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Eurogroup for Animals

Eurogroup for Animals is the leading pan-European animal protection organization.

Lobbying Activity

Meeting with Patricia Reilly (Cabinet of President Ursula von der Leyen)

17 Dec 2025 · Exchange of views regarding the Fitness Check of the EU rules on trade in seal products and the EU animal welfare legislation

Response to Supplementing Regulation (EU) 2016/429 on non-commercial movement of pet animals

9 Dec 2025

The draft delegated regulation represents a welcome and necessary step forward in enhancing the EUs legal framework governing non-commercial movements of dogs, cats and ferrets. In particular, the draft strengthens the definition of a single non-commercial movement, reducing opportunities to evade commercial rules through practices such as splitting large groups of animals across multiple owners. In addition, it sets out clearer conditions for derogations and permits, ensuring that flexibility is maintained but accompanied by appropriate oversight. The consolidation of identification and documentation rules further enhances traceability, while the clearer delineation of responsibilities for veterinarians and competent authorities supports more consistent and effective enforcement. Finally, the reinforcement of control measures at travellers points of entry serves to close existing loopholes and improve the overall integrity of the system. However, to fully realise the goal of combating the illegal pet trade, and to incorporate essential complementary components also identified in the European Commissions Enforcement Action Plan on the illegal trade of cats and dogs, further consideration should be given to the following: Harmonised enforcement powers and penalties, with clearer provisions ensuring consistent sanctions for fraudulent non-commercial declarations across all Member States. Enhanced post-movement monitoring, such as follow-up traceability checks for movements close to commercial thresholds or involving multiple animals, to detect disguised trade after entry. Greater use of data analytics and AI to identify suspicious patterns in microchip registrations, movement declarations, and veterinary certificates, searching for patterns signaling fraudulent non-commercial movements, such as clusters of movements below the limit, suspicious repeated declarations from the same persons or irregularities in official document issuance. Increase documentary controls and verification measures at travellers' points of entry/border crossings to detect forged or incomplete health certificates, passports, and vaccination documents. Intensifying and focusing checks on suspicious operators identified via risk profiling, including repeated cross-border inspections and on-site investigations of breeders and sellers suspected of fraudulent activity or tax evasion Implementation of a digital passport to enhance efficiency, data reliability, traceability, and regulatory oversight, including identification, vaccination, and medical history, supporting stronger enforcement and fraud prevention. Improved awareness and training, with capacity-building requirements for customs, veterinary, and law-enforcement authorities, as well as frontline staff at points of entry and the general public. Closer alignment with animal welfare and criminal law, including explicit links between non-commercial movement rules and existing welfare and criminal provisions to strengthen enforcement and deterrence. Bilateral and multilateral cooperation with key third countries: Emphasising the EUs strategic priority of enlargement by collaborating with candidate and neighbouring countries identified as sources of illegally traded pets (e.g., Serbia, Ukraine, Turkey). Underscoring in particular the need for candidate countries to align their legislation with the EU acquis, especially regarding the regulation of breeders and animal shelters, often key drivers of the illegal pet trade, while also providing targeted support for enforcement, implementation, information exchange, investigations, and capacity building to reduce illegal flows into the EU and as part of the pre-accession assistance. Regular review and update the legal framework based on enforcement experience and emerging fraud schemes, closing loopholes that allow abuse of non-commercial movement rules. There are specific concerns regarding several provisions of this delegated regulation, particularly t
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Meeting with Maria Noichl (Member of the European Parliament)

5 Dec 2025 · Mobile Schlachtung

Meeting with Martin Hojsík (Member of the European Parliament, Shadow rapporteur)

5 Dec 2025 · ECHA Regulation, animal protection

Meeting with Isabella Lövin (Member of the European Parliament)

2 Dec 2025 · Octopus welfare

Meeting with Kathleen Van Brempt (Member of the European Parliament)

26 Nov 2025 · EU-Thailand Free Trade Agreement

Meeting with Christophe Clergeau (Member of the European Parliament, Rapporteur) and European Environmental Bureau and ClientEarth AISBL

20 Nov 2025 · ENVI - ECHA

Meeting with Patricia Reilly (Cabinet of President Ursula von der Leyen)

17 Nov 2025 · to follow

Meeting with Patricia Reilly (Cabinet of President Ursula von der Leyen)

17 Nov 2025 · future animal welfare initiatives.

Meeting with Valérie Deloge (Member of the European Parliament, Rapporteur)

12 Nov 2025 · Transport des animaux

Eurogroup for Animals opposes insect farming in circular economy proposals

6 Nov 2025
Topic — EU Circular Economy Act aims to enhance sustainability and recycling infrastructure.
Message — The organization argues that insect farming should not be promoted as a circular economy solution. They highlight that insects are typically fed grains rather than waste, and that allowing municipal or meat waste as insect feed presents food safety risks.123
Why — This would prevent competition from insect-based products in animal welfare advocacy efforts.4
Impact — The insect farming industry loses potential waste-to-feed pathways and market growth opportunities.5
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Meeting with David Cormand (Member of the European Parliament, Shadow rapporteur)

31 Oct 2025 · Livestock

Meeting with Barbara Bonte (Member of the European Parliament)

27 Oct 2025 · Mercosur

Meeting with Stefan Köhler (Member of the European Parliament)

22 Oct 2025 · Politischer Austausch zur Brasilien-Mission des Agrarausschusses

Meeting with Thomas Waitz (Member of the European Parliament)

22 Oct 2025 · Animal Husbandry

Meeting with Niels Fuglsang (Member of the European Parliament)

21 Oct 2025 · Animal Welfare

Meeting with Alberto Fernandez Diez (Cabinet of Commissioner Marta Kos) and Transport and Environment (European Federation for Transport and Environment) and

20 Oct 2025 · Implementation of EU acquis across several areas, including environment, climate, labour and animal welfare.

Meeting with Tilly Metz (Member of the European Parliament, Rapporteur) and Humane World for Animals Europe and

20 Oct 2025 · Animal transport

Meeting with Maria Noichl (Member of the European Parliament, Shadow rapporteur)

20 Oct 2025 · Animal transport, end cages

Eurogroup for Animals Opposes Dropping Animal Depopulation Reports

14 Oct 2025
Topic — Regulation simplifying food and feed safety requirements across EU animal health laws.
Message — The organization demands that Member States retain the obligation to submit annual reports on emergency animal depopulation operations. They request the Commission harmonize and digitize reporting through a public database instead of eliminating it. They also call for maintaining current BSE/TSE protections and environmental safeguards.123
Why — This would preserve transparency over mass culling operations affecting millions of animals annually.45
Impact — Animals lose welfare protections during emergency culling operations conducted under time pressure.67
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Meeting with Niels Fuglsang (Member of the European Parliament)

14 Oct 2025 · Animal Welfare Intergroup

Meeting with Niels Fuglsang (Member of the European Parliament)

9 Oct 2025 · Animal Welfare

Meeting with Valérie Hayer (Member of the European Parliament)

6 Oct 2025 · Fur

Meeting with Tilly Metz (Member of the European Parliament)

30 Sept 2025 · Laying hens

Meeting with Niels Fuglsang (Member of the European Parliament)

30 Sept 2025 · Animal Welfare

Animal welfare group warns against rewarding industrial farms with nature credits

29 Sept 2025
Topic — EU roadmap for developing a voluntary nature credit system to fund conservation.
Message — The organization requests strict criteria preventing industrial farms from receiving credits and limiting beneficiaries to those solely dedicated to conservation. They demand independent audits and public data to ensure beneficiaries don't undertake harmful activities. Only net positive actions beyond legal obligations should qualify, not mere maintenance of biodiversity.1234
Why — This would prevent nature credits from subsidizing the industrial agriculture sector they oppose.567
Impact — Industrial farms lose potential revenue from nature credits despite their environmental impact.89
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Meeting with Michal Wiezik (Member of the European Parliament, Shadow rapporteur)

23 Sept 2025 · Welfare of cats and dogs

Meeting with Tilly Metz (Member of the European Parliament, Shadow rapporteur)

17 Sept 2025 · Cats and Dogs

Meeting with Niels Fuglsang (Member of the European Parliament)

15 Sept 2025 · Animal Welfare

Response to European Research Area (ERA) Act

10 Sept 2025

Eurogroup for Animals welcomes and supports the European Research Area (ERA) Act proposed by the European Commission, which offers an opportunity to foster an innovation-driven and humane research ecosystem as a central pillar of European competitiveness, sustainability, public health and values. The ERA Act can improve Europes research and innovation (R&I) system by explicitly prioritising animalfree innovationincluding technologies such as organonchip, advanced in vitro models, in silico methods and AIenabled platformsacross its three policy blocks: (1) national commitments to reach the 3% R&D target; (2) better alignment of investments and policies; and (3) improved framework conditions for researchers, open science and research infrastructures. Anchoring animalfree innovation within the ERA Act will: (1) Advance scientific excellence and translation Evidence from the European Commissions Joint Research Centre (JRC) shows nonanimal approaches are particularly effective in disease diagnostics, prevention and humanrelevant modelling, and should become increasingly embedded in EUfunded projects; (2) Respond to strong societal demandEU citizens consistently call for a coordinated strategy to transition to research, testing and education without animals; a recent European Citizens Initiative surpassed 1.2 million signatures; and (3) Boost competitiveness and reduce fragmentationCoordinated EUnational actions can accelerate uptake, standardisation/validation and regulatory use of NAMs, help SMEs scale, strengthen skills, and ensure interoperable research infrastructures. To operationalise this, we propose six mutually reinforcing measures to be embedded in the ERA Act: 1) Binding national trajectories and earmarks within the 3% R&D target to progressively reserve a share of public lifescience R&D and researchinfrastructure investment for the development, standardisation/validation, and uptake of innovative methods without the use of animals. 2) EUnational alignment instruments with cofunded partnerships on animalfree innovation, education and specialisation strategies for animal-free NAMs, as well as interoperable European Research and Technology Infrastructures for patient-relevant science (e.g., organonchip testbeds) with transnational access. 3) Open science and data policy specific to NAMs, promoting FAIR data, panEU NAMs knowledge commons, and incentives for reproducibility and method transfer. 4) NAMs skills and careers, including microcredentials and curricula that mainstream NAMs across medicine, biology, toxicology, data science and other relevant areas, and mutual recognition of NAMs competencies. 5) Regulatory acceptance and innovationfriendly rules grounded in outcomebased approaches, regulatory sandboxes for NAMs, and iterative reviews of animalbased standards. 6) A public scoreboard for humane innovation to monitor progress on funding, infrastructures, skills, regulatory uptake and societal impact. These proposals map directly onto the ERA Acts problem definition and policy architecture as described in the call for evidence, namely, the need to overcome fragmentation, align investments with strategic priorities, and improve R&I framework conditions while upholding fundamental values and the freedom of scientific research. The attached submission elaborates on the above proposals.
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Meeting with Valérie Hayer (Member of the European Parliament)

9 Sept 2025 · Mercosur

Eurogroup for Animals urges EU to protect animal rights organisations

2 Sept 2025
Topic — The consultation aims to develop a strategy for strengthening and protecting European civil society.
Message — The group calls for an EU strategy that treats civil society as an active and equal partner. They request a binding agreement on civil dialogue and a protection framework for defenders against attacks. They also demand systematic civic space impact assessments for all legislative proposals.123
Why — The organization would gain increased political influence and secure long-term financial stability through direct funding.45
Impact — Entities using smear campaigns or abusive lawsuits to silence animal welfare activists would be restricted.6
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Eurogroup for Animals demands robust animal welfare data monitoring

26 Aug 2025
Topic — This initiative amends definitions and exemptions for compiling EU farm sustainability data.
Message — The group demands measurable animal welfare indicators and stricter limits on member state exemptions. They urge linking antimicrobial usage to species and making data publicly available. Future revisions should expand to cover conditions during animal transport and slaughter.123
Why — Harmonized reporting would support the organization's goal of phasing out animal confinement systems.4
Impact — Greece, Sweden, Romania, and France lose their proposed flexibility regarding data reporting exemptions.5
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Eurogroup for Animals urges complete EU fur industry ban

28 Jul 2025
Topic — The Commission is assessing policy options to respond to a fur-free initiative.
Message — The group calls for a total ban on fur farming and imports. They argue current cages cannot meet the species-specific needs of animals.12
Why — A ban would permanently remove fur products from the European market.34
Impact — Fur industry workers and businesses would lose their livelihoods and production revenue.56
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Meeting with Manuela Ripa (Member of the European Parliament)

17 Jul 2025 · Cultivated Fish

Meeting with Jörgen Warborn (Member of the European Parliament)

17 Jul 2025 · Mercosur

Response to Modernisation of the EU legislation for on-farm animal welfare for certain animals

16 Jul 2025

Eurogroup for Animals welcomes the beginning of a much needed process of revision of the EU animal welfare legislation (Eurogroup for Animals, 2021) and the strong reference to phasing out cages, supported by 1.4 million EU citizens, and urges clarity on timelines and inclusion of all farmed animals, including aquatic species. Positive developments also include the proposals to end the killing of day-old chicks and to apply EU animal welfare standards to imports, ensuring fairness for farmers and reducing cruelty abroad. However, outcome-based indicators alone are not enough; they must be coupled with clear, revised, science-based legislation to deliver genuine improvements. This submission offers a concise analysis of the evidence supporting a swift transition to cage-free farming, the use of robust animal welfare indicators, harmonised welfare rules for imports, the ban on male-chick culling and the inclusion of overlooked species such as aquatic animals, equines, and farmed wild animals. Together, these steps will ensure stronger protection, legal clarity, and a fair internal and international market. Over 300 million animals are caged annually in the EU, restricting natural behaviors. While some Member States phase out cages, an EU-wide ban would harmonize standards and meet citizen expectations. Transitions like moving sows to free-farrowing systems (3-5 years) and hens to cage-free systems (4-6 years) improve welfare and productivity. For broilers, lower stocking densities and slower-growing breeds improve health and welfare and are highly measurable. It is crucial that these standards apply equally to imported goods, first and foremost to ensure EU consumption does not fuel practices banned in the EU elsewhere in the world. We believe that import requirements can be introduced wherever ethical concerns of EU citizens have been established. Therefore, it will be hard to apply existing standards to imports, as they are not aligned anymore with citizens expectations and scientific knowledge. Including all products placed on the EU market within the scope of the revision will also create more level playing field for EU farmers. The grinding and gassing of over 370 million male chicks and ducklings annually must end. Highly cost effective solutions of in-ovo sexing, now adopted for 28% of EU hens, detect sex before hatching, among other solutions being used such as dual-purpose breeds, answering citizens' calls to stop this cruel practice. Countries like Germany and France are leading the way and already applying these techniques with success. The farming and release of game animals such as pheasants and hares for hunting raises ethical, environmental, and health concerns. A complete ban is necessary. With an estimated 7 million equids in Europe, their welfare remains a serious concern, largely due to inconsistent protection and the absence of species-specific legislation. The lack of traceability further exacerbates critical issues such as unregulated breeding, document fraud, poor care of working equids, abandonment and inadequate housing, among others. Aquatic animals, over 1 billion farmed annually in the EU-are still excluded from binding welfare rules. Despite clear evidence of sentience and EFSA guidelines, and industry support, protections are lacking. New legislation must address water quality, density, handling, and slaughter. With 70% of seafood imported, welfare standards must also apply to imports to ensure fair competition and meet strong public support, 9 out of 10 of Europeans agree fish should be protected. In conclusion, the EU must seize this opportunity to lead on animal welfare. Ending cages, setting measurable standards, applying rules to imports, banning chick culling, regulating game farming, and protecting aquatic species are essential. With science, public support, and digital tools aligned, policymakers must act decisively to create a transparent, ethical, and enforceable animal welfare framework
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Eurogroup for Animals urges animal welfare-centered farming renewal

14 Jul 2025
Topic — EU initiative to attract young farmers and address demographic challenges in agriculture.
Message — The group wants renewal funding conditional on animal welfare outcomes. They recommend prioritizing organic systems and rejecting investments in cages and insect farming.12
Why — Linking renewal to welfare standards shifts significant agricultural subsidies toward animal protection.34
Impact — Industrial livestock producers and the insect farming sector would lose access to renewal funding.5
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Meeting with Manuela Ripa (Member of the European Parliament, Rapporteur)

9 Jul 2025 · CITES

Meeting with Niels Fuglsang (Member of the European Parliament)

2 Jul 2025 · Meeting on intergroup for animal welfare

Meeting with Patricia Reilly (Cabinet of President Ursula von der Leyen) and VIER PFOTEN International and Compassion in World Farming Brussels

30 Jun 2025 · Discussion on animal welfare in the Common Agriculture Policy (CAP

Meeting with Patricia Reilly (Cabinet of President Ursula von der Leyen) and VIER PFOTEN International and Compassion in World Farming Brussels

30 Jun 2025 · to follow

Meeting with Adam Jarubas (Member of the European Parliament, Committee chair)

27 Jun 2025 · one health - zależności zdrowia ludzkiego i zwierząt

Meeting with Bernard Van Goethem (Director Health and Food Safety)

20 Jun 2025 · To discuss the outcome of the future new EU-UK Agreement in the area of animal welfare

Eurogroup for Animals backs lab meat over insect farming

19 Jun 2025
Topic — This initiative seeks solutions for a circular, climate-neutral and competitive European bioeconomy.
Message — Eurogroup for Animals asks the Commission to support the biotechnology sector and its food system applications. They specifically recommend funding open-access research to help smaller companies scale up production. Finally, they advise against false solutions such as insect farming.123
Why — Promoting lab-grown alternatives would reduce the environmental impact and land usage of farming.4
Impact — The insect farming industry faces losing credibility and funding due to high resource intensity.5
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Meeting with David Cormand (Member of the European Parliament, Shadow rapporteur) and Compassion in World Farming Brussels and

18 Jun 2025 · Policy Breakfast

Eurogroup for Animals Urges Support for Animal-Free Biotech Methods

11 Jun 2025
Topic — New EU framework aiming to accelerate biotechnology products from labs to markets.
Message — The organisation calls for support of cellular agriculture while rejecting insect farming as a sustainable solution. They urge the EU to prioritise animal-free methodologies like organ-on-chip and AI over traditional testing.12
Why — Adopting non-animal methods would advance the group’s core mission of animal protection.3
Impact — The insect farming industry would lose access to critical EU financial support.4
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Meeting with Michal Wiezik (Member of the European Parliament, Shadow rapporteur)

10 Jun 2025 · Illegal pet trade

Meeting with Raquel García Hermida-Van Der Walle (Member of the European Parliament)

3 Jun 2025 · Positive list pets

Meeting with Martine Kemp (Member of the European Parliament)

