Greening the Common Agricultural Policy

Written evidence submitted by the Royal Society for the Prevention of Cruelty to Animals (RSPCA) (GCAP 01)


Executive summary

The proposed 2011 reforms do nothing to promote or enhance animal welfare additional to the existing CAP, and in some areas are a retrograde step. The greening of the CAP under Pillar 1 will take emphasis and finance away from enhancing Pillar 2 payments, which is where the animal welfare measures are. The greening proposals do not contain any measures to promote animal welfare. The Commission proposals do not add any budget line or incentives to improve animal welfare. To rectify this Pillar 2 should be enhanced and animal welfare measures made compulsory, and an element in the greening proposals under Pillar 1 should contain measures that also enhance animal welfare.

1. The RSPCA welcomes the opportunity to comment on the effects of the "greening" proposals included in the Commission communication on CAP reform, as it relates to animal welfare.

2. The impact of additional greening requirements on food production and the competitiveness of the agricultural industry

The competitiveness of the agricultural industry has a close link to welfare improvements in the farming method, particularly in the pigs, chickens, calves and laying hens sectors. There have been suggestions that these disadvantage UK producers against products being more intensively farmed in other countries either within or outside the EU. The phase out of the conventional battery cage on 1st January 2012, and the projected non-compliance of around 20-30% of European eggs as illegal systems are kept on in at least six of the main egg producing Member States, also raises the prospect of a harmonised but not enforced welfare standard which will result in differing standards occurring in the EU. This could have a major impact on the competitiveness of British egg producers as studies in the laying hen sector shows a production cost difference of 8-10% when moving to the enriched cage system, and 46-59% when moving to a free range system [1] , [2] .

3. Eggs are not the only sector that could be disadvantaged. The move to a phase out of the stall and tether ban for pig production in 2013 has also raised concerns on non-compliance of the systems in other countries and their effect on British farming. Economic analysis done in the pig sector [3] also shows a competitive disadvantage to British producers which CAP measures such as payments for assurance schemes or animal welfare could rectify.

4. There is a simple solution to ensuring that a harmonised system occurs when a change over in animal welfare standards under an existing law occurs and that any non compliance of existing standards within the EU does not impact on competitiveness in the UK. The cross compliance mechanism at present only applies to the general farming Directive 98/58, the calves Directive 97/2, and the pigs Directive 2001/88. The RSPCA wants this list of cross compliance legislation to be expanded to include the legislation on live transport of animals (Regulation 1/2005), chickens (Directive 2008/43) and laying hens (Directive 1999/74). Without these cross compliance measures, a lack of harmonised standards in other EU Member States could impact on the competitiveness of British farmers. At present there is a real risk of British egg producers being put under threat from imports from EU countries where standards are lower, and eggs are being produced from illegal systems from 1st January 2012 or from pigs being produced under illegal systems from 21st January 2013.

5. As well as enhancing cross compliance, more detailed workstreams are required under Pillar 2 of the CAP proposals to encourage farming at higher animal welfare standards. None of the six priorities in the Rural Development section of the CAP proposals include animal welfare, though there are links to some of the measures proposed such as enhancing competitiveness and investment in quality schemes. The number of schemes that could be used for animal welfare have been reduced from seven to five with only one specific to animal welfare (Article 34). As none of the animal welfare measures are obligatory, the RSPCA fears that the poor take-up that occurred under the present CAP programme will be replicated. Only nine rural development schemes took up the animal welfare payments in the present period and only Scotland of the four devolved authorities has a specific scheme targeted at animal welfare, though clear improvements from this scheme were generated in the sheep and dairy cattle sectors" [4] .

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.

Recommendations for improving the greening proposals

7. The cross compliance measures under Pillar 1 should be widened to include more animal welfare laws than the present three. This would be a good step towards reducing any competition problems arising from harmonised standards not being properly introduced. Secondly, introducing an animal welfare measure in to the "greening payment" proposed under Pillar I would start to address the problem of funds being diverted from Pillar 2 into Pillar 1 and the assumption that a greening proposal will solve environmental or animal welfare issues. Finally, payments under Pillar II have suffered from a lack of funding which has resulted in few measures being proposed by Member States. Even though there are over 100 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 to make it mandatory 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 as to which policy they would include under such a regime .

November 2011

[1] The Case against Cages 2005 RSPCA, Hard boiled Reality 2001 RSPCA

[2] van Niekerk , T. & van Horne, P Comparison of Various Housing Systems for Laying Hens. 2009. Animal Sciences Group, Wageningen University and Research Center .

[3] 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.

[4] Targeted help: improving farm animal welfare in Scotland through the rural development programmes. 2008, RSPCA/Eurogroup report. Available at :

Prepared 30th November 2011