APPENDIX 4
Memorandum submitted by Compassion in
World Farming (A5)
INTRODUCTION
Compassion in World Farming (CIWF) believes
that, in the wake of the FMD crisis, substantial reforms are needed
to help prevent the crisis which beset UK farming with some regularity
and to introduce the sustainable, safe and humane agriculture
which the public increasingly wants.
We should at the outset make it clear that in
our view much of modern agriculture—both in the UK and the
rest of the EU—imposes serious welfare problems on animals.
Of particular concern are the long distance transport of live
farm animals and the highly intensive methods which continue to
dominate the pig and poultry industries.
Increasingly many people accept the need to
move away from factory farming and long distance transport. Our
attention must now focus on how to achieve conditions of economic
viability for the introduction of a more humane, sustainable agriculture,
particularly against the backdrop of possible reductions in production
subsidies.
CIWF believes that, if as a society we want
improved farming standards, we must:
1. Let go of the cheap food policy, which
is what has fuelled factory farming. The cost of changing to better
systems is often exaggerated. That said, humane food does in general
cost a little more to produce.
2. Insist on a redirection of part of the
CAP budget to help farmers move away from industrial farming to
more humane systems and practices.
3. Seek revision of the WTO rules to end
their detrimental impact on EU attempts to introduce a better
agriculture.
1. CHALLENGING
THE CHEAP
FOOD POLICY
If we want change, we have to let go of the
cheap food policy, which is what has fuelled industrial agriculture.
The cost of changing to better systems is often exaggerated. As
will be shown below, changing the higher welfare systems often
adds relatively little to on-farm production costs. Indeed in
some cases, as will also be shown below, improving welfare sometimes
reduces costs and increases productivity. However, in cases where
extra costs, albeit small ones, are involved, it is essential
that farmers are not left to bear the burden of these increased
costs alone, but instead we as consumers must be prepared to pay
the small amount extra needed for our food.
CIWF believes that as responsible consumers
we should be willing to pay the little extra needed so that animals
can be kept in kinder and healthier systems. We are, in general,
a reasonably wealthy society. We can afford the lottery, holidays
abroad, and a range of luxuries. Are we really saying that we
cannot afford decent standards of farm animal welfare? In fact
the drive to produce cheap food has arisen, not because most of
us are so poor that we could not feed ourselves without factory
farmed food, but because we wish to save money on essentials so
that we can afford even more luxuries.
That said, there are some people for whom every
penny counts. The answer to their situation is not to continue
with factory farming, but to adopt social policies designed to
ensure that everyone can afford food which is safe, nutritious
and humane. Indeed, it is worth pointing out that people may well
have a healthier diet if they were to replace some of their meat
consumption with fruit and vegetables.
Today we spend only 17 per cent—or even
less—of our income on food, whereas around 50 years ago
it was over 30 per cent. So, the suggestion that we spend a little
more on our food comes at time when food is costing us less, as
a proportion of overall expenditure, than ever before. The dramatic
fall in the proportion of our income spent on food has in part
been achieved by the use of husbandry systems with very poor
welfare. If we were willing to slightly increase the proportion
of our income spent on food, we could easily afford to introduce
humane production methods.
PRODUCTION COST
DIFFERENCES AS
BETWEEN FACTORY
FARMING AND
HIGHER WELFARE
SYSTEMS
The widely-held assumption that factory farming
is inherently much cheaper than more humane systems proves in
many cases to be false. For some products the on-farm production
costs—as opposed to the price charged by retailers—are
only slightly higher for improved welfare systems as compared
with factory farming. In other cases a more humane system can
actually result in lower production costs.
ECONOMICS OF
THE BAN
ON SOW
STALLS
In their report published in January 2001, the
European Commission pointed out that, as regards investment, some
forms of group housing are cheaper than sow stalls (European Commission,
2001). The Commission added that overall pig production costs
(ie including both building and running costs) are also lower
in some group housing systems than with sow stalls.
Figures from France (Institut Technique du Porc),
the Netherlands (Rosmalen Institute) and the UK (MLC and CEAS)
show that even in the better group housing systems—ones
giving reasonable space and ample straw—a kg of pig meat
costs less than 2p more to produce than in sow stalls (this includes
both capital and running costs).
As EU consumers each eat on average 42 kg of
pig meat a year, the recently agreed EU ban on sow stalls will
add less than £1 a year to each person's food bill. As UK
consumers each eat on average only 21.3 kg of pig meat a year,
the move from sow stalls to group housing should be costing consumers
less than 50p each per annum. As indicated earlier, CIWF wishes
to emphasise that if we want improved welfare standards, they
must be paid for by consumers not by eroding farmers' profit margins.
