to  a  limited  extent  to  a  uniform  level  of  protection  of  species 
already included in the legislation.   

While  a  simplified  legislative  framework  has  not  been  developed  under  the  strategy, 
some of the key components relating to such objective have been implemented by means 
of different actions, as described below. 

More uniform level of protection of different species 

As mentioned, the strategy partially delivered on the outputs that were planned in relation 
to  this  objective.  These  outputs  are  mainly  associated  with  the  establishment  of  EU 
Reference  Centres  for  animal  welfare  (EURCAWs),  the  EU  Animal  Welfare  Platform 
and the production of guidelines.  

While there is evidence of knowledge shared among stakeholders in the Platform across a 
range  of  issues,  there  is  no  evidence  yet,  that  these  have  led  to  a  simplification  of 
requirements or a more uniform level of protection across species.  The contribution of 
the outputs described above to achieving a more uniform protection of species has been 
small. 

Overall, there is little evidence that these outputs contributed to a more uniform level of 
protection of different species, due to a low level of progress and the delays incurred.  

Common requirements for competence of personnel handling animals 

This  output  was  linked  to  the  notion  of  including  common  requirements  for  the  new 
potential  new  legislative  framework.  As  the  action  to  consider  the  feasibility  of  a 
simplified legislative framework was  not  implemented, common requirements  were not 
introduced. 

Reference centres  

The concept for developing a network of reference centres existed before the strategy8889 
and it was included in the strategy document as an element which would contribute to a 
possible  simplification  of  the  existing  legal  framework.  The  obligation  to  establish 
reference centres on animal welfare derives from the Official Controls Regulation90.  

The first EU reference centre on animal welfare of pigs91 was set up in March 2018 and 
started its activities in October 2018. A year later in 2019, the Commission designated a 

88   Options  for  animal  welfare  labelling  and  the  establishment  of  a  European  Network  of  Reference 

Centres for the protection and welfare of animals. COM (2009) 584 final 

89   http://www.euwelnet.eu/media/1138/excecutive_summary_final_english.pdf  

90   Article 95 of Regulation (EU) 2017/625 of the European Parliament and of the Council of 15 March 
2017 on official controls and other official activities performed to ensure the application of food and 
feed law, rules on animal health and welfare, plant health and plant protection products 

91      Commission Implementing Regulation (EU) 2018/329 

39 

 
                                                           
second  reference  centre  dedicated  to  the  welfare  of  poultry  and  other  small-farmed 
animals92. In June 2020, the Commissioner announced a plan for designation of a third 
EU reference centre dedicated to the welfare of ruminants and equids in 2021.  

EU  Reference  Centres  on  animal  welfare  aim  at  improving  the  enforcement  of  the 
legislation,  providing  technical  support  and  coordinated  assistance  to  EU  countries  in 
carrying out  official controls  in the field  of animal  welfare. They also  contribute to  the 
dissemination of good practices on animal welfare in the EU. In particular, by providing 
scientific  and  technical  expertise,  carrying  out  studies  and  developing  methods  for 
improving and assessing the welfare level of animals. Today, the role of these centres is 
largely  perceived  as  very  positive  by  all  by  Member  State  representatives,  experts  and 
EU  bodies  and  institutions.  However,  it  is  still  too  early  to  measure  their  impact, 
considering that they have been designated recently. 

Scientific Indicators  

Overall, the strategy contributed to a small extent to the use and delivery of indicators. 
Collected evidence suggest that indicators are being used in an ad hoc manner by some 
stakeholders. The reason is often associated with the fact that only the broilers Directive 
has indicators embedded as of today.  

Another  indication  of  progress  is  the  2017  Official  Controls  Regulation  (OCR).  It 
provided  the  Commission  with  the  power  to  design  and/or  use  indicators  ‘based  on 
measurable  performance  criteria’  to  verify  compliance  with  legislation.  Such  indicators 
had not been adopted yet under Regulation (EC) No 882/2004. Many respondents agree 
that the scientific indicators are useful, but they should be used better by integrating them 
into existing legislation. Others think that a systematic, centralised database of indicators 
is required to be truly useful in measuring animal welfare in the EU.  

The OCR provides an excellent opportunity to  expand future work on the development 
and  use  of  indicators.  At  present,  the  Commission  is  working  on  a  2-years  project  to 
assess whether Member States have a strategic approach to use animal welfare indicators 
to measure the severity, extent and permanence of animal welfare problems and to target 
its  controls  accordingly.  The  main  output  of  this  project  will  be  an  overview  report, 
planned to be released in the first quarter of 2021. This report is expected to support the 
future work of the Commission in this direction. 

5.3.2 Enforcement and compliance  

Enforcement  actions  contributed  to  a  medium  extent  to  improving  enforcement  and 
compliance at a Member State level. 

The strategy identified the uneven enforcement of EU legislation on animal welfare and 
insufficient  incentives  for  the  industry  to  comply  with  regulations  as  key  issues.  To 

92      Commission Implementing Regulation (EU) 2019/1685 

40 

 
                                                           
address  them,  the  strategy  included  actions  to  support  Member  States  in  improving 
enforcement and compliance.  

A  majority  of  surveyed  Member  State  representatives  agreed  (18  of  26),  or  strongly 
agreed (4 of 26), that the strategy helped to improve enforcement at a national level and 
contributed to improving animal welfare in the EU. 

A  questionnaire  developed  by  the  Finnish  Presidency  in  201993  highlighted  that 
enforcement  methods  used  by  the  strategy,  such  as  national  controls  (88%),  national 
(76%) and EU audits (80%), national training (84%), BTSF training (76%) and National 
Contact  Points  (76%),  were  considered  by  CVOs  to  be  very  effective/effective  tools. 
However,  none  of  the  NGOs  believed  that  there  had  been  great  or  significant 
improvements since 2012 in compliance with the EU legislation. 

With  regards  to  the  protection  of  pigs94  back  in  2012  the  main  issue  in  terms  of 
compliance was with the pregnant sows. With an effect from 1 January 2013, they had to 
be kept in groups instead of individual stalls during part of their pregnancy95. One of the 
main contributions of the strategy are associated with improvements in the group housing 
of sows. More concretely, as part of the enforcement actions, infringement proceedings 
were  launched  against  13  Member  States  for  non-compliance  with  the  requirement  on 
group housing of sows. Furthermore, 18 EU pilot dialogue schemes on laying hens and 
pigs have been launched during the strategy. These actions were effective in increasing 
compliance  as  proved  by  Commission  audit  reports  of  2016.  This  evidence  is  further 
supported by the survey findings where, 13 of 23 Member State representatives reported 
a significant improvement in compliance with this Council Directive. Similarly, 53% of 
respondents  in  the  public  consultation  indicated  that  there  were  improvements  in 
compliance with this Directive.  

Against  this  background,  the  largely  practiced  routine  tail  docking  of  pigs  remains  a 
major  challenge  in  terms  of  compliance,  as  showed  below  (5.3.2.1.  Compliance  risk 
areas).  Council  Directive  2008/120/EC  requires  Member  States  to  ensure  that  tail-
docking is not carried out routinely but only where there is evidence that injuries to sows' 
teats or to other pigs' ears or tails have occurred96. The practice of tail-docking of pigs is 
carried out in the early days of life to prevent tail-biting which has a multifactorial origin. 
That  practice  is  done  without  anaesthesia  by  causing  pain  to  pigs  and  is  therefore 
detrimental  to  their welfare.  Furthermore,  a routine practice of tail-docking is  triggered 

93     https://data.consilium.europa.eu/doc/document/ST-6007-2020-INIT/en/pdf  

94   Council  Directive  2008/120/EC  of  18 December  2008  laying  down  minimum  standards  for  the 

protection of pigs 

95   Article 3(9) of Council Directive 2008/120/EC of 18 December 2008 laying down minimum standards 

for the protection of pigs 

96      Point  8,  Annex  I  to  Council  Directive  2008/120/EC  of  18 December  2008  laying  down  minimum 

standards for the protection of pigs 

41 

 
                                                           
by  frequent  tail  biting  which  itself  reflect  suboptimal  animal  welfare  conditions  in  the 
holding.  

On the issue of pigs’ tail docking, the strategy produced a set of guidelines in 201697. 

The  Commission  audit  reports  carried  out  in  addition  to  the  strategy  showed  some 
evidence of improvement, but the largely practiced routine pigs’ tail docking and the use 
of enrichment materials remain challenging.  

The  strategy  action  to  enforce  the  ban  on  the  use  of  unenriched  cages  from  1  January 
2012  made  a  significant  positive  contribution  described  as  a  “success  story”  to 
improving compliance with the protection of laying hens98. Fourteen audits were carried 
out in relation to the laying hens’ Directive.  Based on the findings from these audits, The 
Commission  launched  infringement  proceedings  against  13  Member  States  for  non-
compliance.  There  were  also  ‘EU  pilot  dialogue  schemes’.  As  a  result,  27  national 
actions from Member States and Norway were undertaken to improve compliance.  

During  the  targeted  survey  16  from  23  Member  State  representatives  reported  a 
significant improvement in compliance with this Directive. The same opinion was shared 
by  50%  of  respondents  to  the  public  consultation  who  reported  that  there  had  been 
improvements in compliance with the laying hens legislation.  

The  strategy  contributed  to  a  medium  extent  to  improve  the  enforcement  of  the 
legislation  protecting  chickens  kept  for  meat  production99  as  shown  below.  Since 
2012, a small number of Member States have started to use broiler welfare indicators to 
adapt  their  strategy  for  enforcement  of  legislation.  Specifically,  Denmark,  the 
Netherlands,  Sweden  and  the  UK  implemented  effective  monitoring  systems  for 
assessing on-farm welfare at slaughter through indicators (such as footpad dermatitis100).  

Although evidence is limited, the strategy had indirect contributions to the enforcement 
of  and  compliance  with  the  legislation  protecting  animals  kept  for  farming 
purposes101. Under the strategy, a report102 was produced on the implementation of such 

97   https://ec.europa.eu/food/animals/welfare/practice/farm/pigs/tail-docking_en 

98   Article 5(2) of Council Directive 1999/74/EC of 19 July 1999 laying down minimum standards for the 

protection of laying hens 

99   Council  Directive  2007/43/EC  of  28  June  2007  laying  down  minimum  rules  for  the  protection  of 

chickens kept for meat production 

100   REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL 
on the application of Directive 2007/43/EC and its influence on the welfare of chickens kept for meat 
production,  as  well  as  the  development  of  welfare  indicators,  COM/2018/0181  final:  https://eur-
lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:52018DC0181  

101   Council  Directive  98/58/EC  of  20  July  1998  concerning  the  protection  of  animals  kept  for  farming 

purposes 

42 

 
                                                           
legislation,  which  highlighted  improvements  in  compliance  in  some  areas.  Namely, 
Commission  audits  found  that  Member  States  such  as  Czech  Republic,  Denmark, 
Hungary,  Netherlands, Spain,  Sweden and the  UK put  in  place a risk-based system for 
inspection and have been continuously concentrating efforts to address non-compliance. 
Although  there  is  little  evidence  to  suggest  the  report  influenced  enforcement  or 
compliance directly, it did highlight the need for stakeholder dialogue.  

The strategy contributed to a medium extent to improving enforcement and compliance 
with the legislation protecting animals during transport103 through actions such as the 
production of guidelines, fact sheets and videos to improve the welfare of cattle, horses, 
pigs,  poultry  and  sheep  during  transport104.  The  study  survey  indicated  that  13  of  23 
Member State representatives reported a significant improvement in compliance with this 
Regulation.  Additionally,  the  outcome  of  the  public  consultation  indicated  that  48%  of 
respondents  believed  that  there  had  been  improvements  in  compliance  with  this 
Regulation.  

A series of actions were developed to improve the enforcement of the regulation on the 
protection of animals at the time of killing105. One such action was the implementing 
plan for the slaughter regulation, which consisted in the development of national action 
plans  detailing  how  the  regulation  would  be  implemented.  On  the  other  hand,  actions 
such  as  production  of  guidelines  had  an  indirect  impact.  In  addition,  compliance 
improvements  with  the  Regulation  were  reported  by  40%  of  respondents  to  the  public 
consultation.  The  Commission’s  audit  overview  report  on  the  animal  welfare  at 
slaughter106  showed  that  the  development  of  Standard  Operating  Procedures  (SOPs) 
based  on  guides  to  good  practice,  the  tailoring  of  official  controls  to  operators’ 
procedures  and  the  implementation  of  good  reporting  systems  were  key  factors  in 
improving compliance of operators with animal welfare standards.  

5.3.2.1 Compliance risk areas 

102   REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL 
on  the  implementation  of  Council  Directive  98/58/EC  concerning  the  protection  of  animals  kept  for 
farming 
(https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX:52016DC0558)  

COM/2016/0558 

purposes, 

final 

103   Council  Regulation  (EC)  No  1/2005  of  22  December  2004  on  the  protection  of  animals  during 

transport 

104   http://www.animaltransportguides.eu/  

105   Council Regulation (EC) No 1099/2009 of 24 September 2009 on the protection of animals at the time 

of killing 

106    http://ec.europa.eu/food/fvo/overview_reports/act_getPDF.cfm?PDF_ID=430  

43 

 
                                                                                                                                                                            
Following  a  recommendation  from  the  ECA107,  the  analysis  focused  on  identifying  the 
remaining compliance risk areas. Based on the evidence collected, the areas where most 
Member States are struggling to comply with the requirements set in the legislation are 
animal  transport,  welfare  of  pigs  (e.g.  routine  pig’s  tail  docking)  and  protection  at 
slaughter.  

Animal transport  

Compliance with the transport regulation has improved, but this remains an area at risk. 
In  the  context  of  a  specific  project,  the  Commission  audited  several  Member  States  on 
the  welfare  of  animals  during  transport  by  road  and  published  an  overview  report108 
concluding that “the official data indicate a very high level of compliance with transport 
rules when vehicles are in EU territory.” 

However, there are still challenging issues associated with long journeys and in particular 
transport  in  extreme  temperatures109  and  exports  to  third  countries.  The  same 
Commission  report  also  points  out  that  “the  main  concerns  for  the  welfare  of  animals 
relate  to  the  non-EU  leg  of  the  journey.  The  available  information  indicates  that  most 
transporters do not meet applicable EU rules after leaving the Union.”  

Other  issues  of  risk  in  terms  of  compliance  include  low  and/or  infrequent  penalties  for 
non-compliance110, transport of unfit animals111, breaches in stocking densities112, and the 
insufficient  provision  of  rest,  feed,  water  and  bedding113.  Transport  was  also  the  main 
area reported as lacking compliance by 54% of respondents to a public consultation, with 
a  few  stakeholders  highlighting  long  journeys  and  transport  to  third  countries,  high 
temperatures,  non-observance  of  space  requirements  and  transport  of  calves  and  adult 
bovines as key issues.  

107   Recommendation 1(b) from  ECA Special report No 31/2018: Animal  welfare in the EU: closing the 

gap between ambitious goals and practical implementation 

108   Commission  Overview 

the  Welfare  of  Animals  Exported  by  Road 
https://ec.europa.eu/food/audits-analysis/overview_reports/act_getPDF.cfm?PDF_ID=1520  

report  on 

(2019): 

109   Chapter VI, Annex I to Council Regulation (EC) No 1/2005 of 22 December 2004 on the protection of 

animals during transport  

110   Article 25 of Council Regulation (EC) No 1/2005 of 22 December 2004 on the protection of animals 

during transport  

111   Chapter I, Annex I to Council Regulation (EC) No 1/2005 of 22 December 2004 on the protection of 

animals during transport  

112   Chapter VII, Annex I to Council Regulation (EC) No 1/2005 of 22 December 2004 on the protection 

of animals during transport  

113   Chapter V, Annex I to Council Regulation (EC) No 1/2005 of 22 December 2004 on the protection of 

animals during transport  

44 

 
                                                           
As regards the transport by sea, another Commission audit overview report114 highlights 
insufficient  Member  States  systems  in  place  to  approve  livestock  vessels  with  the 
exception of Ireland and Portugal. As main reasons are mentioned the staff qualifications, 
technical experience and lack of resources to carry out all the necessary specific tasks. 

Welfare of pigs  

Compliance with the Directive on the protection of pigs is another important risk area, 
particularly regarding pig’s tail docking. According to the data collected by DG SANTE, 
tail-docking  of  pigs  is  a  routine  practice  in  26  out  of  28  Member  States  and 
approximately 150 million  pigs  annually are subject  to  this practice.  Commission  audit 
reports  into  several  of  the  big  pig’s  producing  Member  States  highlight  that  although 
actions  have  been  taken  they  have  not  yet  resulted  in  better  compliance  with  the 
provisions  of  the  Pig  Directive  which  prohibit    routine  tail  docking  in  pigs.  With  the 
exception of a few Member States, such as Finland and Sweden, most EU Member States 
did not comply with the ban  or with providing adequate enrichments materials (such as 
rope, fresh wood, branches and straw);115.  

Protection at slaughter  

Audits  across  Member  States  have  also  found  compliance  risk  areas  for  the  Slaughter 
Regulation. In particular, 43% of respondents to the public consultation and 11 out of 15 
NGOs surveyed indicated lack of compliance with this regulation. One of the particular 
areas identified during Commission  audits of 13  Member States116 was non-compliance 
with  the  adequate  procedures  and  with  the  non-applying  the  required  parameters  for 
electrical  waterbath  stunning  of  poultry  (widely  used  method  to  render  poultry 
unconscious). Such issues were also emphasised in interviews with NGOs regarding use 
of  electrical  waterbaths  and  stunning  of  pigs  using  CO2.  Additional  risk areas  included 
shortcomings  in  official  controls  given  the  prevalence  of  ‘traditional’  inspection 
procedures, use of generic SOPs and general risk factors rather than targeted controls on 
specific  slaughter  processes,  issues  in  small  to  medium  size  establishments  in  terms  of 
lack of registers of animal welfare officers' activities and non-compliance regarding new 
equipment  due  to  costs.  In  addition,  the  same  Commission  overview  report  also 
highlights  wide  variations  between  Member  States  on  applying  the  derogation  for 
slaughter without stunning.  

Welfare of broilers  

114  Commission  Overview 

report  on 

the  welfare  of  animals 

transported  by  sea 

(2020): 

https://ec.europa.eu/food/audits-analysis/overview_reports/act_getPDF.cfm?PDF_ID=1543 

115 “Efforts to Ban the Routine Tail Docking of Pigs and to Give Pigs Enrichment Materials via EU Law: 

Where do We Stand a Quarter of a Century on?” Elena Nalon and Nancy De Briyne  

116  Commission  Overview  report  on  Animal  welfare  at  slaughter 

in  Member  States  (2015): 

http://ec.europa.eu/food/fvo/overview_reports/act_getPDF.cfm?PDF_ID=430 

45 

 
                                                           
Regarding broiler welfare, there is considerable variation across Member States on the 
effectiveness  of  systems  used  to  detect  poor  broiler  welfare  at  slaughterhouse  level. 
Sweden, Denmark, the Netherlands and the UK have used this indicator in practice and 
used in addition a scoring system introduced for a first time in Sweden117. Eleven other 
Member  States  who  do  not  have  such  a  scoring  system  carried  out  post  mortem 
inspections, but do not systematically make use of this data to prioritise and better target 
their farm inspections.  

