Agriculture Bill

Written evidence submitted by Compassion in World Farming (AB03)

Compassion in World Farming welcomes the introduction of the Agriculture Bill to Parliament, particularly the recognition that animal welfare is a ‘public good’ that should be part of the future subsidy scheme.

However, there are several areas where the Bill should be strengthened, and we would encourage Committee members to examine the following issues in more detail as the they scrutinise the Bill.

Protecting British farmers from being undermined by trade deals

When negotiating future free trade agreements, it is essential that the Government ensures that British farmers are not undermined and that our animal welfare standards are protected. In order to do this, it should be a legal requirement that imported food products meet UK standards. Without such safeguards it will be very difficult to strengthen UK animal welfare standards and there may be pressure for existing legislation to be diluted to provide a level playing field for UK farmers in relation to imports. The Bill fails to make any reference to protecting British farmers from the potential impacts of trade agreements.

The Bill should legislate to require the UK Government not to conclude any new trade agreement that compels it to allow the import of products produced to standards of animal welfare, food safety or environmental protection that are lower than those required by UK law. This means that imports would either have to meet UK law or be subject to requirements that are genuinely comparable in effectiveness to those of UK law.

Of particular concern is the forthcoming trade negotiations with the US. In negotiating the new agreement, the US is likely to press the UK to accept imports of US meat, dairy products and eggs even though these are generally produced to much lower animal welfare standards than those of the UK. If the UK agrees to this UK farmers could be undermined by lower welfare US imports. To avert this danger the UK must insist on the inclusion of a clause permitting the UK to require imports to meet UK animal welfare standards. However, it will be difficult to secure US agreement to this. Alternatively, the UK could press for the ability to place tariffs on imports that do not conform to UK welfare standards that are sufficiently high to safeguard UK farmers. This too is likely to meet with resistance by the US negotiators.

We would welcome support for amendments that require the Government to ensure that trade deals enable the UK to require imports to meet UK standards on food safety, animal welfare and the environment and for this to therefore be a central consideration in any future trade negotiations.

Financial assistance for improved animal welfare

Taxpayers’ principal role should be to provide funding for public goods that the market cannot, or can only partially, deliver such as high environmental and animal welfare standards. We are pleased that the Bill provides for financial assistance (subsidies) being given for improving animal welfare. We believe that the limited funds available should be used not for marginal welfare gains but to support farmers who are willing to go substantially beyond legal minimum requirements; the role of payments should be to support best practice.

Good welfare entails not just preventing negative factors but enabling positive experiences

The ‘public goods’ section of the Bill (Part 1, Chapter 1) lacks any detail on how financial assistance for improved animal welfare should be used. We believe that further detail should be included. The Bill should provide that, when providing financial assistance, the Secretary of State must take into account the fact that scientific research increasingly indicates that good animal welfare involves not only the prevention of suffering but also the opportunity for animals to have positive experiences.

The Farm Animal Welfare Committee (FAWC) states: "Achievement of a life worth living requires provision of an animal’s needs and certain wants ... Wants are those resources that an animal may not need to survive or to avoid developing abnormal behaviour, but nevertheless improve its quality of life." [1]

Factors that should be a pre-condition for, or a bar to, receiving financial assistance

To ensure that financial assistance is supporting genuinely high levels of animal welfare, the Bill should provide that payments may only be made in respect of farms that:

· enable animals to engage in their natural behaviours as identified by scientific research

· comply with animal welfare legislation

· in the case of dairy cows, keep their animals at pasture during the grass-growing season

· do not perform routine mutilations

· do not kill calves at, or shortly after, birth except when a veterinary surgeon certifies this is necessary due to the calf’s poor health

· do not export animals for slaughter or fattening.

Designing post CAP farm support payments (subsidies)

Taxpayers’ principal role should be to provide funding for public goods that the market cannot, or can only partially, deliver such as high environmental and animal welfare standards. We suggest the following approach for each of the main species:

Pigs: Funding should be available for farmers who achieve intact (neither docked nor bitten) tails. Getting pigs to slaughter with intact tails is recognised by the Farm Animal Welfare Committee as a good outcome-based indicator of good welfare. The German state of Lower Saxony pays farmers €16.50 per undocked pig. The UK should encourage a move to free farrowing systems; farm support payments could help farmers with a proportion of the capital costs involved and for a transitional period of, say, five years with a proportion of the additional running costs. Ultimately the use of farrowing crates should be banned, with farmers being given a reasonable phase out period.

Laying hens: Funding should be available for farmers who used the best of free range systems e.g. with low stocking density, low flock size, mobile housing and the provision of trees and bushes. In addition, in order to receive funding, farmers must not trim hens’ beaks while achieving low mortality and good plumage scores.

Chickens reared for meat (broilers): Many UK broilers are stocked at 38 kg/m2. As chickens in the UK weigh around 2.2 kg at slaughter, this equates to approximately 17 chickens kept per square metre, representing substantial overcrowding. At such high densities, broilers can have high levels of infectious pathogens, leg disorders, foot pad burn and mortality. [2] [3] The maximum permitted broiler stocking density should be reduced to 30 kg/m2, the maximum allowed by the RSPCA Assured scheme. Funding should support the use of slow growing breeds and low stocking densities as scientific research shows that these bring many welfare benefits. [4] [5] [6] However, receipt of funding would be contingent on achieving low footpad dermatitis scores which can be measured at slaughter.

