Medicinal treatment of animals of the equine species : study on the situation as regards the medicinal treatment of animals of the equine species and their exclusion from the food chain : executive summary.
Date: 2025-11-18
Institutions: Directorate-General for Health and Food Safety, OPERA Srl
Subjects: EU Member State, EU law, animal welfare, drug residue, equidae, food chain, food fraud, food safety, import, transport of animals, veterinary legislation, veterinary medicinal product

Medicinal treatment of animals 
of the equine species  

Study on the situation as regards the medicinal 
treatment of animals of the equine species and 
their exclusion from the food chain 

Prepared by OPERA Srl 
February 2025 

 
 
 
 
 
 
 
 
 
 
 
EUROPEAN COMMISSION 

Directorate-General for Health and Food Safety 
Directorate D — Medical products and innovation 
Unit  D.4 — Veterinary Medicines 

E-mail:   SANTE-VETERINARY-MEDICINES@ec.europa.eu 

European Commission 
B-1049 Brussels 

 
 
EUROPEAN COMMISSION 

Medicinal treatment of animals of 
the equine species 
Study on the situation as regards the medicinal treatment of animals of 
the equine species and their exclusion from the food chain 
Executive Summary 

2025 

EN 

Directorate-General for Health and Food Safety 
EU4Health/SMP Food 

 
Manuscript completed in February 2025 

1st edition 

This document has been prepared for the European Commission however it reflects the views only of the 
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© European Union, 2025 

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Unless otherwise noted, the reuse of this document is authorised under a Creative Commons Attribution 
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PDF  

ISBN 978-92-68-28493-3    

doi:10.2875/2197709 

EW-01-25-073-EN-N

 
 
 
 
 
Medicinal treatment of animals of the equine species 

Contents 

1.  Context ..................................................................................................... 6 

2.  Materials and Methods ............................................................................ 7 

3. 

Findings .................................................................................................... 8 

4.  Conclusions ........................................................................................... 14 

5 

 
Medicinal treatment of animals of the equine species 

1. 

Context 

Under EU legislation, animals of the equine species are considered food-
producing animals. To protect public health, animals of the equine species are 
irreversibly excluded from the food chain when they are treated with medicinal 
products containing banned or unauthorised active substances for use in food 
producing animals. Only the national Competent Authority (CA) or the 
veterinarian responsible can exclude animals of the equine species from the 
food chain, for administrative reasons or due to medicinal treatment, 
respectively.  

Medicinal treatment options for food producing animals of the equine species 
(e.g. authorised veterinary medicinal products (VMPs), medicinal products that 
can be used outside their marketing authorisations (MA) or containing a 
substance included in the essential substances list (ESL)) are limited. To avoid 
exclusion from slaughter, some animals may end up without appropriate 
treatment, leading to animal health and welfare issues. The only alternative for 
animals excluded from the food chain and with no residual value is euthanasia 
and rendering of the carcase. Associated costs are variable across Member 
States (MSs) and in some MSs euthanasia is only possible on veterinary advice 
and not at the request of the keeper. Therefore, excluded animals may be 
neglected or even abandoned. Such situation creates conditions that may result 
in welfare issues or incentivise illegal and fraudulent practices. 

Slaughter of animals of the equine species for human consumption is 
concentrated in a limited number of MSs. Meat from animals of the equine 
species is also imported into the EU from certain approved third countries (TCs) 
and traded between MSs. Imported meat must comply with Union requirements.  

The aim of this study is to produce a factual report describing the state of play 
and presenting the views of national CAs and other relevant stakeholders on 
potential EU actions to improve the current situation with regard to public health, 
animal welfare, fraud and the level playing field with TCs linked to the medicinal 
treatment of animals of the equine species.  

6 

Medicinal treatment of animals of the equine species 

2. 

Materials and Methods 

Information was collected from both statistically representative and partially 
unrepresentative sources. Quantitative data were obtained from official 
documents, annual/multiannual reports and other public documents and 
national and international databases. Data was also collected from surveys 
distributed to CAs of MSs (official data), veterinary associations, animal welfare 
associations and representatives from the equine and animal health industries.  
Qualitative information was obtained from surveys distributed to the same 
groups. Thematic analysis was used to identify recurring themes across all 
stakeholder responses. Triangulation was performed using various 
methodologies to enhance the credibility and validity of the collected data. 