As mentioned earlier in 2019, the Commission launched a two years project dedicated to 
animal welfare indicators.  The scope of the project targets farming of pigs and broilers, 
and other livestock sectors where Member State authorities can provide information  on 
effective use of animal welfare indicators. 

Official controls at farm level  

Member  States  carry  out  official  controls  procedures  of  farms  to  ensure  those  are 
compliant  with  existing  animal  welfare  legislation.  The  ECA  report  of  2018  identified 
some examples of good coordination between national authorities and the Commission at 
a national level in France, and at a regional level in Germany (North-Rhine Westphalia) 
and  Italy  (Sardinia).  However,  a  few  issues  were  reported  in  some  Member  States, 
including  a  lack  of  appropriate  enforcement  actions  and  a  reduction  in  on-site  official 
controls  at  farms  due  to  limited  resources  (e.g.  reduced  number  of  veterinary  staff 
available  to  perform  inspections)  (Broom,  2017;  ECA,  2018;  Commission  audits  of 
2018).  

External factors  

Compliance  risk  areas  and  enforcement  efforts  vary  across  Member  States.  There  are 
multiple factors contributing, such as different production systems used, types of animals 
farmed, levels of access to technology and funds, and different policy landscapes, as well 
as control resources and the way in which national authorities organise the enforcement 
and monitoring of legislation. This variation can be problematic, particularly in terms of 
comparing  results  of  national  inspections  and  establishing  a  harmonised  approach  to 
animal welfare (Bock et al., 2014). 

An  additional  factor  hindering  the  enforcement  was  the  absence  of  details  on  certain 
aspects  of  the  EU  animal  welfare  legislation.  For  example,  the  Pig  Directive  lacks 
specificity in its guidelines by using open norms such as ‘sufficient’ food, water, nesting 
material and space. Similar examples could also be taken from the Transport Regulation 
where there are plenty of references to sufficient and appropriate staff, sufficient bedding 
etc.  

117  REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL 
on the application of Directive 2007/43/EC and its influence on the welfare of chickens kept for meat 
production, as well as the development of welfare indicators COM/2018/0181 final 

46 

 
                                                           
 
5.3.3 Functioning of the EU market and a level playing field in the EU  

According  to  the  evidence  collected  under  the  study,  the  strategy  contributed  to  a 
medium extent towards an EU level playing field. The uneven EU level playing field was 
identified  as  a  problem  due  to  the  uneven  levels  of  enforcement  and  compliance  with 
animal  welfare  legislation  across  Member  States.  In  this  context,  the  strategy’s 
contribution  was  associated  with  the  facilitation  of  compliance  and  enforcement  of 
animal  welfare  legislation  across  Member  States  through  audits,  enforcement  actions, 
infringement  proceedings and capacity building initiatives such as training programmes 
and the production of guidelines.   

Case study 03 (see Annex 9 to the study report) investigated this further and explored the 
extent to which the strategy contributed to a level playing field at an EU and global level 
for  broiler  welfare  standards.  The  case  study  found  that,  at  an  EU  level,  the  strategy 
influenced  compliance  with  the  broiler  directive.  While  challenges  remain,  improved 
uniform  enforcement  of  standards  across  Member  States  contributed  to  open  and  fair 
competition. 

The  strategy  identified  the  lack  of  an  EU  level  playing  field  as  a  problem  due  to  the 
uneven  levels  of  enforcement  and  compliance  with  animal  welfare  legislation  across 
Member States. While it was not one of the six primary objectives, it was included in the 
strategy  as  an  indirect  impact  of  the  actions  and  activities  designed  to  improve 
enforcement and compliance.  

One  of  the  strategy’s  main  contributions  is  associated  with  the  improved  enforcement 
and  compliance  of  Member  States  across  several  areas  of  legislation,  as  presented  in 
5.3.2 Enforcement and compliance. The enforcement actions regarding laying hens and 
grouping  of  sows  were  highly  effective  and  led  to  greater  enforcement  of  the  two 
Directives across Member States.  

5.3.4 Level playing field at global level  

At a global level, the strategy contributed to a global level playing field through bilateral 
and  multilateral  cooperation  activities,  trade  agreements,  trainings,  technical  assistance 
and informal agreements between the EU and third countries.  

Over  the  years,  the  Commission  invested  significant  resources  to  animal  welfare 
international activities (see 5.4 Effectiveness and Annex 5: Overview of costs – benefits). 
These activities are a long-term investment, based on three subsequent steps: awareness 
raising,  capacity  building  and  funding.  The  Commission,  with  the  EU  Member  States, 
has played a prominent and decisive role in raising global awareness on animal welfare 
and  tangible  results  have  been  achieved118.  Since  the  strategy  was  launched,  the 
Commission  included  provisions  on  animal  welfare  in  the  following  trade  agreements: 

118 https://ec.europa.eu/food/sites/food/files/animals/docs/aw_international_publication-report_en.pdf  

47 

 
                                                           
EU-Canada CETA (2017); EU-Japan JEEPA (2019); EU-Mercosur (2019; agreement in 
principle); and EU-Mexico (2020).  

An  area  where  the  EU  had  a  strong  influence  relevant  to  animal  welfare  was  on 
slaughter,  as  EU  legislation  contributed  to  changing  the  methods  used  in  third  country 
slaughterhouses (Broom 2017). 

In support to this evidence, the majority of public consultation respondents agreed with 
the statement that the strategy contributed to a more level playing field for EU businesses 
at  an  EU  and  global  level  (61%  of  respondents  agreed  that  it  had  contributed  to  some 
extent, and 13% agreed to a significant or great extent). Similarly, the majority (68%) of 
survey respondents from EU businesses and trade associations stated that the strategy had 
contributed to addressing the lack of a global level playing field. 

The  study  analysis  points  at  the  willingness  of  third  countries  to  proceed  further  on 
animal  welfare  and  the  limited  influence  of  the  Commission  on  them.  International 
activities  require  much  longer  time,  vision  and  investment  than  the  duration  of  the 
strategy.  These  activities  had  overall  positive  impact  to  improving  the  awareness  on 
animal welfare at global level. 

5.3.5 Improving awareness about animal welfare  

Under the strategy, guidelines and studies have been developed, targeting animal owners, 
handlers,  consumers  and  the  public.  Due  to  the  different  approaches/tools  used  (e.g. 
guides, reports, factsheets, videos etc.) to improve awareness among the target audiences, 
the evidence collected varied. The guidelines produced for animal owners and handlers 
were  generally  well-received  and  most  stakeholders  demonstrated  tangible  familiarity 
with them. However, it was not possible to assess in detail their impact due to a lack of 
data on the uptake of the guidelines. 

The studies relating to animal welfare information for consumers did not include specific 
communication or educational activities to increase consumer awareness,  which limited 
the strategy’s impact in this area.  

Animal owners/handlers 

Overall,  stakeholders  consider  guidelines  as  a  useful  output  for  improving  awareness 
among animal owners and handlers. The guidelines included helpful information such as 
handbooks, factsheets, best practice documents  and educational videos that was easy to 
follow  and  was  appropriate  for  their  target  audiences.  There  were  separate  outputs 
targeting three areas of legislation:  

  Council Directive 2008/120/EC on the protection of pigs119;  

119 https://ec.europa.eu/food/animals/welfare/practice/farm/pigs/tail-docking_en 

48 

 
                                                           
  Council  Regulation  (EC)  No  1099/2009  on  the  protection  of  animals  at 

slaughter120121;  

  Council Regulation EC 1/2005 on the protection of animals during transport122.  

Compliance  with  this  legislation  and  awareness  of  the  animal  welfare  requirements 
among animal owners is perceived to have improved since 2012, but views on the extent 
to which the strategy has contributed to this are mixed. This is demonstrated by the lack 
of  consensus  in  the  public  consultation  where  40%  of  respondents123  considered  the 
strategy to have had little to no contribution to improving awareness, but 30% thought it 
had  a  great  or  fairly  significant  contribution  and  almost  a  quarter  (24%)  expressed  no 
strong opinion either way. Contrasting opinions are also seen in the survey, where 62% 
of  Member  State  representatives  agreed  that  the  strategy  had  helped  to  improve 
compliance among animal handlers and owners in their country compared to only three 
of 15 NGOs. Businesses and business/trade associations did not express especially strong 
opinions on the subject.  

Familiarity with the guidelines produced as part of the strategy among stakeholders was 
good,  evidenced  by  the  survey  and  public  consultation.  In  the  survey,  the  majority  of 
businesses and business/trade associations who were familiar with the strategy said they 
were  quite  or  very  familiar  with  the  guidelines  (83%)  and  all  eight  professional 
associations  said  their  profession  had  engaged  with  one  or  more  of  the  guidelines 
produced to at least a moderate extent. The public consultation indicates that familiarity 
with the guidelines is especially high in Belgium (76% of stakeholders extremely or very 
familiar) and lowest in Spain (38% of stakeholders extremely or very familiar).  

In  particular,  the  animal  transport  guide  received  praise  for  being  well-written,  simple 
and for containing practical  information  that supported compliant behaviour among the 
target  audience,  particularly  as  industry  had  been  directly  involved  in  producing  them. 
These  guides  have  also  been  translated  into  languages  not  foreseen  within  the  original 
project, including Bulgarian, Czech and Croatian. The OIE sponsored the translation of 
the  factsheets  on  transport  into  Russian  and  have  popularised  them  in  the  context  of 
different  activities  under  the  OIE  Platform  on  animal  welfare  for  Europe,  further 
illustrating the perceived high quality of these guides. 

Consumers and the public 

The  contribution  of  the  strategy  to  awareness  of  animal  welfare  among  consumers  and 
the  public  was  limited.  While  the  two  studies  carried  out  under  the  strategy  (see  5.1.2. 

120https://op.europa.eu/en/publication-detail/-/publication/ea4ef3e9-cda5-11e7-a5d5-

01aa75ed71a1/language-en 

121 https://ec.europa.eu/food/animals/welfare/practice/slaughter/2018-factsheets_en 

122 http://www.animaltransportguides.eu/ 

123 Out of 3,375 respondents who contributed to the public consultation 

49 

 
                                                           
Relevance) indicate a lack of information for most consumers on animal welfare and an 
increasing interest to receive information on this matter, the Commission did not take any 
follow  up  action  that  could  make  the  studies  useful  for  addressing  the  objective.  This 
limited impact is broadly reflected in stakeholders’ opinions. In the public consultation, 
more  than  half  (57%)  considered  the  strategy  has  made  either  no  contribution  or  only 
some contribution to improving consumer information.  

5.3.6 Knowledge and evidence that contributed to policy and decision-making  

Twelve  strategy  actions  out  of  twenty  were  dedicated  to  producing  reports  and  studies 
contributing to four of the objectives.  

The aim of these studies and reports in the strategy was to produce new knowledge and 
evidence,  which  in  turn  could  contribute  to  policy  and  decision  making.  Evidence 
collected shows that all the outputs were produced, with different levels of quality. Some 
reports and studies contributed to EU-level knowledge on certain animal welfare issues. 
However,  the  lack  of  follow-up  activities  to  disseminate  and  take  into  account  this 
knowledge limited the strategy’s contribution to policy and decision-making.  

A positive contribution under the strategy was in the area of the welfare of farmed fish: 
the  study  and  the  Commission  report  have  increased  knowledge  regarding  fish  welfare 
and provided recommendations for EU policymaking. However, there were no follow-up 
actions taken on the welfare of farmed fish. 

Whilst  Member  State  representatives  felt  that  studies  and  relevant  recommendations 
influenced policy and decision-making to a small extent in Member States124, there is an 
overall lack of evidence with regards to the contribution of the reports and studies to the 
strategy’s  objectives.  This  lack  of  evidence  can  be  attributed  to  the  absence  of  tools  to 
accurately measure any potential contribution. Furthermore, the strategy did not include 
any follow-up to the studies and reports.  

The creation of the EU Platform on animal welfare was not foreseen as an activity of the 
strategy.  Launched  in  2017,  the  Platform  is  now  recognised  as  a  pivotal  forum  for 
Member States and stakeholders to share information and good practices. To support the 
work of the Platform in specific areas, the Commission created thematic subgroups.  

5.3.7 EU’s influence on animal welfare at global level  

The  strategy  had  influence  and  contributed  on  animal  welfare  standards,  policies  and 
practices at global level, as it provided a source of inspiration125 for many third countries.  

More concretely the main contributions are associated with:   

124  Overall,  92%  of  Member  State  representatives  who  responded  to  the  targeted  survey  viewed  the  studies  and  relevant 
recommendations to EU institutions through reports encompassed by the strategy as influencing policy and decision-making in 
Member States. 

125 https://ec.europa.eu/food/sites/food/files/animals/docs/aw_international_publication-report_en.pdf 

50 

 
                                                           
 

Involvement  in  the  OIE  standard  setting  process  (e.g.  by  providing  EU 
coordinated positions);  

  Provision of financial support and co-organisation of OIE training events to raise 

awareness and facilitate the implementation of international standards;  

  Supporting  the  development  and  implementation  of  OIE  regional  strategies  on 

animal welfare. 

The Commission’s coordination with international bodies related to animal welfare was 
strengthened  between  2012  and  2019.  The  strategy  contributed  to  multilateral  and 
bilateral  cooperation  activities  and  events,  and  the  inclusion  of  concrete  provisions  for 
strengthening  the  cooperation  in  the  area  of  animal  welfare  in  bilateral  or  multilateral 
trade agreements. Case study 06 explores this question further.  

The diverse international activities of the strategy contributed to an increased awareness 
and  understanding  of  animal  welfare  issues  by  third  countries  The  challenges  to  the 
inclusion of more specific requirements on animal welfare in trade agreements are linked 
to  the  fact  that  animal  welfare  is  not  explicitly  recognised  under  the  World  Trade 
Organization General Agreement on Tariffs and Trade (GATT) . 

The strategy also supported activities that contributed to the development of third country 
and international standards. The Commission has been very active in particular along the 
whole  process  of  consultation  and  adoption  of  OIE  international  standards  on  animal 
welfare.  The  Commission  also  played  a  key  role  in  the  implementation  of  the  OIE 
standards  on  animal  welfare,  as  it  was  involved  in  the  Steering  Group  of  the  OIE 
Platform  on  animal  welfare  for  Europe  since  its creation  in  2013.  In  2017,  a  milestone 
was achieved when the OIE adopted, with the support of the EU, its first global strategy 
on animal welfare. 

During  the  strategy,  the  Commission  has  also  cooperated  with  FAO  in  organising 
capacity building events126, promoting animal welfare as a public good and a component 
of sustainable production. In addition, the Commission contributed to the development of 
the  FAO  Gateway  to  Farm  Animal  Welfare127,  an  online  platform  allowing  multi-
stakeholder knowledge and exchange.  

In  parallel,  the  strategy  supported  activities  that  contributed  to  creating  the  scientific 
basis for international animal welfare standards and guidelines through tools such as the 
Seventh  Framework  Programme128,  the  Better  Training  for  Safer  Food  programme129, 
and the Technical Assistance and Information Exchange Instrument. 

126   FAO Headquarters, Rome, Sep-Oct 2008, http://www.fao.org/ag/againfo/themes/animal-welfare/ 

127   http://www.fao.org/ag/againfo/themes/animal-welfare/en/ 

128   The Seventh Framework Programme was the main instrument for funding research in Europe between 2007 and 2013.  

51 

 
                                                           
Nowadays, very few stakeholders are fully aware of the whole set of EU animal welfare 
international  activities  carried  out  under  the  strategy.  Following  the  study  report,  this 
might  be  one  of  the  reasons  why  the  respondents  to  the  public  consultation  were  more 
likely to state that the strategy only had some or no contribution to promoting EU animal 
welfare  standards  at  a  global  level  (48%)  than  a  great  or  fairly  significant  contribution 
(25%).  

5.3.8 Member States’ improved use of the CAP to raise awareness on EU rules 
and go beyond  

The  CAP  includes  the  possibility  for  Member  States  to  co-finance  animal  welfare 
measures within their RDPs (i.e. funded under the EAFRD), thereby encouraging farmers 
to  voluntarily  improve  animal  welfare  beyond  the  legal  EU  baseline  through  animal 
welfare payments (see 5.1. Relevance).  

The  strategy  therefore  intended  to  support  uptake  of  this  measure  in  its  objective  to 
optimise synergies with the CAP.   

EAFRD and animal welfare 

The  EAFRD  offered  Member  States  the  possibility  of  co-financing  support  for  animal 
welfare,  via  specific  animal  welfare  payments  or  other  measures  that  could  lead  to 
improvements  in  animal  welfare.  These  specific  animal  welfare  payments  include 
voluntary  management  commitments  going  beyond  the  legally  binding  requirements  or 
commonly  used  agricultural  practices,  which  compensated  farmers  for  additional  costs 
incurred and/or income foregone. The other measures include investments, training and 
advice, organic farming, support for innovation actions (European Innovation Partnership 
for  Agricultural  Productivity  and  Sustainability  (EIP-AGRI)),  quality  schemes,  etc..  In 
order  to  be  used  by  farmers,  the  measures  must  be  included  in  the  national  or  regional 
rural development programme (RDP) for the area in which they are located. As of 2018, 
animal welfare payments were included in 34 of 115 RDPs in 18 Member States. There 
has  been  an  improvement  in  the  uptake  of  “animal  welfare  payments”  insofar  as  more 
Member States included the measure in their 2014-2020 RDPs compared to the previous 
funding period, which ended in 2013 (only 10 Member States at the time).  

Based  on  the  collected  evidence,  it  is  difficult  to  assess  whether/to  what  extent  the 
strategy contributed to these changes.  

Despite the improved uptake in the 2014-2020 RDPs, synergies between animal welfare 
and the CAP remain limited overall during the period considered. It was highlighted that 
the  2014-2020  CAP  funding  period  was  a  missed  opportunity  to  improve  on  animal 

129   Better Training for Safer  Food World has been delivered to non-EU countries through regional workshops in Canada, China, 
Chile, South Korea, Thailand, Brazil, Costa Rica, and Sri Lanka, and sustained training missions in Thailand, Malawi, Lesotho, 
Chile and Brazil 

52 

 
                                                                                                                                                                            
welfare130. This conclusion is also supported by the survey where 38% of Member State 
representatives perceived that the strategy had not contributed to a better use of the CAP 
to improve animal welfare, and a further 35% ‘did not know’. The 2019 survey targeting 
CVOs provided similar results, where 39% considered the measures implemented under 
the EAFRD as being only somewhat effective131.   

Case  Studies  07  and  08  (Annex  8)  suggest  that  there  is  an  increased  likelihood  for 
Member  States  to  include  animal  welfare  measures  as  part  of  their  RDPs  when  animal 
welfare is a more significant national priority.  

