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


Memorandum submitted by Compassion in World Farming (A5)


  Compassion in World Farming (CIWF) believes that, in the wake of the FMD crisis, substantial reforms are needed to help prevent the crisis which beset UK farming with some regularity and to introduce the sustainable, safe and humane agriculture which the public increasingly wants.

  We should at the outset make it clear that in our view much of modern agriculture—both in the UK and the rest of the EU—imposes serious welfare problems on animals. Of particular concern are the long distance transport of live farm animals and the highly intensive methods which continue to dominate the pig and poultry industries.

  Increasingly many people accept the need to move away from factory farming and long distance transport. Our attention must now focus on how to achieve conditions of economic viability for the introduction of a more humane, sustainable agriculture, particularly against the backdrop of possible reductions in production subsidies.

  CIWF believes that, if as a society we want improved farming standards, we must:

  1.  Let go of the cheap food policy, which is what has fuelled factory farming. The cost of changing to better systems is often exaggerated. That said, humane food does in general cost a little more to produce.

  2.  Insist on a redirection of part of the CAP budget to help farmers move away from industrial farming to more humane systems and practices.

  3.  Seek revision of the WTO rules to end their detrimental impact on EU attempts to introduce a better agriculture.


  If we want change, we have to let go of the cheap food policy, which is what has fuelled industrial agriculture. The cost of changing to better systems is often exaggerated. As will be shown below, changing the higher welfare systems often adds relatively little to on-farm production costs. Indeed in some cases, as will also be shown below, improving welfare sometimes reduces costs and increases productivity. However, in cases where extra costs, albeit small ones, are involved, it is essential that farmers are not left to bear the burden of these increased costs alone, but instead we as consumers must be prepared to pay the small amount extra needed for our food.

  CIWF believes that as responsible consumers we should be willing to pay the little extra needed so that animals can be kept in kinder and healthier systems. We are, in general, a reasonably wealthy society. We can afford the lottery, holidays abroad, and a range of luxuries. Are we really saying that we cannot afford decent standards of farm animal welfare? In fact the drive to produce cheap food has arisen, not because most of us are so poor that we could not feed ourselves without factory farmed food, but because we wish to save money on essentials so that we can afford even more luxuries.

  That said, there are some people for whom every penny counts. The answer to their situation is not to continue with factory farming, but to adopt social policies designed to ensure that everyone can afford food which is safe, nutritious and humane. Indeed, it is worth pointing out that people may well have a healthier diet if they were to replace some of their meat consumption with fruit and vegetables.

  Today we spend only 17 per cent—or even less—of our income on food, whereas around 50 years ago it was over 30 per cent. So, the suggestion that we spend a little more on our food comes at time when food is costing us less, as a proportion of overall expenditure, than ever before. The dramatic fall in the proportion of our income spent on food has in part been achieved by the use of husbandry systems with very poor welfare. If we were willing to slightly increase the proportion of our income spent on food, we could easily afford to introduce humane production methods.


  The widely-held assumption that factory farming is inherently much cheaper than more humane systems proves in many cases to be false. For some products the on-farm production costs—as opposed to the price charged by retailers—are only slightly higher for improved welfare systems as compared with factory farming. In other cases a more humane system can actually result in lower production costs.


  In their report published in January 2001, the European Commission pointed out that, as regards investment, some forms of group housing are cheaper than sow stalls (European Commission, 2001). The Commission added that overall pig production costs (ie including both building and running costs) are also lower in some group housing systems than with sow stalls.

  Figures from France (Institut Technique du Porc), the Netherlands (Rosmalen Institute) and the UK (MLC and CEAS) show that even in the better group housing systems—ones giving reasonable space and ample straw—a kg of pig meat costs less than 2p more to produce than in sow stalls (this includes both capital and running costs).

  As EU consumers each eat on average 42 kg of pig meat a year, the recently agreed EU ban on sow stalls will add less than £1 a year to each person's food bill. As UK consumers each eat on average only 21.3 kg of pig meat a year, the move from sow stalls to group housing should be costing consumers less than 50p each per annum. As indicated earlier, CIWF wishes to emphasise that if we want improved welfare standards, they must be paid for by consumers not by eroding farmers' profit margins.


