Opinion of the European Economic and Social Committee – Proposal for a Regulation of the European Parliament and of the Council on the protection of animals during transport and related operations, amending Council Regulation (EC) No 1255/97 and repealing Council Regulation (EC) No 1/2005 (COM(2023) 770 final – 2023/0448 (COD))
Date: 2024-05-31
Institutions: European Economic and Social Committee
Subjects: animal welfare, economic activity, international transport, intra-EU transport, protection of animals, transport of animals, veterinary inspection




C_202404670EN.000101.fmx.xml












Official Journal of the European Union


EN
C series













C/2024/4670


9.8.2024






Opinion of the European Economic and Social Committee

Proposal for a Regulation of the European Parliament and of the Council on the protection of animals during transport and related operations, amending Council Regulation (EC) No 1255/97 and repealing Council Regulation (EC) No 1/2005


(COM(2023) 770 final – 2023/0448 (COD))

(C/2024/4670)


Rapporteur: 
Jaume BERNIS CASTELLS






Advisor


Manuel LINARES ÁVILA (to the rapporteur)




Legislative procedure



2023/0448 COD





Referral


European Parliament, 26.2.2024
Council of the European Union, 6.3.2024




Legal basis


Articles 43, 114 and 304 of the Treaty on the Functioning of the European Union




European Commission documents



COM(2023) 770 final

Summary




Relevant Sustainable Development Goals (SDGs)



SDG 1; 2; 3; 4; 5; 6; 8; 10; 11; 12; 13; 14; 15





Section responsible


Agriculture, Rural Development and the Environment




Adopted in section


21.5.2024




Adopted at plenary session


31.5.2024




Plenary session No


588




Outcome of vote (for/against/abstentions)


167/5/6




1.   Conclusions and recommendations

The European Economic and Social Committee (EESC),








1.1.


Supports the implementation and harmonised enforcement of regulations, backed by scientific evidence and operators’ empirical experience. Therefore points out that the Commission proposal must take into account the practical knowledge of farmers, transporters and veterinarians.












1.2.


Acknowledges that transporting animals entails known risks to their welfare, as evidenced in scientific reports by the European Food Safety Authority (EFSA).












1.3.


Warns that any rule imposed on European producers will only be accepted if equivalent conditions for imports are included in bilateral trade agreements.












1.4.


Understands that legislation that is not capable of adapting to the varied circumstances in the 27 Member States will open the door to asymmetrical or imbalanced situations. Similarly, it recognises that the needs and vulnerabilities of animals are the same everywhere.












1.5.


Calls on the Commission to ensure that the costs associated with the implementation of this new regulation are not borne by stakeholders in the sector. Also calls for a specific source of funding, independent of the funds earmarked for the common agricultural policy (CAP), to enable operators to meet these new requirements.












1.6.


Does not consider supervision by a veterinarian to be necessary when loading animals on a vehicle is carried out by a qualified and authorised person, who may be the farmer, the transporter or a third party, or when the journey is duly recorded in the TRACES system.












1.7.


Emphasises that the provisions laid down in the proposal for a regulation require operators to work night shifts (especially farmers, drivers and veterinarians). The EESC highlights the danger posed to workers by the obligation to work at night. This risk is not only evidenced by the statistic showing an accident rate up to ten times higher compared with daytime work, but also in the difficulties that such workers will face in striking a work-life balance. This situation could have adverse consequences for workers’ mental health, further exacerbating the challenges they face on a day-to-day basis. The EESC therefore proposes adopting legislation on the internal temperature of the vehicle’s load compartment instead of regulating the times at which the journey is authorised, and calls on the Commission to propose alternative solutions to those envisaged in its current proposal that offer a long-term solution that will not have a negative social, economic and environmental impact. It is essential to find a balance to improve animal welfare without compromising workers’ stability and safety at work.












1.8.


Calls on the Commission to consider the impact this proposal will have on supply chains that have been built and distributed over the years on the basis of current time constraints. The EESC points out that change is only possible if adequately supported by the national and European institutions, with funds other than CAP funds.












1.9.


Warns that limiting transport to a slaughterhouse to nine hours would discriminate against producers in Member States where journeys involve long distances or mountain regions or remote areas or areas lacking developed infrastructure, who would lose their freedom to choose and negotiate, and urges the Commission to reverse the current trend of closing local slaughterhouses.












