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Mr Rex Horgan
European Commission
DG SANCO D2 Animal Welfare and Feed
Office F101 02/80
B – 1049 Brussels
Belgium

3 May 2006

Dear Mr Horgan

Thank you for the opportunity for the Farm Animal Welfare Council (FAWC) to comment on the EU Commission Working Document on a Community Action Plan on the Protection and Welfare of Animals 2006-2010.

FAWC welcomes the Commission’s publication of this plan. It provides a statement as to the importance of animal welfare considerations within the EU and the likely direction of future Community policy concerning welfare. This is very useful both for Member States and for extra-Community countries, especially trading partners.

Our detailed comments on the five main action pointes are outlined below.

Action 1 – Upgrading existing minimum standards for animal protection and welfare

FAWC endorses the Commission’s view that new legislation regarding animal welfare standards must be based on scientific knowledge, expertise and practical experience. The lack of specific animal welfare standards for most farmed species at the EU level is indeed difficult to justify given the scientific evidence now available and FAWC would strongly encourage and support appropriate standards that improve welfare for those farmed species currently not adequately covered by EU legislation. It is important that this is supported by appropriate labelling under Action 3 below to ensure that EU producers remain competitive.

Financial support under Council Decision 90/424/EEC for studies to inform policy and for the development of legislation in the field of animal protection should be explored further.

The potential for new measures foreseen by the Commission to benefit farm animal welfare under rural development (including agri-environment) policies should be further explored for the UK.

Action 2 – Giving a high priority to promoting policy-orientated future research on animal protection and welfare and application of the 3Rs principle

FAWC welcomes the continued EU support and funding programmes for policy-orientated scientific research relating to farm animal welfare and supports application of the 3Rs principle to research and to farm animal welfare policy.
FAWC would like to work with Government and others to explore the possibility of establishment of a European Centre for the protection and welfare of animals (as outlined by the Commission in paragraph 2.2) within the UK.

Action 3 – Introducing standardised animal welfare indicators

FAWC very much supports development of precise and measurable indicators of animal welfare. We believe that these should be based on measurable, animal-based welfare outcomes covering the entire lifetime of the individual animals (including the conditions that pertain during the animals’ pre-term existence) as well as on a classification of production systems. FAWC understands the complexity of developing practical and scientifically reliable welfare measures and would encourage EU funding of research for this development.

FAWC strongly supports the concept of an EU label for farm animal welfare and will be publishing a report on welfare labelling shortly. We agree that any system must be based on accepted standardised indicators based on good science underpinned by research with an appropriate and rigorous system of accreditation. To have maximum impact on improvement of animal welfare, FAWC would like to see a mandatory labelling system covering all animal-based products (although in the short term these may include primary livestock products such as cuts of meat, milk and eggs) marketed within the EU (including those imported into the EU from third countries). An appropriate labelling scheme that is widely used could help consumers satisfy their demand for animal-welfare friendly products and help the market to function better, rewarding and encouraging livestock keepers to produce to high welfare standards through price premia.

We await with interest the findings of the Welfare Quality EU-funded study as regards welfare indicators and welfare labelling.

Action 4 – Informing and involving animal keepers and others

FAWC strongly supports the full integration of citizens’ concerns about animal welfare into EU agricultural (and other) policies, not only to avoid animal suffering but also to positively promote animal wellbeing.

It is important that the EU Advisory Group on the food chain and animal and plant health fully takes into account animal welfare considerations.

Informing and educating consumers on animal welfare is very important and appropriate labelling and provision of welfare information at point of sale, leaflets and websites are key initiatives in this regard.

Information and education of animal keepers concerning welfare is also very important but it is essential that price signals effectively communicate consumer preferences for welfare and that producers are adequately rewarded for higher welfare production through price premia and appropriate public support.

Training of animal keepers is vital to high standards of animal welfare. Formal recognition of competence and training through appropriate certification etc. is required.

Action 5 – Support of international initiatives on animal welfare

FAWC agrees that OIE is very well-placed to build international consensus on the issue of animal welfare. This is particularly important where international trade agreements and the WTO are concerned. FAWC strongly supports and encourages EU initiatives for the explicit recognition of animal welfare in international trade agreements and within WTO. FAWC would very much like the UK Government and the Commission to encourage OIE to develop an animal welfare strategy, which clearly lays out OIE’s vision and planned achievements in terms of international agreement and guidelines concerning animal welfare.

It is important that EU Member States can appropriately encourage animal welfare-friendly farming within the Domestic Support pillar and under the EU Development Regulation without contravening international trade rules.

The negotiation of bilateral trade agreements on animal welfare standards are to be welcomed if these result in higher standards of welfare in third country suppliers and prevent a loss of competitiveness of domestic producers producing to higher standards (which otherwise acts as a disincentive to animal welfare-friendly farming).

Continued dialogue between the EU and third countries on animal welfare issues is important, alongside other initiatives.

We hope that these comments from FAWC are helpful for the EU action on animal welfare.