  Data published by the National Farmers Union in 2001 shows that the production costs of a dozen battery eggs amount to 44.8p. The production costs for a dozen barn eggs come to 53.3p and for a dozen free-range eggs to 62.2p (NFU, 2001). The NFU adds that free-range egg production is subject to additional costs ranging from 0.5-1.5p per dozen; we have averaged this additional figure out at 1p per dozen, which means that the cost of a dozen free-range eggs is 63.2p.

  If these per dozen figures are transcribed to production costs per egg, they show that the production costs of one battery egg amount to 3.73p, while the production costs of one barn and one-free range egg are 4.44p and 5.27p respectively. This means that a free-range egg costs just 1.54p more to produce than a battery egg, whereas a barn egg costs just 0.71p more to produce than a battery egg.

  UK consumers eat 163 eggs per person per year; this figure includes the eggs used in processed foods, etc. (Poultry World, 2001). As a free range-egg costs just 1.54p more to produce than a battery egg, we could change from battery to free-range eggs for just £2.51 per person per year, provided that retailers charged no more extra for free-range eggs than is justified to cover their extra production costs.

  As a barn egg costs only 0.71p more to produce than a battery egg, changing from battery to barn eggs would add just £1.16 to each person's annual expenditure on eggs, subject to the proviso in the previous paragraph about retailers' prices.


  In better welfare systems, animals will tend to be healthier. This can lead to savings in terms of reduced expenditure on veterinary medicines, and lower mortality rates.

  Healthier animals also can produce economic benefits in terms of lower feed conversion ratios and higher growth rates.

  Ruiterkamp (1987) found that high levels of penmate-directed behaviour in barren rearing environments have a negative effect on the productivity of pigs due to disturbances in feeding patterns. Morgan et al (1998) also found lower growth rates among pigs in barren rather than enriched environments.

  Beattie et al (2000) compared the rearing of fattening pigs in either barren or enriched environments. The latter incorporated extra space and an area which contained peat and straw in a rack. During the finishing period (15-21 weeks) mean daily food intakes were higher and food conversion ratios were better for pigs in enriched environments compared with those in barren environments. Growth rates were also higher for the pigs in enriched environments during this period, and this resulted in heavier carcase weights.

  A range of studies have produced substantial evidence that increasing the available floor area will benefit the growth rate of finishing pigs (Edwards et al, 1988; Brumm et al, 1996; Meunier-Salaun et al, 1987; Gonyou & Stricklin, 1997; Pearce et al, 1992).

  A major Swedish study by Jonasson & Andersson, (1997) also concluded that giving more space to fattening pigs led to higher growth rates, better feed efficiency and improved health which in turn led to fewer veterinary treatments, lower death rates and less rejections at slaughter. The Swedish study also found that the economic benefits of providing straw for slaughter pigs outweigh the costs of the straw and the associated additional labour costs.

  A Danish study has analysed housing systems for slaughter pigs and shows that the straw-flow system has better profitability than traditional systems with fully or partially slatted flooring (Norgaard & Olsen, 1995). The study reports that the straw-flow system requires 20 per cent less capital and that these lower capital costs outweigh the higher labour input and the straw consumption of the straw-flow system.


  The Meat & Livestock Commission (MLC) reported in 1999 that the cost of feed varied between the major pig producing countries of Europe by 14 pence per kg of pig produced and the environmental costs varied by 8 pence per kg (MLC, 1999). These factors have much more impact on pig production costs than which sow housing system is issued; as seen earlier, even the better group housing systems add less than 2 pence to the cost of producing a kg of pig meat as compared with sow stalls.

  Moreover, in the letter to MPs, Grampian Country Foods stated that a range of factors had added a total of 44p per kg to the production cost of UK pig meat by the end of 1999 as compared with costs on the continent, but the sow stall ban had contributed only 2p/kg to this, whereas the strength of Sterling had contributed 22p/kg.

  It is, moreover, important to note that any increase in on-farm production costs arising from the use of a higher welfare system will have a proportionately smaller impact on the retail price. For example, a 10 per cent rise in on-farm production costs should lead to a significantly lower than 10 per cent increase in the retail price. This is because on-farm production costs are only one of a range of factors which determine the retail price. Distribution and marketing are also significant components of the final price. For example, a rise in the price of petrol may well have more impact on the retail price of pork than whether sows are kept in stalls or groups.