1.10.


Considers that new proposed technical standards on the fitness for transport of terrestrial animals could lead to the closure of many livestock farms. The repercussions of these new technical specifications threaten the viability of farms and the livelihoods of those who depend on them. The EESC therefore calls for a detailed impact study for each livestock sector, given that the change proposed by the Commission will have a massive impact on the structure, investments and management of existing livestock farms in the EU. If the change is applied across the board, many farms will be forced to cease their activity.












1.11.


Believes that the ban on transporting young animals (such as calves, lambs, kids, piglets and foals, which have not been weaned) on long road journeys will have a significant impact on imports of animal breeds from other EU Member States. The EESC does not endorse limiting the genetic diversity and quality of animal breeds available to local producers, which could be detrimental to the competitiveness and sustainability of their livestock farms.












1.12.


Calls on the Commission to take into account the climate-related characteristics of each Member State in relation to Article 31 of the proposal, takes the view that the ban on the transport of animals at certain temperatures appears merely to be a temporary solution that does not adequately address long-term animal welfare in the light of ongoing climate change, and considers it essential to find coherent, more sustainable and truly effective solutions to mitigate the effects of global warming and its impact on animal welfare, without compromising the viability of the sector or the welfare of its workers.












1.13.


Warns that increased space between animals in load vehicles could increase the risk of falls and injury. Reducing animal density and journey times also means more trucks on the road and more CO2 emissions.












1.14.


Maintains that it is essential to promote short supply chains as an effective solution for reducing the need for long journeys by shortening the distance between the places the animals are reared, fattened, slaughtered and consumed.












1.15.


Calls for the importance of the rural community, its agricultural and farming practices and the long-standing traditions of each region to be taken into account. The proposed restrictions could accelerate rural depopulation and the closure or relocation of small and medium-sized livestock farms, contributing to the decline of specific farming practices in each region.












1.16.


Supports the initiatives activating sanitary, economic and legal levers to preserve local slaughterhouses and encourage on-farm slaughtering where appropriate to the size of the farm and the local context. This practice, where feasible, would reduce the need for long journeys and thus reduce both animal stress factors and CO2 emissions.




2.   Explanatory notes


Arguments in support of recommendation 1.1 on the importance of empirical knowledge









2.1.


The proposal presents technical improvements tailored to the current technological reality, but it also includes restrictive rules that may be far removed from practical experience. This could be counterproductive in certain circumstances, both for operators and for the environment.












2.2.


Livestock farmers are highly committed to ensuring that their animals reach their destination in the best possible condition, since they bear the main responsibility for looking after their farms. Moreover, they risk suffering financial losses if the animals are harmed during transport.












2.3.


The Commission and the Member States should guarantee the safety of animals during transport not via restrictive rules, but by promoting advances in scientific knowledge and establishing animal welfare indicators. These indicators could be used to check whether transport is carried out appropriately or if any changes are needed.





Arguments in support of recommendation 1.2 on risks linked to transport









2.4.


These include stress risks associated with handling animals during loading and unloading, prolonged hunger and thirst, heat stress, injuries and motion stress, as well as health risks associated with the spread of pathogens and the consequent decrease in immune defences (1).












2.5.


Similarly, the EFSA points out that increased space in the vehicle could be beneficial for the animals to adjust posture and balance better. However, this general EFSA recommendation is very different from the opinion expressed by professional transporters. They state that more space per animal means a greater risk of falls and injury (2). For example, calf transporters note that keeping the current, sufficient density helps animals cope better with jolting during journeys, thus reducing the risk of injury (3).












2.6.


Recognising the practical advantages of not counting time spent at sea as journey time as long as the animals’ physiological needs are met, as proposed by the Commission, the EESC highlights the specific risks of maritime transport to animal welfare (microclimatic conditions at port and on board, movements linked to conditions at sea, etc.), and calls on the port authorities and commercial operators to make the necessary investments to reduce these risks.





Arguments in support of recommendation 1.3 on requiring equivalent conditions for imports









2.7.


Animal welfare is a priority for farmers, who take special care of their animals on a daily basis and who seek to comply at all times with the highest standards in order to ensure the best quality of life for their livestock. However, they also need the inclusion of mirror clauses for imports to be promoted, in order to maintain market fairness and ensure that all parties follow the same rules.