Cross-compliance 

Through  cross-compliance,  farmers  are  encouraged  to  raise  CAP  beneficiaries’ 
awareness  on  high  European  Union  standards  for  public,  plant,  and  animal  health  and 
welfare.  The  strategy  had  a  limited  impact  on  the  cross-compliance  systems  as  set  out 
under  the  CAP.  Nevertheless,  cross-compliance  can  provide  for  synergies  and 
consistency  of  the  CAP  with  animal  welfare  standards,  and  make  farmers  aware  of  the 
need to respect these.  

The strategy envisioned establishing “a specific inter-services arrangement to assess how 
to  optimise  synergistic  effects  of  the  current  mechanisms  of  the  CAP  in  particular 
through  cross-compliance  [among  others].”  However,  the  strategy  did  not  lead  to  the 
establishment of such a new mechanism.   

In 2018, the Commission published the legislative proposal132 on the CAP beyond 2020. 
The aim of these proposals was to make the CAP more responsive to current and future 
challenges such as  climate change, while  continuing to  support European farmers for  a 
sustainable agricultural sector. One of the future CAP objectives relates to improving the 
response of EU agriculture to societal demands on food and health and animal welfare. 
The  ongoing  reform  of  the  CAP  maintains  in  the  proposal  that  access  to  funds  is 
conditional upon compliance with legislation on animal welfare. 

5.3.9 Extent to which the objectives of the strategy were achieved 

130   Animal  welfare  in  the  reformed  Common  Agricultural  Policy:  Wherefore  art  thou?  -  Diane  Ryland 

University of Lincoln, UK, 2015 : https://core.ac.uk/download/pdf/29176712.pdf 

131   Outcome  of  the  Finish  Presidency  Questionnaire  Animal  Welfare  -  an  integral  part  of  sustainable 

animal production https://data.consilium.europa.eu/doc/document/ST-6007-2020-INIT/en/pdf 

132   Proposal for a Regulation establishing rules on support for strategic plans to be drawn up by Member 
States  under  the  Common  agricultural  policy  (CAP  Strategic  Plans)  and  financed  by  the  European 
Agricultural Guarantee Fund (EAGF) and by the European Agricultural Fund for Rural Development 
(EAFRD)  and  repealing  Regulation  (EU)  No 1305/2013  of  the  European  Parliament  and  of  the 
Council  and  Regulation  (EU)  No  1307/2013  of  the  European  Parliament  and  of  the  Council, 
COM/2018/392 final - 2018/0216 (COD) 

53 

 
                                                           
The 20 actions included in the strategy contributed, to a varied extent, to the achievement 
of the six strategy objectives.  

The  “traffic  light  assessment”  was  used  to  assess  the  extent  to  which  each  of  the  20 
actions have contributed to the six objectives of the strategy.  

Based  on  the  information  provided  above,  Table  2  illustrates  the  effectiveness  of  each 
type of action carried out under each objective.  

54 

 
 
 
OBJECTIVES OF THE STRATEGY                       EFFECTIVENESS of ACTIONS  

High/Medium/low 

1.DEVELOP TOOLS  

TO STRENGTHEN  

MEMBER STATES' 
COMPLIANCE 

•Enforcement actions on laying hens  
•Enforcement actions on grouping of sows  
•Implementing plan for slaughter  
•Guidelines on pigs 
•Best practices on animal transport  
•Guidelines on the protection of animals at the time 
of killing  
•Report on genetic selection - broilers’ directive 
•Report on banning cat and dog fur  
•Report on stunning methods for poultry  
•Report on the farming directive  
•Report on restraining systems for bovine  
•Study on dogs and cats  
•Report on the welfare broilers  

2.PROVIDE CONSUMERS AND 
THE PUBLIC WITH APPROPRIATE 
INFORMATION  

•Study information on stunning 
•Study on education and on information to public and 
consumers  

3.SUPPORT INTERNATIONAL 
COOPERATION  

•Report on international activities  

4.OPTIMISE SYNERGISTIC 
EFFECTS FROM CURRENT 
COMMON AGRICULTURE 
POLICY (CAP) 

•No specific action 

5.INVESTIGATE ON THE 
WELFARE OF FARMED FISH 

•Study on farmed fish during transport  
•Study on farmed fish at the time of killing  

6.CONSIDER THE FEASIBILITY OF 
INTRODUCING A SIMPLIFIED EU 
LEGISLATIVE FRAMEWORK FOR 
ANIMAL WELFARE  

•Possible legislative proposal for a simplified EU 
legislative framework  

5.3.10 Factors influencing the achievement of objectives 

The  strategy  helped  to  set  common  priorities  on  animal  welfare  in  the  EU.  It  also 
supported the sharing of best practices and knowledge on animal welfare.  

55 

 
 
 
 
However,  while  there  is  progress,  most  of  the  strategy  objectives  have  not  been  fully 
achieved. This is due to multiple factors, both internal and external to the strategy.  

Internal factors  

There were some internal factors that contributed to the achievement of the objectives in 
a positive or negative way.  

On the one side, the evidence collected and analysed under the study concludes that the 
strategy was successful in bringing together the work on animal welfare in the EU. This 
enabled  stakeholders  to  prioritise  their  efforts  on  the  topic  and  to  engage  with  the 
Commission in a targeted manner. 

Further, in the case of the guidelines, although engagement with stakeholders took time 
and may have contributed to delays in their delivery, this engagement was seen as crucial 
to producing well-written and informative outputs.  

On  the  other  side,  consulted  stakeholders  pointed  out  that  the  strategy  was  not  very 
ambitious, and that insufficient resources were allocated, leading to delays in the delivery 
for some of the actions up until 2018.  

The  delivery  model  of  the  strategy  has  been  criticised  by  stakeholders  for  not  being 
specific  enough  and  for  not  including  monitoring  mechanisms  for  measuring  the 
progress.  

Another factor identified as challenging by some stakeholders relates to some legislative 
requirements (e.g. in the transport and slaughter regulations) pointed as being not easy to 
understand or easy to enforce.  

External factors 

There were external factors that had a positive influence on the strategy. Animal welfare 
was  seen  to  be  continually  improving  as  a  result  of  a  societal  demand  towards  better 
standards which was perceived to be the result of a combination of increased awareness 
among  consumers,  NGO  campaigns,  media  presence  and  sharing  on  online  social 
platforms. This in turn placed pressure on producers and retailers to better comply with 
welfare  standards,  therefore  supporting  the  strategy’s  objectives.  These  social  factors 
were seen to  have facilitated the strategy’s implementation (at  least  to  some extent) by 
survey respondents (69%). Support for the strategy itself among key stakeholders, such 
as  the  European  Parliament,  was  also  observed  as  having  a  positive  influence  too.  The 
European Parliament both supported actions and often criticized the Commission for its 
work  in  certain  areas  (e.g.  compliance  with  pig’s  tail  docking133,  the  animal  transport 

133

https://www.europarl.europa.eu/RegData/etudes/STUD/2014/509997/IPOL_STU%282014%29509997_

EN.pdf 

56 

 
                                                           
Regulation134,  deficiencies  in  the  current  EU  animal  welfare  legislation  and  the  need  to 
revise it135).  

A  key  external  factor  hindering  the  strategy’s  success  was  the  difference  between 
individual  Member  States.  Political  priorities  can  vary,  impacting  the  degree  to  which 
work around improving animal welfare is resourced and therefore how much work they 
will  undertake  to  achieve  compliance.  Likewise,  interpretations  and  implementation  of 
EU  animal  welfare  legislation  can  be  widely  different.  This  in  turn  means  a  lack  of 
consistency around enforcement which was difficult to address through strategy actions. 
The  study  reports,  for  example,  that  some  Member  States  fined  business  operators  for 
certain  infringements  of  EU  animal  welfare  legislation  while  others  did  not.  A  lack  of 
common and systematic criteria to measure enforcement activities in Member States has 
also been highlighted. To address this issue, the Official Controls Regulation provides an 
opportunity and various tools for the Commission and Member States to further improve 
some  of  the  remaining  challenges  in  terms  of  equal  enforcement  (e.g.  Member  States’ 
annual  reporting,  corrective  measures  and  fines)  and  adoption  of  acts  for  the  use  of 
indicators and inspections methods136.  

The  Commission  is  often  exposed  to  similar  challenges  in  the  area  of  international 
cooperation on animal welfare with third countries. Political priorities of third countries 
are often very different with animal welfare not being high into national political agenda. 
Sometimes animal welfare is not a competence at federal or central national level, but at 
regional or lower level which poses additional difficulties. This also directly relates to the 
challenges around including more ambitious targets on animal welfare into international 
trade agreements. As such, there was seen to be a limit in what the strategy could have 
achieved  in  this  regard.  The  issue  is  reflected  in  the  survey  results,  in  that  half  of  the 
respondents  considered  political  factors  to  have  hindered  the  strategy’s  implementation 
to at least some extent (51%).  

5.4. EFFICIENCY  

Under  efficiency  the  relationship  between  the  resources  used  by  the  strategy  and  the 
generated changes was assessed (i.e. an assessment of costs and benefits). The following 
evaluation questions guided the assessment:  

  To what extent could the same results have been achieved with fewer resources?  
  To what  extent has the need to  simplify and develop  clear principles for animal 

welfare been achieved by the strategy?  

134   MOTION  FOR  A  EUROPEAN  PARLIAMENT  RESOLUTION  on  the  implementation  of  Council 
Regulation  No  1/2005  on  the  protection  of  animals  during  transport  within  and  outside  the  EU 
(2018/2110(INI)) 

135 https://www.europarl.europa.eu/RegData/etudes/STUD/2017/583114/IPOL_STU(2017)583114_EN.pdf 

136 Article 21(8). 

57 

 
                                                           
  Regarding the objectives partially met or unmet, what have been the opportunity 
costs?  (e.g.  issues  with  working  with  the  current  legal  framework,  considering 
technological  and  scientific  developments,  and  problems  unaddressed  at  EU-
level?)  

  To  what  extent  has  the  implementation  of  the  strategy  had  an  impact  on  the 
competitiveness and the economic sustainability of the different economic sectors 
concerned e.g. within and outside the EU?  

Main findings:  

A qualitative assessment of the scale of costs found that the largest costs related to 
enforcement,  monitoring,  international  cooperation,  production  of  studies  and 
reports,  development  and  dissemination  of  guidelines.  However,  a  quantitative 
assessment of the incurred costs by the different stakeholders was not possible due 
to the lack of data.  

There  is  a  clear  perception  of  an  uneven  distribution  of  costs  and  benefits  among 
stakeholders, particularly business associations and businesses.  

The  resources  available  to  implement  the  strategy  were  initially  sufficient  but 
reduced  significantly  in  2015.  Overall,  the  majority  of  stakeholders  perceive  the 
allocated  resources  as  insufficient.  Additional  resources  for  the  strategy’s  actions 
would  have  improved  their  effectiveness  and  may  have  also  improved  their  cost-
effectiveness.  

It  is  unlikely  that  the  benefits  produced  under  the  strategy  could  have  been  achieved 
with fewer resources and, spending more on the strategy’s actions may have improved 
its cost-effectiveness. 

Due to the lack of quantitative data, it was not possible to give a definitive assessment 
of  whether  the  benefits  achieved  by  the  strategy  were  commensurate  with  the  costs 
incurred.  A  qualitative  assessment  shows  that  for  those  actions  with  no  follow-up 
actions, while costs were relatively low, there were no perceived benefits linked to 
them.  On  the  other  hand,  enforcement  actions,  while  higher  in  costs,  contributed  to 
improvements in enforcement and therefore these costs may be justified.  

The notion of ‘simplification’ foreseen under the objective envisaging an EU simplified 
legal  framework  evoked  inconsistent  interpretations  by  stakeholders.  The  strategy 
contributed to the need of simplification mainly via the production of guidelines, which 
helped to understand and apply the requirements of the existing legislation.   

Due to the high degree of uncertainty, it has not been possible to assess the opportunity 
costs  and  in  particular,  whether  the  likely  benefits  of  the  non-implementation  of  the 
action related to a simplified legal framework would have outweighed the costs.  

58 

 
 
There is mixed evidence on the impact of the strategy on the economic sustainability of 
affected economic sectors.  

5.4.1 Could the same results have been achieved with fewer resources?  

Overall, stakeholders demonstrated low levels of familiarity with the funding and human 
resources  associated  with  the  strategy.  However,  interview  and  survey  data  provided 
insights into some of the costs that stakeholders incurred. 

5.4.1.1 Cost categories 

The analysis carried out  under the study identified few stakeholder  groups, such as EU 
bodies  and  institutions,  Member  States,  NGOs  and  professional  organisations  and 
businesses  and  business  associations,  and  11  types  of  costs  incurred  by  these 
stakeholders in relation to the strategy. There were no quantitative data relating to other 
stakeholder  costs,  including  the  costs  incurred  by  Member  States,  businesses, 
professional  organisations  and  NGOs.  It  was  possible  to  identify  some  of  the  planned 
implementation costs of the strategy and its actions for DG SANTE137 using Commission 
documents. The strategy did not have a dedicated budget  and for this reason it was not 
possible  to  identify  the  exact  costs  incurred  by  the  Commission  and  stakeholders 
involved  in  its  implementation.  Quantitative  data  relating  to  other  stakeholder  costs, 
including the costs of Member States, businesses, professional organisations and NGOs, 
are not available. 

Even  when  the  information  on  costs  related  to  the  strategy  was  available,  it  was 
challenging to identify the share of it that directly belonged to the strategy and whether 
the same could have been occurred in the absence of a strategy. A summary of the costs 
and benefits is available in Annex 5. 

137 See Annex 6 to the study 

59 

 
                                                           
Summary of the main costs and benefits by stakeholder group 

Graph.1: COSTS AND BENEFITS FOR MEMBER STATES 

COSTS 

BENEFITS 

CONSULTATION ON THE STRATEGY 

MONITORING AND 
ENFORCEMENT ACTIVITIES 

GUIDELINES 

TRAINING 

INCREASED KNOWLEDGE 

IMPROVED DIALOGUE WITH 
STAKEHOLDERS 

INCREASED COMPETITIVENESS 
INTERNATIONALLY AND WITHIN 
THE EU 

UPSKILLED STAFF 

Graph.2: COSTS AND BENEFITS FOR BUSINESSES 

COSTS 

BENEFITS 

CONSULTATION ON THE STRATEGY 

MONITORING AND ENFORCEMENT 
ACTIVITIES 

GUIDELINES 

TRAINING 

IMPROVED DIALOGUE WITH 
STAKEHOLDERS 

INCREASED KNOWLEDGE 

UPSKILLED STAFF 

IMPROVED ANIMAL HEALTH AND 
PRODUCTS 

TECHNOLOGY AND PRODUCTION COSTS 

INCREASED PROFITS 

Due  to  the  lack  of  quantitative  data,  interviews  and  surveys  data  provided  valuable 
insights  into  some  of  the  costs  that  stakeholders  incurred.  According  to  evidence 
collected during the study, the following costs were associated with the strategy: 

60 

 
 
 
 
 
 
 
 
  Consultation  on  the  strategy  -  wide  spectrum  of  stakeholders,  including  the 
European  Parliament,  Member  States  and  NGOs,  were  consulted  during  the 
development  of the strategy. These costs occurred before the implementation  of 
the strategy (2012). Some stakeholders like business associations and NGOs also 
incurred  costs related to  engaging and meeting  with the Commission  during the 
period of the strategy. 

  Production  or  funding  of  studies  and  reports-  These  costs  were  largely 
incurred  by  the  Commission  and  are  related  to  funding  of  studies  or  reports 
produced by external contractors. For example 15 of the planned 20 actions under 
the strategy included a study  and/or a report. The costs for these is  estimated at 
approximately €1.3 million. 

  Monitoring  and  enforcement  actions  -  These  activities  were  identified  as 
another  significant  area  of  cost.  The  majority  of  Member  States  pointed  at 
increased  monitoring  and  enforcement  costs  at  national  level,  including  an 
increase in audits and inspections, increased government resources for measuring 
equipment  relating  to  laying  hens,  participation  in  contact  point  meetings  for 
transport  and  an  increase  in  human  resources  to  conduct  welfare  checks. 
However,  the  extent  to  which  these  costs  are  due  to  the  strategy  compared  to 
legislation  or  another  factor  is  unclear.  Stakeholders  such  as  business/trade 
associations  and  a  minority  of  NGOs  and  professional  organisations  identified 
costs  related  to  monitoring  compliance  (3  out  of  15  NGOs  and  2  out  of  8 
professional organisations).  

  Production,  dissemination  and  uptake  of  guidelines  -  Guidelines  targeting 
animal  owners  and  handlers,  including  handbooks,  factsheets,  best  practice 
documents  and  educational  videos,  were  produced  under  the  strategy.  They 
covered  the  following  three  main  legislative  areas:  welfare  of  pigs,  animal 
transport,  and  slaughter.  Costs  were  identified  to  the  production,  dissemination, 
translation  and  use  of  guidelines.  These  were  mainly 
the 
Commission,  but  also  by  professional  organisations,  NGOs,  Member  States  and 
businesses or business associations who were involved in different steps of these 
activities and provided input.   

incurred  by 

  Designing,  delivering  and  participating  in  training  -  Some  of  the  strategy’s 
actions involved the provision of training, relating to the protection of laying hens 
and  pigs,  grouping  of  sows,  slaughter,138  and  transport.  Many  of  the  consulted 
stakeholders  described 
the  Commission’s  existing  BTSF. 
Approximately  €3.5  million  was  budgeted  for  animal  welfare  training  through 
BTSF, to deliver 35 sessions between 2012 and 2016. In addition, most Member 
States  incurred  some  form  of  cost  related  to  training.  For  example  from  26  EU 
Member  State  representatives  responding  to  the  survey,  most  (62%)  reported 
costs related to compliance, such as participating in training activities. Businesses 
may  have  also  incurred  costs  related  to  training  and  adapting  their  practices  to 

the  use  of 

138   Actions 1, 2, 3 and 4 

61 

 
                                                           
comply  with  legislation.  However,  the  latter  should  not  be  seen  as  costs  of  the 
strategy as these are legal requirements that apply anyway. 

  International cooperation activities - These activities included the provision of 
training  through  BTSF  with  an  approximate  budget  of  €847,000  spent  between 
2012  and  2015.  In  addition,  the  TAIEX  programme  aimed  to  build  capacity  in 
third countries. The Commission organised events, meetings, and conferences to 
support this goal. The Commission provided co-funding of the OIE activities such 
as global conferences, regional seminars, regional meetings and activities on both 
animal  health  and  welfare.  This  finding  was  estimated  to  around  €3  million 
between 2012 and 2018.  
Production or funding of scientific advice - Scientific advice was produced by 
EFSA  to  address  knowledge  gap  (e.g.  stunning  systems139,  the  use  of  animal-
based measures in risk assessment140, tail biting etc.). While it is clear that some 
of  the  work  that  EFSA  produced  during  the  strategy  period  was  directly 
influenced by the strategy, it is not clear whether a larger number of outputs were 
produced  by  EFSA  than  would  have  occurred  in  the  strategy’s  absence.  In 
addition  to  the  work  completed  by  EFSA,  scientific  studies  were  funded  by  the 
Commission and carried out by experts, relating to pig welfare and management 
of  pigs  that  have  not  had  their  tails  docked.  The  funding  for  these,  and  other, 
studies  came  from  DG  SANTE,  from  projects  financed  through  the  7th 
Framework Programme (FP7141) and Horizon 2020142, and the budget of some of 
these  studies  were  substantial.  However,  while  some  of  this  work  is  clearly 
relevant to the strategy, it is not possible to determine to what extent this funding 
was influenced by the strategy.   