28 May 2025 · Animal Welfare during Transport

Meeting with Olivér Várhelyi (Commissioner) and

27 May 2025 · Animal welfare

Response to European strategy on research and technology infrastructures

22 May 2025

Eurogroup for Animals welcomes the European Commissions initiative and urges that the European Strategy on Research and Technology Infrastructures explicitly supports non-animal new approach methodologies (NAMs). To ensure Europes competitiveness and scientific leadership, the strategy should incorporate the following proposals: 1. Develop a dedicated EU infrastructure network for NAMs Establish interconnected research and technology infrastructures that provide equitable access to non-animal methods, including organoids, organ-on-chip, and computational models. 2. Adopt and replicate best-practice access models Leverage frameworks like the EURL ECVAM Open Lab and the European OoC Society to ensure open and cost-efficient access to advance innovation across Member States. 3. Foster harmonised, professional training programs The EU infrastructure can facilitate structured training and mentorship schemes across the EU to build expertise on NAMs, closing the gap with the well-established training infrastructure for animal-based research. 4. Facilitate validation and qualification studies Strengthen the laboratory network for validating and qualifying NAMs to enhance their acceptance and use, ensuring that industry, regulators and researchers can adopt the most suitable models for their projects. 5. Promote data access and knowledge sharing Promote infrastructure-enabled open data policies and user support systems to increase collaboration and trust in innovative methods. 6. Ensure industrys capacity to accompany scientific development Ensure that targeted industry sectors adopt new test methods as they become embedded in regulations and guidance. 7. Ensure alignment with relevant EU policy initiatives Coordinate with the ERA Action on NAMs, the EU roadmap towards phasing out animal testing, and the upcoming EU Strategy for Life Sciences to maximise synergies and impact. By adopting these proposals, the EU can support a resilient, innovative, and humane research ecosystem that advances scientific excellence and public trust. Please see the attached submission for additional information.
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Meeting with Ton Diepeveen (Member of the European Parliament, Rapporteur)

22 May 2025 · Imported fish products and animal welfare

Meeting with Flavio Facioni (Cabinet of Commissioner Olivér Várhelyi) and Una Terra Alapítvány

16 May 2025 · Animal welfare

Response to New comprehensive strategic approach towards India

6 May 2025

Thank you for the opportunity to provide feedback on the new comprehensive strategic approach between the EU and India. Eurogroup for Animals, the pan-European animal protection organisation, wishes to contribute to this consultation in the context of EU-India trade relations. Eurogroup for Animals calls on prioritising animal welfare in the EU-India agenda. The EU is transitioning towards sustainable food systems with animal welfare at its core, and it is crucial for the EU to cooperate on this with trade partners, as well as to ensure that imported animal products do not undermine these efforts. Please find more information in the attached file.
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Meeting with Christophe Hansen (Commissioner) and

30 Apr 2025 · Sustainable Protein Diversification for the Vision

Meeting with Marta Wcisło (Member of the European Parliament)

28 Apr 2025 · Meeting with Animal Group Europe representatives on animal transport, trade with Ukraine and Mercosur

Meeting with Kosma Złotowski (Member of the European Parliament)

25 Apr 2025 · Protection of animals during transport

Meeting with Cristina Guarda (Member of the European Parliament)

25 Apr 2025 · Animal welfare

Meeting with Maria Noichl (Member of the European Parliament)

23 Apr 2025 · Fur Farming, Cats and Dogs

Eurogroup for Animals urges non-animal methods in life sciences

17 Apr 2025
Topic — A European Commission initiative to boost competitiveness and innovation in life sciences.
Message — They call for a unified EU strategy to replace animal experiments with technology. This includes dedicated funding and harmonized training for researchers.12
Why — This transition would eliminate the ethical burden and animal suffering from testing.3
Impact — Traditional laboratories face significant challenges adapting to complex new regulatory landscapes.4
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Meeting with David Cormand (Member of the European Parliament)

16 Apr 2025 · Animal Welfare

Meeting with Thomas Waitz (Member of the European Parliament)

8 Apr 2025 · Animal welfare

Meeting with Veronika Vrecionová (Member of the European Parliament, Committee chair)

7 Apr 2025 · Priorities of the new legislative term

Meeting with Arash Saeidi (Member of the European Parliament, Shadow rapporteur)

7 Apr 2025 · Echange de point de vue

Meeting with César Luena (Member of the European Parliament)

3 Apr 2025 · Wolf protection status

Meeting with Michal Wiezik (Member of the European Parliament) and Humane World for Animals Europe

2 Apr 2025 · Protection of wolves

Meeting with Raphaël Glucksmann (Member of the European Parliament)

1 Apr 2025 · Animal welfare

Meeting with Annalisa Corrado (Member of the European Parliament) and Essere Animali

1 Apr 2025 · Animal welfare

Meeting with Cristina Guarda (Member of the European Parliament)

1 Apr 2025 · Horse meat

Meeting with Patricia Reilly (Cabinet of President Ursula von der Leyen)

31 Mar 2025 · Animal welfare policies and legislation.

Meeting with Valérie Hayer (Member of the European Parliament) and European Rural Poultry Association

27 Mar 2025 · Animal transport

Meeting with Anja Hazekamp (Member of the European Parliament, Shadow rapporteur) and VIER PFOTEN International

27 Mar 2025 · Welfare of dogs and cats

Meeting with Valérie Deloge (Member of the European Parliament, Shadow rapporteur)

26 Mar 2025 · Transport des animaux

Meeting with Daniel Buda (Member of the European Parliament, Rapporteur) and Blic Oy and

26 Mar 2025 · Animal Welfare during Transport

Meeting with Anja Hazekamp (Member of the European Parliament)

26 Mar 2025 · Working group animal transport

Response to Updating the list of invasive species threatening biodiversity and ecosystem services across the EU

21 Mar 2025

Please find attached Eurogroup for Animals comments on Draft implementing regulation (Ares(2025)1470705) updating the list of invasive species threatening biodiversity and ecosystem services across the EU.
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Meeting with Piotr Rydzkowski (Head of Unit Trade) and BUSINESSEUROPE and

18 Mar 2025 · CSD Contact Group meeting-Overview of Trade priorities and rolling calendar

Meeting with Cristina Guarda (Member of the European Parliament)

17 Mar 2025 · Animal Welfare

Meeting with Tilly Metz (Member of the European Parliament)

13 Mar 2025 · Animal Welfare

Meeting with Niels Fuglsang (Member of the European Parliament)

12 Mar 2025 · Meeting on Animal Welfare

Meeting with David Cormand (Member of the European Parliament)

10 Mar 2025 · Animal Welfare

Eurogroup for Animals urges EU to regulate horse meat

5 Mar 2025
Topic — Targeted updates to the Common Market Organisation to improve food supply chains.
Message — The group wants horse meat included in the regulation's scope for marketing standards. They request mandatory country-of-origin labeling to improve transparency and food safety.12
Why — Regulation would protect the internal market from imports produced under poor conditions.3
Impact — Intermediaries and foreign suppliers lose profits from opaque and cruel trade chains.4
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Meeting with Maria Noichl (Member of the European Parliament)

4 Mar 2025 · Animal Welfare & Mercosur

Meeting with Ton Diepeveen (Member of the European Parliament)

4 Mar 2025 · EU-Mercosur

Meeting with Pascal Arimont (Member of the European Parliament)

26 Feb 2025 · Production standards in Mercosur

Meeting with Alisa Tiganj (Cabinet of Commissioner Christophe Hansen) and Bureau Européen des Unions de Consommateurs and

25 Feb 2025 · Vision for Agriculture & Food Exchange of views on the Vision on agriculture and food, in particular aspects related to the “food” aspects.

Meeting with Francesca Arena (Cabinet of Commissioner Costas Kadis)

24 Feb 2025 · Animal welfare concerning aquatic animals and aquaculture issues

Meeting with Antonella Rossetti (Cabinet of Commissioner Christophe Hansen)

20 Feb 2025 · Exchange of views on the Vision of Agriculture and Food related to animal welfare issues

Meeting with Anja Hazekamp (Member of the European Parliament) and Humane World for Animals Europe and

19 Feb 2025 · Event animal transport

Response to Uniform rules on good manufacturing practice for veterinary medicinal products and active substances

17 Feb 2025

Regulation (EU) 2019/6 of the European Parliament and of the Council of 11 December 2018 on veterinary medicinal products in its Recital (68) exposes that: The good manufacturing practice for the purpose of this Regulation should take into account the Union and international standards of animal welfare when active substances are prepared from animals. While this Commissions implementing regulation exposes on its Recital (2): The good manufacturing practices applicable in the Union should continue to be aligned with relevant international standards. The last Eurobarometer on attitudes of Europeans towards Animal Welfare shows an overwhelming majority of European citizens who demand better EU legislation that truly protects animals. This implementing regulation claims to align with Regulation (EU) 2019/6 but fails to consider EU and international animal welfare standards. It makes no reference to animal welfare and only briefly mentions the safety of treated animals (Art. 5.1a) while there is no mention of the animals from which the starting materials are sourced. One of our key concerns is Equine Chorionic Gonadotropin (eCG), also known as Pregnant Mare Serum Gonadotropin (PMSG), a hormone derived from the blood of pregnant mares, cruelly obtained and used to regulate fertility in farmed animals. The majority is imported from non-EU countries and extensively used in EU agriculture. The European Parliament in its Resolution on the Farm to Fork Strategy point 130 recalls that structural animal experiments that are not indispensable should have no place in the food chain as Directive 2010/63/EU prescribes the replacement and reduction of the use of animals in procedures; calls on the Commission and Member States to stop the import and domestic production of Pregnant Mare Serum Gonadotropin (PMSG), which is extracted from the blood of pregnant horses that are systematically impregnated and exposed to blood collections, involving health and welfare issues. The use of the Equine Chorionic Gonadotropin (eCG) is in breach of Directive 2010/63/EU since there are alternative methods available to achieve a satisfactory result: eCG produced in vitro (reCG), synthetic alternatives (36 in Germany only) and zootechnical measures among others. The 3Rs principle (replacement, reduction, and refinement) should be systematically integrated into the application of Good Manufacturing Practices. Furthermore, Annex II on additional requirements for biological and immunological veterinary medicinal products explicitly emphasizes on V7: the need to ensure traceability of substances of animal and human origin used in their manufacture. With eCG being imported from Uruguay and Argentina under suboptimal conditions largely reported by Animal Welfare Foundation (AWF) together with its Swiss sister organisation Tierschutzbund Zürich (TSB) both members of Eurogroup for Animals, traceability remains compromised to say the least. Our recently published White Paper: Good Welfare for Equids highlights concerns over blood collection from pregnant mares, which exceeds safe guidelines for non-pregnant horses. This practice can cause serious health issues, including hypovolemic shock, venous disease, anemia, and miscarriage. Fear, pain, and stress from these procedures prevent mares from experiencing even basic welfare standards. Besides mares used for production, eCG also entails welfare concerns for farmed animals on which it is used, such as sows, cows, goats and ewes whose safety should be taken into account (Art 5.1 a). While there are no internationally agreed guidelines on the volume of blood that can be safely extracted from pregnant horses, in Appendix 6 of the White Paper: Good welfare for equids we strongly recommend that the German guidelines for the collection of blood be used as a reference. Finally, a reminder of the European Unions core principles: Article 13 of the TFEU underscoring the need to incorporate AW standards to GMP.
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Response to Rules on good manufacturing practice for active substances used as starting materials in veterinary medicinal products

17 Feb 2025

Regulation (EU) 2019/6 of the European Parliament and of the Council of 11 December 2018 on veterinary medicinal products in its Recital (68) exposes that: The good manufacturing practice for the purpose of this Regulation should take into account the Union and international standards of animal welfare when active substances are prepared from animals. While this Commissions implementing regulation exposes on its Recital (2): The good manufacturing practices applicable in the Union should continue to be aligned with relevant international standards. The last Eurobarometer on attitudes of Europeans towards Animal Welfare shows an overwhelming majority of European citizens who demand better EU legislation that truly protects animals. This implementing regulation claims to align with Regulation (EU) 2019/6 but fails to consider EU and international animal welfare standards. It makes no reference to animal welfare and only briefly mentions the safety of treated animals (Art. 5.1a) while there is no mention of the animals from which the starting materials are sourced. One of our key concerns is Equine Chorionic Gonadotropin (eCG), also known as Pregnant Mare Serum Gonadotropin (PMSG), a hormone derived from the blood of pregnant mares, cruelly obtained and used to regulate fertility in farmed animals. The majority is imported from non-EU countries and extensively used in EU agriculture. The European Parliament in its Resolution on the Farm to Fork Strategy point 130 recalls that structural animal experiments that are not indispensable should have no place in the food chain as Directive 2010/63/EU prescribes the replacement and reduction of the use of animals in procedures; calls on the Commission and Member States to stop the import and domestic production of Pregnant Mare Serum Gonadotropin (PMSG), which is extracted from the blood of pregnant horses that are systematically impregnated and exposed to blood collections, involving health and welfare issues. The use of the Equine Chorionic Gonadotropin (eCG) is in breach of Directive 2010/63/EU since there are alternative methods available to achieve a satisfactory result: eCG produced in vitro (reCG), synthetic alternatives (36 in Germany only) and zootechnical measures among others. The 3Rs principle (replacement, reduction, and refinement) should be systematically integrated into the application of Good Manufacturing Practices. Our recently published White Paper: Good Welfare for Equids highlights concerns over blood collection from pregnant mares, which exceeds safe guidelines for non-pregnant horses. This practice can cause serious health issues, including hypovolemic shock, venous disease, anemia, and miscarriage. Fear, pain, and stress from these procedures prevent mares from experiencing even basic welfare standards. Besides mares used for production, eCG also entails welfare concerns for farmed animals on which it is used, such as sows, cows, goats and ewes whose safety should be taken into account (Art 5.1 a). While there are no internationally agreed guidelines on the volume of blood that can be safely extracted from pregnant horses, in Appendix 6 of the White Paper: Good welfare for equids we strongly recommend that the German guidelines for the collection of blood be used as a reference. These official German guidelines prohibit taking blood from pregnant or lactating mares. Furthermore, they state that a horse used for blood collection must have a body weight greater than 400 kg, be more than 3 years old and blood must not be taken at quantities greater than 1.5 litres for every 100 kg body weight every 30 days. The guidelines also set provisions for blood collection from other animal species and, if included in the GMP, would help protect animals worldwide. Finally, a reminder of the European Unions core principles: Article 13 of the TFEU underscoring the need to incorporate high international animal welfare standards into the GMP.
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Meeting with Marko Vešligaj (Member of the European Parliament)

17 Feb 2025 · Animal Welfare in trade agreements

Eurogroup for Animals Urges EU to Protect Aquatic Species

14 Feb 2025
Topic — New European policy framework aiming to coordinate all ocean-related activities and environmental goals.
Message — The organization calls for integrating aquatic animal welfare into all EU ocean policies, specifically requesting species-specific protections during farming, transport, and slaughter. They advocate for banning octopus farming and shifting aquaculture toward low-impact, plant-based or non-fed systems.123
Why — This would secure legal recognition of aquatic animal sentience and advance their animal protection agenda.45
Impact — Industrial fish producers and emerging octopus farmers face higher costs or complete bans on their operations.678
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Meeting with Kathleen Van Brempt (Member of the European Parliament) and 11.11.11, Koepel van Internationale Solidariteit

12 Feb 2025 · EU-Mercosur Agreement

Meeting with Bert-Jan Ruissen (Member of the European Parliament)

6 Feb 2025 · EU Mercosur

Meeting with Valérie Hayer (Member of the European Parliament)

5 Feb 2025 · Mercosur agreement

Meeting with Krzysztof Hetman (Member of the European Parliament)

3 Feb 2025 · Animal welfare under the Mercosur Agreement

Meeting with Dario Nardella (Member of the European Parliament, Shadow rapporteur)

3 Feb 2025 · Discussion about the report on welfare of dogs and cats and their traceability

Meeting with Anna Strolenberg (Member of the European Parliament)

31 Jan 2025 · Mercosur

Meeting with Peter Liese (Member of the European Parliament) and Fern and

29 Jan 2025 · Austausch

Meeting with Catarina Vieira (Member of the European Parliament)

29 Jan 2025 · EU-Mercosur

Meeting with Ricard Ramon I Sumoy (Acting Head of Unit Agriculture and Rural Development) and Bureau Européen des Unions de Consommateurs and

28 Jan 2025 · Exchange of views on issue considered relevant by the organisations on the Vision of agriculture and food, under preparation; in particular the food aspects.

Meeting with Maria Noichl (Member of the European Parliament, Shadow rapporteur) and Humane World for Animals Europe

28 Jan 2025 · Animal Welfare

Meeting with Cristina Modoran (Head of Unit Health and Food Safety)

23 Jan 2025 · Exchange of views on the Vision on Agriculture and Food

Meeting with Thomas Waitz (Member of the European Parliament, Shadow rapporteur) and VIER PFOTEN International and

22 Jan 2025 · Animal welfare during transport

Meeting with Peter Liese (Member of the European Parliament)

22 Jan 2025 · Austausch

Meeting with Tilly Metz (Member of the European Parliament, Rapporteur)

16 Jan 2025 · Animal Transport

Meeting with Thomas Waitz (Member of the European Parliament, Shadow rapporteur)

16 Jan 2025 · Animal welfare during transport

Meeting with Idoia Mendia (Member of the European Parliament, Shadow rapporteur for opinion)

15 Jan 2025 · Meeting with Eurogroup for animals

Meeting with Camilla Laureti (Member of the European Parliament)

15 Jan 2025 · Mercosur

Meeting with Anja Hazekamp (Member of the European Parliament)

15 Jan 2025 · Animal Welfare Intergroup bureau meeting

Meeting with Cristina De Avila (Head of Unit Environment) and Humane World for Animals Europe and

14 Jan 2025 · CITES: Transparency; the future Multi-Annual Financial Framework; EU Live Animal Transport Regulation; and Registration of Captive Breeding Facilities for Appendix-I Species

Meeting with Tilly Metz (Member of the European Parliament, Shadow rapporteur)

12 Dec 2024 · Welfare of dogs and cats

Meeting with Costas Kadis (Commissioner) and

11 Dec 2024 · Exchange of views on aquatic animal welfare

Meeting with Michal Wiezik (Member of the European Parliament, Shadow rapporteur)

11 Dec 2024 · Pet trade

Meeting with Manuela Ripa (Member of the European Parliament, Rapporteur for opinion)

10 Dec 2024 · Welfare of Cats and Dogs

Meeting with Valentina Palmisano (Member of the European Parliament) and LEGA ANTI VIVISEZIONE

5 Dec 2024 · Promuovere il benessere animale nell'UE

Meeting with Antonio Decaro (Member of the European Parliament)

5 Dec 2024 · Evento Promuovere il benessere animale nell'UE: priorità 2024-2029"

Meeting with Salvatore De Meo (Member of the European Parliament, Shadow rapporteur)

5 Dec 2024 · Welfare of dogs and cats and their traceability

Meeting with Annalisa Corrado (Member of the European Parliament)

5 Dec 2024 · Animal welfare

Meeting with David Cormand (Member of the European Parliament)

4 Dec 2024 · Food Policy

Meeting with Anja Hazekamp (Member of the European Parliament)

2 Dec 2024 · Animal Welfare Intergroup bureau meeting

Meeting with Christophe Clergeau (Member of the European Parliament, Shadow rapporteur)

28 Nov 2024 · One Substance One Assessment

Meeting with Borja Giménez Larraz (Member of the European Parliament, Shadow rapporteur)

27 Nov 2024 · Animal welfare during transport

Meeting with Tilly Metz (Member of the European Parliament)

26 Nov 2024 · Animal Welfare

Meeting with Niels Fuglsang (Member of the European Parliament)

13 Nov 2024 · Animal Welfare Intergroup

Meeting with André Rodrigues (Member of the European Parliament)

5 Nov 2024 · Introductory meeting & S&D group priorities in the PECH Committee

Meeting with Isabella Lövin (Member of the European Parliament, Rapporteur for opinion)

4 Nov 2024 · Stakeholder discussion on protection of animals during transport

Meeting with Céline Imart (Member of the European Parliament)

