EU Dog Cat Alliance
The EU Dog Cat Alliance was created in 2014.
ID: 790258914732-21
Lobbying Activity
Response to Protection of animals during transport
12 Apr 2024
The EU Dog & Cat Alliance in principle welcomes the Commissions proposed regulation on the Protection of Animals During Transport and Related Operations (COM(2023)770). The legislation would mark an important step forward for standards in dog and cat welfare by updating the rules covering animal transit, which have been in place since 2005. However, this is a crucial opportunity to effect real change for dog and cat welfare and we believe the legislation, as it has been proposed, has not sufficiently considered the species-specific needs of dogs and cats. The legislation does not make clear which provisions apply to dogs and cats, as they are not included within the definition of terrestrial animals but are referred to under the technical rules for terrestrial animals. We have outlined our concerns and recommendations in more detail in the attached file.
Read full responseResponse to Welfare of dogs and cats and their traceability
14 Mar 2024
The EU Dog & Cat Alliance welcomes the Commissions proposed regulation (COM(2023)770) on the welfare and traceability of dogs and cats. The legislation would mark an important step forward for standards in dog and cat welfare. However, we would like to see the regulations go further to effect real change for dogs and cats and we have outlined our recommendations in the attached file.
Read full responseMeeting with Maria Noichl (Member of the European Parliament)
24 May 2023 · Überarbeitung Tiertransportverordnung
Meeting with Martin Hojsík (Member of the European Parliament)
6 Sept 2022 · Cction plan on illegal trade of dogs and cats
Response to Preventing and combatting gender-based violence
18 May 2022
The EU Dog & Cat Alliance urges the European Commission to acknowledge in the proposed Directive the barrier that pets can represent for people escaping domestic abuse so that this is taken into consideration in EU Member States’ efforts to protect people experiencing domestic abuse.
The founding member of the EU Dog & Cat Alliance, Dogs Trust, has found through its dog fostering service for people fleeing domestic abuse and going into refuge that many women accessing this service do not want to leave their home until their pet is in a place of safety. Furthermore, if the pet is left behind when the person experiencing domestic abuse flees to refuge, even if the pet left behind is legally owned by the perpetrator or a ‘joint’ pet owned by both parties, the pet may be at risk of significant harm from the perpetrator. One study in the UK found that 71% of pet owners report that their perpetrator had threatened, injured or killed family pets [1]. In 2019, Dogs Trust surveyed Domestic Abuse Professionals and Practitioners in the UK, finding that almost 89% of professionals had seen cases where a pet has also been abused and almost half were aware of domestic abuse cases where the pet has been killed. 97% of professionals said pets are often used as a means of controlling someone experiencing domestic abuse [2].
The UK NGO Safe Lives recognises that “threats to damage the property and cause injury to pets” is one of the characteristics of coercive control [3]. Research has also shown that acts of animal abuse may be used to coerce, control and intimidate women and children to remain in, or be silent about, their abusive situation [4]. The well-known domestic abuse resource, The Duluth Power and Control Wheel also recognises that behaviour towards pets can be used to intimidate someone and maintain power and control over them [5].
The EU Dog & Cat Alliance recommends that behaviour towards pets in domestic abuse situations be recognised in the European Commission’s proposal for a Directive as this could lead to a clearer understanding and better protection for people and pets experiencing domestic abuse.
[1] Ascione, F.R., Weber, C. V. & Wood, D. S. 1997). The abuse of animals and domestic violence: A national survey of shelters for women who are battered. Society & Animals 5(3), 205-218.
[2] Dogs Trust. 2019. Research findings available at: https://www.moretodogstrust.org.uk/freedom-project-parent/news-and-updates
[3] Safe Lives. 2019. Introduction to Coercive Control. [ONLINE] Available at: http://www.safelives.org.uk/practice_blog/introduction-coercive-control. [Accessed 6 May 2022]
[4] Ponder, C. and Lockwood, R. (2000) ‘Cruelty to animals and family violence’, Training Key, 526, pp.1 - 5. (Published by the International Association of Chief of Police)
[5] The Duluth Power and Control Wheel. [ONLINE] Available at: https://www.theduluthmodel.org/wheels/. [Accessed 6 May 2022]
Read full responseResponse to Animal welfare labelling for food
4 Aug 2021
The EU Dog & Cat Alliance represents 73 organisations in 25 EU Member States and 21 organisations from the UK, Jersey and Guernsey. These include veterinary organisations, organisations involved in the rescue/rehoming of dogs and cats and organisations working to protect dog and/or cat welfare.