Member  State  representatives,  business,  trade  associations  and  individual  businesses 
incurred  costs  relating  to  consultation,  monitoring  compliance,  attending  and  providing 
training  sessions,  contributing  to,  disseminating  and  using  guidelines,  and  consultation 
activities.  Some  stakeholders  also  noted  that  businesses  may  also  have  incurred  costs 
relating to training and other related activities such as peer-to-peer exchanges. The data 
from  interviews  suggests  that  Member  State  and  business/trade  associations  and 
individual  businesses  may  have  incurred  small  to  moderate  costs  related  to  guidelines 
and consultation activities.  

139   Four scientific opinions were produced on stunning methods at slaughter for poultry, three for  rabbits, one for lambs and kid 

goats, and one for small ruminants between 2012 and 2020. 

140   Scientific  opinions  were  produced  on  the  use  of  animal-based measures  for  pigs, dairy  cows,  broilers,  beef  cattle  and calves, 
sheep  and  rabbits  between  2012  and  2020,  and  guidance  was  produced  on  risk  assessments  for  animal  welfare.  It  should  be 
noted  that  several  of  the  scientific  opinions  on  the  use  of  animal-based  measures  for  certain  species  not  covered  by  existing 
regulation, such as dairy cows and beef cattle, were produced in responses to Commission mandates. 

141   https://wayback.archive-it.org/12090/20191127213419/https:/ec.europa.eu/research/fp7/index_en.cfm 

142 https://ec.europa.eu/programmes/horizon2020/en 

62 

 
                                                           
NGOs  and  professional  organisations  reported  costs  related  to  consultation  activities, 
monitoring and enforcement, guidelines and scientific advice. A very small number also 
reported costs related to contributing to studies, reports and training. 

Businesses may have also incurred costs related to technology and production costs, such 
as  acquiring  new  infrastructure  or  hiring  additional  personnel,  but  it  is  unclear  to  what 
extent these can be considered additional costs. 

A summary of the types of costs incurred by stakeholder group and, where possible based 
on  data  availability,  a  qualitative  assessment  of  the  scale  of  this  cost,  is  presented  in 
Annex  6.  According  to  such  assessment,  the  largest  costs  related  to  monitoring  and 
enforcement, guidelines, trainings, international activities, studies, reports. 

5.4.1.2 Types of benefits 

A detailed discussion of the benefits  can also  be found under effectiveness  section, 5.3 
focusing on the implementation of the strategy objectives and actions. Some elements are 
also available under coherence and EU added value sections.  

The positive effects of the strategy are associated with:  

1.  The common set of objectives and priorities. 
2.  Improved enforcement and compliance with animal welfare requirements such as:  

a)  Reduced use of sow stalls  for pigs  and compliance with  requirements  on the 

grouping of sows. 

b)  Reduced use of unenriched cages for laying hens and better compliance with 

the laying hens Directive. 

c)  Improved compliance with the farm animals Directive. 
d)  Some improvements towards reducing tail-docking in pigs.  
e)  Improved  enforcement  and  harmonisation  of  animal  welfare  standards 

contributing to some extent to a more level playing field at EU level.  

Some mentioned that improved animal welfare standards leading to higher quality animal 
products could contribute to increased profits for the operators.  

3.  Increased  awareness  of  animal  welfare  standards  and  good  practices  among 

animal owners and handlers because of the guidelines. 

4.  Production of new knowledge, with studies on farmed fish influencing decision-
making by industry and policymaking, as well as contributing to the establishment 
of a sub-group for the welfare of farmed fish under the EU Platform  on Animal 
Welfare. 

5.  Contributions,  to  different  extents,  to  international  animal  welfare  standards 
through  promotion  of  animal  welfare  in  third  countries,  leading  to  greater 
awareness  of  animal  welfare  issues,  greater  harmonisation  and  higher  standards 
internationally,  which  in  turn  supported  a  more  even  playing  field  at  a  global 
level. 

63 

 
 
6.  Influencing the creation of the EU Animal Welfare Platform,  which appeared  as 

unexpected outcome of the strategy.  

5.4.1.3 Distribution of costs and benefits  

There  is  a  clear  perception  of  an  uneven  distribution  of  costs  and  benefits,  particularly 
among businesses. However, given the lack of information available on costs, it was not 
possible  to  assess  how  costs  and  benefits  were  distributed  among  stakeholders,  both  in 
terms  of  differences  by  Member  State  and  over  time  because  of  the  lack  of  data.  The 
interviews  and  surveys  carried  out  during  the  one  year  study  helped  to  fill  this  gap  to 
some extent. Among respondents to the survey, just over half of respondents disagreed or 
strongly disagreed that costs and benefits had been similarly distributed between sectors 
(54%) and countries (55%) compared to less than (10%) who agreed or strongly agreed. 
Among  businesses  and  business  associations,  more  than  70%  disagreed  or  strongly 
disagreed with the statements compared to less than 10% who agreed.  

5.4.1.4 Comparison of costs and benefits 

Due to lack of indicators and data on the total costs of the strategy, it was not possible to 
give  a  complete  and  definitive  assessment  of  whether  the  benefits  achieved  by  the 
strategy  were  commensurate  with  the  costs  incurred.  While  survey  data  indicate 
relatively  low  levels  of  familiarity  with  the  Strategy’s  costs,  respondents  were  more 
likely to disagree that the benefits outweighed the costs incurred. 

Despite the data limitations, it was possible to  assess cost-effectiveness  in a qualitative 
sense based on the study’s findings on the strategy’s results and the likely scale of cost 
involved  for  each  type  of  action.  For  those  actions  with  no  follow-up  (e.g.  knowledge 
products),  while  costs  were  relatively  low,  there  were  no  perceived  benefits  linked  to 
them.  On  the  other  hand,  enforcement  actions,  while  higher  in  costs,  contributed  to 
improvements in enforcement and therefore these may be justified. Annex 5 provides an 
overview of the cost-benefits identified by the study. 

The use of resources evolved during the strategy’s implementation period that started in 
2012 and ended with  a delay in  2018 for some  of the actions, such as the international 
activities  study  and  report,  farmed  fish  welfare  study  and  report,  best  practices  on 
slaughter, broiler welfare study and report and other. Interview findings suggest that the 
strategy may have had sufficient resources at its early stages. For example, there was the 
creation of an animal welfare unit ahead of the strategy’s launch, and an initial resource 
to implement the actions.  

However, there were already constraints on resources due to the impacts of the financial 
crisis, which continued to have an impact over the period of the strategy.  

The  ECA  report  of  2018  also  supports  these  findings  pointing  at  the  insufficient 
resources as a reason for delays and stated that more could have been achieved with more 
resources.  

64 

 
In  favour  of  this  position,  only  5%  of  organisations  who  responded  to  the  public 
consultation  stated  that  the  funding  and  human  resources  associated  with  the  strategy 
were very or extremely appropriate, compared to nearly half (47%) of respondents who 
stated this was somewhat or not at all appropriate.  

In the light  of the above, available data suggests that the resources were  insufficient  to 
achieve the set objectives. Further, the strategy’s actions may have been more effective – 
and more efficient – if additional resources were allocated to their implementation. It is 
unlikely  that  it  would  have  been  possible  to  achieve  the  benefits  produced  under  the 
strategy with fewer resources.  

5.4.2 Simplification and development of clear principles  

Considering the fact that the actions to implement the objective to consider the feasibility 
of a simplified legislative framework were dropped, the strategy had a small contribution 
in  terms  of  simplifying  principles  for  animal  welfare.  However,  some  stakeholders 
approached during the consultation activities consider that the strategy contributed to the 
need  of  simplification  mainly  via  the  production  of  guidelines,  which  helped  to 
understand and apply the requirements of the existing legislation.   

Overall,  consulted  stakeholders  expressed  mixed  views  on  the  extent  to  which  the 
strategy simplified and developed clear principles on animal welfare.  

5.4.3 Opportunity costs  

Assessing  the  opportunity  costs  required  an  assessment  of  what  might  have  been 
achieved  if  a  simplified  EU  legislative  framework  for  animal  welfare  had  been 
developed, and synergies with CAP Pillar II (EAFRD) improved. 

An assessment of opportunity costs was performed in three case studies carried out and 
available  in  Annex  9  to  the  study.  Case  study  1  assessed  the  opportunity  costs  of  not 
producing a simplified EU legislative framework for animal welfare. Case studies 7 and 
8  focussed  their  assessment  on  the  subject  of  synergies  between  the  CAP  and  the 
strategy.  Findings  in  this  section  are  primarily  based  on  the  outcomes  from  these  case 
studies.  

Exploring the feasibility of setting up a simplified EU legislative framework  

The benefits and costs of setting up a simplified EU legislative framework were assessed 
under the study by drawing on desk research and data collected through the stakeholders’ 
consultation. This exercise was qualitative only because of the lack of concrete monetary 
data. Extensive details on the approach and methodology used are available in case study 
1 (Annex 9) of the study report. 

The need and potential benefits of having a simplified legal framework remain an issue 
of  debates  also  today.  Some  of  the  stakeholders  perceive  a  potential  new  legislative 
framework  as  a  compromise  between  the  different  interests  and  aspirations.  Such  a 
compromise may have taken various forms. For instance, not all steps anticipated in the 

65 

 
strategy  (such  as  the  introduction  of  animal  welfare  indicators)  might  have  been 
eventually included in the new legislative framework. In this context, it was necessary to 
consider  different  levels  of  implementation  and  enforcement  the  new  legislative 
framework might have achieved.  

Summary of possible scenarios for producing a simplified EU legislative framework for 
animal welfare  

  Scenario  1:  Framework  simplifies  but  does  not  add  further  protection.  There  is 

limited variation in terms of compliance between Members States. 

  Scenario  2:  Framework  simplifies  and  adds  further  protection  (including 
protection  extended  to  other  species,  indicators,  common  competence  standards 
and/or  guidelines).  There  is  limited  variation  in  terms  of  compliance  between 
Members States. 

  Scenario  3:  Framework  simplifies  but  does  not  add  further  protection.  There  is 

significant variation in terms of compliance between Member States. 

  Scenario  4:  Framework  simplifies  and  adds  further  protection  (including 
protection  extended  to  other  species,  indicators,  common  competence  standards 
and/or guidelines). There is significant variation in terms of compliance between 
Member States. 

In conclusion, it was not possible to estimate the net opportunity costs given the absence 
of  robust  quantitative  data  at  hand.  Following  the  analysis,  it  can  be  assumed  that 
scenarios  1  and  3  have  lower  costs  and  more  limited  benefits,  while  scenarios  2  and  4 
have  higher  costs  while  offering  possible  greater  benefits.  The  simplified  legal 
framework  would  have  provided  limited  benefits  besides  a  reduction  in  administrative 
burden and some efficiencies for competent authorities and the Commission. By contrast, 
options 4, and, in particular, option 2, are more likely to have had benefits across a wider 
range of stakeholders, while translating into more costs.  

Exploring the take-up of EAFRD support for animal welfare and beyond 

The assessment of opportunity costs also aimed to estimate the costs and benefits of the 
activities  anticipated  in  the  strategy,  had  the  improved  synergies  between  the  CAP  and 
animal welfare materialised. Evidence for this assessment is based on the data collected 
for Finland and Ireland. Both Member States were selected based on their different levels 
of  budget  programmed  for  animal  welfare  payments  in  their  RDPs143.  While  it  was  not 

143   Finland has programmed 4.21% of its EAFRD budget for M14. There are only three Member States 
with  a  higher  budget  in  their  national  2014-2020  RDPs:  Estonia  (4.3%),  Slovakia  (5.71%)  and 
Romania  (8.41%).  Ireland  has  programmed  2.41%  of  the  EAFRD  budget  for  M14,  which  is  the 
smallest share other than for Bulgaria (1.98%). 

66 

 
                                                           
possible  to  provide  an  economic  assessment  due  to  the  lack  of  monetary  data,  a 
qualitative assessment was possible.  

The strategy intended to “establish a specific inter-services arrangement to assess how 
to optimise synergistic effects of the current mechanisms of the CAP”. This would have 
likely involved increased coordination and formalised engagement between the involved 
Commission Services, beyond existing collaboration and communication arrangements.  

The focus of this assessment was the animal welfare payments (‘measure 14’ or ‘M14’) 
under the EAFRD144. The  assessment of opportunity  costs carried out  by the study  (i.e. 
case studies 7 and 8) suggests that there would have been both costs and benefits for the 
Commission,  Member  States,  industry  and  consumers  if  the  inter-services  arrangement 
had been established. These costs would have included resourcing and staff time for the 
Commission  and  Member  States,  familiarisation  and  adaption  costs  for  industry. 
Potential benefits include improved animal welfare, efficiency gains for the Commission 
as  a  result  of  greater  coordination  between  DG  SANTE  and  DG  AGRI,  a  potentially 
more  level  playing  field,  more  support  for  farmers,  and  more  high-welfare  products 
available for consumers.  

5.4.4 Competitiveness and the economic sustainability  

There is mixed evidence on the impact of the strategy on the economic sustainability of 
affected  economic sectors. Survey respondents  were more likely to agree than disagree 
that the strategy had contributed to the sustainability of EU industry (40% compared to 
18%). Despite this,  respondents  who provided further detail  on their views appeared to 
believe the strategy didn’t have an impact on sustainability.  

Survey respondents were more likely to disagree than agree that the strategy contributed 
to  improving  competitiveness  of  the  EU  industry.  Representatives  from  Member  States 
pointed out that there was still a lack of a level playing field.  

These  findings  come  in  contrast  with  the  findings  of  the  study  on  the  impact  of 
international  activities145  and  the  relevant  Commission  report146  which  concludes  that: 
“overall  costs  of  compliance  with  animal  welfare  standards  remain  very  low  when 
compared to other production costs”. This issue has been presented more in detail under 
5.3 Effectiveness (see sections 5.3.3 and 5.3.4).  

144   For further details on the scenario considered, refer to section 4.4.3 of the study. 

145   https://op.europa.eu/en/publication-detail/-/publication/dc039353-ca9c-11e7-8e69-01aa75ed71a1  

146   https://ec.europa.eu/food/sites/food/files/animals/docs/aw_international_publication-report_en.pdf  

67 

 
                                                           
5.5. EU ADDED VALUE 

Under this criterion it was assessed the extent to which the strategy has added value in a 
way  that  could  have  not  been  achieved  by  any  actions  at  national  level.  The  following 
evaluation questions were used to guide this assessment: 

  Why has action at EU-level been the most appropriate? To what extent have the 
results produced under the strategy gone beyond what Member States would have 
achieved in its absence? 

  To what extent have the results produced under the strategy gone beyond what the 

EU would have achieved in its absence?  

Main findings:  

The  strategy  produced  results  that  would  not  have  been  possible  at  national  level 
and helped to harmonise and coordinate animal welfare policy and activities in the 
EU.  Overall,  the  strategy  was  an  appropriate  response  to  address  animal  welfare 
issues.   

At  national  level,  the  added  value  of  the  strategy  differed  between  Member  States 
depending on national priorities and their existing animal welfare policies.  

At  an  EU-level,  the  strategy  contributed  through  coordination  and  harmonisation  of 
animal welfare practices, knowledge generation and compliance improvements, thereby 
enabling a level playing field.  

Internationally,  the  strategy  helped  the  EU  to  speak  in  one  voice  to  promote  and 
raise awareness about animal welfare. 

The  strategy  had  a  small  added  value  in  relation  to  the  achievement  of  a  more 
comprehensive  and  uniform  protection  of  animals  in  the  EU  and  a  very  limited  one 
regarding consumer awareness.  

Nevertheless,  the  strategy  encouraged  coordination  and  exchange  of  information 
and best practices  among Member States and  thus  created synergies and efficiencies 
instead of each country spending resources on their own in a potentially non-coordinated 
manner.  

This section is based on purely qualitative evidence collected via the public consultation, 
interviews and surveys and it reflects the findings under effectiveness and efficiency.      

5.5.1 Action at EU level  

According to the evidence collected, the development and implementation of a strategy at 
EU-level was an appropriate response to address animal welfare issues. The majority of 
stakeholders surveyed agreeing (65%) that the objectives, actions, studies and reports in 
the  strategy  were  an  appropriate  response  to  animal  welfare  issues  in  2012.  Further,  a 
majority  (60%)  also  agreed  that  they  were  still  relevant  in  addressing  animal  welfare 

68 

 
 
issues  today.  The  strategy  was  praised  for  setting  out  common  priorities  for  animal 
welfare,  and  for  supporting  the  sharing  of  best  practice  and  expertise  across  the  EU 
through specific actions. For example, the production and dissemination of the guidelines 
were considered as an important step towards increased awareness and harmonisation of 
animal welfare standards at EU-level (see relevant Effectiveness sections 5.3.2; 5.3.5 and 
5.3.6).  

Findings  also  showed  that  the  strategy  actions  had  improved  national  enforcement  and 
compliance  with  specific  areas  of  EU  animal  welfare  legislation,  in  turn  supporting  a 
level  playing  field  across  Member  States.  Additionally,  the  strategy  promoted  animal 
welfare at an international level by facilitating international cooperation activities such as 
training,  as  well  as  contributing  to  the  development  of  third  country  and  international 
standards (e.g. OIE standards). These outcomes suggest that the strategy added value by 
coordinating actions to support animal welfare at both an EU-level and an international-
level.  

The survey results further supported this. The majority of respondents (62%) agreed that 
the strategy produced results that would not have been otherwise achievable at a national 
level.  EU  National  Competent  Authorities  were  particularly  positive  about  the  added 
value of the strategy (77%). Similar results were found in the public consultation, where 
over  half  of  respondents  (61%)  agreed  that  the  strategy  brought  benefits  in  the  field  of 
animal  welfare  or  related  fields  that  could  not  have  been  achieved  through  national 
interventions alone.  

Whilst the strategy was largely coherent with national level interventions, its added value 
varied between Member States (see Coherence section 5.2.3 and Case study 03 in Annex 
9  to  the  study  report).  For  example,  the  different  political  priorities  of  Member  States 
influenced the allocation of resources for improving compliance with animal welfare at 
national-level,  so  the  strategy  likely  had  more  added  value  where  there  was  political 
support for making improvements to animal welfare.  

5.5.2 Potential for going beyond in the absence of strategy  

The  analysis  strategy  helped  to  achieve  results  that  would  not  have  been  possible  at  a 
national level. There are mixed views on the extent to which the results produced under 
the Strategy went beyond what would have otherwise been achieved in its absence.  

