Select Committee on Environment, Food and Rural Affairs Minutes of Evidence

Memorandum submitted by Compassion in World Farming (H22)

  Compassion in World Farming (CIWF) welcomes the Commission's thinking on animal welfare and in particular, its statement that "Animal welfare concerns must be fully integrated within the CAP". We fully support the Commission's emphasis on the need for Pillar two to include not just social and environmental objectives but also animal welfare.

  CIWF particularly hopes that the EFRA Committee will support the Commission's proposal:

    —  that a new "Meeting Standards" Chapter should be added to the Rural Development Regulation to help farmers adapt to demanding standards based on Community legislation in the field of, among other things, animal welfare. CIWF believes that this aid should not be available for farmers who do no more than meet the bare minimum standards required by EU law. All farmers are required to comply with the law. In our view, those who wish to receive financial aid under this Chapter must be prepared to go further than the minimum standards laid down by legislation;

    —  that the Agri-Environment Chapter should be extended to include animal welfare. CIWF particularly welcomes this proposal which is designed to encourage farmers to introduce really good welfare practices which go significantly beyond minimum legislative requirements; and

    —  to make direct payments conditional on compliance with statutory animal welfare standards, ie to introduce cross-compliance in respect of animal welfare.

  1.  Compassion in World Farming (CIWF) welcomes the Commission's thinking on animal welfare and in particular its statement that "Animal welfare concerns must be fully integrated within the CAP".

  2.  We fully support the Commission's belief that CAP support must move away from Pillar one to Pillar two, and are pleased at the Commission's emphasis on the need for Pillar two to include not just social and environmental objectives, but also animal welfare.

  3.  CIWF totally concurs with the Commission's statement that CAP expenditure must be justified by the products and services which society expects farmers to provide. Public expenditure must, says the Commission, yield something in return—whether it is food quality, the preservation of the environment or animal welfare, landscapes, cultural heritage or enhancing social balance and equity.


Proposed "Meeting Standards" Chapter

  4.  We welcome the Commission's proposal to add to the Rural Development Regulation a new "Meeting Standards" Chapter to help farmers adapt to demanding standards based on Community legislation in the fields of environment, food safety and animal welfare.

  5.  We are, however, concerned that the sum proposed—a maximum of EUR 200 per hectare in the first, best supported year—is too low. We certainly hope that the hectarage to be taken into account is the new, not the former area used by a farm. Thus, for example, an intensive pig or poultry farm would use a much smaller area than the area needed to conform with new legislative standards requiring a more extensive approach.

Proposed extension of agri-environment chapter to include animal welfare

  6.  Particularly welcome is the proposal to add animal welfare to the agri-environmental chapter so that animal welfare payments can be made for efforts that go beyond a mandatory reference level in line with agri-environment schemes. This is extremely important as it will encourage farmers to go further than required by the law (which often still permits very intensive, low-welfare farming) and to introduce really good welfare practices.

  7.  We very much welcome the Commission's assurance that the agri-environment chapter will continue to be mandatory after its extension to animal welfare. Clearly legislation will have to lay down which practices/systems qualify for the new welfare payments. CIWF would welcome the opportunity of contributing to the debate as to what standards should qualify for the new payments.

  8.  We are encouraged by the Commission's statement that in recognition of the considerable importance it attaches to the further development of agri-environment and animal welfare schemes, it proposes an increase in the fixed co-financing rate for these measures by a further 10 points to 85 per cent in areas covered by Objective one, and 60 per cent in other areas.


  9.  We welcome the proposal that the proposed decoupled farm income payment will be conditional on the respect of statutory animal health and welfare standards. The Commission states that the focus of cross-compliance requirements is on supporting the enforcement of "good farming practices" defined as encompassing mandatory standards. The Commission goes on to say that it will ensure a level playing field through basic implementation criteria. Member States should, says the Commission, define and enforce standards, following a common framework providing basic implementation criteria. The Commission will in the next few months begin the work needed to establish such a framework.

  10.  CIWF hopes that the standards for cross-compliance will be set higher than current welfare legislation, which all too often allows highly intensive systems/practices which have serious welfare problems inherent within them.


  11.  CIWF welcomes the proposal to establish a Community-wide system of farm auditing which would include on-farm processes and equipment relating to environment, food safety and animal welfare. We agree with the Commission that the inclusion of food safety and animal welfare in cross-compliance and their systematic monitoring through the farm audit will improve transparency and give consumers greater confidence.


  12.  CIWF welcomes the Commission's recognition that the way in which live cattle exports take place "has raised increasing concerns about the respect of animal welfare standards". The Commission intends to reinforce the conditions and controls under which export subsidies for live animals can be granted. While this is welcome, CIWF believes subsidies on live cattle exports should be stopped altogether. It is unacceptable for taxpayers' money to be used to subsidise a trade which time and again has been shown to routinely inflict great suffering on animals.



  13.  CIWF believes that aid should not be available for farmers who do no more than meet the bare minimum standards required by EU law. All farmers are required to comply with the law. In our view, those who wish to receive financial aid must be prepared to go further than the minimum standards laid down by legislation.