BATTERY CAGE
BAN
Data published by the National Farmers Union
in 2001 shows that the production costs of a dozen battery eggs
amount to 44.8p. The production costs for a dozen barn eggs come
to 53.3p and for a dozen free-range eggs to 62.2p (NFU, 2001).
The NFU adds that free-range egg production is subject to additional
costs ranging from 0.5-1.5p per dozen; we have averaged this additional
figure out at 1p per dozen, which means that the cost of a dozen
free-range eggs is 63.2p.
If these per dozen figures are transcribed to
production costs per egg, they show that the production costs
of one battery egg amount to 3.73p, while the production costs
of one barn and one-free range egg are 4.44p and 5.27p respectively.
This means that a free-range egg costs just 1.54p more to produce
than a battery egg, whereas a barn egg costs just 0.71p more to
produce than a battery egg.
UK consumers eat 163 eggs per person per year;
this figure includes the eggs used in processed foods, etc. (Poultry
World, 2001). As a free range-egg costs just 1.54p more to
produce than a battery egg, we could change from battery to free-range
eggs for just £2.51 per person per year, provided that retailers
charged no more extra for free-range eggs than is justified to
cover their extra production costs.
As a barn egg costs only 0.71p more to produce
than a battery egg, changing from battery to barn eggs would add
just £1.16 to each person's annual expenditure on eggs, subject
to the proviso in the previous paragraph about retailers' prices.
IMPROVED WELFARE
CAN LEAD
TO REDUCED
PRODUCTION COSTS
In better welfare systems, animals will tend
to be healthier. This can lead to savings in terms of reduced
expenditure on veterinary medicines, and lower mortality rates.
Healthier animals also can produce economic
benefits in terms of lower feed conversion ratios and higher growth
rates.
Ruiterkamp (1987) found that high levels
of penmate-directed behaviour in barren rearing environments have
a negative effect on the productivity of pigs due to disturbances
in feeding patterns. Morgan et al (1998) also found lower growth
rates among pigs in barren rather than enriched environments.
Beattie et al (2000) compared the rearing
of fattening pigs in either barren or enriched environments. The
latter incorporated extra space and an area which contained peat
and straw in a rack. During the finishing period (15-21 weeks)
mean daily food intakes were higher and food conversion ratios
were better for pigs in enriched environments compared with those
in barren environments. Growth rates were also higher for the
pigs in enriched environments during this period, and this resulted
in heavier carcase weights.
A range of studies have produced substantial
evidence that increasing the available floor area will benefit
the growth rate of finishing pigs (Edwards et al, 1988; Brumm
et al, 1996; Meunier-Salaun et al, 1987; Gonyou & Stricklin,
1997; Pearce et al, 1992).
A major Swedish study by Jonasson & Andersson,
(1997) also concluded that giving more space to fattening
pigs led to higher growth rates, better feed efficiency and improved
health which in turn led to fewer veterinary treatments, lower
death rates and less rejections at slaughter. The Swedish study
also found that the economic benefits of providing straw for slaughter
pigs outweigh the costs of the straw and the associated additional
labour costs.
A Danish study has analysed housing systems
for slaughter pigs and shows that the straw-flow system has better
profitability than traditional systems with fully or partially
slatted flooring (Norgaard & Olsen, 1995). The study
reports that the straw-flow system requires 20 per cent less capital
and that these lower capital costs outweigh the higher labour
input and the straw consumption of the straw-flow system.
NON-WELFARE
FACTORS HAVE
GREATER IMPACT
ON COSTS
AND PRICES
THAN WELFARE
The Meat & Livestock Commission (MLC) reported
in 1999 that the cost of feed varied between the major pig producing
countries of Europe by 14 pence per kg of pig produced and the
environmental costs varied by 8 pence per kg (MLC, 1999).
These factors have much more impact on pig production costs than
which sow housing system is issued; as seen earlier, even the
better group housing systems add less than 2 pence to the cost
of producing a kg of pig meat as compared with sow stalls.
Moreover, in the letter to MPs, Grampian Country
Foods stated that a range of factors had added a total of 44p
per kg to the production cost of UK pig meat by the end of 1999
as compared with costs on the continent, but the sow stall ban
had contributed only 2p/kg to this, whereas the strength of Sterling
had contributed 22p/kg.