2.8.


In reality, this fairness comes undone as soon as imported products which are not subject to the same requirements are allowed to enter the European market, creating a comparative disadvantage for EU producers. If the requirements applying to domestic production are to be raised, the same requirements must also be met in third countries.












2.9.


Before imposing additional requirements for European producers, it must be ensured that the bilateral trade agreements negotiated by the EU include reciprocity clauses for imported products.





Arguments in support of recommendation 1.4 on adaptation to the different Member States’ individual situations









2.10.


While aware that achieving a united Europe is contingent on finding common solutions applicable to all, the EESC maintains that it is imperative to take into account the idiosyncrasy of each Member State.












2.11.


This opinion stresses the importance of taking into account the specific geographic and climate-related characteristics of each country, especially as regards average annual temperatures, area location and size, road and infrastructure networks, and proximity to slaughterhouses.












2.12.


Similarly, it is essential to consider the various economic and social situations in order to ensure an equitable and effective approach. Each country has its own unique set of circumstances, which include aspects such as the level of economic development, social structure and wealth distribution.












2.13.


These differences can be especially marked between rural and urban areas, where living conditions, job opportunities and available resources can vary significantly. It is essential to ensure a fairer distribution of added value in the value chain, and to move towards responsible and sustainable production and consumption.





Arguments in support of recommendation 1.5 on the cost of the proposed measures









2.14.


The Commission proposal responds to society’s demand for better animal protection, with a large majority of European citizens wanting to see shorter transport times (4). However, the cost of this transition cannot fall exclusively onto consumers (5), who have been suffering food price increases for many years (6). The EESC calls on the European Commission to carry out a thorough study to assess the extent to which European families are willing to face the economic impacts of the proposed measures, particularly the increase in the final price of products.












2.15.


The EESC calls for consideration to be given – beyond the scientific studies carried out by EFSA – to the potential direct or indirect economic repercussions of the proposal, with a particular focus on the livestock and transport sectors and on rural areas (7).












2.16.


Stresses the importance of assessing the direct and indirect costs that the regulation will entail in the different areas it covers; highlights, inter alia, the provisions that will have a direct cost for livestock farmers and transporters:






(a)


the obligation for a veterinarian to be present during the loading and unloading of animals on means of transport (Articles 17 and 25);










(b)


the requirement for an animal welfare officer to be present for journeys on livestock vessels (Article 21);










(c)


the imposition of night shifts – which will occur especially frequently in Mediterranean countries – with the corresponding payment of a salary top-up (Article 31);










(d)


the refurbishment and adaptation of farms – a direct consequence for farmers, given the new considerations regarding the animals’ fitness for transport (Annex I; Chapter I; point 1);










(e)


the minimum requirements in terms of vertical height and space allowance, which will result in an increase in the number of transports required, implying greater investment in the fleet of vehicles and an increased need for labour, together with a considerable increase in CO2 emissions (Chapter III; point 6; and Chapter VII; points 1, 2 and 3).
















2.17.


The EESC calls for an assessment of the externalities caused by the current livestock production and marketing system, comparing it against alternatives involving structural changes that could reduce prolonged animal transport.





Arguments in support of recommendation 1.6 on the presence of a veterinarian or a qualified and authorised person









2.18.


The proposal states that the loading of animals on means of transport must be supervised by a veterinarian, a requirement which the EESC considers unnecessary when loading is carried out by a qualified and authorised person, who may be the farmer, the transporter or a third party. The requirements that define what makes a person qualified should be set out in a specific document.












2.19.


As asserted in various studies carried out by sectoral organisations, for loading to be supervised by a veterinarian, at least a 120 % increase in veterinary personnel would be required (8).












2.20.


Moreover, veterinarians supervising the loading of animals for transport does not provide any added value with regard to information on the health status of animals, which is already available in the automated TRACES system.





Arguments in support of recommendation 1.7 on night shifts









2.21.


The EESC considers that the provisions contained in the Commission’s proposal oblige operators to work in night shifts in certain circumstances, especially farmers, drivers and veterinarians.












2.22.


Obviously, this will be especially so in countries where average temperatures are higher (mainly southern European countries such as Croatia, Greece, Italy, Malta, Portugal and Spain, among others).












