APPENDIX 37
Memorandum submitted by Compassion in
World Farming (F 56)
In certain important respects, the standards
set by the EU Regulation on organic standards for livestock (Council
Regulation No. 1804/1999) are disappointingly low. Indeed, they
permit mammals and poultry to be kept indoors for significant
proportions of their lives. In Compassion in World Farming's (CIWF)
view, the Regulation is in danger of devaluing the term "organic"
as EU consumers will not be able to rely on it as a guarantee
of high animal welfare standards.
Indeed, CIWF believes that consumers would be
surprised, and even feel deceived, to discover that the term "organic"
in some cases entails lower welfare standards than the term "free-range"
and that "organic" animals may spend substantial parts
of their lives indoors.
In these comments we shall refer not just to
the EU Regulation, but also to the August 2000 Edition of the
Standards for Organic Livestock produced by the United Kingdom
Register of Organic Food Standards (for short, the UKROFS standards).
EU Regulation permits animals to be housed indoors
for part of their lives
Paragraph 8.3.1 of the EU Regulation (and the
same paragraph of the UKROFS standards) provides that "all
mammals must have access to pasturage or an open-air exercise
area or an open-air run". Under this provision, organic producers
are not obliged to provide access to pasturage or even an open-air
exercise area; they can fulfil their obligations by merely providing
access to an "open-air run". This term is not defined,
but suggests that a fairly limited open-air space would be sufficient
to fulfil the producer's obligations.
Even more worrying, paragraph 8.3.4 of the EU
Regulation (and the same paragraph of the UKROFS standards) provides
that by way of derogation from the obligation to provide access
to pasturage or an open-air exercise area or run, "the final
fattening phase of cattle, pigs and sheep for meat production
may take place indoors, provided that this indoors period does
not exceed one-fifth of their lifetime and in any case for a maximum
period of three months".
In CIWF's view, this provision is totally unsatisfactory.
We believe that animals reared organically should either be kept
free-range or should have continuous daytime access to the outdoors
except in adverse weather conditions. In our view, it is unacceptable
for organic livestock to be housed indoors for a significant proportion
of their lifetime.
We welcome the fact that paragraph 8.3.8 of
the EU Regulation (and the same paragraph of the UKROFS standards)
provides that sows must be kept in groups. We are, however, unhappy
about the exception to this which provides that sows do not have
to be kept in groups "in the last stages of pregnancy and
during the suckling period". This exception appears to permit
use of the farrowing crate, which is highly detrimental to sow
welfare. The farrowing crate is so narrow that the sow cannot
even turn round; often she is kept in the crate for about four
weeks, ie for a few days before farrowing, during farrowing and
until the end of the weaning period. We are pleased that the new
Soil Association Livestock Standards (which came into force on
24 August 2000) expressly prohibit the use of farrowing crates
(paragraph 6.315).
We also welcome the recommendation in the new
Soil Association standards that pigs should not be weaned from
the sow until the age of 8 weeks (paragraph 6.313). No minimum
weaning age for piglets appears to be provided by the EU Regulation
or the UKROFS standards.
Derogation for tethering of cattle
CIWF is totally opposed to paragraph 6.1.5 of
the EU Regulation which gives a derogation from the prohibition
on keeping livestock tethered set out in paragraph 6.1.4. The
derogation provides that cattle can be tethered in buildings already
existing before 24 August 2000 provided that regular exercise
is provided. This derogation can be authorised by the inspection
authority or body for a transitional period until 31 December
2010.
Paragraph 6.1.6 gives a further derogation,
permitting cattle in small holdings to be tethered if it is not
possible to keep the cattle in groups, provided that they have
at least twice a week access to pastures, open-air runs or exercise
areas. CIWF is opposed to this derogation.
Poultry
Paragraph 8.4.1 of the EU Regulation (and the
same paragraph of the UKROFS standards) provides that poultry
must be reared in "open-range conditions". At first
sight this appears welcome, but it is contradicted by paragraph
8.4.5 (of both the EU Regulation and the UKROFS standards) which
provides that poultry only have access to an open-air run "for
at least one-third of their life". In our view it is totally
unsatisfactory for organic poultry to be given access to the outdoors
for only one-third of their lives. Our concern is particularly
strong in the case of laying hens, as these have much longer lives
than the broilers reared for their meat.
We welcome the provision in the Soil Association
standards that laying hens must have outside access for all their
laying life and that broilers must have such access for two-thirds
of their life (paragraph 6.411). We believe that the UKROFS standards,
and indeed the EU Regulation, must eventually be strengthened
to provide that laying hens must have outside access for all their
laying life, and broilers such access for two-thirds of their
life.
We also believe that the EU Regulation and the
UKROFS standards permit outdoor stocking rates which are far too
high for laying hens. Annex VIII of the EU Regulation (and of
the UKROFS standards) provides that laying hens only have to be
given an outdoors areas of 4m2 per hen; that is, an outdoor stocking
rate of 2,500 laying hens per hectare. In our view this is an
unacceptably high stocking density for organically reared poultry.
Indeed, it is much higher than the maximum stocking density permitted
under the EC marketing standards for eggs (Commission Regulation
1274/91) for free-range hens, which is 1,000 hens per hectare.
We welcome the fact that, in contrast to the
EU Regulation and the UKROFS standards, the new Soil Association
standards provide a maximum outdoor stocking rate of 1,000 birds
per hectare for laying hens (paragraph 6.419).
14 September 2000
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