Written evidence submitted by the Royal
Society for the Prevention of Cruelty to Animals (RSPCA)
EXECUTIVE SUMMARY
The reforms of 1999 and 2003 were important in obtaining
measures to achieve animal welfare goods, but the few measures
under Pillar II have not been adequately funded, and cross compliance
is questionable as to its effectiveness to improve animal welfare.
The Commission's Communication (COM 2010 672/3), whilst advocating
that farming communities need to be supported for animal welfare
measures, does not contain any specific measures on improving
or promoting animal welfare. The RSPCA fears that the proposals
will achieve nothing to improve animal welfare under the CAP and
may place British farmers at a competitive disadvantage in the
EU.
1. The RSCPA welcomes the opportunity to
comment on the effects of the CAP reform on British agriculture,
as it relates to animal welfare.
2. How will the Commission's proposals affect
the ability of UK agriculture to be competitive in a global market?
Welfare improvements in the way animals are farmed
have been made in specific legislation in the pigs, chickens,
calves and laying hens sectors. There have been suggestions that
these disadvantage the EU against products being more intensively
farmed in other countries worldwide. For instance, studies in
the laying hens sectors show a production cost difference of 8-10%
when moving to the enriched cage system, and 46-59% when moving
to a free range system[13],[14].
Economic research on laying hen standards in the third countries
expected to export to the EU shows a competitive advantage from
the main exporting countries2. Economic analysis has
also been done in the broiler[15]
and pig sector[16].
3. At present UK farm animal agriculture
is not under threat from imports from non EU countries where standards
are lower, with the exception of egg products. The beef and chicken
imported under retailer own standards are at or above minimum
EU standard and if stocking density is taken as an indicator of
welfare, chicken is produced at or above the EU. However, liquid
and dried egg are being imported at poorer standards than are
currently in the UK. The CAP reforms do not contain any real
incentives for producers to level this playing field.
4. There is little detailed information
in the Communication to show how the reformed CAP payments will
assist British farm animal agriculture exports compete globally.
Assistance measures, such as marketing grants, have not been
widely used in the UK and other measures such as financial assistance
to change production systems have not been used at all. In Ireland
producers were given incentives in 2010 to change over from battery
cage systems to more extensive systems under Pillar TwoI payments.
There seems a mismatch between the lack of detail in the proposals
and the Commission's willingness to ensure higher welfare standards
are addressed in bilateral trade negotiations.
5. Do the proposals ensure fair competition
for British agricultural products within the European Union?
Outside of cross compliance, there are no compulsory
measures to promote animal welfare in the CAP. The four devolved
authorities have tended to take a laisser faire attitude to animal
welfare under the CAP with only Scotland introducing a specific
measure under Pillar II to promote animal welfare, which did translate
into improvements in sheep and dairy cattle"[17].
6. It is difficult to see how the proposals
in the Communication, which contain no new compulsory measures
will ensure fair competition for British agricultural products,
particularly in those sectors such as chicken and pig production
where British standards are above some of the other Member States
and competition will be much greater than on a global level.
7. There is no incentive in the proposals
to ensure that minimum legal standards are complied with, despite
the competitive advantage for farmers in Member States where compliance
with the legal standards is poor. As their production costs are
generally lower, this can lead to trade distortion at intra-community
level. Enforcement actions are generally not sufficient and the
sanctions that are imposed to producers are not dissuasive or
proportionate. The system of penalties and infringement procedures
is slow and inefficient.
8. The Commission should undertake financial
studies on the effects of differences in welfare standards and
in enforcement of those standards on competition and this should
inform measures that could be proposed under the CAP reform.
10. Will the proposals achieve the correct
balance between productivity and sustainability?
No. The biggest part of CAP funding on animals still
goes to the larger farms as direct payments, with no other condition
than cross-compliance. The only potential measures promoting
animal welfare in the first pillar are in Article 68 where member
states can use part of their national envelope "for practising
enhanced animal welfare standards". The Netherlands
is the only Member State which is planning to use it for animal
welfare in 2011. There are no incentives under the proposals that
would change this position.
11. Do the proposals place the UK in a good
position to help meet future food supply challenges?
The Communication contains no specific details on
how it will meet consumer demands for animal welfare and ensure
a future food supply. The proposals lack the introduction of
any specific animal welfare measures, or non contractual actions
into Pillar I payments, unless these could be introduced via the
greening component proposal. The RSPCA would support measures
to assist animal welfare under the greening proposal but it is
not clear that this is the Commission's intention. Without these
measures it is unclear how the CAP can and should respond to the
needs for increased and better (ie more humane) food production.
12. Will the proposals redress the inbalance
in support to different sectors created by the historic basis
of payments?
No, it is difficult to see how the present inbalance
in historic payments will be corrected. Most pig, laying hens
and meat chicken farms do not receive pillar I payments. The RSPCA
has called for a substantial part of agriculture subsidies to
be used to promote environmental protection and improvement of
animal welfare, so being consistent with the objective of the
EU Sustainable Development Strategy. Payments could be incentivized
to improve the way animals are treated, for instance by tailoring
subsidies only to those who respect the law, but the proposals
contains no ideas on such areas unless animal welfare is tacked
on to the environmental payment.
13. What aspects
of the proposals should be made a common policy and which are
best left to member states?
Mandatory policies should be implemented on Pillar
I payments by keeping cross compliance measures on animal welfare
and introducing an animal welfare measure in to the "greening
payment" proposed under Pillar I. Payments under Pillar
II, agreed in 2003, have suffered from a lack of funding which
has resulted in few measures being proposed by Member States.
Even though there are 90 rural development schemes under the
2007-13 programme that have programmes where animal welfare could
benefit, only eight countries have taken the two specific animal
welfare schemes under 16 different programmes. A common policy
so that Member States introduce at least one animal welfare measure
under Pillar II payments would rectify this. It would be left
to Member State discretion which policy.
December 2010
13 The Case against Cages 2005 RSPCA, Hard boiled Reality
2001 RSPCA Back
14
van Niekerk, T & van Horne, P Comparison of Various Housing
Systems for Laying Hens. 2009. Animal Sciences Group, Wageningen
University and Research Center. Back
15
The economic consequences for the broiler industry of legislatively
enforced reductions in maximum stocking density. Centre for
Rural Research, Exeter University 2005 Back
16
Effect of higher welfare standards on the costs of producing
beef and pork in the EU. Bondt et al 2004 Agricultural Economics
Research Institute The Hague. Back
17
Targeted help: improving farm animal welfare in Scotland through
the rural development programmes. 2008, RSPCA/Eurogroup report.
Available at : http://www.eurogroupforanimals.org/policy/pdf/targetedhelp.pdf Back
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