The EU Dog & Cat Alliance has the following feedback on the roadmap:
- The inclusion of dog and cat welfare in transport for commercial purposes in the revision of EU animal welfare legislation is highly welcome. We support the general conditions for the transport of animals under Regulation (EC) 1/2005, as well as the specific provisions for dogs and cats transported commercially between Member States, but we see significant room for improvement and new provisions to better protect dog and cat welfare.
- It is crucial that EU legislative provisions take new learnings, based on scientific evidence on the possible effects of long-distance transportation on dog and cat welfare, into account. While research in this area is not extensive, studies have been conducted into the effect of transportation on dog welfare, and wider research on potential sources of fear or distress during transportation across species is likely to be applicable to dogs and cats. In specific areas where evidence is limited, the Commission should seek input from independent animal health and welfare experts and recognised animal behaviour experts.
- We strongly support “Option 2” to introduce dog- and cat-specific requirements for both journeys and transport facilities. More detailed requirements such as pre-departure inspections, health certificates, and approval and logging of journey plans in TRACES would greatly improve transparency and accountability when dogs and cats are transported for commercial purposes, thereby better ensuring their welfare. Furthermore, such checks would enhance enforcement of animal health requirements in commercial transport in Directive 92/65/EEC (“Balai” Directive), many of which, for example the minimum age requirements, directly impact welfare and are often subject to non-compliance by illegal traders of pets. While further action is needed to target misuse of other legislation by illegal traders, pre-departure checks (including checks against information on national databases) and journey logs could improve enforcement of the rules set out in the Balai Directive.
- We strongly support the proposal for specific requirements for transport facilities, including space allowances, travel times and temperature limits. Space allowances were among the recommendations in EFSA’s Opinion on welfare of animals during transport published in 2004(1). Regarding travel times, we strongly recommend that new provisions in Regulation (EC) 1/2005 include appropriate maximum journey times and rest stop requirements specific to dogs and cats, and revised maximum intervals for water provision. Requirements on temperature range should consider the differing needs of young versus adult dogs and cats, as well as of dogs and cats transported during the gestation period, and should go together with ventilation requirements.
- We also recommend bringing forward the limit for transport during pregnancy (set at 90% in Regulation (EC) 1/2005) to earlier in the gestation period for dogs and cats.
Regarding the consultation of citizens and stakeholders:
- We wish to stress the importance of a wide consultation on animal welfare during transport. Requirements for transport of dogs and cats for commercial purposes should be agreed with input from independent experts including vets, animal welfare experts and recognised animal behaviour experts.
- There is wealth of expertise and extensive experience in best practices in the transport of dogs and cats amongst EU Dog & Cat Alliance members. We would welcome the opportunity to participate in targeted consultations regarding dog and cat welfare in transport.
(1) https://www.efsa.europa.eu/en/efsajournal/pub/44
Read full responseResponse to Digital Services Act: deepening the Internal Market and clarifying responsibilities for digital services
31 Mar 2021
Advertisements for pets involved in illegal trade pose significant risks to the health and welfare of the animals involved, as well as to EU consumers. While the EU Pet Advertising Advisory Group (EUPAAG) works to support online platforms’ self-regulation, we see the Digital Services Act as an opportunity for the EU to improve standards of online advertising of pets via regulatory obligations.
EUPAAG welcomes the proposed obligations on online platforms to ensure traceability of traders in online marketplaces, and the proposed requirement for online platforms to put user-friendly and easy-to-access notice and action mechanisms in place on their websites. The latter is crucial to enable consumers and volunteers to flag advertisements of dogs and cats for sale that could potentially be involved in illegal commercial practices. Platforms must have a duty to act on these, including carrying out appropriate checks and suspending services to traders who post such adverts or banning those who repeatedly post them.
