Fédération Européenne pour la Santé Animale et la Sécurité Sanitaire
FESASS
Créée depuis 2001, la Fédération Européenne pour la Santé Animale et la Sécurité Sanitaire (FESASS) regroupe les fédérations professionnelles nationales en charge de la santé des animaux et de la qualité de leurs produits ainsi que des questions relatives au bien-être animal.
ID: 64923022627-39
Lobbying Activity
Response to New categorisation of infection with bluetongue virus
21 Oct 2025
FESASS is particularly involved in the daily management of diseases such as bluetongue and is aware of their consequences for both animals and farmers. It thanks the Commission for this essential consultation in the current health context of the Union. Bluetongue is a vector-borne disease whose pathogenicity varies depending on serotypes, strains (sub-serotypes) and whether they are exotic or enzootic in nature. Furthermore, the prevention and control of this disease are dependent on the existence and availability of vaccines adapted to the serotypes present in the territories concerned. In recent years, we have seen an increase in the introduction of different serotypes into Member States, complicating prevention and control and making it difficult, if not impossible, to eradicate this disease. The same is true for the emergence of new viruses resulting from the combination of already existing BTV viruses. Consequently, it is necessary to adapt the regulations to allow for pragmatic management based on the specific risks and needs of each farm. The proposed recategorization into category DE should allow for such a change if, and only if, it is accompanied by appropriate provisions to support targeted risk-based management. We would like to highlight here the contribution of FESASS concerning the management of vector-borne diseases transmitted by culicoides (see enclosed document). Given that the great majority of serotypes of this disease are currently exotic to the European Union and that trade rules will be maintained, it is imperative to ensure: - dedicated, appropriate, and harmonized surveillance within the Union. The aim is to ensure rapid detection and response in the event of the emergence of a new serotype so that, depending on its pathogenicity, a program of prevention, control, and possibly eradication of this type of serotype can be initiated as soon as possible: - prevention and control efforts by encouraging Member States to use vaccination against serotypes present in the EU, which means supporting the production of multivalent vaccines. In addition, the reclassification of bluetongue as D+E should strengthen the consistency of European regulations governing the management of this disease with those applicable to a very similar disease: epizootic hemorrhagic disease (EHD). These two diseases are indeed very similar. It is therefore essential that the provisions applying to movements, including possible derogations, are identical for both diseases and allow trade between Member States with the same health status. The recently adopted adaptations should be replicated and harmonized between these two diseases. The aim is to maintain trade opportunities, provided that this does not threaten the health status of the destination country or the destination farm.
Read full responseResponse to Modernisation of the EU legislation for on-farm animal welfare for certain animals
16 Jul 2025
The European Federation for Animal Health and Sanitary Security (FESASS) welcomes the opportunity to provide feedback to the call for evidence on the revision of the EUs animal welfare legislation. Our statement is focused on the key relationship between animal health and animal welfare, our main areas of competence. Though distinct concepts, they are closely interconnected. Please find our statement in the attached file.
Read full responseMeeting with Alisa Tiganj (Cabinet of Commissioner Christophe Hansen) and European farmers and
30 Apr 2025 · • ELV five recommendations for the Vision for the Future of EU Agriculture and for the mandate • Presentation of ELV (European Livestock Voice) • Exchange of views: Vision for the future of Livestock • EU Trade policy review: State of play
Response to Protection of animals during transport
12 Apr 2024
Please find the cotribution of FESASS attached
Read full responseResponse to Evaluation of the European Food Safety Authority (EFSA) 2017-2024
8 Apr 2024
La FESASS accueille avec grand intérêt le processus d'évaluation des performances de l'EFSA pour la période 2017 - 2024. Nous vous remercions nous donner la possibilité de contribuer à ce processus et de prendre en comptes nos propositions et remarques qui sont formulées dans le document joint.