Overall, the strategy led to improvements in enforcement and compliance across different 
areas  of  legislation  at  a  Member  State  level  (with  varying  levels  of  success).  These 
findings  were  reflected  in  the  survey,  where  more  than  half  (56%)  agreed  that  the 
strategy produced results in terms of enforcement and compliance would not have been 
otherwise achievable at the national level. Outcomes form the survey also demonstrates 
that the EU business associations, trade associations and businesses were more likely to 
agree with this (68%) compared to NGOs (33% agreed), although NGOs were typically 
more  critical  of  the  strategy  in  general.Error!  Bookmark  not  defined.  In  addition, 
interviewees  including  business  associations,  professional  organisations,  and  EU 

69 

 
institutions as well as NGOs, stated that the strategy results could not have been achieved 
without it. 

Some interviewees stated that the strategy played an important role in coordinating and 
harmonising animal welfare practices and legislation across the EU. 

Surveyed stakeholders who considered the strategy to have produced results that would 
not  have  otherwise  been  achieved  at  national  level  were  asked  about  how  important 
different  factors  were  in  contributing  to  said  results.  Promotion  of  EU  standards  at  an 
international  level  was  most  frequently  mentioned  as  being  very  or  quite  important 
(71%),  followed  by  coordination  and  synergy  gains  (64%)  and  greater  influence  when 
negotiating standards with non-EU countries (56%).  

On the other hand, some strategy actions were less successful according to data obtained 
from  the  stakeholders’  consultation  activities.  For  example,  actions  targeting  the 
protection of animals at the time of killing and in particular the implementing plans set 
out  in  the  slaughter  Regulation  would  have  happened  regardless  of  the  strategy’s 
existence.  

At the international level, the strategy contributed to promoting animal welfare standards 
with one voice in international fora and raising awareness on animal welfare.  

6.  CONCLUSIONS 

Scope and limitations of the evaluation  

The  evaluation  covers  all  activities  implemented  under  the  strategy  in  line  with  the 
principles  of  Better  Regulation.  The  evaluation  was  supported  by  an  external  study 
assessing  the  strategy’s  overall  relevance,  coherence,  effectiveness,  efficiency  and  EU 
added value.  

Although the evaluation of the strategy did not specifically target the legislative gaps in 
the EU animal welfare acquis, it has included an assessment of the key compliance risk 
areas.  

The analysis was constrained by some limitations such as, at first place, the lack of data 
to  develop  a  baseline  in  order  to  assess  potential  impacts  based  on  the  strategy  Impact 
Assessment  of  2012.  Second,  a  breakdown  of  the  results  by  animal  production  system 
and respondents geography was not possible due to a small base of data. Third, there was 
a low response rate to some questions requiring greater familiarity with the strategy (e.g. 
on  its  efficiency),  and  it  was  difficult  for  many  stakeholders  to  answer.  The  short 
duration  of  the  study  and  the  Covid-19  crisis  added  challenges  to  the  already  complex 
evaluation process, but, none of them hampered the quality of the collected evidence.  

The  analysis  was  based  on  an  extensive  literature  review,  data  collection  through  desk 
research,  wide  consultation  activities,  which  allowed  incorporating  the  opinions  of  a 
broad  range  of  stakeholders.  The  results  have  been  tested  and  validated  during  a 
stakeholder’s  workshop.  To  ensure  reliability  of  the  data  collected,  different  sources  of 

70 

 
data  were  compared  and  opinions  from  stakeholders  were  examined  against  other 
evidence (i.e. triangulation) to the extent possible. This approach mitigates the effect of 
the limitations described above.  

Relevance  

The  problems  and  drivers  identified  in  the  strategy  were  relevant  in  2012  and  most  of 
them are still relevant today. The knowledge on the welfare of farmed fish species was 
limited in  2012 and,  thanks to  the  awareness developed through the strategy, increased 
progressively and has further potential to increase with respect to some fish species, such 
as the European sea bass and Gilthead sea bream.  

A key challenge remains the need to improve compliance across Member States in some 
legislative  areas.  In  this  respect,  the  Official  controls  Regulation147  offers  tools  to  the 
Commission  to  address  some  issues  related  to  specific  control  requirements  and 
verification  of  compliance  with  animal  welfare  rules.  In  particular,  for  the  design  of 
animal  welfare  indicators  as  a  tool  to  assist  official  control  activities,  the  experience 
gathered  so  far  in  some  areas  where  indicators  are  already  used  (i.e.  broilers  and 
slaughter) can play a role and serve as an example in the process of development of new 
indicators. 

The increased EU consumers’ interest and demand for animal welfare make the need to 
inform  them  even  more  relevant  today  than  it  was  in  2012.  This  need  is  accounted  for 
also in the Farm to Fork strategy in a broader context of the information to consumers on 
sustainable  food.  This  is  a  second  key  challenge,  which,  in  some  instances,  operators 
have shown are ready to address individually, in the absence of specific rules.    

The same is true also for the need to strengthen international cooperation overcoming the 
reluctance  of  some  third  countries  to  adopt  animal  welfare  requirements  comparable  to 
the ones applicable in the EU. In this context, the Farm to Fork strategy foresees the EU 
to  support  the  global  transition  to  sustainable  agri-food  systems  including  through 
development of Green Alliances with all its partners in bilateral, regional and multilateral 
fora.  

There is a clear need to further optimise synergies with the CAP for the period 2021-27 
and to make better use of the instruments offered by it to strengthen CAP beneficiaries’ 
awareness  on  animal  welfare  requirements,  to  improve  animal  welfare  standards  in 

147   Regulation  (EU)  2017/625  of  the  European  Parliament  and  of  the  Council  of  15  March  2017  on 
official controls and other official activities performed to ensure the application of food and feed law, 
rules on animal health and welfare, plant health and plant protection products, amending Regulations 
(EC) No 999/2001, (EC) No 396/2005, (EC) No 1069/2009, (EC) No 1107/2009, (EU) No 1151/2012, 
(EU)  No  652/2014,  (EU)  2016/429  and  (EU)  2016/2031  of  the  European  Parliament  and  of  the 
Council,  Council  Regulations  (EC)  No  1/2005  and  (EC)  No  1099/2009  and  Council  Directives 
98/58/EC, 1999/74/EC, 2007/43/EC, 2008/119/EC and 2008/120/EC, and repealing Regulations (EC) 
No  854/2004  and  (EC)  No  882/2004  of  the  European  Parliament  and  of  the  Council,  Council 
Directives  89/608/EEC,  89/662/EEC,  90/425/EEC,  91/496/EEC,  96/23/EC,  96/93/EC  and  97/78/EC 
and Council Decision 92/438/EEC (Official Controls Regulation), OJ L 95, 7.4.2017, p. 1–142. 

71 

 
                                                           
animal  husbandry,  and  to  mainstream  them  into  the  regulatory  framework  governing 
agricultural activities.   

As  to  the  regulatory  framework,  the  gaps  which  existed  in  2012  remain,  and  still  rules 
regarding  the  protection  of  some  animal  species  are  missing.  In  addition,  the  need  to 
simplify  existing  rules  and  to  improve  their  enforceability  continues  to  be  relevant.  In 
both cases, the strategy did not contribute to address significantly these issues. 

The delivery model of the strategy  was  criticised for not  being ambitious enough in  its 
design  and  follow-up  actions.  The  design  of  future  initiatives  should  include 
arrangements  and  specific  indicators  for  the  monitoring  of  implementation  and  of 
progress against the baseline.  

Coherence  

The strategy was internally coherent and its actions operated well together. While there is 
no evidence of contradiction between EU policies developed between 2012 and 2019, the 
extent to which the strategy was coherent with other EU policies depends on the policy 
area.  The  strategy  was  certainly  overall  coherent  with  food  and  feed  safety  policies  as 
well  as  with  research  policies.  In  contrast,  it  emerged  from  the  assessment  that 
consistency with other policy areas has been to some extent sub-optimal. This concerns 
the CAP, and the policies on fisheries, trade environmental protection and transport, with 
which  a  more  coordinated  and  consistent  approach  is  being  sought  more  rigorously  in 
recent years. The Green Deal, and especially the Farm to Fork strategy implementation, 
by facilitating a transition to a fair, healthy and sustainable food system, is expected to 
strengthen  further  the  coherent  approach  between  animal  welfare  and  the  mentioned 
policies. 

The  strategy  was  overall  coherent  with  national  legislation  in  most  Member  States. 
Inconsistencies detected are mainly due to differences in the level of public concern and 
social  perception  of  animal  welfare,  the  different  relevance  across  Member  States  (i.e. 
animal  sentience  not  always  sufficiently  recognised,  and  implementation  gaps),  a 
different  degree  of  political  interest  in  animal  welfare  aspects  and  the  insufficient 
resources allocated to the enforcement of animal welfare rules. 

At an international level, synergies have been achieved between the strategy and the OIE 
interventions in the area of animal welfare. Some synergies have also been noted with the 
FAO activities on animal  welfare. The future work at  international  level  needs to  build 
further on these synergies and to enhance the cooperation on animal welfare with an aim 
to  obtain  ambitious  commitments  for  the  global  transition  to  sustainable  agri-food 
systems as also foreseen under the Farm to Fork strategy. 

Effectiveness 

The strategy contributed to setting common priorities that led to improvements on animal 
welfare  across  the  EU.  It  also  contributed  to  improve  knowledge  and  share  of  best 

72 

 
practices  on  animal  welfare.  However,  none  of  the  strategy’s  objectives  has  been  fully 
achieved. This despite the fact that most planned actions have been implemented.  

The most successful actions were those that contributed to improved enforcement of the 
EU legislation, in  particular in  specific areas (i.e. group housing of sows, protection of 
laying hens), and, to a lesser extent, those on the welfare of broilers and on the transport 
of animals. The strategy also indirectly contributed to the protection of animals kept for 
farming  purposes  where  the  Commission  audits  revealed  the  use  of  risk-based  systems 
for selecting sites for inspection and continuous efforts to address non-compliance. 

The  Commission  audits  in  combination  with  infringement  cases  proved  to  be  effective 
tools  in  accelerating  and  strengthening  enforcement  efforts  in  some  areas  (again,  in 
particular group housing of sows and the protection of laying hens).  

However, there are still important areas in which compliance remains a challenge, such 
as animal transport, routine tail docking of pigs, the protection of animals at the time of 
slaughter and the welfare of broilers.  

The  possibility  given  by  the  Official  controls  Regulation  to  carry  out  specific  controls 
offers the tools to further improve enforcement.  

International  level  activities  delivered  by  the  strategy  contributed  to  a  certain  extent  to 
increased  multilateral  and  bilateral  cooperation  activities.  The  strategy  contributed  to 
promoting  animal  welfare  standards  with  one  voice  in  international  fora  and 
strengthening  synergies  with  the  OIE  and  FAO  and,  indirectly,  to  some  extent,  also 
towards a global level playing field. The international activities on animal welfare are a 
long-term  investment  with  a  view  to  consolidate  the  EU’s  leading  role  in  the  global 
transition to sustainable, and thus animal welfare friendly food systems. 

The  creation  of  the  EU  Platform  on  Animal  Welfare,  although  not  foreseen  in  the 
strategy,  contributed  to  its  positive  outcomes  by  enabling  the  discussion  amongst 
different groups of actors, facilitating the production of guidelines and exchanges of best 
practices. Many stakeholders perceive the Platform as an indirect and natural follow-up 
of the strategy.  

The  strategy  failed  to  deliver  on  the  stated  objective  of  introducing  a  simplified  EU 
legislative  framework  on  animal  welfare.  Due  to  lack  of  quantitative  data  it  was  not 
possible to assess the opportunity costs of not having revised the legislation. 

Also  the  strategy  had  very  limited  contribution  as  regard  the  information  to  consumers 
and the optimisation of synergies with the CAP.  

Data gathering activities (studies and reports) conducted under the strategy had no follow 
up actions and were perceived not having contributed to any of the anticipated changes.  

The non-specific formulation of some actions and objectives in the strategy (i.e. those on 
international  cooperation,  synergies  with  CAP  and  the  feasibility  of  an  EU  legislative 

73 

 
framework)  are  the  factors  which  influenced  the  extent  to  which  the  strategy  was  less 
successful in meeting its objectives.  

The Farm to Fork strategy clearly commits to explore possible options for animal welfare 
labelling.  The  new  CAP,  presently  under  discussion  at  the  time  of  writing,  provides 
opportunities  to  improve  integration  of  animal  welfare  legislation  and  promote  best 
practices with respect to farm animals.  

Efficiency  

A qualitative assessment of the scale of costs found that costs related to the strategy were 
split among EU bodies and institutions  (including the European Commission),  Member 
States,  NGOs,  professional  organisations,  businesses  and  business  associations.  These 
costs  were  primarily  related  to  enforcement,  monitoring,  international  cooperation, 
studies, reports, development and dissemination of guidelines.  

Due to the lack of data, it was not possible to quantify the amount of costs incurred by 
the different stakeholders groups. There was a wide perception among stakeholders that 
those costs were unevenly distributed. A qualitative assessment showed that the benefits 
of the strategy may have been higher than the  costs incurred, at  least  regarding  actions 
which were followed-up, for instance on enforcement. 

The resources available in the Commission to implement the strategy have been reduced 
significantly in 2015, reflecting a change in political priorities. This is considered one of 
the  reasons  for  the  delay  with  the  delivery  of  some  actions  under  the  strategy  up  until 
2018.  

EU added value  

issues. 
The  strategy  was  an  appropriate  response 
Internationally,  it  helped  the  EU  speak  in  one  voice  to  promote  animal  welfare  in 
different  context  (i.e.  conferences,  negotiations,  cooperation  initiatives,  trainings, 
technical assistance activities etc.)    

to  address  animal  welfare 

At EU level,  it created synergies  and efficiencies, helping to  harmonise  and coordinate 
animal  welfare  policy  and  activities  and  contributing  to  a  level  playing  field  across 
Member States. However, there is evidence that the added value of the strategy differed 
between  Member  States  depending  on  national  priorities  and  animal  welfare  policies. 
The newest animal welfare was as a priority in the national political agenda, the greatest 
the added value of the Strategy was. In Member States where animal welfare standards 
established  in  national  legislation  were  higher  than  EU  ones,  the  added  value  was  the 
lowest.  

In specific areas, such as in relation to a more comprehensive and uniform protection of 
animals  in  the  EU,  consumer  awareness  and  optimising  synergies  with  the  CAP,  the 
strategy had limited added value as it was less effective.  

74 

 
Animal welfare is a multidimensional issue and has social, environmental, and economic 
implications.  Further  action  at  EU level  in  the framework of the Farm to Fork strategy 
would  ensure  policy  coherence.  It  would  also  provide  the  necessary  means  to  reach  a 
high level of protection of animals in the EU. EU policies have in this respect a powerful 
role to play in accelerating and supporting the needed changes.  

Outlook  

In  June  2018,  the  Commission  published  legislative  proposals  on  the  Common 
Agricultural  Policy  beyond  2020  which  aim  to  support  European  farmers  for  a 
sustainable and competitive agricultural sector. One of its objectives relates to improving 
the  response  of  EU  agriculture  to  societal  demands  on  food,  animal  health  and  animal 
welfare.   

On  the  other  hand,  the  European  Green  Deal  (2019)  recognises  higher  animal  welfare 
standards as part of sustainable practices, and the Farm to Fork strategy (2020) sets out 
an ambitious agenda, which will allow to deliver concrete actions on animal welfare in 
the  years  to  come,  including  a  review  of  the  whole  legislative  framework  and  the 
strengthening of international cooperation.  

In  fact,  the  Farm  to  Fork  strategy  announced  the  commitment  to  revise  the  EU  animal 
welfare legislation by 2023. One of the objectives of the revision is to broaden its scope 
and  align  its  ambition  with  societal  expectations  regarding  the  sustainability  of  food 
systems. The review will also allow to take into account the latest scientific evidence in 
this area.  

The  forthcoming  review  will  look  at  the  legislative  gaps  identified  in  2012  and  at  any 
new that could emerge from the ex-post evaluation of the rules in force. This will be the 
basis for further reflections on the options available to make the animal welfare acquis fit 
for purpose. Another objective is to make the legislation easier to enforce. There, special 
attention will be given to  the compliance risk areas identified by this evaluation  and to 
the potential of exploiting the power given by existing instruments.  

In  particular,  the  opportunities  provided  by  the  Official  Controls  Regulation  to  further 
improve controls will be explored. This included the use of science-based animal welfare 
indicators as considered at the time of adoption of the animal welfare strategy in 2012, 
and  the  possible  establishment  of  specific  controls  requirements  to  strengthen 
compliance. 

In  addition  to  the  above,  in  the  Farm  to  Fork  strategy,  the  Commission  commits  to 
explore  options  for  animal  welfare  labelling  in  order  to  empower  consumers  to  make 
more sustainable food choices. Further actions in this area will elaborate on the findings 
of this evaluation in terms of consumers’ awareness and demand for information.  

The  evaluation’s  findings  will  assist  the  Commission  in  designing  relevant  animal 
welfare actions under the Farm to Fork strategy. These actions will aim to  ensure more 

75 

 
sustainable  food  production  and  higher  welfare  of  animals,  in  synergy  with  CAP 
instruments and objectives.   

76 

 
   
ANNEX 1: PROCEDURAL INFORMATION 

1.  Lead DG, Decide Planning/CWP references 

Lead DG: Directorate General Health and Food Safety (DG SANTE) 

Decide planning: PLAN/2019/5270 

2.  Organisation and timing 

This evaluation was included in the DG SANTE evaluation plan. It followed the Better 
Regulation  guidelines  with  regard  to  evaluations.  The  evaluation  work  was  carried  out 
through  an  external  evaluation  study,  conducted  in  conformity  with  the  DG  SANTE 
procedure  for  the  organisation  and  management  of  policy  evaluations  carried  out  by 
external  contractors.  The  work  was  supervised  under  the  technical  as  well  as  the 
contractual management of SANTE unit G2 now G5 with the support of unit A1 and F2. 

An Inter-service Steering Group (ISG) was set up by the Commission in May 2019, with 
the mandate to provide information, prepare the terms of reference, monitor the work of 
the  external  study  team,  discuss  and  give  advice  on  the  approval  of  the  final  report, 
comment on the draft evaluation SWD. 

The ISG was composed of the Secretariat-General of the Commission and DGs SANTE, 
AGRI, MARE, TRADE, GROW, ENV, DEVCO, NEAR, MOVE and JRC. The Steering 
Group started its meetings on 27.05.2019.  

The evaluation  roadmap was published on the 17.05.2019.  It set  out  the  context,  scope 
and aim of the exercise. The roadmap presented the questions to be addressed under the 
five  criteria  of  effectiveness,  efficiency,  relevance,  coherence  and  EU  added  value. 
During the feedback period on the roadmap (17.05.2019 – 14.06.2019), 37 contributions 
were  received148.   These did not  require changing the approach towards the evaluation, 
but helped to further enrich the Terms of reference. 

The evaluation support study carried out by the external contractor started on 10/10/2019 
and finalised on 09/10/2020. This  external  support study, together with  the outcome of 
the public consultation provided the basis for this SWD. 