  So far we have looked at on-farm production costs and have pointed out that in some cases improving welfare leads to only a small increase in production costs and in others it actually results in savings. It would, however, be erroneous to assume that we only pay for our food as consumers at the shop. When we also look at what we pay as taxpayers in CAP subsidies (of which more later) and in a variety of ways to clean up the environmental pollution and deal with the health problems associated with modern farming, we find that industrial agriculture is much more expensive than we think.

  A recent study by Pretty et al (2000) calculates the total external environmental and health costs of modern agriculture in the UK to be £2,343 million per annum. The authors states that they believe their figures are a conservative estimate of the true costs. This study estimates two types of damage costs:

  (i)  the treatment or prevention costs; those incurred to clean up the environment and restore human health, and,

  (ii)  administration and monitoring costs; those incurred by public authorities and agencies for monitoring environmental, food and health parameters.


  Modern farming has a serious impact on human health and, in the case of BSE and FMD, also on animal health. Public Health Laboratory Service data show that food poisoning incidents rose to 94,000 per year in 1997, a 10-fold increase since the 1950's. Moreover, notified cases represent only a small proportion of the total cases of food poisoning as only one in 30 cases is notified.

  Food poisoning entails costs in terms of lost production due to time off work and medical treatment. The total costs for food poisoning are estimated by Pretty et al to be £677 million per year. The authors conservatively assume that only 25 per cent of food poisoning cases arise directly from UK farming.


  Clearly the challenge is to persuade consumers to pay the little extra needed so that animals can be kept in good systems. To some extent, people are already willing to do so; for example, the proportion of barn and free range eggs has risen from around 10 per cent of all eggs produced a few years ago to the present level of 21.5 per cent. Much more, however, needs to be done by the industry, government and retailers to educate the public into understanding that our cheap food has come at a very high price in terms of animal suffering. CIWF believes that if consumers knew the true facts of modern farming—were aware of the tiny cages for hens and that many slaughter pigs are kept on slatted or concrete floors and knew of the serious health problems imposed on dairy cows and broilers by the drive to increase productivity—they would be willing to pay the small extra sums needed for improved welfare.

  Unfortunately, the farming industry, government and retailers have all chosen to keep the pubic largely unaware of the state of modern animal farming. Much greater honesty needs to be followed by a broad public debate in which we as a society must decide whether or not we wish to move towards a better agriculture. CIWF hopes that we will decide to make changes, that we will accept that a responsible society should not treat animals as something placed in this world for our convenience, for us to use in whatever way we wish, but instead that we will accept that we have an ethical obligation to ensure that the animals we rear for food are treated humanely. Our well-being should not be founded on the suffering of other creatures. We hope the public will commit itself to ending the suffering that is systematically imposed on million of animals in the name of cheap food.

  Supermarkets and the providers of fast food must be encouraged to act more responsibly. In their bid to make food ever cheaper, supermarkets have in effect driven farmers to use low welfare systems. Supermarkets must now adopt new policies designated to encourage farmers to improve welfare. We welcome the decision by Marks & Spencers and Waitrose not to sell battery eggs (indeed Marks & Spencers only sell free-range eggs) and McDonalds' policy of only using free range eggs. If all supermarkets and providers of fast food were to follow these leads—and indeed to adopt such policies across the board and not just for eggs—a major beneficial change in modern agriculture could be achieved.

  Moreover, the supermarkets and others must not only set high welfare standards, but also be willing to pay farmers for the extra costs involved in attaining those standards. It is supermarkets and consumers, not farmers whose margins are already extremely tight, who must bear the cost of improved welfare.

  Caterers and food manufacturers also have a vital part to play if we are to achieve high welfare standards. At present these sectors generally buy on price alone. They must be encouraged to include animal welfare within their specifications. Ultimately the key player here, as elsewhere, is the consumer: caterers and food manufacturers are only likely to change if consumers make it clear they are willing to pay the extra involved in producing food and to good welfare standards.

  Certainly it will be difficult for farmers to change without:

  (i)  Major changes of policy from supermarkets, the providers of fast food and indeed, the catering and food processing trades.