2.23.


The EESC warns that night work greatly hinders the family and social lives of such workers and can have an impact on their mental health.












2.24.


As indicated by European statistical sources on occupational accidents in transport, the probability of a collision at night is at least ten times higher than during the day (9).












2.25.


According to the recent report issued by the World Meteorological Organisation (WMO) (10), which shows an unprecedented rise in temperature over the past 30 years, Europe is on the frontline of climate change. Between 1991 and 2021, the temperature rose by 0,5 degrees Celsius per decade, a trend that was even more pronounced in areas near the Mediterranean Sea. Despite this global warming, humans are continuing to adapt to adversity and carrying out daily activities as normal. Therefore, the proposal to ban the transport of animals at certain temperatures appears to be only a temporary solution that does not adequately address long-term animal welfare in the face of ongoing climate change. Temperatures are continuing to rise with each passing year, making it necessary to seek more sustainable and effective solutions to mitigate the effects of global warming and its impact on animal welfare.












2.26.


The EESC points out that while the proposal considers the temperature at the place of departure and the place of destination, it does not take into account the thermal feeling of the compartment where the animals are transported, and calls on the Commission to take this fundamental aspect into account when determining what animals feel during the journey (11).












2.27.


Air conditioning systems can provide a suitable environment for animals during periods of extreme heat or cold, ensuring optimal temperature and humidity conditions throughout the journey. However, it is essential that this solution be economically viable for professionals in the sector. The Commission is therefore requested to carry out a detailed analysis of the costs associated with the installation and operation of air conditioning systems, as well as possible incentives and financing possibilities to improve animal welfare during transport.












2.28.


The EESC calls for a sustainable food system that takes into account extreme climate events and their impacts on farm yields and animal welfare, and urges the Commission to carry out a comparative assessment of the efficiency of public aid and its long-term viability through two approaches: the first is to finance the technical improvement of long-distance animal transport within the current business model, while the second involves financing the transition towards more sustainable livestock farming adapted to local ecosystems.





Arguments in support of recommendation 1.8 on disruptions to the logistics chain









2.29.


Supply chains in the livestock and transport sector have been developed and optimised over time, taking into account existing time constraints. The proposed new regulation imposes additional restrictions or changes in the schedules allowed for the transport of animals, with a significant impact on the efficiency and viability of the established logistics chains.












2.30.


Modifying the entire European supply system within the deadlines proposed by the Commission seems idealistic. In addition, supply chains are interconnected with other industries and sectors, meaning that any change in time restrictions for animal transport could have cascading affects across the supply chain and affect food production, distribution and availability.












2.31.


The EESC therefore stresses that it is essential that any legislative proposal that affects animal transport be carefully assessed and considered in light of the impact it may have on existing supply chains and the economy in general.





Arguments in support of recommendation 1.9 on restrictions on access to slaughterhouses









2.32.


Farmers in certain countries will be deprived of access to the slaughterhouses to which they currently transport their animals. In the most remote areas there might even be no slaughterhouses within the nine-hour range. This situation will mean not just the disruption of the distribution channel they have been using, but also a considerable reduction in their freedom of choice. The EESC urges the Commission to ensure that all farmers are able to choose the slaughterhouse.












2.33.


Statistical studies project a 58 % decrease in the export of calves for slaughter to the European Union, which is equivalent to 42 000 calves. Similarly, there is expected to be a 57 % reduction in the export of calves for slaughter to third countries, which is equivalent to 100 000 calves (12).





Arguments in support of recommendation 1.10 on the difficulty of reorganising existing farms









2.34.


The increase in the minimum age of calves to five weeks (and three weeks for piglets, lambs and kids), and their minimum weight to 50 kilograms, would force many farms to close. The farms were built for the measures currently in force; refurbishing and completely rebuilding their production structures and cycles would be not be financially viable for many of them.












2.35.


In addition, the unexpected costs associated with the need to keep livestock for longer periods could pose a significant challenge for many producers. These additional expenses may include purchasing extra food, increasing the cost of accommodation and care, as well as extra transportation costs if livestock need to be moved to alternative facilities. For many producers, especially those with tight profit margins, the inability to cover these additional expenses can lead to significant financial difficulties and even jeopardise the long-term viability of their livestock activities.