3.  Exceptions to the better regulation guidelines 

The  open  public  consultation149  of  reference  for  this  evaluation  is  the  open  public 
consultation launched on 23 March and closed on the 22 June 2020. Its aim was to gather 

148  https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/2140-Evaluation-

of-the-EU-Animal-Welfare-Strategy-2012-2015- 

149  https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/2140-Evaluation-

of-the-EU-Animal-Welfare-Strategy-2012-2015-/public-consultation 

77 

 
 
 
                                                           
the  views  of  public  authorities,  stakeholders  and  EU  citizens.  Due  to  the  COVID-19 
crisis this consultation has been extended with one more week to the initially foreseen 12 
weeks period.  

4.  Consultation of the RSB (if applicable) 

The RSB will not scrutinize this evaluation SWD.  

5.  Evidence, sources and quality 

The  evaluation  required  gathering  of  relevant  data  and  information  from  European 
Union,  as  well  as  national  and  local  levels,  international  organisations  and  some  third 
countries.  The  overall  approach  therefore  combined  three  main  sources  and  types  of 
evidence:  EU  level  data  and  information  gathering,  review  and  analysis.  In  addition,  8 
case  studies  have  been  developed  in  order  to  supply  additional  evidence  on  subjects 
agreed  by  the  ISG.  The  study  preliminary  findings  have  been  presented  and  validated 
during a stakeholders validation workshop carried out on 9 July 2020.  

78 

 
 
 
ANNEX 2: STAKEHOLDER CONSULTATIONS  

Synopsis report 

1. Introduction  

This report presents the synopsis of all stakeholder consultation activities undertaken as 
part  of  the  ‘Study  to  support  the  evaluation  of  the  European  Union  strategy  for  the 
Protection  and  Welfare  of  Animals  2012-2015’  (SANTE/2019/G2/034).  The  study  was 
commissioned by the European Commission’s Directorate General for Health and Food 
Safety - (DG SANTE) and it was carried out by ICF in collaboration with RAND Europe 
and Cerebrus, supported by a team of thematic experts.   

The aim of the consultation activities is support the consultation process required in order 
to  evaluate    the  European  Union  strategy  for  the  Protection  and  Welfare  of  Animals 
2012-2015 (COM/2012/6 final; hereinafter ‘the strategy’). The consultative process helps 
the study team  to  address questions  concerning the relevance, coherence, effectiveness, 
efficiency and EU added value of the strategy.  

Following main forms of consultation have been conducted during this study: 

  A  public  consultation  (PC),  which  includes  tailored  sets  of  questions  for 

different stakeholder groups.  

  Targeted  consultations, addressing specific  groups  of stakeholders, including 

in-depth interviews and surveys 
  A stakeholder validation workshop 

The sections below provide an overview of the stakeholders and the activities covered as 
well as the main results of the consultation activities.  

2. Stakeholder groups covered by the consultation activities  

The  consultation  activities  aimed  to  elicit  the  views  of  the  general  public,  and  of 
particular stakeholder groups, on specific questions concerning the strategy. Input from a 
wide  range  of  stakeholders  was  collected  as  described  in  the  methodology  section 
(section 3) of the main report. These include national competent  authorities in Member 
trade/professional  organisations;  non-governmental 
States;  business  organisations; 
organisation (NGOs); consumer organisations; national competent authorities in non-EU 
countries; and international organisations. 

The Table 1 below provides and overview on the types of stakeholders mapped out for 
the consultations and the data collection method on how information was gathered from 
specific stakeholders.  

Overview of conducted stakeholder consultations 

Stakeholder type 

Data collection method 

Academic Expert 

Public consultation  

Interviews 

79 

 
 
 
 
Stakeholders validation workshop 

Public consultation  

Competent  authority  in  an 
EU Member State 

Targeted survey 

Interviews 

Stakeholders validation workshop 

Public consultation  

Business or trade association 
and 
business 
based in the EU 

individual 

Targeted survey 

Interviews 

Stakeholders validation workshop 

Public consultation  

Professional 
based in the EU  

association 

Targeted survey 

Interviews 

Stakeholders validation workshop 

EU Institution and EU body 

Public consultation  

Non-governmental 
organisation (NGO) 

Interviews 

Public consultation  

Targeted survey 

Interviews 

Stakeholders validation workshop 

Competent  authority outside 
of the EU 

Multilateral organisation 

Other  (including  consumer 
organisations,  EU  and  non 
EU citizens) 

Public consultation  

Targeted survey 

Interviews 

Public consultation  

Targeted survey 

Interviews 

Public consultation  

3. Overview of consultation activities  

3.1 Public consultation (PC) 

The goal of the public consultation was to gather information and perspectives from all 
stakeholders,  including  the  general  public.  The  questionnaire  was  designed  around  the 
five  objectives  of  the  strategy,  and  included  questions  relating  to  each  of  the  five 

80 

 
 
evaluation  criteria  as  well  as  future  challenges.  The  public  consultation  was  accessible 
from 23 March until 22 June in all official EU languages.  

A total of 3,375 respondents contributed to the public consultation, of which 2,704 were 
identified  to  come  from  a  coordinated  response.  The  campaign  was  noticed  due  to  an 
increase in answers from EU citizens during the month of June 2020, all with the same 
reply.  Further,  the  Non-Governmental  Organisation  (NGO)  Eurogroup  for  Animals 
published the campaign on their website150. Following Better Regulation Guidelines, the 
responses  were  segregated  and  analysed  separately  from  the  non-campaign  responses 
(with  the  2,704  campaign  responses  treated  as  one  response  for  the  purposes  of  this 
report). 

Of  the  remaining  671  responses,  410  came  from  EU  citizens,  and  55  from  non-EU 
citizens.  The  other  207  respondents  were  30  academics/researchers,  34  were  business 
associations, 31 companies, 49 NGOs, 8 organisations (2 consumer organisations and 6 
environmental organisations), 19 public authorities, 4 trade unions and 31 self-identified 
as ‘other’.   

3.2 Targeted surveys 

The  online  survey  complemented  the  information  collected  through  the  public 
consultation  and  interviews,  and  focused  on  questions  about  effectiveness,  coherence, 
relevance  and  EU  added  value.  The  survey  was  conducted  in  English  and  targeted  the 
following stakeholders:  

trade/professional organisations; 

  national competent authorities in Member States; 
  business organisations; 
 
  non-governmental organisation (NGOs);  
  consumer organisations; 
  national competent authorities in non-EU countries; and  
 

international organisations. 

The  survey  was  launched  on  1  April  2020  and  ran  for  five  weeks.  The  survey  was 
disseminated  through  several  channels,  including  348  targeted  emails  and  via  the  EU 
Animal  Welfare  Platform,  with  75  targeted  members  representing  the  different 
stakeholder  groups.  It  received  103  responses  in  total  (approximately  a  30%  response 
rate). 

3.3 Interviews 

The  purpose  of  the  interviews  was  to  explore  in  detail  specific  aspects  of  the  strategy, 
such as the contribution of the strategy’s actions to its objectives, examples of coherence 
among  policies  and  the  strategy’s  costs  and  benefits.  The  study  team  completed  102 
telephone interviews with a sample of key stakeholders at national, EU and international 
level. On that basis, the following interviews were completed:  

  Business organisations (14 interviews) 
  EU Institutions and EU bodies (18 interviews) 
  Academic Experts (10 interviews) 

150 https://www.eurogroupforanimals.org/public-consultation 

81 

 
 
                                                           
International organisations (3 interviews) 

 
  EU  Member  States  competent  authorities  (30  interviews,  representing  23 

Member States) 

  Non-governmental organisations (NGO) (13 interviews) 
  Professional organisations 
  Non-EU competent authorities (7 interviews) 

(8 interviews) 

Despite significant efforts to reach the foreseen number of interviewees, 102 out of the 
planned 130 were conducted. The remaining interviews were not pursued further, as the 
stakeholders contacted either (i) refused to participate or (ii) have not reacted to repeated 
attempts  at  contacting  them  including  several  emails  and  follow-up  calls.  Despite  not 
reaching  100%  of  the  target  for  some  stakeholder  groups,  the  data  collected  is  of  high 
quality and it reached a saturation point, so there was no need to pursue more interviews. 
Qualitative research sample sizes are not set in fixed rules for determining rigour. Rather, 
the sample size is determined more by what is wanting to be understood, or what data are 
being sought in the research (Varkevisser et al., 2003:207).  

3.4 Stakeholder workshop 

The study organised one online validation workshop on 9 July 2020. The event enabled 
EU and national-level stakeholders and experts to share their perspective and insights on 
the findings of the study. It served as a source of information for this study, with the aim 
of  complementing  and  verifying  the  information  obtained  from  the  desk  research, 
stakeholder interviews, surveys, and the public consultation. 

The stakeholders invited to this event were the 75 members of the EU Animal Welfare 
Platform.  Various  types  of  stakeholders  were  invited  and  attended  the  online  event.  A 
total of 29 stakeholders attended. 

4. Results of the stakeholder consultation  

The sections below include a description of the results of the consultation activities per 
targeted  surveys,  an  online  public 
evaluation  criteria,  including  findings  from 
consultation, in-depth interviews and a stakeholder validation workshop.  

Relevance 

Under this criterion, the aim is to assess whether the strategy’s objectives were objective 
to  address  the  main  animal  welfare  problems  in  2012,  whether  they  continue  to  be 
relevant today and the factors influencing the relevance of these problems. 

Relevance in 2012 

There  was  general  agreement  among  stakeholders  consulted  that  the  strategy  was  an 
appropriate  response  to  the  challenges  in  2012,  although  stakeholders  had  a  range  of 
views.  Member  State  representatives  and  businesses/business  associations  were  more 
likely to agree with this, while NGOs were less likely to agree.  

In terms of the relevance of issues that the strategy aimed to address in 2012: 

  Most stakeholders identified non-compliance with existing legislation due a lack 
of enforcement by Member State representatives and, to a lesser extent, a lack of 
awareness among animal handlers and owners as one of the most relevant animal 
welfare issues in 2012. In particular, compliance issues were mentioned in relation 
to pig welfare, laying hens, slaughter and transport. Relatedly, many stakeholders 

82 

 
 
also  noted  that  implementing  new  legislation  was  a  key  challenge  in  2012, 
following the directives on laying hens and group housing of sows. 

  An  uneven  level  of  protection,  lack  of  consumer  information  and  an  uneven 
playing  field  were  also  identified  as  quite  or  very  relevant  issues  in  2012. 
Approximately  three  quarters  of  survey  respondents  viewed  uneven  levels  of 
protection  for  difference  species  of  animals  (74%,  n=103),  a  lack  of  consumer 
information (71%, n=103) and an unequal playing field for the EU (71%, n=103) 
as quite or very relevant in 2012, and these issues were also mentioned by several 
interview participants. 

Stakeholders  were  less  likely  to  state  that  non-compliance  due  to  a  lack  of 
business  incentives,  complexities  of  EU  legislation,  lack  of  synergies  with  the 
CAP and lack of knowledge on the welfare of farmed fish were relevant issues in 
2012.  

Relevance today 

Overall, most stakeholders indicated that the issues targeted by the strategy continue to 
be relevant today.  

  Most  stakeholders  agreed  that  non-compliance  due  to  a  lack  of  enforcement 
(particularly  in  relation  to  the  transport  regulation),  an  uneven  level  of 
protection  across  different  animal  species  (especially  horses,  pets  and  wild 
animals,  but  also  dairy  and  beef  cattle,  sheep,  goats,  turkey,  rabbits,  male 
chicks),  lack  of  consumer  information,  and  an  uneven  playing  field  for  EU 
businesses are key issues that continue to be relevant issues today. Related to 
both  a  need  to  simplify  and  develop  clear  principles  and  an  uneven  playing 
field,  several  participants  also  noted  challenges  with  implementation  of 
legislation  and  a  lack  of  harmonisation  in  how  legislation  had  been 
implemented across Member States.  

  There  is  some  disagreement  over  the  extent  to  which  a  lack  of  awareness 
among  animal  owners  and  handlers  is  a  relevant  issue  today,  although  a 
significant proportion of the stakeholders consulted felt this continued to be a 
relevant issue that merited further action.  

  While  stakeholders  were  less  likely  to  agree  that  simplifying  the  legal 
framework is a relevant issue, the related issue of simplifying and developing 
clear principles may still be a key challenge. Some stakeholders noted that the 
relevance of this issue is less clear because “simplification” can be interpreted 
in different ways. 

  Stakeholders were least  likely to  agree that lack of knowledge on welfare of 
farmed  fish  and  insufficient  synergies  with  the  CAP  are  relevant  issues  that 
require further action, although a relatively high proportion of those consulted 
through the survey or public consultation stated they “did not know” whether 
the welfare of farmed fish was relevant or required further action.  

  Almost all individual respondents stated all of these issues were important to 
tackle,  with  the  exception  of  simplifying  animal  welfare  law,  which  a  much 
smaller majority stated was very or extremely important.  

Stakeholders disagreed over whether there were any other notable animal welfare issues 
in the period of 2012-2020. This varied significantly by stakeholder group. Most NGOs 
stated there were other relevant issues not covered by the strategy, while only a minority 
of business/trade associations and professional organisations stated this.  

83 

 
 
In addition to issues related to species or groups of animals not focused upon within the 
strategy,  including  companion  animals  and  wildlife,  key  challenges  identified  by 
stakeholders  included:  a  lack  of  reflection  of  scientific  opinion  and  challenges  putting 
research into practice;  the assessment of  animal  welfare, including a lack of systematic 
data collection/indicators to measure animal welfare; labelling of animal products; a need 
for  further  revision  and/or  implementation  of  existing  laws;  issues  related  to  climate 
change and the environment; a need to promote the reduction of animal products; lack of 
consideration  for  the  emotional  needs  and  intelligence  of  animals;  a  need  to  improve 
welfare  for  caged  animals;  an  increase  in  intensive  farming;  and  industry  challenges, 
including  the  challenge  of  ensuring  traceability  in  the  supply  chain  and  the  challenge 
(and cost) of meeting societal demands. 

Factors influencing relevance 

Stakeholders  tended  to  agree  that  scientific  and  technological  progress,  changes  in 
consumer expectations and changes due to national-level action were key factors that had 
influenced  animal  welfare  since  2012.  Additionally,  several  stakeholders  highlighted  (a 
lack of) political support and resources as factors leading to (a lack of) change, and also 
noted the impact of EU-level action including stakeholder engagement, working groups, 
training  and  improved  use  of  cross-compliance  measures  under  the  CAP.  A  few  also 
mentioned climate change, variation between Member States and changes in volumes of 
animal products traded as relevant factors. 

Coherence 

The  assessment  of  coherence  aims  at  grasping  both  internal  coherence  (possible 
inconsistencies, gaps and overlaps between the actions envisioned under the strategy) and 
external  coherence  in  relation  to  policies  and  actions  at  EU,  national  and  international 
level. 

Internal coherence 

Stakeholders overall agreed the actions of the strategy were coherent with each other, but 
there  were mixed perceptions on this area. Survey  respondents  were most likely  to  say 
that the different actions envisioned under the strategy were quite or very coherent (50%, 
n=87), non-individual respondents to the public consultation were most likely to say that 
the  actions  were  moderately  coherent  (37%,  n=206).  Interview  findings  suggest  that 
stakeholders  tended  to  think  at  least  some  of  the  strategy’s  actions  were  coherent,  but 
while  some  interview  participants  identified  aspects  of  the  strategy  that  supported 
coherence (e.g. reference centres and the guidance and educational materials produced), 
several stakeholders mentioned a lack of coherence on consumer awareness, the CAP, or 
the lack of legislation for certain species.   

External coherence – with EU policies 

Overall,  stakeholders  had  mixed  views  on  the  extent  to  which  EU  actions  had  been 
coordinated and complementary with the strategy.  

Animal health was perceived as  very  coordinated and complementary with the strategy 
by  around  half  of  stakeholders  consulted  through  the  public  consultation  and  targeted 
surveys. It was also identified as an area of coherence among interview participants. 

Some stakeholders also agreed that EU policies on transport were coordinated, although 
this  varied  by  stakeholder  group.  Notably,  among  respondents  to  the  targeted  survey, 
while  half  of  EU  business/trade  associations  and  individual  businesses  (n=  38)  and 
Member State representatives (n=26) felt these were quite or very coordinated, none of 

84 

 
the 15 NGOs who responded to the survey agreed with this (although six stated that they 
did not know). 

Stakeholders had mixed views on the  coherence  between the strategy  and the CAP  but 
were  more  likely  to  disagree  than  agree  that  there  was  coherence.  Some  stakeholders 
explained  this  was  because  they  view  the  CAP  as  incentivising  large-scale  farming, 
which they see as at odds with animal welfare. 

Stakeholders also tended to disagree that there was coherence between the strategy and 
other EU policies, particularly in  relation  to  sustainability  and the environment. Survey 
respondents also emphasised low levels of coherence between the strategy and trade and 
fisheries.  Among  the  small  number  of  interview  participants  from  EU  institutions  who 
commented on coherence between DGs, there were mixed views on whether DGs work 
well together to support animal welfare. 

External coherence – with national policies 

Reflecting  stakeholders’  views  on  the  coherence  with  EU  policies,  most  stakeholders 
perceived national policies as consistent with the strategy, particularly policies on animal 
health. Comments from survey respondents indicated that animal health has been a key 
focus  for  national  governments,  and  competent  authorities  work  closely  together  to 
ensure  coherence  between  animal  welfare  and  health,  which  may  explain  this 
consistency.  

Coherence with international policies 

There was limited stakeholder feedback on the coherence between the strategy and non-
EU actions and policies, and views were mixed. While some stakeholders emphasised the 
alignment  with  OIE  initiatives,  others  emphasised  a  lack  of  compliance  with  EU 
standards  among  third  countries  and  a  lack  of  inclusion  of  animal  welfare  standards  in 
trade negotiations.  

Effectiveness 

When looking at effectiveness, the consultation process focused on assessing whether the 
objectives  of  the  strategy  were  achieved,  and  the  factors  that  may  have  supported  or 
hindered the strategy’s implementation.  

Opinions  on  the  effectiveness  of  the  strategy  were  mixed,  with  stakeholder  groups 
holding  different  opinions.  Stakeholders  tend  to  feel  that  the  strategy  has  helped  to 
improve  animal  welfare  to  at  least  a  small  extent,  but  implementation  could  have  been 
better.  

Regarding the extent to which the strategy achieved its objectives: 

  The  majority  of  stakeholders  did  not  feel  the  strategy  had  contributed  to  a 
more comprehensive and uniform protection of animals across species in the 
EU. Some felt the strategy had supported better protection for animals, but the 
corresponding  actions  were  generally  not  seen  to  have  made  a  significant 
contribution  towards  the  objective.  Stakeholders  also  highlighted  that  there 
was  a  need  to  expand  species-specific  EU  legislation  to  cover  those  species 
which  were  seen  to  be  inadequately  protected,  such  as  farmed  fish  and 
domestic animals. 

  Compliance  and  enforcement  were  seen  to  have  improved  in  some  areas, 
specifically in relation to the use of cages for hens (Directive 1999/74/EC) and 
the  group  housing  of  sows  (Directive  2008/120/EC).  While  stakeholders 
tended to view enforcement actions and guidelines as effective, this varied by 

85 

 
stakeholder  group. Member State representatives were largely positive about 
the  strategy’s  support  for  enforcement  and  compliance,  while  NGOs  and 
business/trade associations were more negative.  