  (ii)  A change in the situation in which for every pound we spend in the shop now on food and drink, just nine pence gets back to farmers and rural communities, whereas 50 years ago that figure was 50-60 pence in the pound (Pretty, 2001). While the profits of supermarkets continue to rise (the profits of the big four supermarkets rose 38 per cent in the four years to 1999 (Pretty, 2001), at the same time less and less money goes to farmers. This trend must be reversed if farmers are to be in a position to introduce better systems.


  CIWF believes that the CAP must be completely overhauled so that taxpayers' money is no longer used to support undesirable farming methods, but instead to promote the sustainable, humane and safe agriculture that the public increasingly wants.

  To achieve this, we must move away from the inefficient, outdated mechanisms of the CAP's Pillar I (ie the production subsidies of market support and direct payments to farmers) and replace them with Pillar II rural development measures which encourage environmentally sensitive production, high standards of animal welfare and an increase in farm employment.

  CIWF believes the CAP should play a key role in:

  (a)  fostering a move away from (i) the industrial systems which dominate the pig and poultry sectors, (ii) feedlots for beef cattle and (iii) zero-grazing systems for dairy cows (such feedlots and zero-grazing systems are common in parts of southern Europe), and

  (b)  helping replace the long distance transport of live farm animals with local slaughter and fattening.

  In order to promote improved welfare, CIWF advocates:

  I.  The introduction of Animal Welfare Impact Assessments. No new CAP policy or subsidy should be implemented until it has been properly assessed to ensure that it will not have a detrimental impact on animal welfare.

  II.  The introduction, alongside the agri-environment measures, of a new Farm Animal Welfare Scheme, to offer financial support to farmers who wish to change from factory farming to extensive husbandry systems.

  Under the Scheme, farmers would be helped with the capital costs of change and possibly also for a transitional period of, say, four years, with the additional running costs. It is the transitional period which is the most vulnerable for any business which embarks on fundamental change.

  The existing EU Regulation on Rural Development already includes the preservation and improvement of animal welfare standards among the objectives of financial support for "investments in agricultural holdings". However few, if any, Member States give any financial support under this provision. The new Farm Animal Welfare Scheme would have to be framed in such a way as to ensure that the Community and Member States give a certain level of support for welfare improvements.

  III.  The use of Land Management Contracts (LMCs). Whole-farm LMCs have been pioneered in France and are also now to be developed in Scotland.

  LMCs replace production based subsidies with support for environmental and social benefits. CIWF urges that animal welfare requirements should be included in LMCs as well as the environment, land use and employment terms which appear in French LMCs.

  For example, a requirement in the LMC for a dairy farmer could be that s/he implements a health plan, drawn up in conjunction with a veterinarian, designed to keep to a minimum the incidence of lameness and mastitis and to promote a high health and welfare status in the herd. LMCs could also require the use of slower growing breeds or more appropriate breeds, eg beef/dairy cross cattle. LMCs could also include requirements such as provision of bedding for cattle and pigs.

  IV.  The targeting of support so as to discourage the long distance transport of live farm animals for slaughter or further fattening. For much of the public, it is completely unacceptable that CAP support should be given in respect of animals which have been, or are likely to be, transported over long distances. CIWF believes that all CAP subsidies, whether direct payments under the cattle and sheep regimes or under LMCs, should be subject to the condition that no payment can be made in respect of animals in cases where the animal—or its young—have been, or are likely to be, transported for more than a certain distance for slaughter or further fattening. This would encourage farmers to ensure that animals are slaughtered near to the farm of rearing and indeed are fattened as near as possible to the farm where they have been reared for the first part of their lives.


  The WTO rules act as a major impediment to EU attempts to introduce higher standards of farm animal welfare. Under the WTO rules, the EU can prohibit a cruel rearing system in its own territory. It cannot, however, restrict the import of meat and eggs coming from animals reared in that system in third countries. This acts as a major deterrent to the EU pressing ahead with its own welfare reforms as its farmers risk being undermined by low welfare imports.

  We believe that the WTO rules must be relaxed so that when the EU adopts improved welfare standards, it is able to prevent the import of produce coming from animals reared to lower standards. Without such safeguards, EU producers are placed at an unfair competitive disadvantage and could well experience both a significant fall in income and loss of market share.