Arguments in support of recommendation 1.11 on the ban on the long-distance transport of unweaned animals









2.36.


For all the structural changes included in the proposal, even longer transition periods than those proposed would not be sufficient, as they are incompatible with the investment capacity of most producers and cooperatives, their access to finance and land, the possible implications with environmental permits, increased administrative burden, etc. The transition period for changes of the scale suggested by the European Commission with its proposal would have to be several decades (13) (while these changes would still have a major impact on competitiveness and the very existence of livestock production in the EU). We therefore call for a feasibility study and proper support for farms that would be affected by the new regulation, as otherwise we would be speeding up the closure of low resourced livestock farms.












2.37.


This restriction limits the mobility of these animals, making it difficult to transport them from their place of origin to other EU countries. As a result, breeders and farmers who rely on the acquisition of animals of specific breeds from other Member States will be adversely affected. The inability to access these specific breeds could result in decreased genetic diversity in the livestock of local breeders, which could in turn have consequences in terms of productivity, disease resistance and adaptation to changing environmental conditions.












2.38.


On the other hand, trade and competition in the livestock market would be hindered, as local breeders and farmers could face greater difficulties in obtaining certain animal breeds that are more desirable in terms of specific genetic characteristics or productivity. The Commission should propose ways to support the transition towards livestock farming that is respectful towards animals.





Arguments in support of recommendation 1.12 on temperatures









2.39.


As previously stated, the temperature ranges laid down effectively prevent any daytime movement for more than five months per year in the southern countries. The northern countries will be affected by extreme minimum temperatures.












2.40.


The deficit of 400 000 animal transport vehicle drivers needed to meet demand in Europe becomes even harder to cover considering that the obligation to work at night makes it difficult to reconcile work, family and private life (14).





Arguments in support of recommendation 1.13 on increasing space per animal









2.41.


Restrictions regarding density and journey time would increase the number of journeys by a factor of 3,5, with CO2 emissions rising from 116 263,14 Tm to 406 920,99 Tm (15). The increased number of lorries in circulation would also increase traffic congestion, which could result in longer travel times and higher operating costs for transportation companies.












2.42.


In addition to greatly increasing the number of falls, shocks and injuries, especially among taller animals, the increased space between the animals in the vehicle would allow them to move from one side to the other in the compartment, potentially destabilising the vehicle. This, combined with increased lorry traffic would also have negative impacts on road safety.












2.43.


Encouraging a farming model based on local production, on-farm slaughtering and short commercial channels would make it possible to counteract emission increases.





Arguments in support of recommendation 1.14 on local production









2.44.


The EESC calls on the Commission to carry out an impact assessment on shifting the current livestock farming model to one based on localising and shortening the distance between production and consumption.












2.45.


Short supply chains not only reduce the stress and suffering of animals, they also reduce carbon emissions associated with long-distance transport. In addition, they promote the transparency and traceability of products, which increases consumer confidence and benefits local producers.












2.46.


A commitment on the part of public administrations to promote the development of local slaughterhouses would make it possible to build a more sustainable livestock farming model that would resolve not only the problems of social and work impacts that are presented in this opinion, but also environmental issues in terms of increased CO2 emissions.





Arguments in support of recommendation 1.15 on the territorial impact









2.47.


Restrictions on movements for the slaughter of animals could result in farms relocating to be closer to slaughterhouses. This measure would accelerate rural depopulation, contributing to the decline of specific farming practices in each region. This aspect is of great concern if we take into account the tendency to reduce the number of slaughterhouses and increase their size, which would lead to a concentration of slaughterhouses (16).












2.48.


The proposed restrictions are particularly detrimental to small and medium-sized livestock farms, which have less infrastructure and fewer resources to adapt to the new requirements. This could widen the gap between large holdings and put their economic viability at risk.





Arguments in support of recommendation 1.16 on small and mobile slaughterhouses









2.49.


Given the concentration of slaughterhouses registered in the European Union, an ‘intelligent’ approach should be taken to decentralisation, in order to maintain proximity between farms and slaughterhouses without neglecting the importance of rural communities. This could be achieved by setting up smaller slaughterhouses in rural areas or by encouraging on-farm slaughtering where appropriate to the size of the farm and the local context (17).












2.50.