24 Oct 2024 · Agriculture

Response to Evaluation of the EU-Japan Economic Partnership Agreement

23 Oct 2024

Eurogroup for Animals notes the evaluation assessing the impact of the Economic Partnership Agreement (JEEPA) with Japan after five years of implementation. We hope the findings of this evaluation will help the EU and Japan fully activate the cooperation mechanism on animal welfare, which has yet to be utilised. JEEPA only started to be implemented in 2019, but some effects can already be witnessed. Japan, though not a significant source of animal products for the EU, has become the EUs third-largest source of butter and dairy spread. Between 2018 and 2019, imports of Japanese fresh and chilled beef increased by 31%, while imports of pig meat more than doubled. Japan also became the EUs fifth-largest source for egg products, even if the amounts remain low (63 tonnes). These trends underline why it is crucial to link trade preferences in trade agreements, like JEEPA, to the respect of animal welfare standards applied within the EU. Eurogroup for Animals welcomes the creation of an Animal Welfare Technical Working Group, as outlined in the agreement, and calls on the parties to strengthen their sustainability commitments by bringing it into operation. A key implementation priority could be cooperation on improving welfare standards in Japan's chicken sector as well as the welfare of wild animals under the Trade and Sustainable Development chapter. JEEPA represents a unique opportunity to advance cooperation on animal welfare. As global leaders in sustainability and like-minded partners, the parties must recognise that poor animal welfare standards compromise the environment, climate, and biodiversity. Please see the file attached for more details.
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Meeting with Maria Noichl (Member of the European Parliament, Shadow rapporteur)

23 Oct 2024 · Animal transport

Meeting with Stéphanie Yon-Courtin (Member of the European Parliament)

22 Oct 2024 · Bien être animal

Response to Professional qualifications recognition of veterinary surgeons - training requirements update

21 Oct 2024

The veterinary profession is at the forefront of protecting animal welfare standards in all the fields in which animals are used for human benefit, including but not limited to, animals in agriculture, research, zoos, and companion animals. Veterinarians are also called upon to advise on the humane management of wild species. Over the years, the Federation of Veterinarians of Europe published many position papers on issues related to animal welfare, clearly highlighting the role that the veterinary profession must playa role in guaranteeing the best possible animal welfare standards for the species under their care. Eurogroup for Animals fully supports the view that veterinarians should receive compulsory and comprehensive training in animal welfare and wishes to emphasise the importance of treating animal welfare as an essential and stand-alone area of study in any veterinary curriculum. Consequently, animal welfare training should be explicitly included in the proposed Directive. As mentioned in the Strategic Dialogue on the Future of EU Agriculture, veterinarians are important actors when it comes to ensuring that full regard is paid to animals welfare requirements when formulating and implementing the EUs agriculture, trade, and internal market policy. Therefore, this area of veterinary education should have a more prominent role in the proposed syllabus than it has now. Currently, animal welfare is only referenced as a secondary subject within the "animal production" category (Annex, section B, point c). However, this approach is too limited. Animal welfare must be a core subject within veterinary practice and studies that encompasses companion animals, laboratory animals, wild animals, and other areas, in addition to farm animals production. To ensure veterinarians have comprehensive training, we propose the following amendments to the Annex of the proposal: Inclusion of animal welfare in Section B - Specific Subjects, point a) Basic Sciences or Section B- Specific Subjects, point b) Clinical Sciences. By integrating animal welfare more robustly in the curriculum, we can ensure that future veterinarians are not only experts in animal health but also leaders in promoting animal welfare across all areas of their work. Thank you for considering these suggestions. Kind regards, Eurogroup for Animals
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Meeting with Tilly Metz (Member of the European Parliament, Rapporteur)

15 Oct 2024 · Animal transport

Meeting with Bernd Lange (Member of the European Parliament, Committee chair) and Greenpeace European Unit and Friends of the Earth Europe

14 Oct 2024 · General exchange of views

Meeting with Niels Fuglsang (Member of the European Parliament)

3 Oct 2024 · Animal Welfare Intergroup

Meeting with Anja Hazekamp (Member of the European Parliament)

2 Oct 2024 · Eurogroup Annual conference (roundtable on political priorities for this new term)

Eurogroup for Animals urges welfare conditions for Ukraine trade

1 Oct 2024
Topic — The consultation concerns accelerating the mutual removal of customs duties with Ukraine.
Message — The group argues that further trade liberalization for animal products must depend on Ukraine implementing EU welfare standards. They also call for financial support to help Ukrainian farmers adapt.12
Why — This ensures that high-volume imports do not undermine animal welfare and policy objectives.34
Impact — Ukrainian poultry producers face high costs to replace widely used battery cages.56
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Meeting with Sebastian Everding (Member of the European Parliament) and VIER PFOTEN International

1 Oct 2024 · Networking Event: Exhibition Silent Suffering

Meeting with Stefan Köhler (Member of the European Parliament, Shadow rapporteur for opinion) and VIER PFOTEN International and

1 Oct 2024 · Politischer Austausch

Meeting with Christine Schneider (Member of the European Parliament)

1 Oct 2024 · Animal welfare

Meeting with Martin Schirdewan (Member of the European Parliament) and Climate Action Network Europe and

26 Sept 2024 · Fairer Handel

Meeting with Anja Hazekamp (Member of the European Parliament)

25 Sept 2024 · Europees dierenrecht event

Meeting with Valérie Hayer (Member of the European Parliament)

24 Sept 2024 · Animal welfare ongoing and pending issues

Meeting with Valérie Deloge (Member of the European Parliament) and La Fondation Droit Animal, Ethique et Sciences (LFDA)

24 Sept 2024 · Bien-être animal

Meeting with Benoit Cassart (Member of the European Parliament)

24 Sept 2024 · Prise de contact

Meeting with Janusz Wojciechowski (Commissioner) and

19 Sept 2024 · The revision of the poultry marketing regulation and the future of the CAP.

Meeting with Veronika Vrecionová (Member of the European Parliament, Committee chair)

18 Sept 2024 · Priorities of AGRI committee in the new mandate

Meeting with Sebastian Everding (Member of the European Parliament) and Animal Society e.V. and Albert Schweitzer Stiftung für unsere Mitwelt

17 Sept 2024 · Online Introductory meeting

Meeting with Niels Fuglsang (Member of the European Parliament)

16 Sept 2024 · Meeting on Animal Welfare Intergroup

Meeting with Tilly Metz (Member of the European Parliament, Rapporteur)

15 Sept 2024 · Animal Welfare

Response to Ex-post evaluation of European Maritime and Fisheries Fund (EMFF) 2014-2020

6 Sept 2024

Please find enclosed Eurogroup for Animals' feedback.
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Response to Evaluation of the Common Fisheries Policy

6 Sept 2024

Please find Eurogroup for Animals' feedback in the attached document.
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Meeting with Ruth Reichstein (Cabinet of President Ursula von der Leyen) and Global Action in the Interest of Animals

5 Sept 2024 · Animal welfare next mandate

Meeting with Anja Hazekamp (Member of the European Parliament)

4 Sept 2024 · Roundtable #EUforAnimals and the Brussels Times

Meeting with Tilly Metz (Member of the European Parliament)

3 Sept 2024 · Animal testing

Response to Integrated Farm Statistics - list of variables and their description for reference year 2026

14 Aug 2024

We at Eurogroup for Animals appreciate the opportunity to contribute to this public consultation, allowing stakeholders like us to assist in the refinement of the EU farm statistics for the year 2026. Below, we present our list of proposed variables: Usable area in all types of animal farming Number of breeding sows, sows in confinement during gestation and farrowing (any cases above 24 hours) Duration of confinement of sows in crates Number of pigs with docked tails, pigs kept on fully slatted floors, entire male pigs, tooth clipped pigs, immunocastrated pigs, pigs kept permanently indoors (no access to outdoor area), pigs with permanent access to an outdoor run, pigs with partial access to outdoor run (in days per year) Number of doses of PMSG (Pregnant Mare Serum Gonadotropin) fertility hormones administered to sows per breeding cycle, doses of fertility hormones other than PMSG administered to sows per breeding cycle Number of breeding cycles per sow per year, liveborn piglets per litter, weaned piglets per litter Number of calves and types of systems used (individual and group) - individual confinement for longer than one week should be reported, calves separated from cow within 8 hours after calving, calves separated from cows within 48 hours after calving, calves separated from cow within 7 days after calving, calves separated from their mother within 5 weeks after calving, calves separated from their mother within 3 months after calving, calves separated from their mother within 6 months after calving Duration of confinement of calves in single crates in weeks Number of cattle tethered/kept in tie-stalls (also if seasonal tethering during autumn/winter months is practised), cattle kept on fully slatted floors, cattle kept permanently indoors (no access to the outdoor area), cattle with permanent access to an outdoor run, cattle with partial access to outdoor run (in days per year) Percentage of seasonal tethering and full-year tethering of cattle Number of goats kept permanently indoors (no access to the outdoor area), goats with permanent access to an outdoor run, goats with partial access to an outdoor run (in days per year) Number of kids in a herd, kids leaving the herd within 6 weeks after kidding Number of lambs in a herd, lambs leaving the herd within 6 weeks after kidding Number of laying hens, broiler chickens, turkeys, ducks, quail, and geese kept permanently indoors (no outdoor access, no wintergarden) Number of laying hens, broiler chickens, turkeys, ducks, quail, and geese with permanent access to an outdoor run, with partial access to an outdoor run (in days per year) Number of laying hens, broiler chickens, turkeys, ducks, quail, and geese with permanent access to a veranda/wintergarden, with partial access to a veranda/wintergarden (in days per year) Number of beak trimmed turkeys, laying hens, ducks Number of comp dubbed broiler and laying hen breeders Number of toe clipped male broiler breeders Number of de-spurred male broiler breeders Number of raised brother roosters Expansion of the survey to include the type of production system for other surveyed species: Caged rabbits and free-range rabbits (breeding does, breeding bucks, and fattening rabbits) Presence of cages for ducks, geese, and quail Parental stock of broiler chicken and laying hens Inclusion of insects: Number of insect farms and number of insects farmed in the EU for food and feed per species Number of honey bee farms and number of farms transporting beehives for pollination purposes Substrate used for insect rearing: former foodstuff, vegetables, grains, etc. 4. Tons of insect products produced per market destination (human food, animal feed, pet food). Differentiation between plants grown for food vs. for feed: The EU farm statistics regulation for the reference year 2026 should expand the data collected to differentiate between crops and legumes grown for human consumption versus for animal feed
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Meeting with Eric Sargiacomo (Member of the European Parliament)

22 Jul 2024 · Bien être animal

Response to Update of State aid procedural rules, considering the EU’s international commitments, recent practice and case law

27 Jun 2024

For more than four decades, Eurogroup for Animals (EfA) has brought together animal advocates throughout Europe to significantly enhance the welfare and protection of animals. EfA welcomes the opportunity to contribute to the evaluation and supports the Commission's commitment to the full implementation of the Aarhus Convention in view of the beneficial impact it could have on animal welfare. EfA recommends that this initiative: Introduces transparent rules and more effective monitoring of state aid, in order for infringements of European environmental law to be detected at an early stage and remedied efficiently; Provides the opportunity to non-governmental organisations which have an interest in environmental justice, including animal welfare organisations, to submit requests for internal review comparable to the procedure already established in Article 10 of the current Aarhus Regulation (Regulation 1367/2006); Empowers stakeholders to challenge state aid decisions that go against EU climate, environment and animal welfare objectives.This includes funding, grants or subsidies being put towards methods of capture and farming of animals which breach environmental law or are against these objectives. Finally, EfA hopes that this initiative will lay the ground for access to justice in animal health and welfare law linked to EU state aid decisions.
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Meeting with Anja Hazekamp (Member of the European Parliament)

25 Jun 2024 · Animal Welfare Intergroup bureau meeting

Meeting with Janusz Wojciechowski (Commissioner) and

23 May 2024 · The review of the marketing standards for poultry meat and in particular the arbitrary requirement of minimum liver weights for foie gras production, contained in Article 1, point 3 of Commission Regulation (EC) No 543/2008.

Eurogroup for Animals opposes relaxing EU manure nitrate rules

17 May 2024
Topic — The consultation concerns updating rules on using processed livestock manure as fertiliser.
Message — The group opposes easing rules on manure-based fertilisers. They urge prioritizing animal number reductions and request an impact assessment. They also advocate for shifts toward plant-based diets.12
Why — Restricting manure use helps their mission to end intensive animal farming.3
Impact — Intensive farmers would face herd reductions and restricted waste management options.4
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Response to Better protecting sharks through sustainable fishing and trade

8 May 2024

Shark finning is cruel and unjustifiable Shark finning is a cruel practice that harms, mutilates and causes distress to sharks. The practice is, rightly, banned in the EU that applies a fins-naturally-attached policy for its fishing fleet. While EU member states are not the main consumers of fins, and finning is not authorised for EU fishers, the EU participates in creating and maintaining the global market for loose fins and, therefore, the unjustifiably cruel and wasteful practice of finning then discarding in third countries. Finning contributes to decreasing shark populations, most of which are now threatened The demand for shark fins drives fishing pressure on shark populations globally going against any conservation efforts. Whereas the Commission re-stated in the European Parliament on 11 May 2023 that it is committed to protect and sustainability fish sharks, by authorising or otherwise supporting the trade of loose fins, the European Union contributes to the overexploitation of sharks and undermines efforts to develop sustainable shark fishing. As the Commission itself highlights in its Communication C(2023)448 final, according to the IUCN, more than one third of all sharks are threatened with extinction and the proportion is higher - 75% - for oceanic sharks. In fact, the overall abundance of sharks is only 6% of the numbers which existed 70 years ago. For tropical sharks, the number is just 3%. Maintaining and promoting a legal market for loose fins creates incentives and loopholes for illegal fins. Monitoring, tracking and tracing in the fins market is complicated as it is difficult to determine the geographic origin, the species or sexual maturity of a shark just by looking at a loose fin. As shark population numbers continue to decline, sharks and rays must be managed as highly endangered wildlife. Requiring vessels to land sharks whole is not a perfect solution but remains a good policy. However, as fins drive the global market in sharks, this principle should be strengthened by a fin trade ban to take away the incentive to catch sharks for their fins. Such a ban is justifiable at WTO level and compatible with Article XX of the GATT 1994. Shark finning stifles economic growth and wellbeing in fishing communities In fishing communities, the beneficiaries of shark exploitation are limited to a wealthy few. Shark conservation, on the other hand, stimulates sustainable livelihoods in the tourism sector, improves food security and mitigates the impacts of climate change and biodiversity loss. For instance, research determined that the global shark diving industry generates $314 million/year, directly supporting 10,000 jobs. This is expected to double within the next 20 yrs, generating more than $780 million/year. By comparison, the landed value of global shark fisheries is $630 million and has been in decline for the past decade as a consequence of overfishing. In Europe, shark tourism has significant growth potential. Its value is difficult to assess as it is not considerably studied. However, shark diving tourism has been responsible for a shift in the socio-economic importance of sharks from a fishery product to a more valuable reusable resource. Not only for direct revenues for local operators, but also through the stimulation of other economic development of local businesses like hotels and restaurants. Whereas shark tourism is still developing in the EU, operators already exist in Portugal, Spain, Ireland, Italy and Croatia, in the wider Mediterranean as well as in the UK or Norway. The economic impact of shark tourism was assessed in the Azores concluded that this nascent industry already yields around 1m. The economic value of sharks must not only be seen from a fishing perspective. It needs to be balanced with other, more sustainable activities, whose economic returns are both greater than those of fishing, but also threatened by the development of shark fishing for their fins.
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Eurogroup for Animals demands CETA review to protect welfare

12 Apr 2024
Topic — The Commission is evaluating the economic and environmental impacts of the EU-Canada trade agreement.
Message — The organization calls for an early review of CETA to address animal welfare. They argue current voluntary cooperation fails to mitigate the negative environmental impacts of industrial farming.12
Why — The organization would see trade policies shift away from supporting industrial livestock production.345
Impact — Intensive livestock producers lose market advantages as trade shifts toward sustainable models.67
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Eurogroup for Animals Demands Shorter Journeys and Export Ban

12 Apr 2024
Topic — A revision of European rules governing animal welfare during transport.
Message — The group requests a maximum eight-hour journey for free-moving animals and four hours for those in containers. They also call for a total ban on live exports to non-EU countries.12
Why — This would shift the market toward the group's preferred, more cost-effective carcass trade model.3
Impact — Agricultural exporters would lose their business routes if live exports to third countries are banned.4
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Eurogroup for Animals urges data sharing to end animal testing

4 Apr 2024
Topic — The consultation addresses a proposal for a common chemical data platform.
Message — They want mandatory data sharing to prevent redundant animal experiments. They also propose notifying authorities about planned studies before they begin. Finally, they suggest prohibiting results from studies not previously notified to regulators.123
Why — These measures would reduce the total number of animals used in safety assessments.4
Impact — Chemical companies would face stricter rules and mandatory sharing of proprietary data.5
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Response to Evaluation of the European Food Safety Authority (EFSA) 2017-2024

4 Apr 2024

We at Eurogroup for Animals appreciate the opportunity to contribute to the discussion and evaluation of the EFSA functioning. Please see our feedback below. Enhancing NGO engagement and dialogue within EFSA One of the challenges in our engagement with EFSA has been participating in stakeholder forums that often prioritise information dissemination over actual dialogue. This dynamic limits the potential for NGOs to substantially contribute to discussions, reducing our role to passive recipients of information rather than active contributors. This imbalance can relegate NGOs to the periphery, treating us more as clients than as partners. What is more, our ability to interact directly with relevant experts is further limited, as we often need to communicate through mediators, which can diminish the effectiveness of our contributions. To address these challenges, we propose a series of improvements to EFSA's engagement with NGOs. Drawing on best practices from within EFSA's own procedures and those of other agencies, such as the European Chemicals Agency, we believe a new process for NGO engagement should be created. This process would give NGOs and other stakeholders the opportunity to engage in dialogue, give presentations, and discuss specific issues with EFSA two to three times a year. Furthermore, the reinstatement of the NGO Roundtable would serve as a pivotal forum for direct dialogue, facilitating a richer exchange of perspectives and expertise. Additionally, more effort should be dedicated to obtaining participation from all relevant NGOs whenever a stakeholder forum or consultation group is set up. This is essential to ensure a balanced representation of economic interests versus civil society in such fora. It is crucial that EFSA's internal processes evolve to recognise NGOs not merely as output receivers but as expert contributors whose insights are invaluable to the authority's mission. Allocation of budget for NGOs and smaller stakeholders- The lack of budget availability for non-profits is a barrier to engagement Another challenge is the financial barrier faced by NGOs, for whom the lack of a daily allowance policy poses a significant obstacle to participation, which is particularly harmful for smaller organisations. While EFSA offers reimbursements for travel and accommodation for specific meetings, the absence of a daily rate restricts the ability of financially constrained NGOs to engage fully in the authority's activities. Moreover, the representation of NGOs within EFSA's consultations often does not reflect a balanced spectrum of economic and non-economic interests. It is essential to recognise that NGOs, which do not have specific economic interests, are not like other stakeholders because they represent the voice of civil society, which should significantly impact EFSA's direction. By allocating a budget for NGO involvement, including provisions of a daily allowance, EFSA can support the active contribution of NGOs. Treating NGOs as experts and compensating them for their expertise, on top of the travel and accommodation reimbursements, would support NGOs participation. By implementing these recommendations, EFSA can enhance its engagement with NGOs, leading to more robust decision-making processes, improved transparency, and strengthened trust among stakeholders.
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Animal advocates urge EU to prioritize non-animal chemical testing