7 

 
Medicinal treatment of animals of the equine species 

3. 

Findings  

The number of animals of the equine species in the EU/EEA and their 
status as regards the food chain. 

Data on the number of animals of the equine species in the EU/EEA for the 
period 2018-2022 was available for almost all EU/EEA countries. The 
population size is particularly relevant for Spain, France, Netherlands, Romania, 
Ireland, Germany, Italy, Poland and Belgium, which accounted in total for nearly 
6 million animals in 2022. In the MSs providing data, the percentage of animals 
registered as excluded from slaughter for human consumption in 2022 was low 
for Netherlands (6%) and Romania (9%), moderate for Spain (26%) and Ireland 
(28%), and higher for Belgium (47%), Italy (60%) and Austria (68%). Data on 
exclusion due to medicinal treatment was very limited. 

The number of animals of the equine species slaughtered in the EU/EEA 
and tons of meat produced. 

Collected data shows a decreasing trend in the number of animals of the equine 
species slaughtered and in the production of meat from those animals in the 
majority of MSs in the period 2018-2022, with the notable exception of Italy, and 
to a lesser extent, Bulgaria and Croatia. No data about breed or age of the 
slaughtered animals was provided.  

The size of the trade in live animals. 

The movement of live animals of the equine species between MSs specifically 
for slaughter appeared to decrease over the observed period. Conversely, an 
increasing trend in intra-EU trade in live animals moved for purposes other than 
slaughter was observed over the study period. No CA reported imports of live 
animals from TCs intended for slaughter. The trend in the trade in live animals 
imported from TCs for purposes other than slaughter was stable over the 
observed period.  

The size of meat trade relating to animals of the equine species within the 
EU/EEA. 

Overall, available data for the period 2018-2022 show a stable trend of intra-EU 
trade for meat. A significant intra-EU trade of meat was observed in 2022 from 
other MSs to Italy (ca. 20,000 tonnes) and Belgium (ca. 10,000 tonnes), where 
consumption rates are the highest in the EU at 1 kg and 0,7 kg/per capita per 
year, respectively. A decline of meat traded from some MSs to other MSs in 
2018-2022 is most likely justified by the decline of the meat produced in these 

8 

Medicinal treatment of animals of the equine species 

countries over that period. But steady trade to other MSs continues in 2022 
from Belgium (ca. 8,800 tonnes), the Netherlands (ca. 8,500 tonnes), Poland 
(ca. 6,000 tonnes), Spain (ca. 5,500 tonnes) and Romania (ca. 5,500 tonnes), 
some of which may include meat imported from TCs.  

Data showed that in 2022 almost 14,000 tonnes of the meat traded in the EU 
were imported and, in line with the previous years, Argentina was the most 
important exporter, followed by Uruguay, Canada, Australia and the United 
Kingdom. A decreasing trend is observed over the period in tonnes of meat 
imported from TCs, most notably for Canada and Australia.  

Euthanasia and exclusion from the food chain. 

Data was provided from very few MSs on the number of animals euthanised 
over the study period. Almost no data was provided on animals that were 
euthanised because they had no value due to prior exclusion from slaughter. In 
several countries, this would be illegal; only 10 MSs reported having national 
legislation regulating euthanasia. Cost of euthanasia varied widely from €50 in 
Romania and Poland to a high of €630 in Sweden. Similarly, the cost of 
rendering an equine carcass varied widely from €80 in Finland to €800 in 
France. 

Effect of the (un)availability of VMPs on the exclusion from the food 
chain.  

CAs expressed opinions on the limitations to developing and authorising new 
VMPs for food-producing animals of the equine species, which included the 
relatively small equine market when considering the costly MA procedures. This 
is compounded by the uncommon nature of some indications in equines, and 
the cost of providing the required data for setting Maximum Residue Limits 
(MRLs), for determining the withdrawal period of the specific VMP and for 
maintaining a VMP on the market. Stakeholders opined that it was essential that 
there are authorised VMPs available to treat animals of the equine species 
safely and effectively. In relation to provisions in EU law to incentivise 
medicines availability for food producing animals of the equine species, MRL 
extrapolation under Regulation (EC) No 470/2009 has proven to be of limited 
help, since the cost of the withdrawal period studies for the specific VMPs is the 
main limiting factor. More time is necessary to assess the impact of the new 
provisions in the VMP Regulation aimed at incentivising medicines availability 
(e.g. submission of applications for products having been considered eligible 
under Article 23 – limited markets). 