The EESC also calls for the swift development of the on-farm slaughtering of hens at the end of their laying cycle, and the implementation of an on-farm emergency slaughter service, particularly relevant for end-of-career cows and sows.




3.   Proposed amendments to the legislative proposal of the European Commission







NB:


The following amendments are not exhaustive.





Amendment 1

linked to Recommendation 1.1 (Article 2.3)






Text proposed by the European Commission


EESC amendment










3.


This Regulation shall not apply to the following types of transport:












3.


This Regulation shall not apply to the following types of transport:








[…]


[…]




 










(g)






the transport of hard-to-handle animals for the purposes of participating in training, exhibitions, competitions, cultural events, circuses, and equestrian sport and leisure activities;











Reason

The regulation does not take into account the particular nature of animals that are difficult to handle, i.e. animal breeds that are characterised by fierce and unpredictable behaviour and which require a specific approach to transport in order to ensure their well-being.

Amendment 2

linked to Recommendation 1.1 (Article 14(1))






Text proposed by the European Commission


EESC amendment





1.   Organisers shall be responsible for ensuring that the entire journey from the place of departure to the place of destination in the Union or in a third country complies with this Regulation.




1.   Organisers 
and competent authorities
 shall be responsible for ensuring that the entire journey from the place of departure to the place of destination in the Union or in a third country complies with this Regulation.






Reason

Responsibility should not lie solely with organisers; it should be shared with the competent authorities.

Amendment 3

linked to Recommendation 1.6 (Article 17.2)






Text proposed by the European Commission


EESC amendment










2.


Loading of animals on means of transport shall be supervised by a veterinarian.












2.


Loading of animals on means of transport shall be supervised by a veterinarian 
except where it is carried out by a qualified and authorised person, who may be the farmer, the transporter or a third party, or where the automated TRACES system is used. The Commission shall establish guidelines to define the relevant qualifications.











Reason

For loading to be supervised by a veterinarian, at least a 120 % increase in veterinary personnel would be required. It does not make sense to require the presence of a veterinarian, as all the relevant health information is already available in the automated TRACES system.

Amendment 4

linked to Recommendation 1.12 (Article 31.2)






Text proposed by the European Commission


EESC amendment










2.


For transport of terrestrial animals by road, except for dogs and cats:












2.


For transport of terrestrial animals by road, except for dogs and cats:
















(a)






when the temperature forecast indicates temperatures below 0 °C, road vehicles shall be covered and air circulation in the animal compartment controlled to protect animals from exposure to windchill during the journey;
















(a)






ventilation systems on means of transport by road shall be designed, constructed and maintained in such a way that, at any time during the journey, regardless of whether the vehicle is stationary or moving, within the means of transport a suitable temperature can be maintained for the given animal species;


















(b)






when the temperature forecast indicates temperatures below - 5 °C, in addition to the measures in point (a), the journey time shall not exceed 9 hours;
















(b)






when the temperatures forecast indicates temperatures above 30 °C or below - 5 °C, operators shall give priority to vehicles with an air-conditioning system. In any event, the suitable temperature for the given animal species shall be maintained;


















(c)






when the temperature forecast indicates temperatures between 25 °C and 30 °C, the journey time during the period between 10h00 and 21h00 shall not exceed 9 hours;
















(c)






means of transport by road shall be equipped with a warning system which alerts the driver when the temperature in the compartments containing the animals reaches the maximum or minimum limit suitable for the given animal species.


















(d)






when the temperature forecast indicates temperatures above 30 °C, only journeys taking place fully between 21h00 and 10h00 shall be allowed.








 












(e)






when the temperature forecast indicates temperatures above 30 °C between 21h00 and 10h00, the space allowance for the animals shall be increased by 20 %.








 





Reason

The regulation does not take into account the climate factors specific to each Member State.

Amendment 5

linked to Recommendation 1.10 (Recital 6)






Text proposed by the European Commission


EESC amendment




[…]


[…]




The EFSA opinions broadly conclude that providing more space, lowering maximum temperatures and keeping journey times to a minimum, are all required to improve the protection of animals during transport. Therefore, Regulation (EC) No 1/2005 should be replaced by a new Regulation that is in line with the latest developments in scientific and technical knowledge in this field and with consumers’ demands, while avoiding barriers to the functioning of the internal market and trade in live animals and ensuring the enforceability of the new rules.