  Stakeholders highlighted several risk areas where compliance continues to be 
perceived  as  problematic.  Despite  noted  improvements  in  relation  to  group 
housing of sows, the tail-docking of pigs was frequently mentioned as an area 
where  compliance  was  low  (Directive  2008/120/EC).  Issues  relating  to 
welfare  during  transport  (Regulation  (EC)  No.  1/2005)  were  also  frequently 
mentioned. For transport, the issues of long-distance travel, especially to third 
countries, and high temperatures were of particular concern.  

  Stakeholders  did  not  feel  that  the  strategy  had  had  a  notable  effect  on  the 
functioning of the EU market or to have contributed to a more level playing 
field,  although  their  recognition  of  better  compliance  with  specific  areas  of 
legislation  does  indicate  that  some  progress  had  been  made  towards  a  more 
level playing field at EU-level. Business/trade associations were more critical 
of the strategy’s contribution towards more level playing field, both within the 
EU and outside the EU, and were also critical of the strategy in respect of its 
incentivisation of compliance. Despite this, some third country Member State 
representatives  highlighted  that  the  strategy  had  positively  influenced  the 
efforts of third countries to improve animal welfare. 

  Awareness  of  animal  welfare  among  industry  stakeholders  was  felt  to  have 
improved since 2012, which may help  to  explain why the  actions to  address 
this in order to support compliance, such as the guidelines and training, were 
viewed particularly positively.  

  Actions  to  improve  awareness  of  consumers  and  the  general  public  through 
communication  and  education  were  highlighted  as  being  particularly 
ineffective.  Some  stakeholders  stated  that  the  consumer  studies  could  have 
had more success if they had led to corresponding actions and noted that EU 
communications  to  consumers  on  the  subject  were  lacking,  with  several 
expressing support for an EU labelling scheme. However, some Member State 
representatives  felt  that  the  strategy  had  contributed  to  improving  awareness 
of industry practices among consumers.  

  With  regards  to  international  activities,  stakeholders  perceived  the  strategy 
had  made  a  moderate  contribution  towards  promotion  of  animal  welfare 
standards at international level, but a small contribution only towards levelling 
the playing field at global level. 40% of respondents to the public consultation 
perceived international cooperation on animal welfare to be the least effective 
strategy  activity  in  achieving  its  objectives  (n=206).  On  the  other  hand, 
interviews  and  the  workshop  highlighted  the  contribution  of  the  strategy 
towards international cooperation, and the fact that the strategy had positively 
influenced the efforts of third countries to improve animal welfare. 

  Other  knowledge  products  (studies  and  reports)  received  mixed  feedback.  A 
minority of stakeholders reported that studies (35% of responses) and reports 
(30%)  were  the  most  effective  of  the  Strategy’s  actions,  while  others  (24% 
and  20%  respectively)  considered  them  the  least  effective.  This  reflects  the 
high  number  of  studies  and  reports  produced  (12  out  of  20  actions)  and  the 
varies quality of them, as explored in the main report. This did not vary much 
by  stakeholder  type.  While  no  NGOs  surveyed  stated  that  they  had  made  a 
significant  or  great  contribution  to  policy  and  decision-making  in  their 
Member State, most stated that they did not know. The main criticism of the 

86 

 
knowledge  products  was  that  they  did  not  always  lead  to  action  to  improve 
animal welfare, which some stakeholders identified as a missed opportunity. 
  Stakeholders were either unsure or did not consider the strategy to have made 
a significant contribution to its objective to improve synergies with the CAP. 
This  higher  proportion  of  ‘don’t  know’  responses  may  be  influenced  by  the 
lack  of  tangible  strategy  actions  in  relation  to  the  CAP.  Among  those  who 
considered  it  had  made  a  contribution,  stakeholders  tended  to  mention  the 
animal welfare payments under the EAFRD rather than explicit work resulting 
from  the  strategy.  However,  there  was  evidence  that  support  for  animal 
welfare under RDPs had improved since 2012. Member State representatives 
reported  increased  use  of  animal  welfare  payments,  investment  support  and 
the farm advisory service between 2012 and 2020.  

In terms of the factors that influenced the strategy’s implementation: 

  Political  and  economic  factors  were  seen  as  hindrances  to  the 
implementation of the strategy. A key reason for this was the perception that 
animal  welfare  was  not  necessarily  a  political  priority  for  either  the 
Commission  or  Member  States,  influenced  by  unwillingness  in  the  farming 
industry  to  make  changes.  Nevertheless,  there  was  some  understanding  that 
the  Commission  was  aiming  to  strengthen  future  action  on  animal  welfare 
with  the  2018  CAP  reform.  Financial  challenges  were  also  thought  to 
negatively affect animal welfare due to the primary focus being on supporting 
the economy.  

  On the other hand, social, scientific and technological factors were seen as 
positively influencing the strategy’ implementation. The main social factor 
was  the  perceived  increase  in  public  interest  in  animal  welfare,  which  was 
seen to result in greater pressure on industry to adopt higher welfare practices. 
The  introduction  and  use  of  science-based  welfare  indicators  was  also 
mentioned  as  supporting  improvements  to  animal  welfare.  In  relation  to 
producing guidelines, collaboration with stakeholders was also identified as a 
factor that supported success.   

Some  stakeholders  reflected  on  the  choice  of  using  “soft  tools”  rather  than  legislative 
changes.  They  generally  agreed  that  it  was  appropriate  that  the  strategy  focused  on 
enforcing  existing  legislation  but  noted  “soft  tools”  often  take  longer  to  effect  change, 
therefore making it challenging for the strategy to contribute to its objectives. 

Efficiency 

Stakeholders provided only limited information as regards the efficiency of the strategy 
(i.e. the cost and benefits associated with the implementation of the strategy) making it 
difficult to draw detailed conclusions on the matter based on the consultation process.  

Costs  

Stakeholders  tended  to  have  low  levels  of  familiarity  with  the  funding  and  human 
resources associated with the strategy. However, interview and survey data provided 
insights into some of the costs that stakeholders incurred: 

  The  Commission  incurred  costs  related  to  consultation,  studies  and  reports, 
monitoring  and  enforcement  activities,  guidelines,  training,  international 
cooperation activities, and scientific advice.  

  Member  State  representatives  and  business/trade  associations  and  individual 
businesses  incurred  costs  relating  to  consultation,  monitoring  compliance, 

87 

 
attending  and  providing  training  sessions,  contributing  to,  disseminating  and 
using  guidelines,  and  consultation  activities,  although  it  is  not  always  clear 
whether  such  costs  would  have  also  been  incurred  in  the  absence  of  the 
strategy. Some stakeholders also noted that businesses may also have incurred 
costs  relating  to  training  and  other  related  activities  such  as  peer-to-peer 
exchanges, and interview data suggests that Member State representatives and 
business/trade associations and individual businesses may have incurred small 
to moderate costs related to guidelines and consultation activities.  

  NGOs  and  professional  organisations  reported  costs  related  to  consultation 
activities,  monitoring  and  enforcement,  guidelines  and  scientific  advice.  A 
very  small  number  also  reported  costs  related  to  contributing  to  studies  and 
reports and training. 

  Businesses may have also incurred costs related to technology and production 
costs, such as acquiring new infrastructure or hiring additional personnel, but 
it is unclear to what extent these can be considered additional costs. 

Comparison of costs and benefits 

Stakeholders  had  mixed  views  on  the  cost-effectiveness  of  the  strategy.  Among 
respondents  to  the  targeted  survey,  most  likely  to  say  they  did  not  know  whether  the 
benefits of the strategy outweighed the costs, reflecting low levels of familiarity with the 
strategy’s costs, but were more likely to disagree than agree that the benefits outweighed 
the cost. NGOs were more likely to state that the strategy was not cost-effective, while 
Member State representatives were more likely to state that is was. 

Stakeholders tended to disagree that the strategy received sufficient funding and human 
resources, although interview data suggests there may have been sufficient resources at 
early stages.  

Most stakeholders also disagreed that the costs and benefits of the strategy were equally 
distributed  across  sectors  and  countries,  although  data  is  limited.  Among  survey 
respondents,  a  clear  majority  of  individual  businesses  and  business  associations 
disagreed  that  costs  and  benefits  had  been  equally  distributed,  and  individual  business 
and business associations tended to emphasise the costs they had incurred, in some cases 
without any perceived benefits.  

Stakeholders had mixed perceptions on whether the benefits achieved justified the costs 
incurred. Some participants from EU institutions or EU bodies generally felt that it would 
not  have  been  possible  to  achieve  the  benefits  produced  under  the  strategy  with  fewer 
resources, as resources were already limited. A few NGOs stated that the entire strategy 
or  particular  aspects  of  the  strategy  did  not  represent  value  for  money,  while  several 
Member State representatives, who focused on the monitoring and enforcement activities 
and  training,  thought  that  resources  had  been  used  effectively.  Some  stakeholders  felt 
that  it  was  not  possible  to  assess  whether  the  resources  were  used  efficiently,  and 
therefore whether the benefits were proportionate to the costs incurred, due to a lack of 
indicators. 

Simplification and clear principles  

Overall, stakeholders had mixed views on the extent to which the strategy simplified and 
developed  clear  principles  on  animal  welfare.  Among  those  who  felt  the  strategy  had 
simplified  requirements  for  animal  welfare,  most  explained  that  this  was  due  to  the 
guidelines  produced  under  the  strategy.  The  consultation  suggest  that,  while  guidelines 
were  generally  seen  to  be  helpful,  they  are  also  seen  as  limited,  because  they  are  not 

88 

 
legally binding. Some participants expressed that better, more specific legislations would 
be  more  effective.  Additionally,  a  few  stakeholders  mentioned  training  and  mentioned 
advice from EFSA as contributing to the simplification of animal welfare requirements. 

Competitiveness and sustainability   

There is limited data from stakeholders on the impact of the strategy on competitiveness. 
Survey  data  shows  that  stakeholders  tended  to  disagree  that  the  strategy  has  had  a 
positive impact on competitiveness, but this varied by stakeholder group, with individual 
businesses and business  associations and professional organisation being more likely to 
disagree than Member State representatives and NGOs. A few respondents who provided 
qualitative comments noted that consumers globally are less concerned about the welfare 
of  animals,  which  makes  EU  farmers  less  competitive  due  to  increased  cost  and  lower 
returns. 

There  is  also  limited  data  from  stakeholders  on  the  impact  of  the  strategy  on 
sustainability.  Survey  data  shows  that  respondents  were  more  likely  to  agree  than 
disagree that the strategy had contributed to the sustainability of EU industry. However, 
individual  businesses  and  business  associations  and  Member  State  representatives 
emphasised the costs that improving animal welfare can impose on industry, which they 
perceived may not be sustainable for farmers from an economic point of view. It was also 
noted  that  there  was  tension  between  animal  welfare  interests  and  environmental 
interests. 

EU Added Value 

The EU added value refers to the positive effects and results resulting from the strategy 
compared to action at Member State level or individual EU actions.  

Most  stakeholders,  including  organisations  and  individuals,  agreed  that  the  strategy 
achieved results that could not have been achieved through national interventions alone. 
They  also  tended  to  agree  that  the  strategy  achieved  resulted  that  would  not  otherwise 
have been achieved at EU-level.  

Regarding the factors that led to EU-added value: 

  Stakeholders  tended  to  emphasise  coordination  and  synergy  gains.  Interview 
participants  similarly  emphasised  the  importance  of  the  strategy  in  setting  a 
clear  vision  for  action,  establishing  a  roadmap,  ensuring  accountability  and 
motivating action.  

  There  were  mixed  perceptions  on  the  extent  to  which  the  strategy  enabled 
greater  leverage  when  negotiating  standards  with  non-EU  countries  or 
level  and  enhanced 
promoting  EU 
competitiveness.  While  some  stakeholders  thought  these  were  important 
factors  contributing  to  EU-added  value,  some  emphasised  ongoing  (or 
increasing)  differences  between  standards  and  costs  in  EU  and  non-EU 
countries, negatively impacting competitiveness.  

standards  at  an 

international 

  Some  stakeholders  also  mentioned  increased  efficiency  or  effectiveness 
compared  to  national  level  action  or  other  EU-level  action  and,  to  a  lesser 
extent, reduced administrative burden.  

Among  those  who  did  not  agree  that  the  strategy  achieved  results  that  could  not  have 
been achieved through national interventions alone, it was felt that (some) actions would 
have happened anyway, particularly where these related to existing legislation or within 
Member States with a strong interest in animal welfare. 

89 

 
ANNEX 3: METHODS AND ANALYTICAL MODELS 

1.  CONSULTATION ACTIVITIES  

Consultation  activities  can  be  divided  between  targeted  consultation  activities  and  the 
online public consultation:  

 

 Open  public  consultation  in  23  EU  languages.  This  activity  provided  any 
interested  party,  not  consulted  under  the  other  activities,  the  possibility  to 
contribute  to  the  evaluation.  A  dedicated  webpage  page  was  available  on  the 
Commission’s Better Regulation Portal;  

  Foreseen targeted consultation activities included:  
  Interview(s)  to  collect  detailed information  on different  aspects  of the evaluation 
and  also  cross  check  findings  drawn  from  other  activities  groups.  They  were 
conducted  throughout  the  entire  evaluation  process,  both  at  Member  State  level 
(also  in  the  context  of  case  studies/in-depth  pieces  of  analysis),  EU  and 
international levels; 

  Targeted survey(s) designed for specific preselected stakeholders groups (instead 

of, or in addition to an interview). 

  Stakeholders’  validation  workshop  aimed  to  inform  and  validate  preliminary 

findings of the study. 

2.  MAIN MEETINGS, EVENTS AND TOOLS USED TO INFORM STAKEHOLDERS:  

  EU  Platform  on  animal  welfare  –  a  forum  guttering  75  Members  representing 
public entities (EU/EEA countries, EU bodies and international organisations) and 
private  stakeholders  of  the  animal  welfare  sector  (business  and  professional 
organisations, organisations from civil society, independent experts from academic 
and research institutes); 

  Meetings  of  the  Standing  Committee  on  Plants,  Animals,  Food  and  Feed  (PAFF 

Committee); 

  Regular  consultative  committees  such  as 

the  Animal  Health  Advisory 

Committee; 

  Others (e.g. Steering Group of the OIE Platform on Animal Welfare, Council 

of the EU and other). 

  The  EU  Platform  digital  tool,  DG  SANTE’s  website  and  the  Commission 
Better  Regulation  portal  have  been  regularly  updated  with  the  most  recent 
developments all along the evaluation process.  

3.  EXTENSIVE DESK RESEARCH  

It included a detailed review of all existing quantitative and qualitative data and evidence 
focusing primarily on: EU policy documents, EU legislative documents, EU reports and 
communications on animal welfare; national reports and other relevant documents, audit 
reports,  national  action  plans,  international  reports  on  animal  welfare  standards  and 
policies,  various  web-based  sources  from  relevant  stakeholders,  academic  publications, 
scientific  opinions,  consumer  opinions  on  animal  welfare,  and  competitiveness  in  the 
farmed animal sector, among others.  

90 

 
 
 
 
4.  CASE STUDIES  

The data collected through desk research and the set of consultations activities have been 
additionally supported by eight cases studies (see annex 9 of the study) aimed to assess 
the extent to which the actions of the strategy contributed to its planned objectives. Each 
case  study  explored  the  impact  for  each  delivery  model  of  the  strategy  in  order  to 
understand  the  processes  and  what  contributed  to  the  outcomes.  The  eight  case  studies 
used contribution analysis, comparative analysis and assessment of opportunity costs to 
provide  further  evidence  for  all  the  questions  under  effectiveness.  These  findings  were 
validated during the stakeholders’ workshop.  

5.  INTERVENTION LOGIC 

The  initially  developed  intervention  logic  served  as  valuable  tool  for  the  contractor  to 
establish  a  clear  link  between  the  evaluation  questions  to  be  addressed  and  the 
corresponding methodology. The intervention logic helped the contractor to  understand 
the initial intention of the Commission at the time of the adoption of the strategy and how 
the  strategy  evolved  with  the  time.  Detailed  analysis  based  on  the  intervention  logic  is 
available in Annex 1 of the study.  

6.  EVALUATION MATRIX 

The study team developed an extensive evaluation matrix (see annex 7 of the study) that 
articulates evaluation questions to sub-questions, success or judgment criteria, targets or 
indicators, data sources, stakeholders involved, and data analysis methods.  

7.  TRAFFIC LIGHT ASSESSMENT  

The study team has also produced a traffic light assessment (see Annex 3 of the study), to 
assess the extent to which each of the 20 actions have contributed to the six objectives. 
The traffic light assessment is a rating system for evaluating the performance in relation 
to a goal. The assessment aimed to establish the degree of implementation of the twenty 
actions  defined  under  the  strategy.  It  was  used  to  answer  the  effectiveness  question 
“extent  to  which  the  20  actions  have  contributed  to  achieving  the  objectives  of  the 
strategy” and triangulate evidence for the rest of the effectiveness questions.  

8.  TRIANGULATION  

To ensure robustness of findings triangulation of methods/data/sources was used by the 
study team in both quantitative and qualitative evidence. Triangulation was done with at 
least two statistically representative sources. Non-representative sources from a statistical 
point  of  view,  including  surveys,  interviews  and  validation  workshop  were  used  in 
two. 
the 
addition 

above 

to 

91 

 
  
 
 
 
ANNEX 4: LIST OF ACTIONS UNDER THE STRATEGY AND OVERVIEW TABLE  

Table 1: List of actions under the Strategy 

Actions 

Completion details 

Series of enforcement actions on the protection of laying 
hens (Directive 1999/74/EC) * 

Implementing plan and enforcement actions on the 
grouping of sows (Directive 2008/120/EC) * 

Implementing plan for the slaughter regulation (Council 
Regulation (EC) N° 1099/2009) 

2012 

2012 

2012 

1 

2 

3 

4 

EU guidelines on the protection of pigs 

5  Report to the European Parliament and the Council on 
the impact of genetic selection on the welfare of 
chickens bred and kept for meat production* 

6  Report to the European Parliament and the Council on 
the application of the Regulation (EC) No 1523/2007 
banning the placing on the market of cat and dog fur*  
2012 

7 

8 

Report to the European Parliament and the Council on 
the various stunning methods for poultry * 

Study on the opportunity to provide consumers with the 
relevant information on the stunning of animals* 

Commission Recommendation 
(EU) 2016/336 of 8/3/ 2016 
SWD (2016) 49 final - Staff 
Working Document 

COM(2016) 182 adopted on 
7/04/2016  

2013 

2013 

2015 

9  Report to the Council on the implementation of Directive 

98/58/EC 

10  Report to the European Parliament and the Council on 
system restraining bovine animals by inversion or any 
unnatural position* 

11  Study on the welfare of dogs and cats involved in 

commercial practices 

12  Study on animal welfare education and on information 
activities directed to the general public and consumers 

COM/2016/0558 final 
Adopted on 8/9/2016 

COM/2016/048  Adopted 
8/02/2016 

Published on web 15/3/2016 
Click here to access 

Published on 15/3/2016 
Click here to access 

92 

 
 
 
 
 
Actions 

Completion details 

13  EU implementing rules or guidelines on the protection of 
animals during transport: a pilot project on best practices 
for animal transport 

14  Report to the European Parliament and the Council on 

the application of Directive 2007/43/EC and its influence 
on the welfare of chickens bred and kept for meat 
production 

15  Report on the impact of animal welfare international 

activities on the competitiveness of European livestock 
producers in a globalised world 

16  EU guidelines or implementing rules on the protection of 

animals at the time of killing 

17 

18 

Study on the welfare of farmed fish during transport  

Study on the welfare of farmed fish at the time of killing 

19  Report to the European Parliament and the Council on 
the possibility of introducing certain requirements 
regarding the protection of fish at the time of killing* 

Published in September 2017 
Click here to access  

COM(2018)181 adopted on 
13/04/2018 

COM(2018)42 final adopted 
on 26/01/2018  

Published on web 07/2018 
Click here to access  
Published on web 10/2017 
Click here to access  

Published on web 10/2017 
Click here to access 

COM(2018)087 final adopted 
on 6/3/2018  

20 

Possible legislative proposal for a simplified EU 
legislative framework for animal welfare 

dropped 

* Obligations deriving from EU legislation 

93 

 
 
 
 
 
 
 
Table 2: overview of the strategy objectives, the changes that have influenced them 
and their degree of relevance. 