EUPAAG understands that the Regulation is designed to fit together with the E-Commerce Directive and to take a horizontal approach rather than specifying obligations for individual sectors. However, according to the findings of the EU coordinated control plan for the official controls on online sales of dogs and cats[1], there is a concerning lack of information about sellers and the animals they are advertising in a large share of online advertisements of dogs and cats for sale. Given the cross-border nature of the illegal pet trade and the prevalence of cross-border practices of many online traders of pets[2], a harmonised EU approach to tackling illegal practices in online pet advertising is urgently needed to protect EU consumers and the welfare of the animals in question.
EUPAAG calls for an EU-wide requirement for online platforms to request a minimum of information from online traders in their advertisements of pets for sale. As in Article 22 on the minimum of information for traders, platforms should be required to make reasonable efforts to assess the information in adverts for pets and should suspend the service to the trader if the trader fails to correct or complete inaccurate or incomplete information in the advertisement. Consideration should be given to what reasonable efforts to assess the information should entail, for example running automated filters and checks for signs of illegality or for ‘blacklisted’ words or terms in the advertisements, such as for banned breeds.
The minimum of information for advertisements of pets for sale should include the registration details of the breeding establishment (registration of breeding establishments will become mandatory in all EU Member States from 21st April 2021), their status as a hobby breeder, commercial breeder or intermediary trader, the age of the animal, its country of origin, country of residence and a photo of the animal. Where identification and registration of owned cats and dogs or for cats and dogs at the point of ownership change is mandatory in a Member State, microchip numbers should also be required. Including the breeder/seller registration number and, in the case of dogs, the microchip number in advertisements is already a legal requirement in Ireland under the Animal Health and Welfare (Sale or Supply of Pet Animals) Regulations 2019.
To ensure that consumers are sufficiently informed regarding adverts for pets potentially involved in illegal practices, EUPAAG strongly recommends that obligations for online traders go together with a requirement for online platforms to provide consumers with, or direct them to, information on relevant national and EU legislation on the sale of pets, advertising of pets for sale, and cross-border trade of pets.
[1]https://ec.europa.eu/food/animals/welfare/other_aspects/online_dog-cat_en
[2]https://s3.eu-west-1.amazonaws.com/assets.dogandcatwelfare.eu/live/media/publicationtemp/EUPAAG_Report_FINAL_low_res.pdf
Read full responseResponse to Fitness Check of the EU legislation on animal welfare
29 Jul 2020
The EU Dog & Cat Alliance represents 90 organisations across 25 EU Member States. These include veterinary organisations, organisations which are involved in the rescue/rehoming of dogs and cats and organisations which are working to protect dog and/or cat welfare. Please find our feedback on the Roadmap for the Fitness check of the EU legislation on animal welfare of farmed animals in the document attached.
Read full responseMeeting with Diana Montero Melis (Cabinet of Commissioner Jutta Urpilainen) and Dogs Trust
14 Jan 2020 · The contribution of working animals to the 2030 Agenda for Sustainable Development and the SDGs
Response to Evaluation of the EU Animal Welfare Strategy (2012-2015)
14 Jun 2019
About the EU Dog & Cat Alliance
The EU Dog & Cat Alliance represents 83 organisations across 25 EU Member States. These includes veterinary organisations, organisations which are involved in the rescue/rehoming of dogs and cats and organisations which are working to protect dog and/or cat welfare. A list of all Alliance members can be found at https://www.dogandcatwelfare.eu/about/. The Alliance’s main focus is on lobbying the EU to introduce and improve EU legislation in relation to dogs and cats.
The EU Dog & Cat Alliance has the below feedback on the Roadmap for the Evaluation of the European Union Strategy for the Protection and Welfare of Animals 2012-2015.
General feedback
• We strongly welcome the confirmation that the European Union Strategy for the Protection and Welfare of Animals will be evaluated in 2019 and 2020. The EU Dog & Cat Alliance has concerns that several actions within the strategy have not been sufficiently taken forward.
• Although the Roadmap states Q4 2020 for the planned completion date, it is not clear when the full findings of the evaluation will be published and how these will be shared with the European Parliament, Council of the EU and other important stakeholders.
• We welcome the point that the targeted consultation activities will be conducted by a consultant, as this will help to ensure they are conducted independently. However, we have concerns that the overall evaluation, and any conclusions drawn, may be conducted by the DG SANTE team responsible for the drafting of the Strategy, and that this will not allow a completely independent assessment of the extent to which the Strategy has delivered against its intended objectives. We therefore recommend that all stages of the evaluation process are run, and all results analysed, independently.