3 Apr 2024
Topic — This consultation aims to streamline chemical safety assessments by re-attributing tasks among agencies.
Message — They request that the development of non-animal methods be prioritized for chemical assessments. The proposal should be amended to require methodologies not entailing live animal use. ECHA must preserve expertise in conducting risk assessments without the use of animals.123
Why — Prioritizing non-animal methods would accelerate the transition towards an animal-free testing framework.4
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Eurogroup for Animals urges welfare-focused Animal Health Law updates

3 Apr 2024
Topic — Evaluation of EU animal health rules and their continued fitness for purpose.
Message — They want transport certificates to include fattening animals and health laws to incorporate welfare standards. The group also urges mandatory vet visits and inclusion of farmed insects in definitions.123
Why — Harmonisation would simplify compliance for stakeholders while advancing their animal protection goals.45
Impact — Operators mislabeling animals to bypass transport time limits would lose their regulatory loophole.6
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Meeting with Grace O'Sullivan (Member of the European Parliament)

5 Mar 2024 · Animal Welfare legislation

Meeting with Marlene Mortler (Member of the European Parliament, Shadow rapporteur)

29 Feb 2024 · Welfare of dogs and cats and their traceability

Meeting with Caroline Roose (Member of the European Parliament)

27 Feb 2024 · Transport des animaux aquatiques - 2023/0448(COD) Protection of animals during transport and related operations

Response to Welfare of dogs and cats and their traceability

22 Feb 2024

For more than four decades, Eurogroup for Animals has brought together animal advocates throughout Europe to significantly enhance the welfare and protection of animals. This proposal for a Regulation on the welfare of dogs and cats and their traceability has been extremely well-received, introducing much-needed measures regarding the traceability of cats and dogs, breeding practices, and imported animals. Likewise, we are pleased to note that the recommendations put forth by both the Voluntary Initiative on the health and welfare of pets (specifically dogs and cats) and EFSA's opinion on housing and health of cats and dogs in commercial breeding establishments have been substantially recognized. Nevertheless, we feel that additional efforts are necessary to address issues such as extreme breeding and online sales, among others. To guide the European Commission through our suggested amendments and their underlying reasoning, we will adhere primarily to the structure of the Chapters and, to a lesser extent, the Articles. It is not our aim for this document to be exhaustive in nature. (Please find attached our detailed feedback). As the preeminent pan-European organisation dedicated to animal protection, Eurogroup for Animals directs its primary focus towards advancing the interests of animals. We sincerely anticipate that our approach will prove instrumental in refining the proposal and contributing to the establishment of a societal framework wherein animals are esteemed and acknowledged as sentient beings.
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Meeting with Olivia Gippner (Cabinet of Commissioner Wopke Hoekstra)

14 Feb 2024 · 2040 target plan and animal welfare

Response to 8th Environment Action Programme – Mid-term Review

26 Jan 2024

Eurogroup for Animals welcomes the 8th environmental action programme (EAP) to 2030 and its role in achieving the EUs vision to 2050 of living within planetary boundaries. We particularly welcome the inclusion of protecting the health and well-being of animals and ecosystems from environment-related risks; protecting, preserving and restoring biodiversity; promoting environmental aspects of sustainability in food systems; prioritising efforts towards achieving a toxic free environment; and supporting the transition to non-animal testing under the Chemicals Strategy for Sustainability. Additionally, we applaud the identification of enabling conditions in the programme, namely the need to step up and coordinate efforts to promote the development and validation of alternatives to animal testing; transforming the Unions food system to ensure a high level of animal welfare; as well as the recognition of the interconnection between the environment and human and animal health. A core objective of the 8th EAP was to support the objectives of the European Green Deal and to build on the commitments of the strategies and initiatives falling under it. Additionally, when establishing the role of the Commission in facilitating the attainment of the priority objectives of the 8th EAP, the programme included ensuring effective, swift and full implementation of the EU legislation on the environment and climate. In 2020, the Commission highlighted the Farm to Fork Strategy as being at the heart of the European Green Deal and announced the adoption of key files, namely the revision of the animal welfare acquis and the sustainable food systems framework law (SFS), to take place at the end of 2023. Regrettably, the Commission only partially delivered one of the four promised animal welfare proposals, and delayed the presentation of the SFS Framework law. With regard to the Chemicals Strategy for Sustainability (CSS), 85 specific actions were initially addressed. While all these actions are still ongoing, many relevant pieces have not been delivered as intended, REACH (Registration, Evaluation, Authorisation and Restriction of Chemicals) being the most prominent example. There is a substantial amount of work still ahead, including ongoing efforts to accelerate the transition to non-animal testing for safety assessments. The objectives of the 8th EAP will not be achieved without solid, sound and comprehensive legislation on animal welfare, sustainable food systems and chemicals management. We urge you to take this into account in your mid-term review report, and to put forward a holistic approach that takes includes all dimensions of sustainability, starting with: (1) the swift adoption of the pending proposals on the welfare of kept animals; on slaughter; on labelling; and on the framework for sustainable food systems; (2) upholding the objectives of the Chemicals Strategy for Sustainability and a clear commitment to prioritise the roadmap towards phasing out the use of animals for chemical safety assessments; (3) maintaining the protective status of wolves and large carnivores in the EU; (4) conducting research on non-lethal and humane methods demonstrating high efficiency; (5) adopting an EU wide positive list of animal species which can be traded to be kept in a household.
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Response to Postponement of deadlines within the Accounting Directive for the adoption of certain ESRS

11 Dec 2023

Eurogroup for Animals notes the Commissions proposal on the postponement of deadlines under the Accounting Directive for the adoption of European Sustainability Reporting Standards (ESRS). We hope the postponement provides sufficient time to develop high-quality ESRS, including on animal welfare. The legislation on Corporate Sustainability Reporting represents a milestone for animal welfare in the context of corporate sustainability governance. Eurogroup for Animals welcomes that businesses would need to report on how their activities impact the welfare of animals given the inherent links between animal welfare and sustainability. It is important that future ESRS delegated acts on animal welfare take into account the general policies of businesses regarding the respect for animal welfare; measures of businesses to prevent and reduce harm to animal welfare caused directly or indirectly (through suppliers) by their activities; budgetary measures provided for research and development to find alternatives to the use of animals in business activities; measures taken in favour of animal welfare within the supply and purchasing policies of businesses; quantitative objectives from businesses to reduce impacts on animal welfare in the medium and long term, and means to implement those objectives; and relations maintained with animal welfare organisations. Please see the file attached for more details.
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Meeting with Ruth Reichstein (Cabinet of President Ursula von der Leyen)

28 Nov 2023 · Animal welfare

Meeting with Maroš Šefčovič (Executive Vice-President)

24 Nov 2023 · Animal welfare

Meeting with Zuzana Dorazilova (Cabinet of Vice-President Věra Jourová)

23 Nov 2023 · End of Cage Age European Citizen Initiative

Meeting with Anja Hazekamp (Member of the European Parliament)

15 Nov 2023 · reshaping EP committees

Eurogroup for Animals Urges Shift Toward Animal-Free Drug Innovation

8 Nov 2023
Topic — The EU is revising its pharmaceutical legislation to ensure affordable medicines and innovation.
Message — The organization calls for a transition away from animal testing toward human-relevant approaches. They recommend including language that accommodates innovative technologies like AI and organoids.12
Why — This approach would reduce research costs and improve the success rate of drug development.34
Impact — Patients currently suffer when effective treatments are discarded because of misleading animal test results.5
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Meeting with Anja Hazekamp (Member of the European Parliament)

24 Oct 2023 · Petition Commissioner for Animal Welfare

Meeting with Anja Hazekamp (Member of the European Parliament)

11 Oct 2023 · Demonstration No Animal Left Behind

Meeting with Caroline Roose (Member of the European Parliament)

11 Oct 2023 · Réforme législation UE bien-être animal

Meeting with Anja Hazekamp (Member of the European Parliament)

6 Oct 2023 · Demonstration Octopus Farming

Response to Revision of EU rules on textile labelling

21 Sept 2023

Please find attached.
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Meeting with David Cormand (Member of the European Parliament)

20 Sept 2023 · Animal welfare

Meeting with Stéphane Séjourné (Member of the European Parliament)

19 Sept 2023 · Bien-être animal (équipe)

Meeting with Jérémy Decerle (Member of the European Parliament)

19 Sept 2023 · Bien-être animal

Meeting with Lukas Visek (Cabinet of Vice-President Maroš Šefčovič)

12 Sept 2023 · animal welfare

Response to EU financing instrument to support Ukraine

5 Sept 2023

Eurogroup for Animals welcomes EUs support to Ukraine through the Ukraine Facility mechanism. Despite the protracted war, we believe that Ukrainian people need their lives to be rebuilt today. We also support your idea that recovery and reconstruction is not only about rebuilding what was destroyed in the country, but it is about investing in the transition of Ukraine towards a green and sustainable economy. Along with Ukraines candidate status to the EU and their expressed will to link reconstruction to the reforms on the European integration path, the post-war reconstruction provides opportunities for Ukraine to rebuild a green and sustainable economy, even under such unfortunate circumstances. We are pleased to see several mentions of the green reconstruction of the country in terms of environment and climate, although we would like to highlight that a green economy also implies sustainable agriculture and food systems with animal welfare at their core. Only by conditioning investments into the agricultural sector to sustainability and animal welfare requirements, we can ensure that such investments will not be wasted. Therefore, Eurogroup for Animals calls for the introduction of explicit conditions related to animal welfare in the Ukraine Facility Regulation. Please see the file attached for more details.
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Response to Evaluation of the Consumer Programme

1 Sept 2023

As per the document attached: Recommendation Citizens have been empowered to play an important role in the internal market and a higher level of consumer protection has been achieved. However, at Eurogroup for Animals, we believe that since consumer protection is inextricably linked to both human and animal health and welfare, a stronger focus on the online pet trade and horse meat labelling is needed in current and future Consumer Protection Programmes. Regarding the online pet trade and as recommended by the EU PAW Platform, the only animals that a consumer should be able to buy should be animals that are fully identified and registered with their breeder, and if necessary with any other person that is owning the animal at time of advertising. When identified and registered in national databases that are linked to an EU database, both animals and subsequent owners are fully traceable, being the latter fully accountable thus providing essential information and protection to consumers. Unidentified and unregistered domestic equines are extensively traded on line with no traceability back to subsequent owners. Dubious medical information (e.g. updated vaccinations and/or blood tests confirming lack of infectious diseases), is putting at risk human health and disregarding consumers' information and protection rights. In respect of horse meat, a label where not only the geographical origin and slaughtering conditions but also the level of animal welfare under which the animal has been kept throughout their lifetime is awaited by citizens/consumers. Only then, informed purchasing decisions by EU consumers on issues of their particular concern: sustainability and animal welfare can accurately be made.
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Meeting with Suvi Leinonen (Cabinet of Commissioner Jutta Urpilainen)

29 Aug 2023 · Trade, animal welfare

Response to Suspensions of import into the EU of certain endangered animal and plant species from specific source countries

24 Aug 2023

Eurogroup for Animals welcomes the trade prohibition of Piliocobulus temminckii from Guinea. However, we note with concern that the trade restrictions are lifted for 15 animal species populations. This decision is inconceivable in the current biodiversity crisis and in the context of the European Green Deal. We highlight that the import of these species will have detrimental effects on conservation, public health, and animal welfare. This decision was taken following the recommendations from the Scientific Review Group on Trade in Wild Fauna And Flora. The discussions of this group and the scientific evidence considered for each of the species assessed are not publicly available, revealing a clear lack of transparency in breach of Article 15 of the Treaty on the Functioning of the European Union. No justification and motivations for these decisions are provided. In addition, interested parties such as the civil society have not been consulted in this process. It is important to note that the majority of these species populations remain threatened. For instance, Brookesia decaryi is an endemic species of Madagascar, meaning that the whole species population would be authorised to trade. However, it is classified as endangered on the IUCN Red List of Threatened Species and the population trend is decreasing. Other endemic species like Kinyongia fischeri and Kinyongia tavetana, which according to the IUCN Red List of Threatened Species are Near Threatened, appear to be vulnerable to the international pet trade due to the small number of individuals in the wild, as already stated Tolley & Menegon, 2014; K. fischeri: "Because this species is attractive, it is a potential target for the pet trade, but removals from the wild could prove detrimental to populations."; K.tavetana: "The extent of harvesting for the pet trade is unknown, but if there are only a few collection localities supplying the captive market, the species may be undergoing local declines as a result of unsustainable harvest levels." Until today there has been no further assessment for those two species telling otherwise. In addition, Macaca fascicularis is classified as Endangered on the IUCN Red List since 2022, with a significant population decline in recent decades. Long tailed-macaques are increasingly being traded, either legally or illegally, to meet the global demand for biomedical and toxicological research with significant consequences for local populations. The population in Lao PDR whose trade prohibition would be lifted is not exempt from this situation and the CITES compliance process is still on-going to determine the legal acquisition of founder stock for captive breeding facilities in the country. Indeed, several investigations show that a significant number of long-tailed macaques are caught in the wild, kept in breeding facilities and further traded as captive born and bred. Failure to address the trade in the species will undoubtedly jeopardise its survival. Finally, we call for the prohibition of the introduction into the Union for all specimens of species whose protection has been upgraded at the latest Conference of the Parties to the Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES), mentioned in paragraph 3, under Commission Implementing Regulation (EU) 2019/1587. In the absence of scientific rationale supporting the lifting of the trade restrictions, and taking into consideration the increasing pressure from global trade on species populations, we call for the keeping of these restrictions. We also call for the Scientific Review Group to provide specific rationale for the decisions and changes suggested.
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Meeting with Camilla Laureti (Member of the European Parliament)

19 Jul 2023 · Dossier 2023

Meeting with Caroline Roose (Member of the European Parliament)

13 Jul 2023 · Intergroup bien-être animal : les élections européennes 2024

Meeting with Maria Angela Danzì (Member of the European Parliament)

5 Jul 2023 · Animal welfare

Eurogroup for Animals urges EU to target animal farming emissions

20 Jun 2023
Topic — The Commission is establishing a 2040 climate target to reach climate neutrality by 2050.
Message — The group advocates for including food system transformation in climate targets. They propose shifting toward plant-based diets and prioritizing food for humans.12
Why — This would promote their core mission of reducing animal farming and consumption.3
Impact — The livestock industry would face decline from lower demand and restricted feed imports.4
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Meeting with Lukas Visek (Cabinet of Executive Vice-President Frans Timmermans)

15 Jun 2023 · Animal welfare

Meeting with Annukka Ojala (Cabinet of Commissioner Stella Kyriakides), Panayiotis Pourgourides (Cabinet of Commissioner Stella Kyriakides)

15 Jun 2023 · Revision of Animal Welfare Legislation and Legislative framework for sustainable food systems

Meeting with Niels Fuglsang (Member of the European Parliament)

7 Jun 2023 · Eurogroup for Animals’ annual conference

Meeting with Janusz Wojciechowski (Commissioner) and

24 May 2023 · Proposal on the marketing standards of foie gras; potential ban on fur farming following the successful ECI Fur Free Europe; updates on Eurogroup for Animals' work for the new EU animal welfare legislation in Poland.

Response to Review of egg marketing standards

19 May 2023

Eurogroup for Animals believe that removing the 16-week period from the poultrymeat marketing standards poses a risk not only to the welfare of the birds, as they will not be able to use the space they would be otherwise provided, but also to the farmers who will be unfairly impacted by such a restriction. Those who will continue to provide the animals with access to the open-air range will have higher costs than those who will keep them inside, yet both products will be marketed as free-range, creating unfair competition. Furthermore, keeping animals indoors cannot be a long-term solution to the problem that AI poses to the poultry industry, as it does not address the root problem, and only worsens animal welfare, undermining the Commissions goals to improve farm animal welfare standards and going against the EU citizens will to improve farm animal protection. We strongly believe that forward-thinking solutions, such as vaccination and lowering stocking densities, are the answer to this issue, and these will only develop if there is incentive to do so - if farmers can simply keep the hens indoors and still label the eggs as free-range, there will be no reason to develop long-term solutions to the problem, which will impact animal welfare profoundly. We believe the 16-week period should not be removed, however, in specific cases, Member States should be allowed to access a derogation from this rule. It is important to ensure that Member States use this possibility only when absolutely necessary and that at the same time, they are developing long-term strategies to mitigate the risks of AI. We would also wish to highlight the importance of ensuring the highest possible welfare standards when housing orders apply - covered verandas and daylight must be obligatory for all farms. Should the housing orders persist in the next production cycle, the stocking density should not be higher than 4 birds/m2.
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Response to Marking of eggs on farm as general rule

19 May 2023

Eurogroup for Animals strongly believe that on-farm marking is necessary to ensure traceability and clear, correct information for consumers on the provenance of the product they are choosing. All of the eggs produced must be marked on the farm where they are produced to decrease the risk of fraud, as such cases greatly undermine the trust consumers have in EU producers and in the EU itself.
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Response to Review of poultry marketing standards

19 May 2023

Eurogroup for Animals calls for the removal of the requirements for minimum liver weights from the EU Regulation on marketing standards for poultrymeat as they are arbitrary and are the reason for the continuation of the inhumane, cruel practice of force-feeding. A vast body of scientific evidence points to the immense negative welfare effects of force-feeding, among which a prominent example is the SCAHAW report published already in 1998 (25 years ago!). 25 years and countless scientific studies later, EFSA announced in their scientific opinion on duck, geese and quail welfare that all husbandry systems used in foie gras production systems should be avoided. It is imperative for the credibility of EU institutions to consider the input of EU scientific bodies when revising legislative acts. Furthermore, the current requirements for minimum liver weights discriminate against small farmers, who are extremely important to ensure a sustainable agricultural system. 22 EU Member States have outlawed the practice of force-feeding. The European Commission has the opportunity to improve the lives of great numbers of ducks and geese farmed for foie gras with a simple deletion of these arbitrary and cruel requirements, simultaneously ensuring a better market for farmers and acting in accordance with the wishes of EU citizens. EU citizens prove time and time again that animal welfare is an important value for them and that they believe animal welfare should be improved in the EU. We strongly believe that the Commission will follow the will of the citizens and prove that it is a leader in animal welfare standards.
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Meeting with Caroline Roose (Member of the European Parliament) and Humane World for Animals Europe and PETA Science Consortium International e.V.

20 Apr 2023 · Animal Welfare Intergroup - Tests sur les animaux

Eurogroup for Animals urges non-animal methods in chemical regulations

30 Mar 2023
Topic — This consultation concerns the revision of EU rules for classifying and labelling hazardous chemicals.
Message — The group wants the revision to include concrete steps for adopting non-animal testing methods. They request that the regulation prevents any new or increased animal testing for hazard identification.12
Why — This shift would help the organization achieve its primary goal of ending animal use in science.34
Impact — Testing laboratories would lose revenue as the EU transitions away from traditional animal-based safety trials.5
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Meeting with Stella Kyriakides (Commissioner) and

23 Mar 2023 · Animal welfare file

Meeting with Lukas Visek (Cabinet of Executive Vice-President Frans Timmermans)

21 Mar 2023 · Animal welfare

Meeting with Saskia Bricmont (Member of the European Parliament)

16 Mar 2023 · EU trade policy (meeting with APA)

Meeting with Stéphane Séjourné (Member of the European Parliament)

15 Mar 2023 · Bien-être animal (équipe)

Meeting with Margrete Auken (Member of the European Parliament) and Dyrenes Beskyttelse

9 Mar 2023 · Animal welfare in EU legislation

Meeting with Erik Poulsen (Member of the European Parliament) and Dyrenes Beskyttelse

8 Mar 2023 · Animal welfare related issues

Meeting with Caroline Roose (Member of the European Parliament) and L214 Ethique et Animaux

16 Feb 2023 · Intergroupe bien-être animal : PHASING OUT CAGES IN THE EU

Eurogroup for Animals urges EU to link animal welfare to mental health

14 Feb 2023
Topic — The European Commission is consulting on a comprehensive, prevention-oriented approach to mental health.
Message — The organization requests that the Commission recognize the role animals play in mental health. They advocate for a multidisciplinary approach including animal welfare and housing.12
Why — This recognition would institutionalize animal welfare as a key component of health policy.3
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Meeting with Janusz Wojciechowski (Commissioner) and

7 Feb 2023 · The upcoming 4 legislative proposals on animal welfare and the recent positions raised by some Member States in this regard.