Further feedback on availability of VMPs and its effect on exclusion of animals 
from slaughter for human consumption indicated that no data were available on 
the percentage of animals prescribed or administered a VMP that required their 

9 

Medicinal treatment of animals of the equine species 

exclusion from slaughter for human consumption, nor in relation to those 
prescribed a substance on the ESL. Veterinary respondents considered a 
common situation that, where no product licenced for equine animals intended 
for slaughter was available for some indications, no alternative licenced 
products for other food producing animals were available. Conversely, 
substances on the ESL are usually available. However, it was reported as 
common that when authorised VMPs available in other MSs were required, 
urgent treatment needs often required the use of VMPs that resulted in 
exclusion of the animal from slaughter for human consumption.  

Occurrence of fraud linked to the exclusion from the food chain.  

Data retrieved from the EU Alert and Cooperation Network point to 96 fraud 
suspicions (without associated health risks), 74 non-compliances (without 
associated health risks) and 30 Rapid Alert System for Food and Feed (RASFF) 
notifications (with health risks) in the period 2018-December 2024. These 
notifications point to documentary and records issues, poor traceability of 
animals, diversion to the food chain of animals excluded from slaughter for 
human consumption, detection of residues of VMPs above their MRLs and one 
occurrence of detection of residues of an unauthorised substance. Specific 
fraud cases were reported from Denmark, Spain, Romania and Ireland, and 
further information from the report of the Operation OPSON IX suggested a 
trend of falsification of horse passports in Europe. Illegal activities were further 
highlighted in 2022, under Operation Yucatan, which uncovered a large criminal 
network altering the traceability of horse meat by falsifying transfer and 
identification documents. Qualitative responses from CAs and other 
stakeholders opined that the paper-based passport system may be sensitive to 
fraud. 

Animal welfare issues linked to the exclusion from the food chain.  

In relation to welfare considerations, little recorded data were available. 
Veterinary and animal welfare organisations do not collate this information. No 
data were available on the frequency of animals not being appropriately treated 
for medical conditions so as to avoid exclusion. Respondents from the meat 
producing sector asserted though that animal welfare issues due to lack of 
treatment were common. All stakeholders reported that euthanasia to avoid 
treatment was uncommon.  

National databases indicating if an animal of the equine species is 
excluded from the food chain. 

The majority of MS CAs confirmed the existence of a national database of 
animals of the equine species, which in most cases contain data on exclusion 

10 

Medicinal treatment of animals of the equine species 

although reasons for exclusion are not always specified. In a few cases, 
national databases are accessible to the general public. Where access to the 
general public is not available, databases are accessible to official and private 
veterinarians, breed societies and food producers upon authorisation by the 
responsible body.  

The level of awareness among stakeholders of the current EU legal 
requirements 

Surveyed CAs reported a general lack of knowledge, misunderstanding or 
disregard for complex regulations, legal texts and guidelines on the use of 
VMPs (including use outside the terms of the MA) supplementing the VMP 
Regulation. These difficulties were confirmed by feedback received from 
representatives of the veterinary profession, in particular the issue on lack of 
understanding of what constitutes the use of VMPs outside the terms of the MA 
in accordance with Article 112(4) or 113 of the VMP Regulation vs. the “off-
label” use, which is not allowed by the legislation. A cross-cutting issue seems 
to be the difficulty to keep up to date with updates and changes in EU or 
national legislation.  

Overall, respondents believe that there is room for improving awareness about 
the current EU legal requirements both in veterinarians and keepers of animals 
of the equine species.   

Use of medicinal products outside the terms of the marketing 
authorisation.  

No data were available on the percentage of animals treated with medicinal 
products outside the terms of the MA in the observed period. While this use is 
checked during official inspections of farms and veterinary and pharmacy 
premises, the data is not collated on a national basis.  