The EFSA opinions broadly conclude that providing more space, lowering maximum temperatures and keeping journey times to a minimum, are all required to improve the protection of animals during transport. Therefore, Regulation (EC) No 1/2005 should be replaced by a new Regulation that is in line with the latest developments in scientific and technical knowledge in this field
, with the empirical experience of professionals in the sector (farmers, transporters and veterinarians), with a feasibility study and a social, economic and environmental impact assessment
 and with consumers’ demands, while avoiding barriers to the functioning of the internal market and trade in live animals and ensuring the enforceability of the new rules.





Reason

The experience of professional transporters in the livestock sectors, who state that increased space may sometimes increase the risk of falls and injuries, has not been taken into account. In addition, the proposed new space and vertical height rules would significantly reduce the number of animals transported per truck, increasing the number of trucks needed on the road (more investment and CO2 emissions) and making it necessary to hire more new drivers (socioeconomic impact).


Brussels, 31 May 2024.


The President


of the European Economic and Social Committee

Oliver RÖPKE
               





(1)  
            https://efsa.onlinelibrary.wiley.com/doi/full/10.2903/j.efsa.2022.7442.

(2)  COPA-COGECA Position Paper on Animal Protection During Transport AHW(24)01288[2].

(3)  Technical document on the impact of the proposed Animal Welfare Regulation on the transport of beef cattle, PROVACUNO (the Spanish Interprofessional Agri-Food Organisation of the Beef Industry).

(4)  
            Eurobarometer on Animal Welfare.

(5)  
            
Los consumidores españoles apoyarían una nueva normativa que garantice el bienestar animal
 [Spanish consumers would support new legislation to ensure animal welfare].

(6)  
            
OCU denuncia que los precios de supermercados han subido de media un 38 % en tres años
 [The OCU condemns the 38 % average hike in supermarket prices over three years].

(7)  The European Commission’s Directorate-General for Health and Food Safety, in its document entitled 
Modelling of policy options to support the impact assessment accompanying the revision of the EU legislation on the welfare of animals during transport
, declares that there will be no impact on farm production costs; it also states that the impact for the end consumer will only be between EUR 2,81 and EUR 14,09 per person per year.

(8)  
            Report on the impact of the proposal on animal welfare, by Avianza (Spanish Interprofessional Association of Poultry Meat).

(9)  PRAISE Report Tackling Fatigue: EU Social Rules and Heavy Goods Vehicle Drivers, by the European Transport Safety Council.

(10)  
            https://library.wmo.int/records/item/66214-state-of-the-global-climate-2022#.ZEZNoXZBxD8.

(11)  Currently, lorries are equipped with assisted ventilation and temperature control systems, with settings tailored to each species, automatically reducing or increasing the temperature according to set limits.

(12)  Technical document on the impact of the proposed Animal Welfare Regulation on the transport of beef cattle, PROVACUNO (the Spanish Interprofessional Agri-Food Organisation of the Beef Industry).

(13)  COPA-COGECA Position Paper on Animal Protection During Transport AHW(24)01288[2].

(14)  
            Impact report on the proposal for a Regulation on animal welfare in transport, European Livestock Transport.

(15)  
            Impact report on the proposal for a Regulation on animal welfare in transport, European Livestock Transport.

(16)  
            https://www.eca.europa.eu/Lists/ECADocuments/RV-2023-03/RV-2023-03_EN.pdf.

(17)  Many small slaughterhouses had difficulties meeting EU hygiene requirements and remaining economically viable; they were therefore forced to close when in April 2004 the European Parliament and the Council adopted rules on food hygiene (Regulation (EC) No 852/2004 of the European Parliament and of the Council of 29 April 2004 on the hygiene of foodstuffs (OJ L 139, 30.4.2004, p. 1), Regulation (EC) No 853/2004 of the European Parliament and of the Council of 29 April 2004 laying down specific hygiene rules for food of animal origin (OJ L 139, 30.4.2004, p. 55), and Regulation (EC) No 854/2004 of the European Parliament and of the Council of 29 April 2004 laying down specific rules for the organisation of official controls on products of animal origin intended for human consumption (OJ L 139, 30.4.2004, p. 206).


ELI: http://data.europa.eu/eli/C/2024/4670/oj
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