  We, of course, accept that there should be no discrimination against imported meat and eggs coming from animals reared to standards equivalent to those required in the EU. What we cannot accept is that EU farmers should have to compete with imports from producers who use systems which are illegal in the EU.

  The problems are highlighted by the 1999 EU Hens Directive which prohibits the use of the battery cage as from 2012. This decision was firmly based on a report by the European Commission's Scientific Veterinary Committee. However, the Hens Directive provides that in 2005 (ie before the cage ban comes into force) the Directive is to be reviewed in the light of, among other things, the outcome of the WTO negotiations. This is a clear indication that if the WTO rules are not amended to allow the EU to protect its farmers from imported battery eggs, the EU may decide not to proceed with its own prohibition on the cage.

  We welcome the fact that the need to find an appropriate balance between trade and animal protection is included in the EU's Comprehensive Negotiating Proposal for the negotiations on the WTO Agreement on Agriculture. In particular, the EU has proposed:

  (a)  The inclusion in the "Green Box" of payments designed to assist livestock farmers who wish to introduce improved husbandry systems. The inclusion of such payments in the Green Box means that the EU would not be subject to commitments under the WTO Agreement on Agriculture to reduce the level of such payments.

  (b)  That the consistency of labelling schemes with the WTO rules should be recognised, and,

  (c)  That a multi-lateral agreement on animal protection should be negotiated.

  Whilst these suggestions are welcome, CIWF fears that they do not, on their own, go far enough. At the core of the problem is the WTO's restrictive attitude to process and production methods (PPMs) being taken into account. As currently interpreted, the WTO rules prevent a WTO member's marketing or import regulations from distinguishing between products on the basis of the way in which they are produced, if that distinction applies to imported as well as to domestic products.

  This is a major problem as nearly all attempts to improve animal welfare are concerned with the way in which animals are reared or treated.

  At the heart of the WTO rules is the requirement that imported products must be treated no less favourably than like domestic products. At first sight this causes no problems. The WTO, however, has interpreted this rule quite perversely: in determining whether products are "like" one another a country may not look at the way in which they are produced. An egg is an egg, whether it is battery or free range. Thus if a country prohibits the marketing of domestically produced battery eggs, it cannot extend that ban to imported battery eggs as, as far as the WTO is concerned, a battery egg is "like" a free-range egg and so imported battery eggs cannot be treated differently from free-range eggs.

  This leads to the absurdity that, starting off from a rule that prevents imported products being discriminated against, we arrive at the position where imported products must be treated more favourably than domestic ones. For example, a WTO member can prohibit the marketing of domestically produced stall and tether-pigmeat, but cannot extend that ban to imported pigmeat.

  CIWF believes that WTO members should be permitted to make PPM distinctions in their marketing or import regulations, subject to rules designed to prevent abuse. We suggest that such rules could provide that PPM distinctions must:

  (a)  Be transparent, non-discriminatory and proportionate.

  (b)  Be science-based, ie there must be a body of science which shows that the distinction being made is legitimate in pursuit of the policy objective trying to be achieved.

  (c)  Be supported by a significant proportion of the population of the country making the distinction.

  (d)  Be concerned with a matter of substance rather than an insignificant point.

  Other areas in which progress is essential are:

Preferential tariff rates

  We urge the EU to press for the revised WTO Agreement on Agriculture to permit WTO members to encourage good welfare by offering reduced tariff rates for imports derived from animals reared to high welfare standards. For example, the EU's position could be that it is willing to agree only a modest reduction in tariff rates for meat and eggs in general, while agreeing a much greater reduction for meat and eggs coming from animals reared to reasonable welfare standards.

  This approach would produce a classic win-win situation. Trade would be promoted by reduced tariffs, while at the same time exporting countries would be encouraged to adopt improved standards of welfare.


  It is absurd that the WTO, which believes in the primacy of the free market and market mechanisms, stands in the way of mandatory labelling schemes designed to ensure that consumers have the information they need to make informed purchasing decisions. Certainly the EU takes the view that mandatory labelling schemes are inconsistent with WTO rules; the EU's recent regulation on egg labelling requires eggs produced in the EU to be labelled as to farming method, but applies a much weaker labelling regime to imported eggs.

Compassion in World Farming

December 2001

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