Memorandum submitted by Compassion in
World Farming (H22)
Compassion in World Farming (CIWF) welcomes
the Commission's thinking on animal welfare and in particular,
its statement that "Animal welfare concerns must be fully
integrated within the CAP". We fully support the Commission's
emphasis on the need for Pillar two to include not just social
and environmental objectives but also animal welfare.
CIWF particularly hopes that the EFRA Committee
will support the Commission's proposal:
— that a new "Meeting Standards"
Chapter should be added to the Rural Development Regulation to
help farmers adapt to demanding standards based on Community legislation
in the field of, among other things, animal welfare. CIWF believes
that this aid should not be available for farmers who do no more
than meet the bare minimum standards required by EU law. All farmers
are required to comply with the law. In our view, those who wish
to receive financial aid under this Chapter must be prepared to
go further than the minimum standards laid down by legislation;
— that the Agri-Environment Chapter
should be extended to include animal welfare. CIWF particularly
welcomes this proposal which is designed to encourage farmers
to introduce really good welfare practices which go significantly
beyond minimum legislative requirements; and
— to make direct payments conditional
on compliance with statutory animal welfare standards, ie to introduce
cross-compliance in respect of animal welfare.
1. Compassion in World Farming (CIWF) welcomes
the Commission's thinking on animal welfare and in particular
its statement that "Animal welfare concerns must be fully
integrated within the CAP".
2. We fully support the Commission's belief
that CAP support must move away from Pillar one to Pillar two,
and are pleased at the Commission's emphasis on the need for Pillar
two to include not just social and environmental objectives, but
also animal welfare.
3. CIWF totally concurs with the Commission's
statement that CAP expenditure must be justified by the products
and services which society expects farmers to provide. Public
expenditure must, says the Commission, yield something in return—whether
it is food quality, the preservation of the environment or animal
welfare, landscapes, cultural heritage or enhancing social balance
and equity.
FINANCIAL SUPPORT
FOR FARMERS
ADOPTING GOOD
ANIMAL WELFARE
STANDARDS
Proposed "Meeting Standards" Chapter
4. We welcome the Commission's proposal
to add to the Rural Development Regulation a new "Meeting
Standards" Chapter to help farmers adapt to demanding standards
based on Community legislation in the fields of environment, food
safety and animal welfare.
5. We are, however, concerned that the sum
proposed—a maximum of EUR 200 per hectare in the first,
best supported year—is too low. We certainly hope that the
hectarage to be taken into account is the new, not the former
area used by a farm. Thus, for example, an intensive pig or poultry
farm would use a much smaller area than the area needed to conform
with new legislative standards requiring a more extensive approach.
Proposed extension of agri-environment chapter
to include animal welfare
6. Particularly welcome is the proposal
to add animal welfare to the agri-environmental chapter so that
animal welfare payments can be made for efforts that go beyond
a mandatory reference level in line with agri-environment schemes.
This is extremely important as it will encourage farmers to go
further than required by the law (which often still permits very
intensive, low-welfare farming) and to introduce really good welfare
practices.
7. We very much welcome the Commission's
assurance that the agri-environment chapter will continue to be
mandatory after its extension to animal welfare. Clearly legislation
will have to lay down which practices/systems qualify for the
new welfare payments. CIWF would welcome the opportunity of contributing
to the debate as to what standards should qualify for the new
payments.
8. We are encouraged by the Commission's
statement that in recognition of the considerable importance it
attaches to the further development of agri-environment and animal
welfare schemes, it proposes an increase in the fixed co-financing
rate for these measures by a further 10 points to 85 per cent
in areas covered by Objective one, and 60 per cent in other areas.
CROSS-COMPLIANCE
WITH ANIMAL
WELFARE STANDARDS
9. We welcome the proposal that the proposed
decoupled farm income payment will be conditional on the respect
of statutory animal health and welfare standards. The Commission
states that the focus of cross-compliance requirements is on supporting
the enforcement of "good farming practices" defined
as encompassing mandatory standards. The Commission goes on to
say that it will ensure a level playing field through basic implementation
criteria. Member States should, says the Commission, define and
enforce standards, following a common framework providing basic
implementation criteria. The Commission will in the next few months
begin the work needed to establish such a framework.
10. CIWF hopes that the standards for cross-compliance
will be set higher than current welfare legislation, which all
too often allows highly intensive systems/practices which have
serious welfare problems inherent within them.
FARM AUDITING
11. CIWF welcomes the proposal to establish
a Community-wide system of farm auditing which would include on-farm
processes and equipment relating to environment, food safety and
animal welfare. We agree with the Commission that the inclusion
of food safety and animal welfare in cross-compliance and their
systematic monitoring through the farm audit will improve transparency
and give consumers greater confidence.
SUBSIDIES ON
EXPORT OF
LIVE CATTLE
TO THIRD
COUNTRIES
12. CIWF welcomes the Commission's recognition
that the way in which live cattle exports take place "has
raised increasing concerns about the respect of animal welfare
standards". The Commission intends to reinforce the conditions
and controls under which export subsidies for live animals can
be granted. While this is welcome, CIWF believes subsidies on
live cattle exports should be stopped altogether. It is unacceptable
for taxpayers' money to be used to subsidise a trade which time
and again has been shown to routinely inflict great suffering
on animals.
WHAT ANIMAL
WELFARE STANDARDS
SHOULD BE
SET FOR
FARMERS WHO
WISH TO
RECEIVE CAP
PAYMENTS
NEW "MEETING
STANDARDS" CHAPTER
13. CIWF believes that aid should not be
available for farmers who do no more than meet the bare minimum
standards required by EU law. All farmers are required to comply
with the law. In our view, those who wish to receive financial
aid must be prepared to go further than the minimum standards
laid down by legislation.