Meeting with Grace O'Sullivan (Member of the European Parliament)

1 Feb 2023 · Introduction and areas of possible collaboration

Meeting with Ska Keller (Member of the European Parliament, Shadow rapporteur)

26 Jan 2023 · Common Fisheries Policy implementation

Meeting with Caroline Roose (Member of the European Parliament)

19 Jan 2023 · Animal Welfare Intergroup

Meeting with Martin Hojsík (Member of the European Parliament) and Humane World for Animals Europe and International Fund for Animal Welfare

11 Jan 2023 · Wildlife

Eurogroup for Animals demands faster action on antimicrobial import bans

3 Jan 2023
Topic — The European Commission is consulting on banning specific antimicrobials in animal products imported from non-EU countries.
Message — The group urges the Commission to set short deadlines for remaining rules and reduce the transition period. They also request including colistin and insects within the scope of the ban.123
Why — The proposal would protect public health by preventing the promotion of unsustainable global farming practices.4
Impact — Non-EU producers face higher costs to meet strict European standards for veterinary medicine usage.5
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Eurogroup for Animals urges ban on live sea exports

6 Dec 2022
Topic — The consultation concerns requirements for official controls to verify animal welfare rules on livestock vessels.
Message — The organization demands a ban on sea transport and replacing live exports with meat. They argue third-country exports are illegal because EU welfare standards cannot be enforced abroad.12
Why — A ban would eliminate animal suffering caused by delays, harsh weather, or vessel capsizing.3
Impact — Livestock exporters would lose their international trade routes and face the closure of sea-based operations.4
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Eurogroup for Animals Demands Stricter Livestock Vessel Controls

6 Dec 2022
Topic — Implementing regulation for recording official animal welfare controls on livestock transport vessels.
Message — The group calls for independent veterinarians, contracted by the EU, to oversee all stages of transport. They advocate for strict vessel standards, including automated sensors and CCTV monitoring. Clear emergency plans must be established for situations where landing is refused.123
Why — Stricter oversight would improve animal welfare and ensure transport operators remain accountable.45
Impact — Shipping enterprises face higher operational costs and potential bans for non-compliance.67
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Meeting with Caroline Roose (Member of the European Parliament)

22 Nov 2022 · Bien-être des poissons et animaux aquatiques

Meeting with Frances Fitzgerald (Member of the European Parliament, Rapporteur) and EUROPEAN TRADE UNION CONFEDERATION and

27 Oct 2022 · Proposal for a Directive on combatting violence against women and domestic violence

Meeting with Janusz Wojciechowski (Commissioner) and

26 Oct 2022 · Horse meat trade, Challenges around horse rescue and rehoming, Horse Welfare, Food Promotion Policy, Review marketing standards, Status Strategic National Plan and Animal Welfare, Insect farming

Eurogroup for Animals urges non-animal methods for chemical hazards

18 Oct 2022
Topic — The Commission is revising hazard classification rules for chemical substances and mixtures.
Message — The group calls for chemical classification to prioritize human data and non-animal methods over animal testing. They want animal studies used only as a last resort, with mandatory validation evidence for such trials.12
Why — This would legally mandate the group's mission to prioritize alternative research methods over animal testing.3456
Impact — Industry labs face higher hurdles to justify animal testing through new validation rules.78
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Meeting with Lara Wolters (Member of the European Parliament, Rapporteur)

11 Oct 2022 · Meeting about Due Diligence legislation encompasses animal welfare

Eurogroup for Animals demands ECHA prioritize non-animal testing

10 Oct 2022
Topic — Reforming the European Chemicals Agency governance and expanding its legislative responsibilities.
Message — The group wants ECHA to formally promote non-animal testing methods to replace outdated safety assessments. They also suggest improving collaboration between agencies to synchronize data and expertise.12
Why — Institutionalizing these methods would directly advance their core mission of ending animal testing.3
Impact — The general public remains at risk while the agency continues using outdated safety models.4
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Meeting with Alin Mituța (Member of the European Parliament, Shadow rapporteur)

21 Sept 2022 · School Scheme

Response to Communication on the functioning of the Common Fisheries Policy

8 Sept 2022

-- Functioning of the CFP -- The key objectives to fish at sustainable levels and to end discarding have been hindered by the CFP’s regional approach. Member States have used their powers to gain exemptions on key objectives rather than implement conservation measures, and the Commission has failed to use its powers to propose plans with the necessary conservation measures. -- Improving Delivery of CFP Objectives -- This Member State-led regional approach to fisheries management and controls has induced inactivity rather than proactivity, effectively slowing progress towards the CFP’s objectives of restoring fish stocks, protecting healthy ecosystems and safeguarding profitability for fishers. The Commission should foresee a more direct role for itself in implementation and enforcement of this CFP.. The Commission should use its delegated powers to propose fisheries management measures including multi annual plans where the CFP’s objectives are not being met and Member States have failed to propose plans that will meet the CFP’s objectives. The Commission should reject or revise multiannual plans that are not in line with the CFP’s objectives. The Commission should create improved transparency and accountability over the implementation of management and control measures, promoting localised responsibility by fishers as ‘Stewards of the Sea’. Reducing ghost gear should be a priority issue in the conservation and documentation (including logbooks) requirements established under the CFP. -- Emerging Trends -- The welfare of fish and aquatic invertebrates are absent from the objectives of the current CFP. This void has severely limited progress in fisheries and aquaculture. Conversely, recognition of animal welfare in aquaculture in the previous EMFF regulation, the outgoing CMO regulation and animal welfare policy contributed to progress on animal welfare in the aquaculture sector. Acknowledging the absence of CFP objectives to deliver on Article 13 of the Treaty of the Functioning of the European Union by taking animal welfare into account in fishery policy, is the necessary first step towards addressing fish welfare in future fishery policy. Fish welfare can already be improved through the existing CFP by: - mandating STECF to study the economic costs and benefits in production and marketing of high animal welfare standards in aquaculture and in fisheries, - introducing mandatory enhanced Method of Production Animal Welfare Labels (MoP+) alongside sustainability labelling, - collecting and publishing data on welfare indicators in aquaculture and fisheries, including injury and mortality rates, use of medications, production methods used, and other animal based outcomes. The current CFP can be used to meet its climate ambitions by: - promoting and focussing financial and technical support towards low-carbon production systems including non-fed aquaculture systems; - mandating STECF to assess the climate impact of bottom trawling - prohibiting high-carbon activities; In line with the Farm to Fork Strategy and the Green Deal, a fundamental change is needed in the whole food system, from production to consumption, while taking account of externalities. Fishery policy must also be part of this new food systems approach. This can be achieved initially by encompassing the CFP in the Sustainable Food System Framework Law, and by integrating fishery, agriculture and other related policies under a future Common Food Policy. Additionally, the definition of Maximum Sustainable Yield should be updated to aim for recovering and maximally productive marine environments, rather than aiming at and embedding the current degraded state of marine environments.
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Meeting with Sarah Wiener (Member of the European Parliament, Shadow rapporteur)

8 Sept 2022 · Staff meeting EU School fruit, vegetables and milk scheme

Meeting with Lukas Visek (Cabinet of Executive Vice-President Frans Timmermans) and Bureau Européen des Unions de Consommateurs and European Public Health Alliance

12 Jul 2022 · Food security

Meeting with Anja Hazekamp (Member of the European Parliament)

29 Jun 2022 · Annual Conference Eurogroup

Meeting with Andrea Beltramello (Cabinet of Executive Vice-President Valdis Dombrovskis) and International Federation for Human Rights and

10 Jun 2022 · Trade and sustainable development, Free Trade Agreements

Meeting with Anja Hazekamp (Member of the European Parliament)

18 May 2022 · Launch event ECI Fur Free Europe

Meeting with Janusz Wojciechowski (Commissioner) and

3 May 2022 · Debate about the CAP Strategic Plans and Animal Welfare

Response to Improving environmental protection through criminal law

21 Apr 2022

We welcome the Commission's proposal for a new Directive on the protection of the environment through criminal law that intends to increase environmental protection and requires Member States to implement stronger criminal provisions more likely to dissuade potential criminals. Eurogroup for Animals and Four Paws call on the European Institutions to support this strong proposal and the necessary improvements. Offences and Sanctions The new proposal encompasses a wider range of criminal offences related to the environment with more specific and clear descriptions. In particular, the proposal sets a minimum for maximum sanctions and additional penalties for the killing, destruction, taking of, possession, sale or offering for sale and trading of protected wildlife. We acknowledge and support this comprehensive list of offences but the proposal falls short on the scope and sanctions. We believe it is essential to widen the scope of species concerned for all these crimes to include the ones listed in all annexes, A, B and C, to Council Regulation (EC) No 338/97. In a precautionary approach, we must ensure that species that are not already endangered because of wildlife crime do not become so. In this context, sanctions should be strengthened to truly be a deterrent. Wildlife crime is a low risk and high reward crime so it is crucial that sanctions align with the seriousness of the crime. The list of aggravating circumstances must also consider the protected status of species involved in wildlife-related offences, the occupation of the offender in relation to these crimes as well as the number of specimens concerned. Update of the Directive It is also essential to include a provision to update the Directive in due course when a new environmental law is adopted, which should go beyond the current statement where the Directive “should be amended in order to add to the categories of criminal offences also the new serious breaches of Union environmental law” to state how this should happen in a systematic and timely way to ensure inclusion of all updates. In that sense, we recall our support for the adoption of an EU Positive List of allowed pet species, which is a mechanism through which animal species are objectively and scientifically assessed on their safety and suitability to be traded and kept as pets. If such a law were to be proposed and adopted, the Environmental Crime Directive should be updated accordingly and in a timely fashion. Management of Confiscated Animals The proposal should also address the management of confiscated live animals so that they can be accommodated in appropriate conditions with sufficient expertise and resources. The management of confiscated wild animals represents a major challenge for national authorities. Firstly, these authorities often seize or confiscate animals without a clear plan to provide proper long-term care. Secondly, it is often problematic to find facilities which can provide adequate housing and expertise for confiscated animals. National lack of rescue and sanctuary capacity seems to be a reason for different Member States not to enforce regulations and/or to merely sanction individuals with administrative sanctions such as administrative seizures which are not in the best interests of the seized animals and which hardly result in dissuasive signals to individuals/groups trafficking wildlife. Collection of Data We are also pleased that the proposal provides for Member States to collect statistical data to monitor the effectiveness of their system to combat environmental crime offences and submit them to the Commission, which will be communicated publicly afterwards. However, we believe that it is crucial for this information to be made available as soon as possible. This information could not only potentially deter individuals from getting involved in environmental crime but would also assist environmental organisations in providing relevant information.
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Meeting with Anja Hazekamp (Member of the European Parliament) and Humane World for Animals Europe and The Born Free Foundation

20 Apr 2022 · Animal Welfare

Response to Amendment of Regulation 440/2008 (TMR) – 9th ATP / or possibly change to listing of references

7 Apr 2022

Eurogroup for Animals welcomes the initiative to update the approved methods for testing chemicals under the REACH Regulation listed in the Annex to Regulation (EC) No 440/2008 (Test Methods Regulation). In particular, we congratulate the Commission on the deletion of chapter B.5. (corresponding to OECD TG 405) and the introduction of the OECD test guidelines 494 and 492, leading to serious eye damage/eye irritation being now assessed exclusively by in vitro methods. We also welcome the deletion of five in vivo tests and the addition of three in vitro tests with regard to ecotoxicological properties. However, several of the proposed updates to the Annex to Regulation (EC) No 440/2008 do not seem to reflect the Commission’s willingness to reduce the amount of animal testing for chemicals safety assessment, which is also expressed in Recitals 5 and 6 of the draft Commission Regulation amending, for the purpose of its adaptation to technical progress, the Annex to Regulation (EC) No 440/2008 laying down test methods pursuant to Regulation (EC) No 1907/2006 of the European Parliament and of the Council on the Registration, Evaluation, Authorisation and Restriction of Chemicals. A high number of tests involving the use of animals will remain in the Annex to Regulation (EC) No 440/2008, while in vitro methods that are still valid, and where an up-to-date corresponding OECD TG is available, are to be deleted. For example, this is the case for chapter B.40bis. (in vitro skin corrosion) where the corresponding OECD TG 431 was updated in 2019. The same is true for chapter B.46. (in vitro skin irritation) that is to be deleted where the corresponding OECD TG 439 was updated in 2021. Moreover, the present initiative foresees the addition of new tests involving the use of animals. For example, with regard to ecotoxicological properties, five new in vivo tests using vertebrates are planned to be added (OECD TGs 205, 206, 223, 248, 250) on top of the many in vivo methods that are already listed in legislation, showing no significant progress towards animal-free testing for these endpoints. The reasoning behind the plans to delete valid and available in vitro testing methods whilst at the same time keeping in vivo methods that are either outdated or where an in vitro method to replace it already exists is not clear. Therefore, we urge the Commission to fulfil its commitment to review and improve the testing methods with a view to reducing testing on animals and the number of animals involved as stated in recital 5 of the draft Commission Regulation, and remain true to Article 13 of Directive 2010/63/EU which makes it a legal obligation in the Union to use an alternative method that does not entail the use of a live animal, instead of an animal-based method, once such method is recognised under the legislation of the Union. Any delays to the process of introducing new alternative methods into Regulation (EC) No 440/2008 therefore could hinder a timely uptake of such methods once they are adopted at international level.
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Meeting with Andrea Vettori (Cabinet of Commissioner Virginijus Sinkevičius) and Humane World for Animals Europe and

28 Jan 2022 · Trophy hunting in relation to EU biodiversity objectives

Meeting with Helena Braun (Cabinet of Executive Vice-President Frans Timmermans) and Humane World for Animals Europe and

28 Jan 2022 · Trophy hunting in relation to EU biodiversity objectives

Meeting with Anja Hazekamp (Member of the European Parliament)

30 Nov 2021 · Animal Transport

Meeting with Caroline Boeshertz (Cabinet of Executive Vice-President Valdis Dombrovskis), Cristina Rueda Catry (Cabinet of Executive Vice-President Valdis Dombrovskis)

16 Nov 2021 · Trade policy on animal welfare

Response to EU Chemicals Strategy for sustainability - Revision of the Cosmetic Products Regulation

29 Oct 2021

Eurogroup for Animals welcomes this impact assessment with the purpose of reviewing some of the provisions of the Cosmetic Products Regulation in light of the objectives of the Chemicals Strategy for Sustainability. Improving the protection of citizens and of the environment against hazardous chemicals and encouraging innovation for the development of safe and sustainable alternatives are goals that are important to all citizens. Innovation for the development and testing of safe chemicals are of particular interest to Eurogroup for Animals and its 83 Member Organisations as it can provide the technologies necessary to accelerate the transition to animal-free safety assessment frameworks. Today, the Cosmetic Products Regulation is the only EU regulation implementing a ban on animal testing. A review of this regulation under the Chemicals Strategy for Sustainability has therefore the potential of improving harmonisation across safety assessment law, while promoting the full uptake across sectors of the well established animal-free safety assessment approaches for cosmetics. Please find our contribution in attachment.
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Response to Sustainable food system – setting up an EU framework

25 Oct 2021

A) The Food Systems Framework should be a binding umbrella law taking a food systems approach based on policy option 4 To meet the European Union’s objectives, option 4, a new comprehensive framework legislation on the sustainability of the European Union’s food system that applies to all actors is required. Option 4 should also address: - food environments - how to increase the uptake of plant-based food and make sustainable food the most readily available; - financial incentives for plant-based production for human consumption; - innovation in plant-based food and meat alternatives, including cultivated meats; - trade. Binding policies are the most effective drivers to align the food system with the planetary boundaries and ensure fair competition through rules. Voluntary commitments should only complement regulatory initiatives. The law should take a food systems approach The framework law requires the capacity to transform the entire food system. The law must, therefore, include all actors and stages of the food system in its scope. The Framework law should - consider the food system in its entirety, from production through the middle-chain to consumption and waste; apply to all actors; - pursue systemic change to make production and consumption shift to sustainable food production; - facilitate enabling food environments through obligations to disincentivise the promotion of animal products, increase the uptake of plant-based food and make the plant-based choice the most readily available and affordable. A food systems approach is required, rather than a product approach that would only address how to make certain specific products more sustainable. B) The law should mainstream a healthy, sustainable food system and high levels of animal welfare in all agri-food policy and include EU targets The framework law should embed all the Farm to Fork Strategy’s overarching objectives. It should set time-bound, quantitative EU targets following the principles of the EAT-Lancet Planetary Health Diet. A set of daughter laws can help achieve the objectives and ensure Member State action through national plans. Healthy, sustainable food and high animal welfare should be the central objectives of all EU agri-food policy and legislation. The framework law must recognise the interconnectedness of animal welfare with human health and other dimensions of sustainability. The Framework Law should, therefore, steer all other agri-food policies and legislation, such as the Common Agricultural Policy and Common Fisheries Policy. The next revision of the CAP and CFP should fall under this framework and contribute to healthy, sustainable diets within the planetary boundaries.
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Meeting with Anja Hazekamp (Member of the European Parliament)

13 Oct 2021 · ECI Stop Circus Suffering

Response to Animal welfare labelling for food

20 Aug 2021

Eurogroup for Animals welcomes the opportunity to provide feedback on the Inception Impact Assessment, particularly as there is much to welcome in the document. However, as outlined in our full submission (see attached document), we have specific concerns and recommendations around the following: - Legal scope: We believe that Article 114 TFEU should be used as the primary, if not sole, legal basis for any new legislative acts, thereby providing proper grounds for affording legal protections not only to 'farmed' animals, but to all animals used and kept for commercial purposes. This would extend to invertebrates, wild caught fish, cats and dogs bred for the purposes of becoming pets in households and non-human primates. For some of these species, and for others that are already foreseen to be included within the scope, we also believe that Article 114 provides sufficient grounds for outright bans on practices that are incompatible with the most basic definitions of animal welfare, not least with the more ambitious 'Five Domains' model, which we wholeheartedly support. - Live transport: Eurogroup for Animals supports the option of prohibiting the export of certain categories of live animals to non-EU countries in light of the difficulties of ensuring the compliance with animal welfare standards after the transport means has left the Union territory. However, this option needs to be clearer, and it should be made explicit that no food producing animals should be exported under any new legislative act. In-line with the objectives in the Commission's Farm to Fork Strategy, supply chains need to become shorter, and meat should henceforth be transported on the hook, not on the hoof. Likewise, semen and embryos should henceforth supplant any trade in breeding animals with third countries. - Animal welfare at the time of killing: Whilst we support the opening of smaller abattoirs, such developments should not be accompanied by a 'simplification' of standards, which we fear would come at the expense of animal welfare. Enhanced animal welfare provisions at the time of slaughter should not be sacrificed as a response to special pleas from smaller operators. Furthermore, whilst we welcome the option of species-specific requirements for the killing of farmed fish, requirements should go further to at least the top 7 farmed species (including eel and turbot). Also, any definition of 'slaughterhouse' should include fish slaughter facilities.The welfare of fish during killing in wild capture fisheries also needs to be addressed with specific measures. - Animal welfare labelling: It is important for consumers not only to make choices based on animal friendly products, but also to make choices based on transparent information concerning the way animals are reared. The current situation, with good provision of information in some Member States, but not in others, has seen schemes develop and proliferate that are detrimental to cross border exchanges, and which are at best confusing to consumers. As such, a mandatory EU-wide animal welfare related label is absolutely crucial to better inform EU citizens about the way animals are reared and the level of animal welfare they experience throughout their lives. As such, the most transparent, fair and progressive approach would be to implement a “Method of Production plus” label, based on the way animals are reared, transported and slaughtered with the addition of a few selected animal welfare indicators that would increase the transparency of the label. All of these points, and more, are expanded upon in our full submission, which can be found in the attached document.
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Response to Review of the EU school fruit, vegetables and milk scheme - EU aid