National rules and guidelines supplementing EU legislation and frequency 
of official controls  

All responding CAs responsible for identification and registration confirmed that 
national rules were adopted supplementing EU legislation to ensure traceability 
and reliable exclusion of animals of the equine species from slaughter for 
human consumption along with provisions compliant with the requirements of 
Commission Delegated Regulation (EU) 2019/2035 and Commission 
Implementing Regulation (EU) 2021/963. The presence of national texts and 
guidelines for other areas such as import, meat production and trade was less 
consistent. There is a higher rate of available national guidelines on detection of 
VMPs residues, which is related to existing national residue control plans. 

11 

Medicinal treatment of animals of the equine species 

National rules on VMPs use and record keeping are largely available, but 
guidelines in this field are less available. 

In relation to the frequency of official controls along the food chain and of 
veterinarians treating animals of the equine species, data were received from a 
limited number of CAs. All responding CAs for identification and registration 
confirmed that all slaughtered animals were inspected for identification. The 
number of non-compliant checks was, in some cases, lower than or equal to 1% 
of the overall number of implemented checks, while in other cases considerably 
higher. Animals were also checked in relation to prior exclusion from slaughter 
(through identification documents) and likewise in relation to observation of the 
six-month withdrawal period after use of a substance on the ESL. Lack of 
compliance was identified in a limited number of cases, mostly concerning the 
finding of animals excluded from the food chain (by the passport) and illegally 
reintroduced into the food chain, with almost no cases of animals not observing 
the withdrawal period. 2022 European Food Safety Authority (EFSA) data on 
monitoring of VMPs residues in slaughtered animals of the equine species 
reported that out of 2,123 samples taken, only 27 (1,3%) were non-compliant. 
Out of 31 suspect samples, only 1 was non-compliant. Surveyed CAs feedback 
was consistent with this. Limited feedback was received on the number of 
checks concerning the use of VMPs outside the terms of MA or on the 
investigation of record-keeping by animal keepers of the use VMPs. 

Collaboration between the different CAs and stakeholders.  

Most of the responding CAs reported a satisfactory level of cooperation with 
other national CAs (or sub-divisions of their CA), responsible for the pieces of 
legislation concerning animals of the equine species. A lower rate of 
cooperation from the CAs responsible for animal identification and registration is 
perceived by other CAs. A moderate to satisfactory level of cooperation was 
also reported with many of the organisations involved in industries relating to 
animals of the equine species, although it was reported that improvement of the 
cooperation with animal welfare and meat production associations would be 
beneficial. Many comments on better cooperation with stakeholders concerned 
the improvement of communication. Similar feedback was provided by 
veterinary organisations, representatives from the animal welfare sector, and 
the animal health and equine industry. 

Situation in TCs that have an approved residues control plan and level 
playing field.   

In relation to imports of commodities obtained from animals of the equine 
species into the Union, there are discrepancies between the import 
requirements laid down in Commission Delegated Regulation (EU) 2022/2292 
and Council Directive 96/22/EC and the attestation included in the official 

12 

Medicinal treatment of animals of the equine species 

certificates (which only requires attestation of compliance for a six-month period 
prior to slaughter). This results in a lack of a level playing field, which should be 
addressed by aligning the attestations in the relevant certificates for entry into 
the Union of meat and meat products from equine animals with the EU 
requirements laid down Commission Delegated Regulation (EU) 2022/2292. 

Recent EC audit reports recommended that more robust systems and stricter 
enforcement of regulations are needed in TCs to improve effective animal 
traceability, allowing for identification and tracking of any issues that may arise; 
at the same time, ensuring that animals treated with certain VMPs are not 
processed for human consumption.  

Views of relevant stakeholders and CAs on potential EU actions to 
improve the current situation. 

National CAs and stakeholders provided suggestions that in their view would 
contribute to improve the current situation. These were assessed considering 
their potential impact on public health, animal welfare, the risk of fraud and the 
level playing field with TCs. The outcome of such assessment indicates that 
most of the suggested actions that can be undertaken under the current legal 
framework will be beneficial to public health and animal welfare, as well as to 
reducing the risks of fraud. 

13 

Medicinal treatment of animals of the equine species 

4. 

Conclusions 

●  Very limited or no data are available to CAs nor to stakeholders on a 
number of study questions, thus avoiding the possibility to reach valid 
and representative conclusions at EU level.  