Consultation of citizens and stakeholders
The Roadmap states that the consultation process will include a set of targeted consultation activities tailored for particular stakeholders’ groups and possibly a stakeholder conference/workshop/seminar. We are interested to know how it will be decided which stakeholders will be invited to participate in these activities and how they will be invited. There is a wealth of expertise amongst EU Dog & Cat Alliance members and we would welcome the opportunity to participate in surveys, interviews and focus groups, and contribute to the evaluation of the Strategy from a dog and cat welfare perspective.
Data collection and methodology
The EU Dog & Cat Alliance welcomes that the evaluation will also triangulate qualitative and quantitative evidence obtained through stakeholders’ consultation, literature research and reports from a wide range of sources. We urge the Commission to confirm whether there will also be opportunities for relevant stakeholders to put forward their own research for inclusion in the evaluation. For example, the EU Pet Advertising Advisory Group undertook a study looking at the increasing problem of inappropriate dog and cat adverts appearing on classified websites. We believe this study would be useful to the evaluation from a dog and cat welfare perspective. Furthermore, Dogs Trust, the EU Dog & Cat Alliance’s founding member, has produced four reports on the illegal pet trade uncovering widespread abuse of Regulation (EU) No 576/2013, commonly known as the Pet Travel Scheme.
Read full responseMeeting with Vytenis Andriukaitis (Commissioner) and
22 Feb 2018 · Pet welfare
Response to Commission Delegated Regulation on Echinococcus multilocularis (EM) infection in dogs
6 Oct 2017
Overall, the EU Dog & Cat Alliance welcomes the new Delegated Regulation and supports keeping the main provisions of Delegated Regulation (EU) No 1152/2011. However, there are several areas in the new wording which raise potential concerns:
1. The Alliance would question removing the names of specific countries from the new Delegated Regulation (formerly under Annex I of Delegated Regulation (EU) No 1152/2011), thereby not specifying that Finland, Ireland, Malta and the United Kingdom are countries which can benefit from special health measures in order to remain protected from EM infection.
2. Following EFSA’s opinion of December 2015 on “Echinococcus multilocularis infection in animals,” the new Delegated Regulation stipulates that in order to be eligible for preventive health measures in country which has no natural hosts (i.e. wild red foxes), that country must not have recorded the presence of wild foxes in any part of its territory (Article 2.2). This is of great concern because, should even one red fox be detected in the country, that country would then presumably lose its derogation, thereby compromising public and animal health in that country. A more constructive and conducive to protecting human and animal health response would be to maintain a more proportionate approach if a red fox is detected in, for example, Malta, i.e. rather than an immediate loss of derogation or the need to reapply, the presence of a red fox should then trigger the need to monitor for the presence of EM. Such an approach could be based on the example of the United Kingdom, which has a native population of red foxes and still maintains the preventive health measures as stipulated in Delegated Regulation (EU) No 1152/2011 by having in place a thorough detection system for the EM infection in wild animals.
3. Furthermore, should the derogation be lost due to the detection of a red fox in the country, this would introduce a significant risk of the EM infection being passed on to humans through contaminated dog faeces from dogs carrying the parasite into the country if they are no longer required to be wormed prior to entry by potentially introducing disease where there is none. The public health risk is significant, as the parasite can cause alveolar echinococcosis in humans, which significantly impacts the liver, and therefore affects both quality of life and lifespan. The disease is often expensive and complicated to treat, and if left untreated, it has potentially fatal consequences. In Switzerland, it has been estimated that there is a cost of approximately €108,762 per patient treated for alveolar echinococcosis (Togerson et al, 2008). Assuming an annual 5% increase in medical costs, this would equate to more than €140,000 in 2017. [Torgerson, P.R., Keller, K., Magnotta, M., Ragland, N. (2010) The Global Burden of Alveolar Echinococcosis. PLoS Negl Trop Dis 4(6): e722. doi:10.1371/journal.pntd.0000722].
4. The EU Dog & Cat Alliance believes more scientific evidence is needed to support increasing the treatment window for EM in dogs to a 24 to 120 hour period (preamble 13 of Delegated Regulation (EU) No 1152/2011). The longer the window, the greater the chance of reinfection; therefore we would support shortening the window to the previous 24 to 48 hours.
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