Read full responseResponse to Evaluation of the Animal Health Law
3 Apr 2024
FESASS thanks the Commission for launching this process of evaluating the Animal Health Law and its delegated and implementing regulations. The issues at stake are of the utmost importance. As has been rightly so pointed out in the call for evidence, the effectiveness of the regulatory framework and its proper application are crucial to the safety of our food supply (both in terms of quantity and quality), the protection of European citizens against the risk of zoonoses, the economic sustainability of livestock farming as well as the health and welfare of farm animals and wildlife. It is therefore essential to verify how the Animal Health Law's regulatory framework makes it possible to better guarantee the preservation of the health acquis of European livestock farming, to ensure the maintenance and upkeep of rapid and effective response capabilities in the event of an outbreak and to encourage the improvement and harmonisation of health statuses within the Union. Please find our detailed contribution in the attached file
Read full responseResponse to Ban on the use of certain antimicrobials in animals and products of animal origin imported to the Union
3 Jan 2023
FESASS welcomes the opportunity to answer to this public consultation. Please find attached our feedback in PDF.
Read full responseResponse to Use of veterinary medicinal products for diseases in terrestrial animals
2 Sept 2022
FESASS welcomes with interest the proposed Regulation supplementing Regulation (EU) 2016/429 of the European Parliament and the Council as regards rules for the use of certain veterinary medicinal products for the purpose of prevention and control of certain listed diseases.
This text completes the regulatory framework of the AHL already adopted by specifying the possible vaccination strategies in the event of serious epizootic diseases (category A diseases). In this context, it incorporates and clarifies the provisions on emergency suppressive vaccination and emergency preventive vaccination as laid down in Directive 2003/85/EC on foot-and-mouth disease. He develops them for other category A epizootics. It even introduces preventive vaccination for Highly Pathogenic Avian Influenza. All of these provisions are brought together in a single text improving the readability of the Union's strategy for vaccination against epizootics. For FESASS, these innovations constitute a major step forward both in the management of epizootics and in animal welfare (see FESASS' contribution on emergency vaccination in FESASS Annual Report 2019/2020, page 14 to 16 (http://cdn1_2.reseaudesassociations.fr/cities/690/documents/90d0hczpug4yui.pdf)).
However, among the proposed provisions, we would like to draw the Commission's attention to the following points:
- for preventive emergency vaccination to be accepted given its possible negative impacts (see recital 15), it is necessary to involve the stakeholders concerned in the prior risk assessment. We therefore would suggest to complete the end of point 1. (a) of Article 5 by "and integrating the consultation of the relevant stakeholders".
- FESASS is aware that the use of preventive emergency vaccination and preventive vaccination (for HPAI) requires to adapt and strengthen the surveillance and movement control/prohibition. However, these must be both practically and economically viable and acceptable in terms of animal welfare. We believe it is necessary to adapt accordingly the provisions concerning the vaccination of young animals when farms do not have sufficient capacity to keep them beyond a certain age.
- Considering the increased risks of certain epizootic diseases observed in recent decades and the consequences of vaccination for international trade, the FESASS would like the Commission and the Member States to act together to obtain the adaptation of international standards. The aims are to obtain better recognition of the effectiveness of vaccination and the reacquisition of free status within a shorter timeframe. In this context, the priority use of marker vaccines should be encouraged.
Read full responseResponse to List of antimicrobials reserved for treatment of certain infections in humans
17 May 2022
FESASS welcomes with great interest the proposal of a European Commission Implementing Regulation designating antimicrobials or groups of antimicrobials reserved for treatment of certain infections in humans and the opportunity to comment on this draft.
This text is part of the general approach resulting from the application of Regulation (EU) 2019/6 on veterinary medicinal products. It is therefore a component of a broader mechanism aiming at a global control of the use of antimicrobials in veterinary medicine. It is essential to recall that this system:
- provides a very strict framework for the conditions of prescription and use of antimicrobials,
- imposes in-depth monitoring of sales and use of this type of medicine with data collection by species.
The present proposal completes this system by reserving a certain number of antimicrobials for human medicine only. This in no way implies a weakening of the rigour that applies to other antimicrobials. It is indeed vital that veterinary medicine can use antimicrobials to treat animals under strict rules. Veterinarians, farmers and the animal health sector as a whole have demonstrated for over a decade their willingness and commitment in this area which has resulted in a 43.2% reduction in overall veterinary antimicrobial sales between 2011 and 2020. These results have been achieved by developing good practices on the farm to reduce the risk of disease and reduce its impact when it does occur. They have also been made possible using modern technologies that allow faster targeting of prescriptions.