It is, moreover, important to note that any
increase in on-farm production costs arising from the use of a
higher welfare system will have a proportionately smaller impact
on the retail price. For example, a 10 per cent rise in on-farm
production costs should lead to a significantly lower than 10
per cent increase in the retail price. This is because on-farm
production costs are only one of a range of factors which determine
the retail price. Distribution and marketing are also significant
components of the final price. For example, a rise in the price
of petrol may well have more impact on the retail price of pork
than whether sows are kept in stalls or groups.
ENVIRONMENTAL AND
HEALTH COSTS
So far we have looked at on-farm production
costs and have pointed out that in some cases improving welfare
leads to only a small increase in production costs and in others
it actually results in savings. It would, however, be erroneous
to assume that we only pay for our food as consumers at the shop.
When we also look at what we pay as taxpayers in CAP subsidies
(of which more later) and in a variety of ways to clean up the
environmental pollution and deal with the health problems associated
with modern farming, we find that industrial agriculture is much
more expensive than we think.
A recent study by Pretty et al (2000)
calculates the total external environmental and health costs of
modern agriculture in the UK to be £2,343 million per annum.
The authors states that they believe their figures are a conservative
estimate of the true costs. This study estimates two types of
damage costs:
(i) the treatment or prevention costs; those
incurred to clean up the environment and restore human health,
and,
(ii) administration and monitoring costs;
those incurred by public authorities and agencies for monitoring
environmental, food and health parameters.
HUMAN HEALTH
Modern farming has a serious impact on human
health and, in the case of BSE and FMD, also on animal health.
Public Health Laboratory Service data show that food poisoning
incidents rose to 94,000 per year in 1997, a 10-fold increase
since the 1950's. Moreover, notified cases represent only a small
proportion of the total cases of food poisoning as only one in
30 cases is notified.
Food poisoning entails costs in terms of lost
production due to time off work and medical treatment. The total
costs for food poisoning are estimated by Pretty et al
to be £677 million per year. The authors conservatively assume
that only 25 per cent of food poisoning cases arise directly from
UK farming.
NEED FOR
CHANGED APPROACH
BY CONSUMERS
AND SUPERMARKETS
Clearly the challenge is to persuade consumers
to pay the little extra needed so that animals can be kept in
good systems. To some extent, people are already willing to do
so; for example, the proportion of barn and free range eggs has
risen from around 10 per cent of all eggs produced a few years
ago to the present level of 21.5 per cent. Much more, however,
needs to be done by the industry, government and retailers to
educate the public into understanding that our cheap food has
come at a very high price in terms of animal suffering. CIWF believes
that if consumers knew the true facts of modern farming—were
aware of the tiny cages for hens and that many slaughter pigs
are kept on slatted or concrete floors and knew of the serious
health problems imposed on dairy cows and broilers by the drive
to increase productivity—they would be willing to pay the
small extra sums needed for improved welfare.
Unfortunately, the farming industry, government
and retailers have all chosen to keep the pubic largely unaware
of the state of modern animal farming. Much greater honesty needs
to be followed by a broad public debate in which we as a society
must decide whether or not we wish to move towards a better agriculture.
CIWF hopes that we will decide to make changes, that we will accept
that a responsible society should not treat animals as something
placed in this world for our convenience, for us to use in whatever
way we wish, but instead that we will accept that we have an ethical
obligation to ensure that the animals we rear for food are treated
humanely. Our well-being should not be founded on the suffering
of other creatures. We hope the public will commit itself to ending
the suffering that is systematically imposed on million of animals
in the name of cheap food.
Supermarkets and the providers of fast food
must be encouraged to act more responsibly. In their bid to make
food ever cheaper, supermarkets have in effect driven farmers
to use low welfare systems. Supermarkets must now adopt new policies
designated to encourage farmers to improve welfare. We welcome
the decision by Marks & Spencers and Waitrose not to sell
battery eggs (indeed Marks & Spencers only sell free-range
eggs) and McDonalds' policy of only using free range eggs. If
all supermarkets and providers of fast food were to follow these
leads—and indeed to adopt such policies across the board
and not just for eggs—a major beneficial change in modern
agriculture could be achieved.
Moreover, the supermarkets and others must not
only set high welfare standards, but also be willing to pay farmers
for the extra costs involved in attaining those standards. It
is supermarkets and consumers, not farmers whose margins are already
extremely tight, who must bear the cost of improved welfare.
Caterers and food manufacturers also have a
vital part to play if we are to achieve high welfare standards.
At present these sectors generally buy on price alone. They must
be encouraged to include animal welfare within their specifications.
Ultimately the key player here, as elsewhere, is the consumer:
caterers and food manufacturers are only likely to change if consumers
make it clear they are willing to pay the extra involved in producing
food and to good welfare standards.