1.CONSIDER THE FEASIBILITY OF 
INTRODUCING A SIMPLIFIED EU 
LEGISLATIVE FRAMEWORK FOR 
ANIMAL WELFARE  

• Science and technological progress 
• Consumer awareness 
• Member State, private sector and NGO initiatives  

2.DEVELOP TOOLS  

TO STRENGTHEN  

MEMBER STATES' COMPLIANCE 

• Science and technological progress 
• NGO Initiatives  
• Consumer awareness  

3.INVESTIGATE ON THE 
WELFARE OF FARMED FISH 

• Science and technological progress 
• Consumer awareness 
• NGO initiatives 

4.SUPPORT INTERNATIONAL 
COOPERATION  

• Consumer awareness 
• Member State and private sector initiatives 
• Increased animal trade data 

5.OPTIMISE SYNERGISTIC 
EFFECTS FROM CURRENT 
COMMON AGRICULTURE POLICY 
(CAP) 

• Consumer awareness 

6.PROVIDE CONSUMERS AND 
THE PUBLIC WITH APPROPRIATE 
INFORMATION  

• Increased consumer awareness 
• Member State, private sector and NGO initiatives 

(e.g. labelling schemes)  

OBJECTIVES           

CHANGES    

DEGREE OF RELEVANCE 

Maintained with limited progress made during the strategy  

Maintained with progress made during the strategy  

Increased degree of relevance  

94 

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i

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a

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W

e

l

f

a

r

e

S

e

 
 
  
  
  
 
 
 
 
ANNEX 5: OVERVIEW OF COSTS – BENEFITS IDENTIFIED IN THE EVALUATION 

Citizens/Consumers   Businesses and business 

associations  

Member States 
Authorities 

NGOs and Professional 
organisations 

European Commission 

Qualitative  Quantitative 
/ monetary 

Qualitative  Quantitative 
/ monetary  

Qualitative  Quantitative 
/ monetary  

Qualitative 

Quantitative / 
monetary 

Qualitative 

Quantitative / 
monetary 

Cost / Benefit151  
[name] 

[high / 
medium / low 
/ negligible / 
unknown 

Sources [KPIs 
stakeholders?
?] 

[e.g. increase or 
decrease in: 
time taken, 
person days, 
full-time 
equivalents, 
numbers of 
certificates/tonn
es of CO2 
equivalent / 
employment 
rate / GDP /  
life expectancy 
etc 

or 

€ ] 

[Description:  
e.g. 
= economic, social, 
environmental 
=  one off/recurring 

= Type of 
cost/benefit: 
e.g. compliance 
costs, regulatory 
charges, hassle 
costs, 
administrative 
costs, enforcement 
costs, indirect costs  
Changes  in 
pollution, safety, 
health,  
employment 

= Expected?  
prediction from IA 
Unexpected?] 

151   Report under benefits any actual savings, including REFIT savings predicted in the IA. Potential savings identified as a result of the evaluation findings should be reported in a 

separate table.  

95 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
                                                           
Cost: strategy 
consultation 

Administrative 
costs 

Some increase 
in time taken 
and person days 

Moderate 
increase in 
time taken and 
person days 

Some increase 
in time taken 
and person days 

High increase in 
time taken and 
person days 

Citizens/Consumers   Businesses and business 

associations  

Member States 
Authorities 

NGOs and Professional 
organisations 

European Commission 

Qualitative  Quantitative 
/ monetary 

Qualitative  Quantitative 
/ monetary  

Qualitative  Quantitative 
/ monetary  

Qualitative 

Quantitative / 
monetary 

Qualitative 

Quantitative / 
monetary 

Estimated at €1.3 
152
million

Costs:  
Studies and 
reports 
produced under 
the strategy 

Administrative 
costs  

Costs:  
Monitoring and 
enforcement 

Administrative, 
compliance and 
enforcement costs 

Increased 
Equipment, 
technology and 
production 
costs. Setting 
up voluntary 
welfare 
monitoring 
systems for 
farmers 

Benefit: 
Improved 

Reduced use of 
sow stalls for pigs 

Increased profit 
and high 

152 Actual costs should be larger because not all costs can be precisely estimated. 

Participation in 
the pilot 
dialogue 
schemes, 
meetings and 
producing 
action plans 

Increase in time 
taken and person 
days due to EU 
pilot dialogue 
schemes, audits, 
action plans, 
meetings, best 
practices, actions 
against non-
compliant 
Member States 
and other. 

Increased 
audits and 
inspections at 
national level, 
increased 
government 
resources, 
participation in 
meetings (e.g. 
NCPs on 
transport and 
other) and an 
increase in 
human 
resources to 
conduct 
various 
welfare 
checks. 

96 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
                                                           
enforcement and 
compliance  

(2008/120/EC). 
Reduced use of 
unenriched cages 
for laying hens 
(1999/74/EC). 
Improved 
enforcement of the 
transport 
(Reg.1/2005), 
slaughter (Reg. 
1099/2009) and to 
some extent of 
farming legislation 
(1998/58/EC).  

Costs:  
Guidelines 

Production, 
consultation, 
translation and 
dissemination costs  

Benefit:  
Increased 
knowledge  

Costs:  
Training 

Costs:  
International 
cooperation 

Commission BTSF 
and others  

153 Estimates based on no robust evidence. 

quality 
products

153

. 

Some 
consultation 
and 
dissemination 
costs. 

Moderate 
consultation, 
translation and 
dissemination 
costs. 

Some 
consultation, 
translation and 
dissemination 
costs. 

Medium 

High/medium 

Medium/low 

Increased 
production, 
consultation, 
translation and 
dissemination 
costs 

High/medium 

Costs related to 
participation in 
training 
activities. 

Participation in 
international 
meetings. 

Approximately €3.5 
for BTSF between 
2012 and 2016. 

International 
actions spent 
approx. €847,000 
for activities 
between 2012 and 
2015. 
Commission 
154
grants

 to the OIE 

Costs related to 
participation in 
training 
activities. 

Participation in 
international 
meetings. 

Costs related 
to participation 
in training 
activities. 

Participation 
in 
internationals 
meetings 
organised by 
the 
Commission, 
OIE, FAO, 

97 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
                                                           
Benefit:  
Increased 
international 
competitiveness
155

Costs:  
Scientific advice 

Costs: 
EURCAWs 

Costs:  
Increased 
synergies with 

third countries 
etc.  

Low 

Medium/low  

Medium/low 

Some costs for 
research  

Some costs at 
national level  

Costs related 
to participation 
in some of the 
EURCAWs 
activities and 
meetings. 

show around €3 
million budget used 
between 2012 and 
2018. 

Funding documents 
show that €1 
million was 
budgeted for 
EUWelNet, while 
FareWellDock 
received funding as 
part of the 
ANIHWA project, 
which had planned 
funding of 
approximately €2 
million in total. 

Budget for the first 
few months of 
operation in 2018 of 
the EURCAW on 
pigs was 87.000 
. 
EUR

156

Low costs 
associated with 
meetings and 

154 Commission Grants to the OIE to support actions such as OIE global conferences, regional seminars, meetings and activities on both animal health and welfare. 

155   Insufficient evidence to measure it.   

156   These figures increased with the number of activities and the number of new EURCAWs in the forthcoming years which are out of the time scope of this analysis.  

98 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
                                                                                                                                                                                                                                                                                                       
CAP 

Costs:  
Technology and 
production costs 

Cost/Benefit 
EU Platform on 
Animal 
Welfare

158 

Commission expert 
group established 
in 2017 
contributing to 
improved dialogue 
with stakeholders, 
sharing best 
practices and 
improving 
knowledge.  

Costs of 
infrastructure, 
technology, 
time, human 
resources and 
research

157

. 

Costs related to 
participation 

Costs related 
to 
participation, 
dissemination 
and translation 
of guidance. 

Costs related to 
participation, 
dissemination 
and translation 
of guidance. 

operation of 
existing 
mechanisms for 
cooperation.  

Approximate 
operational budget 
of the EU Platform 
and its two sub-
159
 since 
groups
their creation until 
the end of 2018 -   
89.000 EUR 

Commission staff 
engaged in the 
organisation, 
management and 
participation of 
the EU Platform 
meetings and its 
sub-groups (e.g. 
on animal 
transport and 
welfare of pigs) 

157   These costs are not considered a cost of the strategy, as these would have been incurred anyway as largely appear to relate to pre-existing legislative requirements. 

158   The EU Platform on Animal Welfare is largely perceived by stakeholders as a follow-up and natural continuation of the strategy.  

159   The first sub-group, focused on Animal Transport, was established in early 2018; a second one, on Pigs, was created in September 2018. 

99 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
                                                           
ANNEX 6:  SUMMARY OF COSTS

160

A summary of the types of costs incurred by stakeholder group and, where possible based 
on data availability, a qualitative assessment of the scale of this cost, is presented in Table 
below. The possible scorings used by the study team are as follows: 

one asterisk (*): indicates a relatively small cost;  

two asterisks (**): indicates a relatively large cost; 

a dash (-): indicates where a cost is not applicable; 

a zero (0): indicates where a cost is applicable but was not incurred; and 

a tick (

): indicates where the study team identified that stakeholders within a certain 

group incurred a cost, but was unable to judge its scale. 

Heterogeneity  in  the  scale  of  costs  incurred  by  a  stakeholder  group  is  indicated  by 
multiple  values,  divided  by  a  forward  slash.  The  reasons  for  the  scores  provided  are 
given  in  the  “explanation”  column,  and  the  data  sources  used  to  make  the  judgement 
are provided in the “data sources” column. 

160 As identified by the study report (Table 16) 

October,  2020 

100 

100 

 
 
 
  
 
                                                           
Summary of costs incurred due to the strategy by cost type and stakeholder group 

d
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a
s
e
i
d
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n
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i
t
u
t
i
t
s
n
i

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N
A
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e
t
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e
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a
n
o
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n
a

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n
a
s
e
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i
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s
n
o
i
t
a
i
c
o
s
s
a

s
s
e
n
i
s
u
b

Strategy 
consultatio
n 

Studies and 
reports 

**  - 

- 

-161 

- 

Explanation 

Data sources 

While the level of engagement with the Commission appears to vary by 
stakeholder, as some mentioned ongoing engagement with the 
Commission while some do not mention any, the scale of these costs 
and how they compare to business as usual costs is unclear. EU 
bodies/institutions, NGOs, business associations and Member State 
representatives described involvement in consultations, meeting and 
discussions with the Commission related to the strategy during the 
implementation period. Additionally, stakeholders described 
involvement in consultations on the design of the strategy, but this is 
not included here as it falls outside of the period covered in this study.  

The only 
available source 
of data on 
consultation 
activities is 
limited interview 
data.  

Stakeholders within EU institutions stated that funding for studies and 
reports produced by external contractors was the largest direct cost of 
the strategy for DG SANTE. Estimates based on available budget 
documents suggest that more than €1.3 million was set aside for studies 
and reports, supporting the finding from interview data that this was a 
substantial area of cost. 

Assessment of 
the scale of this 
cost type is based 
on interview data 
and a review of 
budget 

161 With the exception of one NGO, who described substantial costs, NGOs and professional organisations did not describe costs related to studies or reports. 

101 

 
 
                                                           
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
**  - 

Monitoring 
and 
enforcemen
t 

documentation. 

Interview data, 
targeted surveys 
and documents 
provided 
evidence on the 
types of 
monitoring and 
enforcement 
activities 
undertaken by 
stakeholders and 
the likely scale 
and cost of these. 

An NGO also described investing “significant resources” into the 
deliverables of the strategy in an interview, but others did not mention 
incurring any such costs. 

The data suggest that some, but not all, Member State representatives 
also incurred costs related to monitoring compliance.  Of those who 
reported costs, some Member States reported only limited additional 
costs, while others, particularly those who participated in a pilot 
programme, may have incurred more substantial costs. Additionally, it 
can be expected that Member States would have required resources to 
produce action plans, although this was not mentioned by stakeholders. 

Business/trade associations and businesses may have also incurred costs 
related to monitoring compliance, although it is unclear how 
widespread or significant these costs were. This finding is based 
primarily on survey data; among interview participants, only one 
business association mentioned a cost related to monitoring and 
enforcement. 

A minority of NGOs and professional organisations may have also 
incurred costs related to monitoring compliance, although this finding is 
based on limited survey data. DG SANTE staff undertook a wide range 
of relevant activities, including audits, infringement proceedings and 
work with Member States. Some of these activities were extensive, such 
as a two-year project on tail docking and tail biting which included 12 
audits. Due to the number of activities and the scale of some of these 
activities, the study team has judged this was a large cost to DG 
SANTE. 

Guidelines  **  -/* 

All stakeholder groups reported costs relating to developing guidelines, 
including participation in relevant working groups. The scale of this 
activity is unclear, although at least one mentioned there was “lots of 

Assessment on 
the scale of the 
costs of 

102 

 
 
 
 
 
 
 
 
guidelines comes 
primarily from 
interview data, 
with some 
evidence also 
from documents. 

stakeholder involvement” (A6), suggesting a moderate cost. 

There is some evidence that DG SANTE and other stakeholders 
translated guidelines, although the extent to which this was done varied 
by output. It is not clear how large this cost was. 

Some stakeholders, including Member State representatives, NGOs, 
professional organisations and business/trade associations and 
businesses, described producing additional guidelines. The nature of 
this task suggests it was at least moderately burdensome. However, the 
extent to which this was done, the scale of this cost and the extent to 
which this work can be considered a cost related to the strategy is not 
clear.  

Stakeholders also described dissemination costs, including the costs of 
dissemination roadshows. While evidence is limited, this was likely a 
fairly large cost for DG SANTE. 

There is no clear evidence that EU bodies and institutions incurred any 
significant costs related to guidelines. One interview participant from an 
EU institution mentioned reviewing one of the guideline documents, 
which suggests that if such costs incurred, they were minimal. While all 
stakeholder groups reported costs, it is unclear what proportion of 
stakeholders these costs apply to, and some did not report any relevant 
costs.  

Training 

-162 

DG SANTE was consulted on training topics and involved in planning 
training, and budget information shows a significant amount of 
expenditure on BTSF trainings specifically related to animal welfare 
during the strategy period. However, it is not clear to what extent the 

Assessment 
based on 
interview data, 
targeted survey 

162 One professional organisation did mention providing training, but no other professional organisations and no NGOs mentioned this. 

103 

 
                                                           
 
 
 
 
 
Internation
al 
cooperation 

- 

- 

Scientific 
advice 

- 

- 

- 

budget was influenced by the strategy. 

Many Member State representatives participated in relevant training, 
although it is also unclear what level of cost they incurred as a result, 
and how this would have differed from training costs that they would 
have incurred in the absence of the strategy. Some also described 
providing additional training as a result of the strategy. There is very 
limited information on the scale of such costs, although one interview 
participant suggested the costs had been quite substantial in their 
Member State.   

NGOs did not report participating in or providing training, although one 
professional organisation mentioned providing training for 
veterinarians. 

Business/trade associations and businesses may have incurred training 
costs, but this is based primarily on survey data.  

While budget information shows that a significant amount of funding 
was allocated to international cooperation activities, including training 
on animal welfare and funding to the OIE, it is unclear to what extent 
this funding was additional, and therefore it is difficult to judge the 
scale of these costs.       

The Commission funded many relevant scientific studies during the 
strategy’s period, however the extent to which the funding for these 
studies was influenced by the strategy is unclear, especially as a number 
of these studies began before the strategy period. 

EFSA produced relevant scientific advice during the strategy period and 
was influenced to do so by the strategy. However, it is unclear to what 
extent EFSA incurred any costs compared to business as usual as a 
result.  

and budget 
information. 

Assessment 
based on 
interview data 
and document 
review. 

Assessment 
based on 
interview data 
and document 
review. 

104 

 
 
 
 
 
 
EURCAWs  - 

- 

- 

Increased 
synergies 
with CAP 

0/
* 

0/* 

- 

- 

- 

- 

- 

- 

- 

- 

- 

-/** 

- 

- 

- 

- 

- 

Technology 
and 
production 
costs 

EU 
Platform on 
Animal 
Welfare 

There is limited evidence that professional organisations also 
contributed to scientific advice, including the development of indicators 
and risk assessments. 

The study team has judged that there are no relevant costs attributable 
to the strategy, as documents state that the EURCAWs were created in 
response to the Official Controls Regulation rather than the strategy. 

Assessment 
based on 
document review.   

This data suggests that no stakeholders incurred any formal costs 
incurred in improving synergies between the strategy and the CAP, 
although informal discussions between DG SANTE and DG AGRI 
using existing structures were reported. 

While stakeholders reported that businesses had incurred such costs, it 
is not clear that these costs were additional, in the sense that they may 
be costs of complying with legislation rather than related to the strategy. 
The extent to which costs were burdensome may vary by business size 
and business type, but this finding is based only on a very limited 
amount of qualitative data. 

As the Platform was not a planned action of the strategy, the study team 
has judged that there are no relevant costs that are directly attributable 
to the strategy. However, Platform members, which include EFSA, 
Member State representatives, independent experts, NGOs/CSOs, 
business associations and the Commission are expected to have incurred 
costs related to participating in twice yearly Platform meetings, 
participating in sub-groups, which entailed attending meetings and 
contributing to documents such as guidance documents, fact-sheets and 
recommendations, and participating in voluntary initiatives. There is no 
data available on the costs of this work and how this may have varied 
between stakeholders. 

Assessment 
based on 
interview data 
only. 

Assessment 
based on 
interview and 
survey data. 

Assessment 
based on the 
strategy, and 
relevant 
information 
about possible 
costs are from 
available 
documents, 
interviews and 
feedback from 
the Commission. 

105