The draft submitted for consultation is based on the scientific expertise of the European agencies (EMA, ECDC and EFSA) and the work of the OIE and WHO. The Commission has followed the recommendations of the EMA. We agree with this choice based on current scientific knowledge and the situation of antibiotic resistances.
However, we consider that it would be appropriate to provide for the possibility of derogations for endangered species and animals races with very limited population (cf. EMA advice). Such derogation should be exceptional and subject to reinforced requirements.
Finally, this project meets the requirements of the One Health approach. However, it will only be effective if other countries in the world apply similar measures. It is therefore essential, in the spirit of Article 118 of Regulation (EU) No 2019/6, that the Commission and the Member States take all necessary measures to ensure that animals and animal products imported from third countries meet the same requirements. Beyond that, we expect an increased effort with these countries and within international institutions to call for the adoption of identical measures.
Read full responseResponse to Method for the Collection of data on antimicrobial medicinal products used in animals
18 Dec 2020
FESASS thanks the Commission for this public consultation on the draft delegated Regulation on the collection of data on the sale and use of antimicrobials in animals.
It is important to continue the exemplary efforts undertaken in the European Union to ensure the effective use of antimicro bial medicines. The animal health services of livestock farmers are very committed alongside livestock farmers and veterinarians in this field. Antibiotics are essential products for veterinary medicine to ensure effective care of animals and thus protect their wellfare.
The collection of harmonised information within the Union on the sales and use of antimicrobials is therefore vital to measure the continuation of efforts and to encourage the less advanced Member States to commit themselves further.
Considering the large amount of information requested, FESASS supports the use of a fully automated system compatible between Member States. In this context and given the administrative burdens that already weigh on farmers, it is desirable that they be solicited as little as possible. Moreover, it seems difficult to have such generalised computer systems in livestock farming by 2023. Could the farmers delagate this task to other competent parties? Here we propose to improve the article 13 wording to add this possibility.
Read full responseResponse to Farm to Fork Strategy
16 Mar 2020
The European Federation for Animal Health and Sanitary Security (FESASS) welcomes the Farm to Fork Strategy (F2F) initiative. It is crucial and urgent to address the social, economic and environmental concerns in a holistic approach. It is indeed a great opportunity to give European livestock farmers new ambitious objectives that will guide European agricultural production in a sustainable and efficient way for the next decade.
It is no longer just a question of feeding Europe, but of ensuring respectful management of its territories and environmental resources. If the primary function of agriculture is to feed people, it is also the first actor and the first user of nature. It is essential that this strategy sets clear and relevant objectives for tomorrow's European agriculture. These must be long-term objectives that give hope back to farmers. That is why we consider that the priority is to move from a policy of support for farmers who stop farming to an ambitious policy of adapting production to the challenges of tomorrow. Farmers have demonstrated their ability to meet the challenges. We must trust them, ensuring consistency between the objectives assigned to agriculture and create a context favourable to innovation. This means guaranteeing a sufficient and fair income. It also means respecting the different forms of agriculture. There is not just one production model that would be the virtuous model to follow. There are necessarily several types of agriculture to ensure the appropriate management of available geographical, economic or genetic resources.
We also want to highlight the importance of Animal Health for the production sustainability. The strategy does not seem to adequately address the role of improved animal health in addressing sustainability, contributing to sustainable primary production, reducing antimicrobial use and reduced green house gas output per unit of production.
Read full responseMeeting with Jorge Pinto Antunes (Cabinet of Commissioner Janusz Wojciechowski)
2 Mar 2020 · Farm to Fork Strategy
Meeting with Jorge Pinto Antunes (Cabinet of Commissioner Janusz Wojciechowski)
2 Feb 2020 · Animal Welfare
23 Jul 2019
The European Federation for Animal Health and Sanitary Security (FESASS) welcomes with great interest the draft of Commission Delegated Regulation supplementing Regulation (EU) 2016/429 of the European Parliament and of Council as regards animal health requirements for movements within the Union of terrestrial animals and hatching eggs. This draft regulation is one of the most important of all the texts prepared by the Commission for the implementation of the AHL. It must secure the Single Market but also guarantee its functioning in the event of a serious health crisis.