Certainly it will be difficult for farmers to
change without:
(i) Major changes of policy from supermarkets,
the providers of fast food and indeed, the catering and food processing
trades.
(ii) A change in the situation in which
for every pound we spend in the shop now on food and drink, just
nine pence gets back to farmers and rural communities, whereas
50 years ago that figure was 50-60 pence in the pound (Pretty,
2001). While the profits of supermarkets continue to rise
(the profits of the big four supermarkets rose 38 per cent in
the four years to 1999 (Pretty, 2001), at the same time
less and less money goes to farmers. This trend must be reversed
if farmers are to be in a position to introduce better systems.
2. REFORM OF
THE COMMON
AGRICULTURAL POLICY
CIWF believes that the CAP must be completely
overhauled so that taxpayers' money is no longer used to support
undesirable farming methods, but instead to promote the sustainable,
humane and safe agriculture that the public increasingly wants.
To achieve this, we must move away from the
inefficient, outdated mechanisms of the CAP's Pillar I (ie the
production subsidies of market support and direct payments to
farmers) and replace them with Pillar II rural development measures
which encourage environmentally sensitive production, high standards
of animal welfare and an increase in farm employment.
CIWF believes the CAP should play a key role
in:
(a) fostering a move away from (i) the industrial
systems which dominate the pig and poultry sectors, (ii) feedlots
for beef cattle and (iii) zero-grazing systems for dairy cows
(such feedlots and zero-grazing systems are common in parts of
southern Europe), and
(b) helping replace the long distance transport
of live farm animals with local slaughter and fattening.
In order to promote improved welfare, CIWF advocates:
I. The introduction of Animal Welfare Impact
Assessments. No new CAP policy or subsidy should be implemented
until it has been properly assessed to ensure that it will not
have a detrimental impact on animal welfare.
II. The introduction, alongside the agri-environment
measures, of a new Farm Animal Welfare Scheme, to offer financial
support to farmers who wish to change from factory farming to
extensive husbandry systems.
Under the Scheme, farmers would be helped with
the capital costs of change and possibly also for a transitional
period of, say, four years, with the additional running costs.
It is the transitional period which is the most vulnerable for
any business which embarks on fundamental change.
The existing EU Regulation on Rural Development
already includes the preservation and improvement of animal welfare
standards among the objectives of financial support for "investments
in agricultural holdings". However few, if any, Member States
give any financial support under this provision. The new Farm
Animal Welfare Scheme would have to be framed in such a way as
to ensure that the Community and Member States give a certain
level of support for welfare improvements.
III. The use of Land Management Contracts
(LMCs). Whole-farm LMCs have been pioneered in France and are
also now to be developed in Scotland.
LMCs replace production based subsidies with
support for environmental and social benefits. CIWF urges that
animal welfare requirements should be included in LMCs as well
as the environment, land use and employment terms which appear
in French LMCs.
For example, a requirement in the LMC for a
dairy farmer could be that s/he implements a health plan, drawn
up in conjunction with a veterinarian, designed to keep to a minimum
the incidence of lameness and mastitis and to promote a high health
and welfare status in the herd. LMCs could also require the use
of slower growing breeds or more appropriate breeds, eg beef/dairy
cross cattle. LMCs could also include requirements such as provision
of bedding for cattle and pigs.
IV. The targeting of support so as to discourage
the long distance transport of live farm animals for slaughter
or further fattening. For much of the public, it is completely
unacceptable that CAP support should be given in respect of animals
which have been, or are likely to be, transported over long distances.
CIWF believes that all CAP subsidies, whether direct payments
under the cattle and sheep regimes or under LMCs, should be subject
to the condition that no payment can be made in respect of animals
in cases where the animal—or its young—have been,
or are likely to be, transported for more than a certain distance
for slaughter or further fattening. This would encourage farmers
to ensure that animals are slaughtered near to the farm of rearing
and indeed are fattened as near as possible to the farm where
they have been reared for the first part of their lives.
3. REFORM OF
THE WTO RULES
The WTO rules act as a major impediment to EU
attempts to introduce higher standards of farm animal welfare.
Under the WTO rules, the EU can prohibit a cruel rearing system
in its own territory. It cannot, however, restrict the import
of meat and eggs coming from animals reared in that system in
third countries. This acts as a major deterrent to the EU pressing
ahead with its own welfare reforms as its farmers risk being undermined
by low welfare imports.