16 Jul 2021

Eurogroup for Animals welcomes the review of the EU school fruit, vegetable and milk scheme. We need to urgently reduce the impact of livestock farming, and shift to more plant-based diets. The Farm to Fork Strategy notes that current food consumption patterns are unsustainable from both health and environmental points of view. The promotion of dairy production under the EU school fruits, vegetables and milk scheme is incoherent with the necessary shift towards more plant-based consumption patterns. Replacing dairy with plant-based alternatives based on soy, legumes, seeds, nuts or cereals can reduce the environmental impact. Dairy has a larger environmental footprint than plant-based alternatives. In determining the eligible products, the most sustainable should qualify. Public money should be used to enable the shift needed and should only be spent on promoting plant-based products, i.e the most sustainable alternatives. Therefore, plant-based drinks should qualify and they should be allowed to be enriched or fortified. By promoting plant-based drinks, the scheme can contribute to favourable food environments making the healthy, sustainable choice the easier one, also later in life. Dairy products from intensive farming systems should not be eligible. In the case that dairy products end up being eligible they should only qualify according to the Farm to Fork principles. This means that the school scheme should only finance organic dairy products to help reach the target of at least 25% of the EU’s agricultural land under organic farming by 2030 as laid out in the Farm to Fork Strategy and EU Biodiversity Strategy. Please find our detailed feedback attached.
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Response to Revision of Non-Financial Reporting Directive

14 Jul 2021

Eurogroup For Animals welcomes the EU initiative aiming at further embedding sustainability into corporate governance, which would amend the reporting requirements of the Non-Financial Reporting Directive (NFRD). In that context, Eurogroup For Animals strongly believes that the concept of non-financial reporting currently developed at the EU level should encompass animal welfare. Such an approach would be supported by: 1/ the inherent links between animal welfare and sustainable development (public health, climate, hunger, poverty, etc.), as acknowledged by the latest EU Farm to Fork Strategy; 2/ several international standards including OECD sector-specific guidance and the IFC Sustainability Framework; 3/ best practices adopted by Member States such as France, which already includes animal welfare in the scope of non-financial reporting, and by companies active in the food and garment sectors as part of their mandatory or voluntary sustainable corporate governance. Including animal welfare in the scope of the future Corporate Sustainability Reporting Directive (CSRD) would therefore be relevant and consistent with actual trends. On the contrary, choosing to enshrine certain established practices while leaving others out, such as animal welfare, could send a wrong signal and hinder the momentum for progress that has been built up, by encouraging companies to focus their efforts only on the points set out in the law. There are thus strong arguments in favour of a comprehensive CSRD that should include animal welfare. Furthermore, extending such a mechanism to animal welfare would be fully in line with EU goals, as Article 13 of the TFEU expressly recognises that animals are sentient beings and provides that the EU shall be mindful of animal welfare when formulating its policies.
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Response to Revision of EU legislation on registration, evaluation, authorisation and restriction of chemicals

1 Jun 2021

Eurogroup for Animals welcomes the Chemicals Strategy for Sustainability of the European Commission. As chemical policies affect the health, safety and welfare of humans and animals, these policies are of particular interest to Eurogroup for Animals and its 73 Member Organisations. We see great opportunities to make further steps towards a toxic-free environment through reliable, time-efficient and humane safety assessment approaches. The legislative proposal needs to respect EU commitments and its citizens’ values Directive 2010/63/EU on the protection of animals used for scientific purposes recognised that “animals have an intrinsic value which must be respected” and that the EU has the final goal of full replacement of procedures on live animals. However, the latest statistics show that around one quarter of the animals used in experiments were used to fulfil regulatory testing requirements - many under REACH. To protect the needs of citizens, industry and environment, whilst respecting EU values and commitments, it should be ensured that every additional testing requirement will be addressed by reliable non-animal methods. The legislative revision needs to guarantee that the number of animals used for regulatory testing under REACH do not rise with the increase of (new) testing requirements. The first online consultation on the Future of Europe revealed that 1 out of 7 citizens mentioned animal welfare in an open question about their hopes for the future EU priorities. Both Directive 2010/63/EU and the REACH regulation set clear responsibilities to promote alternatives to the use of animals, but they are both far from delivering significant reductions on the use of animals. This legislative revision needs to take into account the need to significantly decrease the number of animals used for safety and risk assessment in the near future. The interpretation of the Commission and ECHA regarding the interface between REACH and the Cosmetics Regulation undermines the will of the public and original legislators when implementing the animal testing ban on cosmetics ingredients and products. Therefore, the legislative revision should aim at guaranteeing that testing requirements to ensure workers and environmental protection can be achieved without additional tests on animals. New effective testing strategies need to increase reliance on non-animal approaches Critique of chemical safety testing using animal-based models is abundant as these have been shown to have low relevance in identifying the real risks for human health and the environment. Therefore, new gold standard methods involve in vitro and in silico approaches that focus on human-based transferability and relevance, as for example, for skin sensitisation. Therefore, this legislative revision should address the limitations of the current animal-centred safety testing approaches. The European Commission acknowledged, in its communication on the Chemicals Strategy for Sustainability, that “safety testing and chemical risk assessment need to innovate in order to reduce dependency on animal testing but also to improve the quality, efficiency and speed of chemical hazard and risk assessments”. Indeed, to ensure that the provisions of the REACH regulation reflect the ambitions of the Chemicals Strategy, advanced non-animal, innovative testing approaches will need to be central to the new testing strategy. Fostering implementation, development and standardisation of new approach methodologies, sharing and harmonizing test results, and avoiding duplicate testing increases transparency, saves time and resources, protects animal welfare and strengthens human-relevant safety assessment, whilst boosting innovation in Europe. Therefore, the legislative revision needs to clearly set out key elements and concrete objectives to strategically address a transition to non-animal testing methods in all areas that fall under REACH.
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Meeting with Janusz Wojciechowski (Commissioner) and

1 Jun 2021 · Accountability report on Karim Allah and Elbeik livestock vessels

Response to Pact for Research and Innovation in Europe

12 May 2021

Eurogroup for Animals welcomes this initiative and recognizes the importance of providing a coordinated strategic approach to the European Union’s global interests in relation to research and innovation, in light of new challenges and shared values. EU scientific policies are of particular interest to Eurogroup for Animals and its 73 Member Organisations as they set the frameworks to better understand, consider and mitigate challenges to animal wellbeing. An inclusive Pact addresses EU commitments and its citizens’ values When the Lisbon Treaty came into force in 2009 it amended the 'Treaty on the Functioning of the European Union (TFEU) and introduced the recognition that • animals are sentient beings. Later, the Directive 2010/63/EU on the protection of animals used for scientific purposes recognised that • “animals have an intrinsic value which must be respected” and that • this Directive is an important step towards achieving the final goal of full replacement of procedures on live animals for scientific and educational purposes. The first online consultation on the Future of Europe revealed that • 1 out of 7 citizens mentioned animal welfare in an open question about their hopes for the future EU priorities. The third successful European Citizens Initiative (ECI) “Stop Vivisection” gathered 1,173,130 signatures and was followed by strong conclusions from the European Commission’s conference on “Non-animal approaches - the way forward” recognising: • the opportunity, and need, for a paradigm shift in the way science is performed, • the need to implement science-based policy that is responsive to Citizens’ demands, and • the potential in considering deadlines to phase-out animal testing in specific areas. Eurogroup for Animals would therefore welcome the inclusion of these values and commitments in the upcoming Pact for Research and Innovation in Europe, in line with the intentions of Member States and the Commission to drive for the replacement of animal experiments, whilst boosting innovation in the Union’s life sciences sector, and meeting the expectations of citizens alike. A Pact of excellence commits to science-based policy for better health, and environmental and animal protection The great majority of animal experiments inflict suffering on the animals, but studies on non-human animal species seldom make significant contributions to the development of medical treatments for humans. Faced with the economical, ethical and societal costs of animal experimentation, attention is shifting to advanced non-animal models based on human-relevant tools and thinking to advance our understanding of human diseases and offer new hope to patients. These new scientific approaches will be crucial to achieve the Commission’s ambitious targets set out by the Next Generation EU and the European Green Deal, to overcome the health and environmental challenges the Union and the world are facing. Therefore, a EU strategic approach to research and innovation that addresses our biggest health, and environmental and animal protection challenges must foresee: • an appropriate level of funding to support the development and uptake of new, advanced non-animal models and technologies; • identification and prioritisation of key research areas where resources and efforts need to be targeted, based on current knowledge and challenges; • large scale support for building key infrastructures that would allow fuller exploitation of innovative non-animal models and technologies; • setting ambitious and realistic goals to phase out the use of animals in specific areas, to motivate and drive coordinated multidisciplinary activities towards those goals; • increased synergies to reach people in all relevant roles to help educate, train and provide confidence in the use of new, advanced non-animal models and technologies.
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Response to Communication on the Global Approach to Research, Innovation, Education and Youth

9 Apr 2021

Eurogroup for Animals welcomes the Commission’s initiative to update the current research and innovation international strategy at such a pertinent time. The Next Generation EU gives a strong commitment to empowering innovation and renewing education through, for example, the new Horizon Europe, the European Education and Research Areas and the European Innovation Council. Given the international nature of research, it is important that the EU is open to global cooperation to face the global challenges ahead. EU scientific research and education policies are of particular interest to Eurogroup for Animals and its 72 Member Organisations as it sets the frameworks to better understand, consider and mitigate challenges to animal welfare. Indeed, over the past years, and in response to political, market and citizens’ demands as well as scientific developments, animal welfare legislation in the EU and EU values have evolved and they apply today to many animals, including animals used for scientific and educational purposes. In line with its citizens values, the EU has set a clear goal of fully replacing animals in research, testing, and education. In view of this commitment and the unprecedented health and environmental challenges the world is facing, it seems paramount to reinforce the European interest to transition to innovative, human-relevant, non-animal science when reflecting and projecting internationally the Commission’s green, and health related priorities. The work of the European Commission’s Joint Research Centre on advanced non-animal models in concrete disease areas is showing, for example, where investments in innovative non-animal technologies can lead to the best models for investigating disease mechanisms and potential therapies. Fostering this knowledge while maintaining an open and multilateral approach to cooperation is paramount to respond humanely and efficiently to shared challenges, in a world still battling the COVID-19 pandemic and foreseeing other global health threats. The Chemical Strategy for Sustainability, launched as part of the European Green Deal, has ambitious targets for the protection of human health and the environment from hazardous effects of chemicals. Non-animal testing approaches will be crucial to achieving the Commission’s ambitious goals for predictive toxicological testing. European cooperation with third countries and other international bodies can promote a critical mass for a speedier transition to animal-free safety assessment. Finally, advanced non-animal models often require the acquisition of new key competences and multidisciplinary knowledge. Through its leadership in advancing non-animal science, the EU can enhance synergies and complementarity with international educational activities for the education and training of (future) researchers and other professionals in using these innovative methods.
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Meeting with Anja Hazekamp (Member of the European Parliament)

18 Mar 2021 · animal welfare commissioner

Meeting with Janusz Wojciechowski (Commissioner) and

16 Mar 2021 · Animal welfare (Developments around mink farming and slaughter without stunning; the crisis with the livestock carrier Elbeik) + EU/China:launch a working group on sustainable food systems under their Agricultural se possible

Response to Revision of EU Programme for biological, environmental and socio-economic data collection in fisheries and aquaculture

15 Mar 2021

The monitoring mechanism for aquaculture, established by Regulation 2017/1004 and extended by its subsequent delegated act 2019/910, is meant to provide for a detailed data collection framework. The environmental data to be collected include the numbers of medicine and treatments administered and the number of mortalities of the fish kept recorded in percentage points. The current ongoing revision of the delegated act 2019/910 offers an important opportunity to strengthen and improve the data collection framework for aquaculture. The collection of environmental data should, in the context of the Green Deal and the Farm to Fork Strategy take a priority. We hence welcome the re-introduction of the environmental record keeping obligations in the Commission’s draft, which was not requested under the 2020 data call. The PGECON, in its 2019 report (p.31), concluded that the current environmental variables are considered, by the relevant Commission committees, too general and vague in wording to be effective or useful. The lack of clarity hinders the aquaculture operators to collect such data, and poses a threat to a proper monitoring of fish and their welfare. This issue is, however, not addressed at all in this draft. The specification table for environmental data collection, table 8 in Annex of 2019/910, has been removed which decreases the clarity of the data collection mechanism even further. Hence, a table with clear recording instructions needs to be included. Additionally, the table should be expanded to include specific fish welfare indicators and organised to facilitate meaningful monitoring. The number of animals which are kept in aquaculture establishments is fundamental to allow for proper assessment of their welfare. Mortalities and causes of mortalities should be recorded. And records must be kept that allow traceability of groups of fish from eggs to harvest, if welfare impacts are to be connected to causes. The demand for seafood products is steadily increasing in the EU and the number of farmed fish outnumbers by far any other animals farmed for food. According to the latest numbers from the European Commission, 2 million tonnes of fish are slaughtered in Europe per year. However, they are counted in tonnes rather than individual fish. Based on the recorded tonnes, the best estimate is that circa 1 to 2 billion farmed fish are killed in Europe every year. In aquaculture, humans directly impact and determine the welfare of fish in many ways. Fish are bred and kept through their whole life cycles until slaughter. The animal welfare problems include excessive stocking densities, low water quality, food deprivation, a variety of genetic modifications, handling, and slaughter. This means that there is a significant need to train and educate the personnel on the farms on the species-specific health and welfare needs to ensure proper keeping, handling, and killing. Detailed records of the number of fish kept on each farm are an indispensible minimum responsibility for aquaculture operators to monitor and improve fish health and welfare. Furthermore, we deplore the restricted access to such data for the public. The environmental data collected, including the welfare of fish in aquaculture, concerns not only to the operators, national institutions, but also to the civil society. A lack of publicly accessible data also means a lack of public accountability of the Member States and the aquaculture operators. Specific provisions are needed to provide the end-users, including civil society, with easy access to such data, for example via Eurostat. We call on the Commission to revise the draft delegated act to clarify data recording obligations for aquaculture operators, to expand the scope of environmental data collected and to make them publicly accessible, for example via Eurostat. The public access and the extended environmental data sets are a crucial foundation for the realization of the Farm to Fork strategy
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Meeting with Anja Hazekamp (Member of the European Parliament) and Animal Welfare Foundation e.V.

15 Mar 2021 · Animal transport

Response to Information and promotion measures for agricultural and food products in the internal market and in non-EU countries

5 Mar 2021

Please find attached Eurogroup for Animals’ feedback on the roadmap consultation on EU farm and food products - review of policy on promotion inside and outside the EU. To summarize our feedback, the preferred policy option is option 3 under the objectives and proposed policy options. This option will have the best capacity to contribute to alignment and coherence with the Farm to Fork strategy, EU Biodiversity Strategy and Europe’s Beating Cancer Plan. We consider it necessary that applicants demonstrate support for the relevant EU objectives. Contributions to climate and environmental goals, higher animal welfare (beyond the minimum EU legal requirements), and public health should be part of the specific objectives of the policy. Therefore there should be conditionality requirements and eligibility criteria in order to achieve policy coherence. Importantly, the revision must aim both to change the food environment and facilitate the transition to more plant-based diets as well as remove obstacles to improving animal welfare in food production across Europe. Moreover, we see potential in a revised policy for enhancing the profile and competitiveness of European produced sustainable plant-based food, meat alternatives and production processes, both within the EU and on export markets. Detailed response in attachment.
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Response to Laying down rules on equine passports

4 Mar 2021

The EU’s rules on the identification and registration of equidae has needed updating even since the horsemeat scandal of 2013 exposed serious flaws in the regime hitherto. Therefore, Eurogroup for Animals welcomes the publication of the draft delegated act from the Commission, but suggests amendments as outlined in the document attached to ensure that the system is as robust as possible, under the framework of the Animal Health Law.
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Response to Wildlife trade – alignment of EU rules with recent decisions taken under the CITES convention and changes to EU ivory trade rules

24 Feb 2021

Across Europe, ivory continues to be traded online, in auction houses and markets. The EU and Japan are among the last countries with large, legal domestic ivory markets. The European Commission has the mandate to introduce comprehensive measures aimed at closing the EU domestic ivory market. Only by so doing, the EU will remove any financial value from ivory, reduce the opportunity for new ivory to be laundered through legal markets, and send a clear message to the rest of the world that the EU no longer considers ivory a commodity. We therefore welcome the European Commission’s draft measures to ban the ivory trade in the European Union (EU). We would nevertheless like to highlight that there are some critical concerns about the measures proposed. A particularly concerning one is the lack of consistent language in both the Guidance and the proposed Regulation. Changes made to the guidance document should be integrated into the EU Commission Regulation, in order to ensure that the guidance becomes legally binding and a consistent language in both the Guidance and the proposed Regulation is used. On behalf of Eurogroup for Animals, representing 70 animal advocacy NGOs, and in cooperation with the signatories in the document enclosed - we would like to submit the attached detailed joint recommendations on the EU proposal to tighten further the EU ivory trade regime.
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Meeting with Janusz Wojciechowski (Commissioner)