As we indicate in our Strategic Plan for 2019 – 2021: “The breeding and keeping of livestock is a major cultural heritage of mankind and shapes our rural regions. Trade and transport are essential for multifaceted agriculture – based on the division of labor – and necessary to market products and animals as well as to generate income… The risks to the health of livestock and to food safety by movements of animals and people, contaminations or other environmental impacts should be minimized.” The purpose of this project is to address the need to be able to move animals to meet livestock needs while preserving the health status of animals and farms.
FESASS thanks the Commission for taking into account the detailed suggestions in the attached document.
Read full responseResponse to Animal disease prevention and control measures
19 Jul 2019
The European Federation for Animal Health and Sanitary Security (FESASS) welcomes with great interest the draft of Commission Delegated Regulation supplementing Regulation (EU) 2016/429 of the European Parliament and of Council as regards rules for the prevention and control of certain listed diseases (SANTE/7070/2019).
This text deals with vital issues for the livestock sector in the European Union but also in relation to Third countries. Indeed, it organizes the prevention and control of the most serious diseases that can affect our farms. The sustainability of our holdings and the security of animal health in the Union and neighboring Third countries will depend on the ability and effectiveness of the competent authorities to manage these issues.
FESASS thanks the Commission for taking into account the suggestions detailed in the attached document.
Read full response12 Jul 2019
The European Federation for Animal Health and Sanitary Security (FESASS) welcomes with great interest the draft of Commission Delegated Regulation supplementing Regulation (EU) 2016/429 of the European Parliament and of Council as regards rules for the entry into the Union, and the movement and handling after entry of consignments of certain animals, germinal products and products of animal origin. This text must protect the Union's health status from the risks associated with introductions from third countries, guarantee the health security of the single market and avoid any economic and trade distortions induced by health guarantees of different levels and reliability. FESASS thanks the Commission for taking into account the suggestions of the attached file.
Read full responseResponse to Animal disease notification, reporting, surveillance, eradication and disease-free status
3 Jul 2019
The European Federation for Animal Health and Sanitary Security (FESASS) welcomes with great interest the draft of Commission Delegated Regulation supplementing the Regulation (EU) 2016/429 of the European Parliament and the Council laying down rules for surveillance, eradication programmes and disease freedom for certain listed and emerging diseases. This text will be crucial for the management of animal health in the Union and will have a significant impact on the economy and sustainability of European livestock farming. It takes over the existing rules while integrating the evolutions induced by the categorisation of diseases. Important changes are thus introduced. It also reinforces the aspects related to prevention. As farmers and animal health organisations, we strongly support these approaches and thank the Commission for taking into account our suggestions in the attached file.
Read full responseResponse to Evaluation of the EU Animal Welfare Strategy (2012-2015)
14 Jun 2019
The European Federation for Animal Health and Sanitary Security (FESASS) welcomes the initiative to evaluate the EU animal welfare strategy 2012-2015. It is a logical continuation based on the approach taken so far. We would like to point out the relationship between animal health and animal welfare. Though distinct concepts, they are closely interlinked. The animal health services, represented in our Federation, are supporting farmers to improve the well-being of their animals and we are of course ready to share our experience in the evaluation process.
We are expecting that the evaluation shows in which areas we have made progress and where there are still challenges. In general, we support an approach to focus on the five criteria listed in the roadmap. Ambitious objectives are okay, but at the end of the day, the measures must be practicable and implementable. We would like to recall one of the conclusions of the EconWelfare project: “There is not one single policy solution towards welfare enhancement that will equally fit with all Member States at the same time”. Flexibility might also help Member States with the implementation of the EU legislative framework for animal welfare.
Due account should be taken to voluntary initiatives that proved already that they can work. This is better than theoretical concepts that are not understood, involving the people actually being responsible for the animals is crucial. Companion animals must not be neglected, as e. g. dogs or cats are outnumbering cows or sheep in many Member States.
Read full responseResponse to Rules for establishments keeping terrestrial animals and hatcheries and their traceability
22 May 2019
The AHL implementation is a crucial challenge for the farming sector as regards animal health and public health but it is also a great concern for farms’ competitiveness and sustainability. The FESASS follows with great attention this current full process of implementation. Our federation contributes whenever it has the opportunity and is necessary. We thank the Commission for this public consultation regarding the proposal of delegated act on rules for establishments keeping terrestrial animals and hatcheries, and the traceability of certain kept terrestrial animals and hatching eggs (SANTE/7016/2018).