Dairy cows: Around 20% of UK dairy cows are zero-grazed i.e. they are kept indoors for all or nearly all of the year. This trend needs to be halted; cows should be kept on pasture during the grass-growing season except when the weather is too wet. Funding should be available for farmers who keep their cows on pasture during the grass-growing season except when the weather is too wet – this is already the case in Sweden. Research shows that pasture-based cows have lower levels of lameness, hoof pathologies, hock lesions, mastitis, and mortality than zero-grazed cows. [7] [8] Defra Minister George Eustice has said: "any farmer  who has turned cattle out to grass in April and watched their reaction knows that cattle prefer grazing, all other things being equal". [9] Pasture-based based farmers would only receive funding if they achieve low levels of lameness and mastitis.

Sheep and Beef sectors: Grass-based beef and sheep farmers should receive support provided that they achieve low levels of lameness and disease. In many cases animal welfare payments will be part of a wider scheme for funding environmental programmes and/or supporting farmers in areas of natural constraint.

Encouraging rotational crop-livestock systems: In mixed rotational farming animals are fed on crop residues, pasture and food waste and their manure, rather than being a pollutant, fertilises the land. When well-managed such systems can deliver high animal welfare and environmental standards, for example by enabling ruminants to behave naturally in an unstressed environment and by storing carbon, building soil quality and nurturing biodiversity. These systems should be encouraged by post CAP farm support payments.

Labelling as to farming method

We are pleased that Clause 35(2) (g) enables the Secretary of State to make regulations regarding the farming method.

Consumer demand is being impeded by lack of clear information at point of sale as to how meat and dairy products have been produced. Since 2004 EU law has required eggs and egg packs to be labelled as to farming method. [10] This has been an important factor in the move away from cage eggs. With meat and milk, however, consumers are largely in the dark. The problem is particularly acute as regards milk. Most milk is pooled together making it impossible to distinguish intensive and pasture-based milk.

The Commons EFRA Committee has twice in 2018 recommended "that the Government [should] introduce mandatory method of production labelling". [11] [12]

However, the Bill only enables the Secretary of State to make labelling regulations. We believe that it should be strengthened to require the Secretary of State to make labelling regulations that require meat, milk and dairy products, including those which have been produced intensively, to be labelled as to farming method.

Public procurement

The Government Buying Standards for Food and Catering include animal welfare considerations. However, these only require meat, milk and eggs to have been produced to legislative minimum standards. This is unsatisfactory. It is anomalous for Government to state that its ambition is to achieve good animal welfare, while the public sector undermines this aim by procuring food only to legislative minimum standards which are often low and which in the case of dairy cows lack any detail. Public sector bodies should use their buying power to augment the market for food produced to high nutritional, environmental and animal welfare standards.

The Bill should include a provision akin to section 15(5)(c)(ii) of the Procurement Reform (Scotland) Act 2014 which requires the procurement strategy of public bodies `to "promote the highest standards of animal welfare".

Ending live animal exports for slaughter or fattening

Sheep exports: Figures provided by the Animal and Plant Health Agency (APHA) show that around 20,000 sheep were exported from Britain for slaughter on the continent in 2018. The long journeys are stressful for the animals and in some cases result in great suffering due, for example, to overcrowding, high summer temperatures and animals receiving injuries en route.

Calf exports: APHA figures show that 5,150 calves were sent from Scotland on long journeys to Spain in 2018. Research concludes "Scientific evidence indicates that young calves are not well adapted to cope with transport. Their immune systems are not fully developed, and they are not able to control their body temperature well, thus they are susceptible to both heat and cold stress" [13]

Need for UK to ban live exports: The Agriculture Bill should prohibit live exports for slaughter or fattening with the ban coming into force at the end of the transition period of leaving the EU (i.e. 1st January 2021). The Bill should, however, provide an exception to the ban for genuine cross-border movements from Northern Ireland to the Republic of Ireland provided that the animals involved are not re-exported from the Republic.

February 2020

[1] Farm Animal Welfare Council, 2009. Farm Animal Welfare in Great Britain: Past, Present and Future


[2] Agra CEAS Consulting, 2006. Broiler analysis (Report for RSPCA)

[3] Hall A., 2001. The effect of stocking density on the welfare and behaviour of broiler chickens reared commercially. Animal Welfare 10, 23-40

[4] Bessei W., 2006. Welfare of broilers. World’s Poultry Science Journal. Vol 62, September 2006: 455-466.

[5] Hall A., 2001. The effect of stocking density on the welfare and behaviour of broiler chickens reared commercially. Animal Welfare 23-40

[6] Knowles, T. G., et al, 2008. Leg disorders in broiler chickens: prevalence, risk factors and prevention. Plos one 3 (2): e1545.

[7] Scientific Opinion of the Panel on Animal Health and Welfare on a request from European Commission on welfare of dairy cows. The EFSA Journal (2009) 1143, 1-38.

[8] Arnott et al, 2016. Review: welfare of dairy cows in continuously housed and pasture-based production systems. Animal doi:10.1017/S1751731116001336

[9] George Eustice op.cit.

[10] Commission Regulation (EC) No 589/2008 of 23 June 2008 laying down detailed rules for implementing Council Regulation (EC) No 1234/2007 as regards marketing standards for eggs: Article 12 and Annex I & II

[11] House of Commons Environment, Food and Rural Affairs Committee, February 2018. Brexit: trade in food, paragraph 133

[12] House of Commons Environment, Food and Rural Affairs Committee, February 2018. The future of food, farming and the environment, paragraph 106 and recommendation 16

[13] Weeks C. 2007. UK calf transport and veal rearing. A report for Compassion in World Farming


Prepared 12th February 2020