27 Jan 2021 · Live animal transport

Response to Climate change mitigation and adaptation taxonomy

15 Dec 2020

The text in its current formulation is extremely detrimental as it does not recognise that industrial livestock production is unsustainable, and it will even enable advocates of industrial livestock production to argue that such productions are sustainable. In fact, industrial livestock production is inherently inefficient in its use of resources and is detrimental to the planet, human and animal health. The Delegated Act fails to adequately address the indirect effects of industrial livestock production, which massively relies on monocultures for animal feed and on the use of agrochemicals that lead to water pollution, soil degradation, and biodiversity loss. If the Delegated Act had considered the indirect impact of animal feed production, the conclusion would have been that industrial livestock production significant compromises three of the Taxonomy Regulation’s environmental objectives. Additionally, the impacts of industrial livestock production on public health and animal welfare have not been duly taken into consideration. The delineated criteria on animal husbandry, herd management and feeding not only do not point towards systemic change towards agroecology but even lend themselves to further development of industrial farming and do not adequately deal with any of the above-mentioned concerns. When referring to “sustainable procurement of feed” the Delegated Act states that when there is a large potential for externalised impacts, such as indirect land-use change, animal feeds should be sustainably sourced and certified by a recognised body. However, existing certification schemes for soy have so far failed to curb the expansion of soy monocultures into formerly pristine environments. Additionally, cereals are not normally covered by certification schemes. Another worrying aspect is that the Delegated Act focuses on the use of technological measures – or rather “techno-fixes” – and on the presumed reduction in the use of agrochemicals to reduce the damages caused by intensive farming. We argue that making intensive farming less damaging definitely does not qualify as making it ‘sustainable’. By contrast, the proposal fails to recognise the fundamental role that regenerative agriculture can and should play in restoring soils and biodiversity, carbon sequestration, water conservation and higher animal welfare, thus meeting the objectives of the Regulation. One of the Taxonomy Regulation’s environmental objectives is “the transition to a circular economy”. Inexplicably, the Delegated Act defines as “non-applicable” the impact of livestock on a transition to a circular economy. This is hardly justifiable, considering that intensive livestock productions - and the associated intensive crop production for animal feed - are linear in their structure, relying on high levels of inputs, much of which result in wasteful, environmentally damaging outputs instead of edible products. In contrast to intensive (and linear) animal productions, rotational and integrated crop-livestock systems are circular. The Delegated Act advocates improving ruminant productivity in order to reduce methane emissions, while completely ignoring the animal health and welfare problems that can arise from the further exacerbation of productivity traits in livestock. By contrast, there is no reference to the importance of preserving the genetic diversity of European livestock breeds that are less demanding in terms of external inputs and adapted to a variety of climates and geographical conditions. For the reasons outlined above, we argue that livestock farming should not be included among the sustainable economic activities of the new Taxonomy Regulation. Its inclusion would not only be in contrast with the objective of the Regulation to contribute to the EU’s goals on climate change mitigation and adaptation, but it would also go against the Paris Agreement and the objectives of the EU Green Deal and of the Farm to Fork Strategy.
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Response to REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL on the elimination of customs duties on certain products

19 Nov 2020

Eurogroup for Animals welcomes this consultation on the EU’s decision to eliminate customs duties on certain products. While this proposal came out as a step in de-escalating the EU-US trade tensions, it intends to lower MFN tariffs on the listed products, in compliance with WTO rules. Among these products can be found live and frozen lobsters, on which it is suggested to eliminate duties on an erga omnes basis for the next five years. Eurogroup for Animals does not believe that the EU should decrease the tariffs currently attached to animal products, unless it can ensure that only products produced under higher welfare standards benefit from this decrease. At this moment, EU legislation does not cover the welfare of lobsters used in the production of food. Therefore, the EU cannot impose conditions on imported lobsters. However, the EU animal transport regulation predating 1/2005 had a scope including cold-blooded invertebrates. After the publication of the EU “Farm to Fork” strategy, the coming five years should see progress on animal welfare legislation in the EU and many organisations are pushing for the rules on welfare during transport to again be applied to lobsters as well. The EU proposal aims at helping the US lobster sector as it has been suffering since CETA has granted lower tariffs to Canadian producers. Yet, this decision does not consider at all the sustainability, including welfare conditions, of either the Canadian, the US or the EU productions. It only assesses that the kind of lobsters being produced in the EU is different from the ones raised in the US and Canada. Lobsters are typically transported in very confined conditions and out of water, including in the mail order sector including exports from the USA directly to consumers in Europe. In these conditions they cannot excrete their metabolic waste and are poisoning themselves, cannot maintain normal blood oxygen levels, and cannot express behaviours. We believe the EU should not favour more trade and more production of animal products where it cannot ensure animal welfare is protected. In addition, by lowering tariffs on live lobsters, it will also favour long distance transport of these crustaceans. Decapod crustaceans (including lobsters) demonstrate as many of the physiological and behavioural criteria for pain perception as birds do, and many more than other vertebrates such as amphibia and reptilia. We thus call on the EU to abandon its plans to decrease these tariffs and to work on developing legislation to protect the welfare of lobsters used in food production systems.
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Meeting with Charlina Vitcheva (Director-General Maritime Affairs and Fisheries) and WWF European Policy Programme and

16 Sept 2020 · Workings of the Advisory Councils

Response to Amending administrative & scientific requirements for applications for novel foods in view of “Transparency Regulation

16 Aug 2020

Eurogroup for Animals welcomes the initiative to strengthen the safety of Novel Foods in the EU and in Member States. At the same time we see a great opportunity to make further steps to achieve the goals of Directive 2010/63/EU on the protection of animals used for scientific purposes and move safety testing methods used for risk assessment of Novel Foods towards modern and humane non-animal techniques. The lessons learnt from past actions and commitments need to be considered in the strategy to increase transparency and quality in food risk assessment. As food safety policies affect the safety and welfare of both humans and animals, these policies are of particular interest to Eurogroup for Animals and its 70 Member Organisations. Over the past years, and in response to political, market and citizens’ demands as well as scientific developments, animal welfare has been mentioned in several EU legislations including recital 32 of the Regulation (EU) 2015/2283 on Novel Foods. It states that “tests on animals should be replaced, reduced or refined. Therefore, within the scope of this Regulation, duplication of animal testing should be avoided, where possible.” This is in accordance to article 13 of the Treaty on the Functioning of the European Union (TFEU) and the Directive 2010/63/EU on the Protection of Animals used for Scientific Purposes, as the Union and the Member States shall pay full regard to the welfare requirements of animals and work towards the final goal of full replacement of procedures on live animals as soon as it is scientifically possible to do so. Critique of food safety testing using animal-based models is abundant as well as the existence of methods involving in vitro and in silico approaches that focus on human-based transferability and relevance. Sharing and harmonizing test results, avoiding duplicate testing and promoting the use of advanced non-animal technologies increases transparency, saves resources, protects animal welfare and strengthens human-relevant risk assessment. Thus, it is highly relevant and appropriate to include these values in the Implementing Regulation on Administrative and Scientific Requirements for Applications on Novel Foods. Hence we suggest to amend article 1 of the Draft Implementing Regulation - Ares(2020)3882938 (“Amendments to Implementing Regulation (EU) 2017/2469”) as follows: “Article 5 ‘Scientific data requirements’ is amended as follows: Point 9. is inserted: ‘9. Toxicology studies involving live animals should be used only as a last resort. To avoid duplication of animal testing, applicants should use non-animal methods and evaluate if data already obtained by previous studies could be used for risk assessment instead of conducting new tests on animals.’ “ With this regulatory framework in place, it is the time for the European Union to recommit to its goal of fully replacing the use of animals in science, to drive for the replacement of animal experiments, whilst boosting innovation in the Union’s risk assessment, and meeting the expectations of citizens alike.
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Response to A New Consumer Agenda

11 Aug 2020

Millions of pets are sold within the EU each and every year, both legally and illegally. However, unsuspecting consumers are too often left without any recourse if the pet (to all intents and purposes in this regard a ‘product’) is not what they expected. Dogs and cats that are poorly socialised and, consequently, suffer from serious behavioral issues make for poor companions and can even be dangerous. As a result, these are often the pets that are abandoned and that need re-socialising/training and rehoming, often by many of the organisations that Eurogroup for Animals represents. European consumers too often turn to the internet as the primary source of acquiring new companions, with nine out of ten pets being sourced this way. Unregulated internet platforms lack any proper traceability or verification mechanisms from the seller to the buyer, leaving millions of consumers at risk of pet trade fraud. This all as the market for pets only continues to increase, partly as a direct effect of the Covid-19 pandemic. European consumers and the animals themselves, in short, need more help. Furthermore, such activity spanning the internal market as a whole can only be addressed through common action at a European level. Such action at a European level would also be coherent with the obligations of the Union’s institutions as set out in Article 13 of the Treaty on the Functioning of the European Union, as the means and methods by which consumers buy pets within the single market duly impacts upon the welfare of the cats and dogs that are traded. More needs to be done at EU level to inform and educate European consumers on how to acquire new companions in a responsible manner (firstly through rehoming, and then through registered local breeders). Behavior change across the Union would negate much of the need for greater legislative action, although it is clear that behavior change can only ever do so much. Instead, Member States need to be protecting consumers from illegal and unscrupulous sellers of dogs and cats in a more joined-up manner whilst transposing and implementing the Directive Modernising Consumer Law. At the same time we are hopeful that specific actions can be included within the new consumer agenda both to empower and protect citizens and pets alike.
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Response to Communication on the future of research and innovation and the European Research Area

2 Aug 2020

Eurogroup for Animals welcomes this initiative at such a pertinent time. Strengthening the foundations, quality and impact of the research and innovation system in the EU and in Member States has never been more pressing. The lessons learnt from past actions and commitments need to be considered in the strategy of the European Research Area. EU scientific research policies are of particular interest to Eurogroup for Animals and its 70 Member Organisations as it sets the frameworks to better understand, consider and mitigate challenges to animal welfare. Indeed, over the past years, and in response to political, market and citizens’ demands as well as scientific developments, animal welfare legislation in the EU has evolved and it applies today to many animals, including animals used for scientific purposes. The European Research Area can bring together all relevant DGs and all Member States in an overarching strategy that can meet EU's research policy objectives, including a roadmap to phase out the use of animals in research and testing. A concerted and conscious effort must be made to prioritize (financial) investments into the development of non-animal technologies, while increasingly challenging proposed use of animals in research. The next Framework Programme has a dedicated mission to defeat cancer in an attempt to prevent the current estimate of having more than 4.3 million new cancer cases by 2035. To be successful, research funding must focus on human-relevant approaches involving multidisciplinary projects with combinations of complex in vitro and in silico approaches and strategic thinking about translation into clinical practice. The recent cutting edge EU-funded project Exscalate4Cov, which bundles a high performance computing platform, biochemical and cellular screening tests and 3D models platform shows the way forward in terms of future technologies needed to advance health. In extension, we have to safeguard that this approach does not become the exception, but rather, the new normal. The conclusions of the December 2019 roundtable “Strategies for Innovation in Life Science”, which gathered scientists, Member States, Commission, MEPs and NGOs, identified concrete steps to promote scientific innovation that can improve the translatability of research into human healthcare and significantly reduce the use and suffering of animals in laboratories. Some of these steps are: 1.The limitations of animal-based methods should be made clear, to help build trust in human-based methods: The limitations of using other species to study human diseases have been acknowledged in many publications, but animal experimentation continues to be abundantly practised. 2.Testing and disease models should be standardised to better identify the applications and limitations of each method: It is essential to promote frameworks that enable the standardisation of new advanced methods, to build trust in these technologies, promote their uptake and improve the impact of research overall. 3.Shift of funding and strategic thinking: Huge developments in human-based science have been possible due to dedicated funding programmes, but they continue to be meagre in comparison with the investment on animal-based projects. Drawing from published analyses on cross disciplinarity and research impact, it would be important that on calls for proposals, a methodology assessment would encourage human-relevant approaches and multidisciplinary teams who think strategically about translation into clinical practice, for projects that are prioritised by clinical need. With the regulatory framework already in place, now is the time for the European Union to recommit to its goal of fully replacing the use of animals in science, to honour the spirit as well as the letter of existing Union law, to drive for the replacement of animal experiments, whilst boosting innovation in the Union’s life sciences sector, and meeting the expectations of citizens alike.
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Response to Fitness Check of the EU legislation on animal welfare

23 Jul 2020

Given the bases on which EU law to improve animal welfare can be made, Eurogroup for Animals understands the logic of the basic scope of this fitness check (being limited to farmed animals). However, we regret that such limitation from the outset will naturally prohibit a holistic approach, looking at all aspects of Union law pertaining to the protection of animals, including those covering wild animals and animals in science. Nevertheless, it is of utmost importance to our association that the fitness check remains to be as wide as possible within this definition. Whilst inevitably, in-line with the mandate as prescribed by the Farm to Fork strategy, the fitness check will review the existing Regulations relating to live transport and slaughter, it must go further than this and take into account all of the seven laws that can be assessed, including the Directives relating to the protection of pigs, calves, laying hens and broilers, in addition to the provisions of the General Farming Directive itself. Furthermore, whilst the fitness check is confined to assessing legislation relating to animals, it must also take into account that such legislation is not limited to the welfare of conventionally ‘farmed’ animals. For instance, Council Regulation (EC) No 1/2005 relates to any animal that is transported for commercial purposes, whether that be a cow, a pig, a dog or a fish. Similarly with the General Farming Directive, the provisions of which are too broad as to be practically effective for many species (farmed fish, for instance), and which, in addition, is unclear as to any definition of what constitutes ‘farming purposes’. Are dogs bred on industrial scales for the sole purpose of being sold for commercial gain not, under this definition, covered? Our association believes that they are and that as such, proper provisions should be provided. An approach that covers any animal that is in any way ‘farmed’ — whatever the species — would not only be in line with existing Union law relating to animal health and official controls, but would also be commensurate with prevailing scientific principles on one-health/one-welfare. The flip-side of assessing the current acquis in regard to species that may well be covered hitherto also necessitates an assessment of those species that are currently farmed and yet are not adequately protected, including dairy cows, pullets, several species of poultry, ovines, caprines and aquatic animals. These need to be included too. Whilst Regulations and Directives have their respective benefits, form must follow the function according to the purpose, and the existing acquis has too often led to differential interpretation and implementation. As such, Eurogroup for Animals would naturally favour Regulations over Directives. After all, any animal should be subject to the same high standard of protection whether it is in one Member State or another. Every animal has an intrinsic moral worth, as each is sentient, having the ability to think and feel. This principle, enshrined in the Treaty of the Functioning of the European Union (TFEU), also needs to be fully upheld through any EU law relating to animals. As such, the fitness check must ensure that the current acquis is reviewed not on the basis on which it was made — that of affording basic protection — but on the basis of whether it provides the minimum level of protection to enable each and every animal to live a good life. Only through this lens can the principle as enshrined in Article 13 TFEU be fulfilled. Finally, in order to adequately assess the criteria above, the fitness check must rely on up-to-date scientific standards. In doing so, it also has to be true to the ambitions of the Green Deal, in particular the Farm to Fork strategy. As such, we have compiled a list of shortcomings with the existing acquis, detailing why these laws have to be considered by the fitness check. This can be found in the document attached to this submission.
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Response to Trade policy review, including WTO reform initiative

14 Jul 2020

Eurogroup for Animals welcomes the roadmap published by the EU on Trade policy review, including WTO reform initiative. The COVID-19 crisis has painfully put the spotlight on the detrimental impact of economic and trade policies that prioritise profits above all. Now is our chance to profoundly rethink EU trade policy and make it fit for the 21st century, adapted to face all the challenges of our times, such as the spread of zoonoses, the climate crisis and antimicrobial resistance. As animal welfare is closely linked to these challenges, part of the solution is to better address the impact of EU trade policy on animal welfare, as one dimension of sustainable development. While we welcome that the roadmap recognises the importance of ensuring that trade policy contributes to sustainable development, we regret that it does not acknowledge that trade policy can also have a negative impact, hindering the EU's path towards sustainable production and consumption. With this Trade Policy Review, the EU must ensure that its trade policy does not counter the goals expressed in both the "Farm to Fork" and "biodiversity" strategies, and more generally the Green Deal. As the Members of the European Parliament in their resolution commenting on the "Harnessing Globalisation" communication, we call on the EU to address explicitly its approach to animal welfare in the next Trade strategy. Better addressing the impact of trade policy on animal welfare would help build the EU's resilience, but also, as most animal welfare standards are not imposed on imported products, improve the level playing field for EU producers. In addition, as most UN SDGs will remain out of reach if animal welfare is not improved, trade policy could, by contributing to the promotion of higher animal welfare standards, help deliver on this key objective of the European Commission. Building resilience: At this moment, EU trade policy is blind to the production model it fosters and to the nature of the economic sectors it stimulates. Global markets and further trade liberalisation tend to favour bigger companies that can support the competition and has led, in the dairy and meat sector, to increased integration and intensification. In addition to being intrinsically detrimental to animal welfare, the intensification of animal agriculture has also fueled three key challenges the planet is facing: zoonoses, antimicrobial resistance and the climate crisis. The EU should ensure its trade policy does not further stimulate this trend. Improving the level playing field: At the moment, only rules on welfare at the time of slaughter applies to imported products. This creates a lack of level playing field for EU producers and a feeling of unfairness which has led to the absence of progress in EU standards over the past decade. This could hopefully change with the revision of legislation planned under Farm to Fork, but in the meantime the EU should only further open its market to products respecting animal welfare standards equivalent to those applied in the EU. This would provide the biggest incentive for foreign producers to lift up their standards. How can the EU do better? In bilateral trade policy, the EU should: (1) mainstream conditional liberalisation for animal products; (2) improve the language of provisions on animal welfare cooperation, gather them in a standalone chapter and increase resources to implement them; and (3) strengthen the Trade and Sustainable Development chapter by improving the language and improving enforcement mechanisms. At the WTO, the EU should: (1) include in its plan for modernisation to raise the question of sustainability, including animal welfare, and trade. (2) push for a recognition that method of production that are not visible in the final product (such as animal welfare) can be used to differentiate products.
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Meeting with Stella Kyriakides (Commissioner)

22 Jun 2020 · Farm to Fork Strategy.

Meeting with Virginijus Sinkevičius (Commissioner) and

19 May 2020 · To discuss wildlife trade, environmental crime and other related issues in relations with Covid-19 and in the view of Biodiversity Strategy.