  14.  For example, the 1999 EU Hens Directive prohibits conventional battery cages from 2012, but allows producers to use any of three systems: free-range, percheries and "enriched" cages. Scientific evidence indicates that well-designed and well-managed free-range and perchery systems offer high welfare potential, while "enriched" cages provide very limited welfare benefits. Accordingly, although free-range, perchery and "enriched" cage systems are all permitted by the law, we believe that only farmers who wish to change to free-range or perchery systems should receive financial aid under the proposed new "Meeting Standards" Chapter.

  15.  Similarly, the 2001 EU Pigs Directive prohibits sow stalls from 2013, but permits the use of three systems: group-housing without bedding, group-housing with bedding, and free-range. We believe only farmers introducing group-housing with bedding or free-range systems should receive financial support under the CAP as group-housing without bedding is a very poor system from the welfare viewpoint. (The Pigs Directive requires all pigs to be given manipulable materials to allow the expression of certain behaviours; unfortunately it does not require the provision of bedding of sufficient depth to provide comfort.)

  16.  In its Communication, the European Commission suggests that "Meeting Standards" aid would be available for farmers implementing standards based on Community legislation which will become part of "good farming practice" (GFP). CIWF suggests that the following principles should be used in determining in each livestock sector what constitute GFP as regards welfare:

    —  Animals should not be kept in systems nor be subject to practices which impose ill-health, pain or injuries on them.

    —  Animals should not be kept in isolation, nor in overcrowded conditions. This means that maximum stocking densities should be established.

    —  Animals should not be kept in cages or in stalls which are so narrow that they cannot turn round.

    —  Animals should be kept in appropriate social groupings as in most cases they have strong social instincts. Such groups should, however, not be too large.

    —  Animals should be kept in such a way that they are free to express natural behaviour.

    —  Animals should be provided with adequate, clean bedding. They should not be kept on floors which consist completely of bare concrete or slats.

    —  Non-therapeutic mutilations (such as tail-docking or de-beaking), operations, or invasive procedures should not be carried out.

    —  Fast-growing or high-yielding breeds, when this leads to ill-health or pain, should not be used.


  17.  CIWF believes these payments should only be made to farmers who implement the highest animal welfare standards. Livestock systems for which payments are sought under this Chapter should fulfil the following 13 Key Animal Welfare Determinants:

    (i)  No close confinement at any stage of production—No long-term confinement system should be used that prevents or makes it difficult for the animal to stand up, lie down, turn round, walk normally, or fully stretch its limbs.

    (ii)  Low stocking densities—Farms must have low stocking densities—in many cases, this will mean lower than those required by legislation.

    (iii)  Daytime access to outdoors at an appropriate age or during the grazing season—Animals should be given access to the outdoors at an appropriate life-stage or when climatic or environmental conditions allow.

    (iv)  Access to appropriate shelter should be available—Where animals do have access to the outdoors and are not given free access to fixed housing, as in the case of grazing sheep or cattle, appropriate shelter should be available.

    (v)  Provision of bedding/litter for all housed animals—Appropriate bedding (for mammals) or litter (for poultry) should be provided for all animals.

    (vi)  Small group sizes

    (vii)  Avoid fast-growing or high-yielding breeds when this leads to health or welfare problems for the animals. The farm should use slow-growing strains (in the case of broiler chickens), or lower yielding animals that are less susceptible to physiological problems related to over-production (dairy cattle). Breeds that are prone to birthing difficulties (eg Belgian blue beef cattle) should also not be used.

    (viii)  Appropriate feed; higher in fibre, lower in energy/protein—The farm should use appropriate feed rather than high levels of protein concentrates.

    (ix)  Adequate feed to satisfy hunger at all stages of production—Restrictive feeding practices should not be used (broiler breeders, breeding pigs)—bulky, less nutrient-dense diets should be used to satisfy hunger.

    (x)  No yield or growth promoters permitted—Growth-promoting antibiotics should not be used.

    (xi)  No mutilations permitted except for strict veterinary reasons—Mutilations are widely accepted as painful practices that generally tackle the symptoms but not the cause of husbandry problems. Mutilations must not be carried out except on strict veterinary advice in individual cases. Veterinary "approved" routine mutilations are not acceptable.

    (xii)  Electric goads and rough handling not permitted

    (xiii)  No embryo transfer technology permitted

  18.  These Key Determinants could be used to set detailed species-specific standards which would have to be met by farms which claim aid under the new Animal Welfare section of the agri-environment Chapter.


  19.  As with payments under the "Meeting Standards" Chapter, standards higher than minimum legislative requirements must be set. If this is not done, there is a danger that Pillar one direct payments (eg the new de-coupled farm income payment) and indeed Pillar two payments could be made where at least one component of the farm's enterprise has low welfare standards.

  20.  For example, the UK farming press recently reported the case of a farmer receiving agri-environment payments for one part of his farm, even though on another part he reared lambs intensively indoors throughout their lives with no access to the outdoors. It would be generally agreed that farming lambs indoors throughout their lives, although not illegal, is a very poor welfare practice. In our view, no farmer engaged in this practice should receive CAP payments in respect of any part of his farm.

  21.  We believe that cross-compliance standards should ensure that no CAP money can be received by a farmer in respect of any aspect of his farm, if one part of his farm has low welfare standards.

Compassion in World Farming

27 September 2002

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