Select Committee on Agriculture Appendices to the Minutes of Evidence


Memorandum submitted by Compassion in World Farming (F 56)

  In certain important respects, the standards set by the EU Regulation on organic standards for livestock (Council Regulation No. 1804/1999) are disappointingly low. Indeed, they permit mammals and poultry to be kept indoors for significant proportions of their lives. In Compassion in World Farming's (CIWF) view, the Regulation is in danger of devaluing the term "organic" as EU consumers will not be able to rely on it as a guarantee of high animal welfare standards.

  Indeed, CIWF believes that consumers would be surprised, and even feel deceived, to discover that the term "organic" in some cases entails lower welfare standards than the term "free-range" and that "organic" animals may spend substantial parts of their lives indoors.

  In these comments we shall refer not just to the EU Regulation, but also to the August 2000 Edition of the Standards for Organic Livestock produced by the United Kingdom Register of Organic Food Standards (for short, the UKROFS standards).

EU Regulation permits animals to be housed indoors for part of their lives

  Paragraph 8.3.1 of the EU Regulation (and the same paragraph of the UKROFS standards) provides that "all mammals must have access to pasturage or an open-air exercise area or an open-air run". Under this provision, organic producers are not obliged to provide access to pasturage or even an open-air exercise area; they can fulfil their obligations by merely providing access to an "open-air run". This term is not defined, but suggests that a fairly limited open-air space would be sufficient to fulfil the producer's obligations.

  Even more worrying, paragraph 8.3.4 of the EU Regulation (and the same paragraph of the UKROFS standards) provides that by way of derogation from the obligation to provide access to pasturage or an open-air exercise area or run, "the final fattening phase of cattle, pigs and sheep for meat production may take place indoors, provided that this indoors period does not exceed one-fifth of their lifetime and in any case for a maximum period of three months".

  In CIWF's view, this provision is totally unsatisfactory. We believe that animals reared organically should either be kept free-range or should have continuous daytime access to the outdoors except in adverse weather conditions. In our view, it is unacceptable for organic livestock to be housed indoors for a significant proportion of their lifetime.

  We welcome the fact that paragraph 8.3.8 of the EU Regulation (and the same paragraph of the UKROFS standards) provides that sows must be kept in groups. We are, however, unhappy about the exception to this which provides that sows do not have to be kept in groups "in the last stages of pregnancy and during the suckling period". This exception appears to permit use of the farrowing crate, which is highly detrimental to sow welfare. The farrowing crate is so narrow that the sow cannot even turn round; often she is kept in the crate for about four weeks, ie for a few days before farrowing, during farrowing and until the end of the weaning period. We are pleased that the new Soil Association Livestock Standards (which came into force on 24 August 2000) expressly prohibit the use of farrowing crates (paragraph 6.315).

  We also welcome the recommendation in the new Soil Association standards that pigs should not be weaned from the sow until the age of 8 weeks (paragraph 6.313). No minimum weaning age for piglets appears to be provided by the EU Regulation or the UKROFS standards.

Derogation for tethering of cattle

  CIWF is totally opposed to paragraph 6.1.5 of the EU Regulation which gives a derogation from the prohibition on keeping livestock tethered set out in paragraph 6.1.4. The derogation provides that cattle can be tethered in buildings already existing before 24 August 2000 provided that regular exercise is provided. This derogation can be authorised by the inspection authority or body for a transitional period until 31 December 2010.

  Paragraph 6.1.6 gives a further derogation, permitting cattle in small holdings to be tethered if it is not possible to keep the cattle in groups, provided that they have at least twice a week access to pastures, open-air runs or exercise areas. CIWF is opposed to this derogation.


  Paragraph 8.4.1 of the EU Regulation (and the same paragraph of the UKROFS standards) provides that poultry must be reared in "open-range conditions". At first sight this appears welcome, but it is contradicted by paragraph 8.4.5 (of both the EU Regulation and the UKROFS standards) which provides that poultry only have access to an open-air run "for at least one-third of their life". In our view it is totally unsatisfactory for organic poultry to be given access to the outdoors for only one-third of their lives. Our concern is particularly strong in the case of laying hens, as these have much longer lives than the broilers reared for their meat.

  We welcome the provision in the Soil Association standards that laying hens must have outside access for all their laying life and that broilers must have such access for two-thirds of their life (paragraph 6.411). We believe that the UKROFS standards, and indeed the EU Regulation, must eventually be strengthened to provide that laying hens must have outside access for all their laying life, and broilers such access for two-thirds of their life.

  We also believe that the EU Regulation and the UKROFS standards permit outdoor stocking rates which are far too high for laying hens. Annex VIII of the EU Regulation (and of the UKROFS standards) provides that laying hens only have to be given an outdoors areas of 4m2 per hen; that is, an outdoor stocking rate of 2,500 laying hens per hectare. In our view this is an unacceptably high stocking density for organically reared poultry. Indeed, it is much higher than the maximum stocking density permitted under the EC marketing standards for eggs (Commission Regulation 1274/91) for free-range hens, which is 1,000 hens per hectare.

  We welcome the fact that, in contrast to the EU Regulation and the UKROFS standards, the new Soil Association standards provide a maximum outdoor stocking rate of 1,000 birds per hectare for laying hens (paragraph 6.419).

14 September 2000

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