We believe that the WTO rules must be relaxed
so that when the EU adopts improved welfare standards, it is able
to prevent the import of produce coming from animals reared to
lower standards. Without such safeguards, EU producers are placed
at an unfair competitive disadvantage and could well experience
both a significant fall in income and loss of market share.
We, of course, accept that there should be no
discrimination against imported meat and eggs coming from animals
reared to standards equivalent to those required in the EU. What
we cannot accept is that EU farmers should have to compete with
imports from producers who use systems which are illegal in the
EU.
The problems are highlighted by the 1999 EU
Hens Directive which prohibits the use of the battery cage as
from 2012. This decision was firmly based on a report by the European
Commission's Scientific Veterinary Committee. However, the Hens
Directive provides that in 2005 (ie before the cage ban comes
into force) the Directive is to be reviewed in the light of, among
other things, the outcome of the WTO negotiations. This is a clear
indication that if the WTO rules are not amended to allow the
EU to protect its farmers from imported battery eggs, the EU may
decide not to proceed with its own prohibition on the cage.
We welcome the fact that the need to find an
appropriate balance between trade and animal protection is included
in the EU's Comprehensive Negotiating Proposal for the negotiations
on the WTO Agreement on Agriculture. In particular, the EU has
proposed:
(a) The inclusion in the "Green Box"
of payments designed to assist livestock farmers who wish to introduce
improved husbandry systems. The inclusion of such payments in
the Green Box means that the EU would not be subject to commitments
under the WTO Agreement on Agriculture to reduce the level of
such payments.
(b) That the consistency of labelling schemes
with the WTO rules should be recognised, and,
(c) That a multi-lateral agreement on animal
protection should be negotiated.
Whilst these suggestions are welcome, CIWF fears
that they do not, on their own, go far enough. At the core of
the problem is the WTO's restrictive attitude to process and production
methods (PPMs) being taken into account. As currently interpreted,
the WTO rules prevent a WTO member's marketing or import regulations
from distinguishing between products on the basis of the way in
which they are produced, if that distinction applies to imported
as well as to domestic products.
This is a major problem as nearly all attempts
to improve animal welfare are concerned with the way in which
animals are reared or treated.
At the heart of the WTO rules is the requirement
that imported products must be treated no less favourably than
like domestic products. At first sight this causes no problems.
The WTO, however, has interpreted this rule quite perversely:
in determining whether products are "like" one another
a country may not look at the way in which they are produced.
An egg is an egg, whether it is battery or free range. Thus if
a country prohibits the marketing of domestically produced battery
eggs, it cannot extend that ban to imported battery eggs as, as
far as the WTO is concerned, a battery egg is "like"
a free-range egg and so imported battery eggs cannot be treated
differently from free-range eggs.
This leads to the absurdity that, starting off
from a rule that prevents imported products being discriminated
against, we arrive at the position where imported products must
be treated more favourably than domestic ones. For example, a
WTO member can prohibit the marketing of domestically produced
stall and tether-pigmeat, but cannot extend that ban to imported
pigmeat.
CIWF believes that WTO members should be permitted
to make PPM distinctions in their marketing or import regulations,
subject to rules designed to prevent abuse. We suggest that such
rules could provide that PPM distinctions must:
(a) Be transparent, non-discriminatory and
proportionate.
(b) Be science-based, ie there must be a
body of science which shows that the distinction being made is
legitimate in pursuit of the policy objective trying to be achieved.
(c) Be supported by a significant proportion
of the population of the country making the distinction.
(d) Be concerned with a matter of substance
rather than an insignificant point.
Other areas in which progress is essential are:
Preferential tariff rates
We urge the EU to press for the revised WTO
Agreement on Agriculture to permit WTO members to encourage good
welfare by offering reduced tariff rates for imports derived from
animals reared to high welfare standards. For example, the EU's
position could be that it is willing to agree only a modest reduction
in tariff rates for meat and eggs in general, while agreeing a
much greater reduction for meat and eggs coming from animals reared
to reasonable welfare standards.
This approach would produce a classic win-win
situation. Trade would be promoted by reduced tariffs, while at
the same time exporting countries would be encouraged to adopt
improved standards of welfare.
Labelling
It is absurd that the WTO, which believes in
the primacy of the free market and market mechanisms, stands in
the way of mandatory labelling schemes designed to ensure that
consumers have the information they need to make informed purchasing
decisions. Certainly the EU takes the view that mandatory labelling
schemes are inconsistent with WTO rules; the EU's recent regulation
on egg labelling requires eggs produced in the EU to be labelled
as to farming method, but applies a much weaker labelling regime
to imported eggs.
Compassion in World Farming
December 2001
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