●  The root cause for the exclusion of animals of the equine species from 
the food chain due to veterinary treatment is the lack of medicinal 
products that would allow the treated animal to maintain its status as 
intended for slaughter for human consumption. Financial hurdles limit the 
development, authorisation and maintenance on the market of new 
VMPs for this limited size market. 

●  MRL extrapolation under Regulation (EC) No 470/2009 has proven to be 
of limited effect to increase medicines availability; mainly due to the cost 
of the withdrawal period studies for the specific VMPs. While welcomed 
by stakeholders, more time is necessary to assess the impact of the new 
provisions in the VMP Regulation aimed at incentivising medicines 
availability (e.g. submission of applications for products having been 
considered eligible under Article 23 – limited markets). 

●  The availability of VMPs already authorised in other MSs could be further 
supported by smooth implementation of the subsequent recognition 
procedure (SRP) and the adoption of an attractive fee policy that would 
reduce the authorisation and maintenance costs of these products in the 
new targeted MSs. 

●  Exclusion of animals of the equine species from the food chain may 

directly or indirectly lead to various consequences for equine welfare, the 
most common concern being that equine animals intended for meat 
production are not provided with optimum treatment in order to avoid 
their exclusion from the food chain.  

●  Exclusion of equine animals from the food chain may result in fraudulent 
activities in the areas of identification and documentary traceability, 
mainly with the final objective of illegally reintroducing those excluded 
animals into the food chain. These fraudulent activities may lead to public 
health concerns and also have a negative impact on the reputational 
image of animal keepers and food operators who carefully observe the 
EU legislation. 

●  While the existing control mechanisms have been able to detect 

fraudulent activities and non-compliances with applicable EU rules, 
reinforced cooperation among involved CAs and strengthened control 
activities are crucial for their early detection and to be followed by the 
appropriate actions. That reinforced cooperation would involve sharing 
information between the national databases of MSs, and between CAs 
and equine operators (other than official veterinarians) in relation to 

14 

Medicinal treatment of animals of the equine species 

identification, movement and food status, maximising the potential of the 
current legislation. It could also be complemented by enhanced 
communication and awareness rising campaigns with relevant 
stakeholders.  

●  Veterinarians play a key role in the prescription and use of VMPs in 

accordance with EU and national legislation. Their role is also crucial in 
the exclusion of equine animals from the food chain due to medicinal 
treatment. The veterinary profession, in close cooperation with CAs, 
should keep increasing the level of awareness among veterinary 
practitioners and animal keepers of the relevant EU legislation, mainly 
concerning the identification of equine animals, and the use of VMPs and 
recording of veterinary treatments. This would contribute to reducing the 
exclusion from the food chain of equine animals, and as a result, of its 
unintended consequences in terms of animal welfare, risk of fraud and 
public health. 

●  The assessment of the actions suggested by stakeholders to improve the 
current situation indicates that most of the proposed actions that can be 
undertaken under the current legal framework would be beneficial for 
public health, animal welfare and fraud prevention. These involve three 
main work strands: i) increasing medicines availability for food producing 
animal of the equine species; ii) improving awareness among 
veterinarians and animal keepers about the EU rules on the use of 
medicinal products in food-producing equine animals and their exclusion 
from the food chain and iii) an appropriate enforcement of the existing 
EU legislation. 

●  As for the proposed actions by stakeholders involving a change to the 

EU legislation, their assessment indicates that they may lead to 
unintended effects such as increasing the occurrence of animal welfare 
issues, the risks of fraud or possible public health concerns. 

●  Commission Delegated Regulation (EU) 2022/2292 and Council 
Directive 96/22/EC make no difference between the applicable 
requirements to meat and meat products from animals of the equine 
species produced in Europe or in TCs. However, the current import 
certificates only require attestation of compliance with those EU 
requirements for a six-month period prior to slaughter, producing an 
uneven playing field. The alignment of the attestation in the relevant 
certificates for entry into the Union of commodities containing material 
from animals of the equine species with the EU requirements laid down 
in Commission Delegated Regulation (EU) 2022/2292 should address 
that level playing field issue. 

15 

 
 
 
Medicinal treatment of animals of the equine species 

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