14. For example, the 1999 EU Hens Directive
prohibits conventional battery cages from 2012, but allows producers
to use any of three systems: free-range, percheries and "enriched"
cages. Scientific evidence indicates that well-designed and well-managed
free-range and perchery systems offer high welfare potential,
while "enriched" cages provide very limited welfare
benefits. Accordingly, although free-range, perchery and "enriched"
cage systems are all permitted by the law, we believe that only
farmers who wish to change to free-range or perchery systems should
receive financial aid under the proposed new "Meeting Standards"
Chapter.
15. Similarly, the 2001 EU Pigs Directive
prohibits sow stalls from 2013, but permits the use of three systems:
group-housing without bedding, group-housing with bedding, and
free-range. We believe only farmers introducing group-housing
with bedding or free-range systems should receive financial support
under the CAP as group-housing without bedding is a very poor
system from the welfare viewpoint. (The Pigs Directive requires
all pigs to be given manipulable materials to allow the expression
of certain behaviours; unfortunately it does not require the provision
of bedding of sufficient depth to provide comfort.)
16. In its Communication, the European Commission
suggests that "Meeting Standards" aid would be available
for farmers implementing standards based on Community legislation
which will become part of "good farming practice" (GFP).
CIWF suggests that the following principles should be used in
determining in each livestock sector what constitute GFP as regards
welfare:
— Animals should not be kept in systems
nor be subject to practices which impose ill-health, pain or injuries
on them.
— Animals should not be kept in isolation,
nor in overcrowded conditions. This means that maximum stocking
densities should be established.
— Animals should not be kept in cages
or in stalls which are so narrow that they cannot turn round.
— Animals should be kept in appropriate
social groupings as in most cases they have strong social instincts.
Such groups should, however, not be too large.
— Animals should be kept in such a
way that they are free to express natural behaviour.
— Animals should be provided with adequate,
clean bedding. They should not be kept on floors which consist
completely of bare concrete or slats.
— Non-therapeutic mutilations (such
as tail-docking or de-beaking), operations, or invasive procedures
should not be carried out.
— Fast-growing or high-yielding breeds,
when this leads to ill-health or pain, should not be used.
NEW ANIMAL
WELFARE PAYMENTS
UNDER THE
AGRI-ENVIRONMENT
CHAPTER
17. CIWF believes these payments should
only be made to farmers who implement the highest animal welfare
standards. Livestock systems for which payments are sought under
this Chapter should fulfil the following 13 Key Animal Welfare
Determinants:
(i) No close confinement at any stage of
production—No long-term confinement system should be used
that prevents or makes it difficult for the animal to stand up,
lie down, turn round, walk normally, or fully stretch its limbs.
(ii) Low stocking densities—Farms must
have low stocking densities—in many cases, this will mean
lower than those required by legislation.
(iii) Daytime access to outdoors at an appropriate
age or during the grazing season—Animals should be given
access to the outdoors at an appropriate life-stage or when climatic
or environmental conditions allow.
(iv) Access to appropriate shelter should
be available—Where animals do have access to the outdoors
and are not given free access to fixed housing, as in the case
of grazing sheep or cattle, appropriate shelter should be available.
(v) Provision of bedding/litter for all housed
animals—Appropriate bedding (for mammals) or litter (for
poultry) should be provided for all animals.
(vii) Avoid fast-growing or high-yielding
breeds when this leads to health or welfare problems for the animals.
The farm should use slow-growing strains (in the case of broiler
chickens), or lower yielding animals that are less susceptible
to physiological problems related to over-production (dairy cattle).
Breeds that are prone to birthing difficulties (eg Belgian blue
beef cattle) should also not be used.
(viii) Appropriate feed; higher in fibre,
lower in energy/protein—The farm should use appropriate
feed rather than high levels of protein concentrates.
(ix) Adequate feed to satisfy hunger at all
stages of production—Restrictive feeding practices should
not be used (broiler breeders, breeding pigs)—bulky, less
nutrient-dense diets should be used to satisfy hunger.
(x) No yield or growth promoters permitted—Growth-promoting
antibiotics should not be used.
(xi) No mutilations permitted except for
strict veterinary reasons—Mutilations are widely accepted
as painful practices that generally tackle the symptoms but not
the cause of husbandry problems. Mutilations must not be carried
out except on strict veterinary advice in individual cases. Veterinary
"approved" routine mutilations are not acceptable.
(xii) Electric goads and rough handling not
permitted
(xiii) No embryo transfer technology permitted
18. These Key Determinants could be used
to set detailed species-specific standards which would have to
be met by farms which claim aid under the new Animal Welfare section
of the agri-environment Chapter.
CROSS-COMPLIANCE
19. As with payments under the "Meeting
Standards" Chapter, standards higher than minimum legislative
requirements must be set. If this is not done, there is a danger
that Pillar one direct payments (eg the new de-coupled farm income
payment) and indeed Pillar two payments could be made where at
least one component of the farm's enterprise has low welfare standards.
20. For example, the UK farming press recently
reported the case of a farmer receiving agri-environment payments
for one part of his farm, even though on another part he reared
lambs intensively indoors throughout their lives with no access
to the outdoors. It would be generally agreed that farming lambs
indoors throughout their lives, although not illegal, is a very
poor welfare practice. In our view, no farmer engaged in this
practice should receive CAP payments in respect of any part of
his farm.
21. We believe that cross-compliance standards
should ensure that no CAP money can be received by a farmer in
respect of any aspect of his farm, if one part of his farm has
low welfare standards.
Compassion in World Farming
27 September 2002
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