Meeting with Jean-Eric Paquet (Director-General Research and Innovation)

30 Apr 2020 · Use of animals for scientific purposes and the promotion of alternative methods

Response to Wildlife trafficking - EU action plan (evaluation)

17 Mar 2020

Dear Sir, Madam, Please find attached Eurogroup for Animals' feedback. Best regards
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Eurogroup for Animals calls for animal welfare-centric food strategy

16 Mar 2020
Topic — The consultation gathers feedback on transforming European food systems to be more sustainable and healthy.
Message — They request that animal welfare becomes a stand-alone sustainability pillar. Proposals include phasing out cages and ending long-distance live animal transport. They also suggest reducing animal product consumption by half by 2050.1234
Why — This would redirect European funding toward the higher-welfare livestock systems the group supports.5
Impact — Industrial intensive farmers and transport operators would face significantly higher costs and operational bans.67
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Meeting with Stella Kyriakides (Commissioner) and

25 Feb 2020 · Discussion and exchange of views on animal welfare issues

Meeting with Janusz Wojciechowski (Commissioner) and

20 Feb 2020 · Animal welfare,

Meeting with Phil Hogan (Commissioner) and

18 Feb 2020 · Trade Issues

Meeting with Christine Schneider (Member of the European Parliament)

30 Jan 2020 · Tierwohl

Response to EU 2030 Biodiversity Strategy

17 Jan 2020

Dear Sir, Madam, please find attached Eurogroup for Animals' comments on the Roadmap for the EU Biodiversity Strategy to 2030.
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Meeting with Diana Montero Melis (Cabinet of Commissioner Jutta Urpilainen)

13 Jan 2020 · The contribution of working animals to the 2030 Agenda for Sustainable Development and the SDGs

Meeting with Helena Braun (Cabinet of Executive Vice-President Frans Timmermans)

11 Dec 2019 · biodiversity, sustainable food and animal welfare

Response to Organics production rules

3 Dec 2019

It is the opinion of Eurogroup for Animals that the implementing act proposed by the Commission should properly reflect the desire of the EU legislator and European civil society to observe a high level of animal welfare in organic farming. This contribution therefore aims to suggest implementation opportunities to ensure the new 2018 Organic Regulation provides high animal welfare standards, in line with the objectives of the EU Organic Regulation and the interpretation thereof by the European Court of Justice. Only such high standards would match EU consumers’ expectation of high animal welfare component of EU organic animal-based products, and ensure a level-playing field for EU organic producers – as rightfully underscored in Recitals 6 and 15 of the new 2018 Organic Regulation. Please find attached a provision-by-provision feedback to enhance farm animal welfare standards in the EU organic production rules.
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Meeting with Sabine Weyand (Director-General Trade)

18 Nov 2019 · Trade and Animal Welfare

Meeting with Marco Valletta (Cabinet of Commissioner Vytenis Andriukaitis) and Animals International (The global arm of Animals Australia)

19 Aug 2019 · Animal transport

Response to Animal health requirements for movements of terrestrial animals and placing on the market of products of animal origin

23 Jul 2019

Eurogroup for Animals very much welcomes the draft rules to supplement Regulation (EU) 2016/429 regarding the movement within the Union of terrestrial animals and hatching eggs. Whilst out comments below are solely based on animal health, and the prevention of disease, we would also like to note that our comments are intended to benefit the welfare of the animals as a whole. This is in line with recital (7) of the basic act, which notes “better animal health promotes better animal welfare, and vice versa”, alongside its reference to Article 13 of the Treaty of the Functioning of the European Union. Indeed, as good animal health is one of the ‘five freedoms’ that forms the basis of animal welfare, Eurogroup for Animals recalls that animal health is a subset of animal welfare, as recognised by the World Organisation for Animal Health (OIE). With this in mind, Eurogroup for Animals would like to raise the following, in the document attached.
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Response to Evaluation of the EU Animal Welfare Strategy (2012-2015)

14 Jun 2019

Eurogroup for Animals welcomes the Roadmap on the Evaluation of the EU Strategy for the Protection and Welfare of Animals 2012-2015 allowing to provide our feedback. We hope that our comments will be a valuable contribution to prepare a meaningful evaluation that can inspire and be the trigger for future actions with a positive impact for the welfare of animals in the European Union. Please find our comments attached.
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Response to Rules for establishments keeping terrestrial animals and hatcheries and their traceability

22 May 2019

Eurogroup for Animals notes the logic of grouping delegated powers contained in several Articles of Regulation (EU) 2016/429 in the interest of coherency, transparency and with a view to avoiding duplication for rules that are interrelated and will have to be applied together. However, whilst the rules on the registration of establishments is broadly welcomed, the draft delegated act lacks ambition and eschews the opportunity to be more ambitious when it comes to the identification and registration requirements for several groups of terrestrial animals. It also leaves several questions we had raised during the drafting process unresolved. Specifically, questions remain on the conditions that quarantine establishments need to meet in order to receive primates from unknown origin. Likewise, in light of the definition of ‘establishment veterinarian’ under Article 2, what is the status of a veterinarian in an establishment that shelters and quarantines primates alongside other mammals, or only primates? Do ‘animal acts’ in the same Article also cover zoos, which of course exhibit animals, or does this definition only apply to temporary exhibitions? Clarifications over these points is needed. The draft act too often replicates existing animal traceability rules laid down in existing Union acts, some of which need to be updated. We therefore hope that the comments below, and those of other stakeholders will be taken into account before the draft act is finally adopted by the Commission. Specific feedback on each section is contained in the file attached to these general comments.
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Response to Update of the list of Invasive Alien Species of Union concern

3 Apr 2019

Eurogroup for Animals supports the adoption of the Implementing Regulation and the inclusion of the proposed species in the List of Species of Union Concern. However, we regret that the proposal doesn’t include the American mink (Neovison vison). The scientific evidence provided in the submitted Risk Assessment approved by the Scientific Forum clearly demonstrates that the American mink is one of the most invasive alien mammals in Europe with serious negative impacts on native European fauna. Therefore its non-inclusion in the Union list seriously jeopardizes the credibility of the Regulation 1143/2014 and the processes of implementation. The Regulation stipulates (Article 4 (6)) that updating the Union list will be done with ‘due consideration to the implementation cost for Member States, the cost of inaction, the cost-effectiveness and the socio-economic aspects’. The cost of inaction, in this case, in terms of the impact on biodiversity and the risk of extinction of the European mink, is considerable and immeasurable in monetary terms. However, this has not been appropriately considered to protect the commercial interests of the fur industry (for which there are provisions in the Regulations). The latest escape reported in newspapers, was only on 22 March, when minks escaped from a fur farm in France ( https://one-voice.fr/fr/presse/la-catastrophe-ecologique-de-la-liberation-des-visons-de-montarlot ). Including the American mink on the List of invasive alien species of Union concern would not necessarily mean its automatic ban, nor a cascading negative effect on the fur industry. On the contrary, it would facilitate the management of the species from a common perspective at European level, which is an absolute necessity considering its great impact on European biodiversity. The Commission and Member States should continue to expand the list basing the assessments on sound science in order to include problematic invasive alien species as well as species that have not yet become established in the EU, but which could present a serious risk to biodiversity if the trade therein continues.
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Meeting with Phil Hogan (Commissioner)

5 Mar 2019 · Agri Matters

Meeting with Anne Bucher (Director-General Health and Food Safety)

16 Jan 2019 · courtesy visit, presentation of activities

Meeting with Cecilia Malmström (Commissioner)

7 Jan 2019 · WTO modernisation process, animal welfare provisions in EU FTAs, Brexit

Meeting with Sebastien Paquot (Cabinet of Vice-President Karmenu Vella) and Humane World for Animals Europe and

22 Nov 2018 · CITES

Response to MFF: 9th Framework Programme for Research and Innovation and Rules for Participation and Dissemination

22 Aug 2018

As stated in recital (39) of the Proposal for establishing Horizon Europe: “Article 13 TFEU should also be taken into account in research activities, and the use of animals in research and testing should be reduced, with a view ultimately to replacing their use.” In the current Framework Programme, it is not transparent where and how many animals were/are used in H2020 projects, and where non-animal scientific methods and approaches were adopted that can replace the use of animals in concrete research areas. Therefore, Horizon Europe should – as part of its monitoring and evaluation system – take a step further to guarantee the systematic collection of data on scientific approaches adopted within its projects. This effort should clearly map the innovative scientific approaches that are being advanced. Such a map is essential to understand where further investment on non-animal approaches is still necessary, and provide scientific evidence and technical support to Union policies by facilitating the identification of clear targets where science and society are ready to move towards non-animal science. Both scientific evidence [1-5] and societal positions [6] call for human-based research that can increase the quality, impact and benefits of science, particularly on healthcare and animals’ lives. This is in line with the commitment of the European Commission to contribute to the development and validation of alternative approaches that can replace, reduce or refine the use of animals in scientific procedures (e.g. Article 47 of Directive 2010/63/EU). Therefore, the new Framework Programme should have a clear strategy to promote the creation and diffusion of animal-free breakthrough innovations with a clear impact on the replacement of animals in science. Such strategy should fill the current vacuum in public support and private investment for breakthrough innovation. It shall also be of particular relevance to Cluster “Health” to ensure the development of innovative solutions to prevent, diagnose, monitor, treat and cure diseases. Article 15 of the current Proposal for establishing Horizon Europe should explicitly include references to the ethical principles and requirements of Directive 2010/63/EU for activities making use of non-human animals. Namely, entities participating in the action should be requested to provide details of licensing and control measures that shall be taken by the competent authorities of the Member States concerned, as well as details of the project authorisations that shall be obtained before the activities concerned start. References: 1. Shanks, Niall, Ray Greek, and Jean Greek. “Are Animal Models Predictive for Humans?” Philosophy, Ethics, and Humanities in Medicine 4, no. 1 (2009): 2. https://doi.org/10.1186/1747-5341-4-2. 2. Voskoglou-Nomikos, Theodora, Joseph L. Pater, and Lesley Seymour. “Clinical Predictive Value of the in Vitro Cell Line, Human Xenograft, and Mouse Allograft Preclinical Cancer Models.” Clinical Cancer Research: An Official Journal of the American Association for Cancer Research 9, no. 11 (September 15, 2003): 4227–39. 3. Knight, Andrew. “Systematic Reviews of Animal Experiments Demonstrate Poor Contributions toward Human Healthcare.” Reviews on Recent Clinical Trials 3, no. 2 (May 2008): 89–96. 4. Greek, Ray, and Andre Menache. “Systematic Reviews of Animal Models: Methodology versus Epistemology.” Int J Med Sci 10, no. 3 (2013): 206–21. 5. Pound, P. “Where Is the Evidence That Animal Research Benefits Humans?” BMJ 328, no. 7438 (February 28, 2004): 514–17. https://doi.org/10.1136/bmj.328.7438.514. 6. André Menache. Stop Vivissection, Pub. L. No. ECI(2012)000007, § European Citizens Initiative (2012). http://ec.europa.eu/citizens-initiative/public/initiatives/successful/details/2012/000007.
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Response to Multiannual Financial Framework - CAP Strategic Plans

26 Jul 2018

While the proposal attempts to remedy the shortcomings of the current policy in delivering animal welfare objectives, the propositions put forward still fail to address the structural failures of the CAP, which have led to the proliferation of factory farming across Europe. Two structural aspects of the new CAP remain problematic in our view. First, the increased level of flexibility afforded to Member States in implementing the CAP could lead to reinforcing inter-state competition on the common market to the detriment of animal welfare standards. Second, the significant decrease expected in the overall CAP budget further narrows any improvements in the welfare of farm animals, by constraining the efficiency of mechanisms meant to ensure the implementation of existing standards and incentivize good practices. Furthermore, Eurogroup for Animals was specifically hoping that animal welfare would be viewed as a priority in the CAP legislative proposal. We therefore put forward the following 5 recommendations: 1.The recognition of animal welfare as a “public good” and the expansion of the funding allocated to animal welfare measures Animal welfare fits the policy definition of “public good” – the EU Parliament itself supports such view, and should therefore be prioritized accordingly. Instead, the proposed future CAP does not offer to remedy the shortcomings of compliance mechanisms ensuring the enforcement of animal welfare legislation, nor does it grant enough funding for incentive mechanisms that go beyond minimal legal animal welfare standards. 2.The inclusion of all animal welfare law in Cross Compliance A potentially powerful enforcement tool, Cross Compliance continues being a measure as weak as in the current version of the CAP, as the proposal does not offer to redress the current exclusion of four of the eight animal welfare legislations from Cross Compliance (namely: the directives laying down minimum rules for the protection of poultry and the regulations on transport and slaughter). Cross Compliance remains the most accomplished enforcement mechanism currently available at EU level. Yet, the persisting of numerous exemptions to Cross Compliance weakens the opportunity for effective enforcement of animal welfare legislation. 3.Animal welfare as a standalone objective, with a ring-fenced budget with minimum and mandatory spending under both pillars The Future CAP should address the Member States’ lack of commitment towards animal welfare over the current period by ring-fencing the budget with a minimum mandatory spending on animal welfare. Ring fencing would mitigate the flexibility afforded to Member States, facilitate harmonization across the Union, and prevent market distortions related to animal welfare standards. Additionally, animal welfare should be listed as a standalone specific objective in Pillar I, and standalone priority area in Pillar II, so as to avoid animal welfare to be overlooked in the design of National Strategic Plans and the RDPs. 4.Coupling progressive animal welfare measures with preventive measures against antimicrobial resistance (AMR) Intensive livestock production systems are demonstrably responsible for high antimicrobials usage. The future CAP should therefore promote more diffuse systems, focusing on the reduction of stocking densities – i.e. smaller group size, higher surface area per individual animal, and outdoor access. 5.Subsidies in support of the production of plant-based products for human consumption More than half of the CAP budget currently funds animal-based agriculture, a large portion of which goes to consolidated, unsustainable and inhumane farming also largely responsible for the production of low nutrition and highly processed meat, egg, and dairy products. The new CAP should encourage healthier diets by listing the reduction in the meat and dairy consumption as a priority objective, while proportionally increase support to plant-based agriculture.
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Meeting with Karmenu Vella (Commissioner) and

12 Jul 2018 · Ivory, Animal Welfare in Aquaculture, Laboratory animals

Response to Commission Delegated Regulation on the methodology for risk assessments of invasive alien species

21 Dec 2017

Eurogroup for Animals is very supportive of the Delegated Act as it is currently drafted. Eurogroup for Animals does not believe any substantive amendments are needed to the draft. Indeed, we considers that this draft Delegated Act meets, and in no way exceeds, the scope of the Delegated Act as determined by Article 5(3) the EU IAS Regulation 1143/2014. Eurogroup for Animals welcomes the preventive approach of the Delegated Act. In cases where a species is not yet present in the risk assessment area or is only present in low numbers, and there is no knowledge or incomplete knowledge about that species, the risk assessment should be able to account for such lack of knowledge and information. This is crucial to prevent future introduction or spread of the relevant species. Consequently, it is entirely appropriate, as per international best practice, to consider expert opinion and grey literature when assessing the risk that a species may pose, but only when peer-reviewed evidence is not available and only when the uncertainty surrounding such material is appropriately articulated. As this Delegated Act allows for the use of non-peer reviewed evidence, Eurogroup for Animals praises the considered approach to evidence that this Delegated Act presents. With regards to the section of the Annex of Common Elements relating to Article 5(1)(f); within Paragraph 3, Eurogroup for Animals suggests that ‘endangered habitats’ is changed to simply ‘habitats’. A habitat may become endangered by the presence of an IAS, so merely focusing on endangered habitats, as opposed to all habitats, may miss significant elements for the risk assessment.
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Response to Amendments of the Annexes to REACH for registration of nanomaterials

6 Nov 2017

Eurogroup for Animals appreciates the opportunity to give our opinion on the Draft Regulation - Amendments of the Annexes to REACH for registration of nanomaterials. We would like to invite the Directorate-General for Environment to take the following comments into consideration in further deliberations concerning regulatory safety testing requirements of nanomaterials. Firstly, we would like to point out that there is a lack of clarity on what substances are falling within the scope of this regulation. This has already been stated in other comments, as for example by Verband der Mineralfarbenindustrie e.V., Wirtschaftskammer Österreich (WKÖ), and Eurometaux. Secondly, it is clear that the amendments proposed are still relying, at least in part, in the use of non-validated, and ethically and financially expensive animal-based tests for the safety assessment of new nanomaterials. However, as already stated by EURL-ECVAM, NC3Rs, and other parties including industry and academia: “It is not feasible to assess the safety of all nanomaterials using animal-based toxicity tests.” (Nano Today 12 (2017) 10–13) Considering that for safety testing of nanomaterials validated test methods or testing strategies are still limited, it is not scientifically sound to use testing methods based on animals. Toxicological animal test methods have numerous scientific deficiencies and are not based on modern scientific technologies and validation methods (ATLA 35 (2007) 641–659, ATLA 44 (2016) 281–299). In acknowledging this, the US National Research Council as well as the Joint Research Centre have spelled out a paradigm change from in vivo to in vitro and in silico testing strategies as a vision and a goal for the 21st century (J. Toxicol. Environ. Health 13 (2010) 51–138, Nano Today 12 (2017) 10–13). Additionally, some Member States have committed to scientific policies that establish specific targets to reduce animal testing (NCad (2016), Brussels (2017)). The safety testing of nanomaterials requires new test methods and testing strategies. Scientific and political efforts should set out to develop and validate scientifically sound non-animal testing strategies, making use of modern toxicological test methods and technologies from the beginning. This would stand in line with ECHA’s mission to ensure a high level of human health and environmental protection, as well as ensuring coherence with the EC’s efforts to promote animal welfare and move “towards achieving the final goal of full replacement of procedures on live animals for scientific and educational purposes as soon as it is scientifically possible” (Art 10 of the Directive 2010/63/EU on the Protection of Laboratory Animals). Additionally, in the case of animal tests for the safety assessment of substances intended to be applied without medical motivation, the harm-benefit analysis called for by Article 38(2)(d) of Directive 2010/63/EC in combination with the Severity Classification for Animal Experiments laid down in Annex VIII of this Directive leads to the conclusion that the harms inflicted upon the animals would outweigh the potential societal benefits. In consequence, such animal tests should not be considered ethically acceptable. In order to ensure a high level of human health protection and to play a proactive role in animal welfare, nanomaterials should only be used if their safety to human health and environment can be ensured and if it can be assessed in scientifically validated non-animal testing strategies. Therefore, we propose a review of the Amendments of the Annexes to REACH for registration of nanomaterials that will ensure: - A clear definition of nanomaterials; - Clear safety assessment requirements that do not increase the use of animals in regulatory testing and that promote the use of validated non-animal toxicologic testing methods; - The application of the precautionary principle where validated safety assessment methods do not yet exist.
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Meeting with Cecile Billaux (Cabinet of Vice-President Cecilia Malmström)

12 Oct 2016 · Animal welfare and trade world

Meeting with Cecilia Malmström (Commissioner) and

11 Oct 2016 · Animal welfare in trade agreements

Meeting with Marco Valletta (Cabinet of Commissioner Vytenis Andriukaitis)

16 Sept 2016 · Animal Welfare Platform

Meeting with Vytenis Andriukaitis (Commissioner) and

21 Jun 2016 · Imports of blood serum for breeding pigs

Meeting with Marco Valletta (Cabinet of Commissioner Vytenis Andriukaitis)

10 May 2016 · Animal welfare

Meeting with Cecile Billaux (Cabinet of Vice-President Cecilia Malmström)

27 Apr 2016 · Animal welfare

Meeting with Marco Valletta (Cabinet of Commissioner Vytenis Andriukaitis)

21 Apr 2016 · Bovine tuberculosis control

Meeting with Jean-Luc Demarty (Director-General Trade)

10 Feb 2016 · Trade and animal welfare

Meeting with Xavier Prats Monné (Director-General Health and Food Safety)

5 Feb 2016 · Discussion on Animal Welfaire

Meeting with Karmenu Vella (Commissioner)

1 Dec 2015 · Animal Testing, Invasive Alien Species

Meeting with Mathieu Briens (Cabinet of Commissioner Christos Stylianides)

11 May 2015 · Disaster Risk Management and Protection of Livelihood

Meeting with Tom Tynan (Cabinet of Commissioner Phil Hogan)

26 Feb 2015 · Priorities Comm Hogan and his views on animal welfare and the recent declaration by the NL, DK and DE; Inclusion of animal welfare (art 13 TFEU) in the Common Agricultural Policy and the support for sustainable, higher welfare systems; exchange views on Organic Farming proposal, exchange views on information to consumers and labelling; concerns regarding slaughter, transport, enforcement and controls

Meeting with Dermot Ryan (Cabinet of Commissioner Phil Hogan) and Compassion in World Farming International and Soil Association

24 Feb 2015 · Research into consumer attitudes to method of production labelling, Research into the confusion caused by existing EU labels, The role method of production labelling can play in delivering EU objectives, The ongoing review of the EU's poultrymeat marketing standards.

Meeting with Paolo Berizzi (Cabinet of Vice-President Neven Mimica)

11 Feb 2015 · Relations between animal welfare and development policy

Meeting with Vytenis Andriukaitis (Commissioner) and

30 Jan 2015 · The Food Chain, Innovation and Challenges, Food Information to Consumers, Nutrition, and Food Waste, Animal Health, Animal Welfare and Plant Health

Meeting with Vytenis Andriukaitis (Commissioner) and

23 Jan 2015 · Animal Welfare

Meeting with Andrew Bianco (Cabinet of Vice-President Karmenu Vella), Aurore Maillet (Cabinet of Vice-President Karmenu Vella)

21 Jan 2015 · Protection of Animals