There are many interconnections between the various delegated and implementing acts and they need to be implemented at the same time in order to ensure the effectiveness of the European traceability system. Therefore it is important that these implementing acts are also subject of a public consultation.
Concerning databases, it is important to ensure the possibilities of access and exchange between those in charge of traceability and those in charge of animal health. Access to all data relating to animals and their movements should thus be facilitated for surveillance purposes, epidemiological investigations or during checks, in particular at roadside.
We would like to draw attention to the following specific points:
- The draft delegated act refers (for instance in article 21 point g or in annex 1 part 1 point 1.b) to the term “categories of animals”. As there is no definition for this neither in AHL nor in this delegated act, it would be useful to have a clarification. Does it mean “slaughter and non-slaughter?, “slaughter, fattening, breeding?”.
- The definition of "supply chain" is useful, but we draw attention to the relationship that could be made with the notion of compartment. It is essential that there can be no confusion between these two approaches, which do not have the same purpose and therefore impose different requirements.
- The development of new economic activities especially with Internet or other means of communication requires the same level of safety and traceability. In this context, we believe that the requirements of Article 20 are essential.
- The record-keeping obligations of operators do not specify how long the information should be kept. Is this set elsewhere or is it the responsibility of the competent authorities? A period of 5 years after the establishment ceased to be active would be enough.
Read full responseResponse to Transmissible animal diseases — rules on prevention and control
10 Oct 2018
The European Federation for Animal Health and Sanitary Security (FESASS) thanks the European Commission for the possibility to comment the draft implementing act on the application of certain disease prevention and control rules to categories of listed diseases and establishing a list of species and groups of species posing a considerable risk for the spread of those listed diseases.
Beforehand, and as we already indicated during the previous consultation concerning the draft delegated regulation amending the list of diseases in Annex II of the Animal Health Law (AHL), we are aware of the comprehensive work that is being carried out for the implementation of the AHL. We do, however, deplore the complexity of the process. We know that the COM is obliged to follow legal requirements but without information about all the legal provisions induced by the categorization of these diseases, the scope of this consultation is again limited. We solemnly wish to draw the Commission's attention here to the fact that the current approach does not provide a clear vision of the entire future regulatory framework for Animal Health. We are particularly concerned about the respect of the initial objectives set out in the European Animal Health Strategy, which aimed both at simplifying and modernizing this regulatory framework. Therefore FESASS looks forward to the finalized draft acts on surveillance, eradication, free status, emergency measures, animal requirement for animal movements, etc. We consider that it is not possible to give a final opinion on the proposed categorization without these drafts because they are all closely linked and dependent on each other.
Nevertheless, we can already make some remarks on Bluetongue (BTV). The EFSA assessment (30th June 2017) concluded that the serotypes 1 to 24 (without serotype 16) of this disease comply with the criteria of Annex IV of the AHL and can be categorized in category B as in Article 9 of the AHL. However, the epidemiological situation in the Union with regard to this disease differs greatly depending on the serotypes. 6 of them (BTV 1, 2, 3, 4, 8 and 16) are present in the Union; all the others remain exotic. Within the Union, the present serotypes only affect certain Member States. Given this situation, it is crucial to protect the Union of all exotic serotypes and at the same time to enable Member States to get involved individually in the control and eradication of all or some of the serotypes present on their territory and to be able to set up a mechanism to protect themselves against serotypes not present in their territories but present in other Member States. This approach implies being able to manage the BTV and classify Member States serotype by serotype.
- EU exotic BTV serotypes should not be categorized and would be considered as emerging diseases if they enter the EU territory,
- All serotypes already present in some EU Member States, in C+D+E.
However, for BTV serotypes categorized in C+D+E, it is important to allow the possibility to approve eradication programmes for the control of one or more bluetongue serotypes present on their territory. Indeed, such flexibility is necessary because there are no multivalent vaccines adapted to different epidemiological situations.
For the other diseases, the assessment of their categorization will depend of the concrete requirements which will laid down by the other related acts.
Read full response30 May 2018
The European Federation for Animal Health and Sanitary Security (FESASS) thanks the COM for the possibility to comment the draft delegated regulation amending the list of diseases in Annex II of the AHL. In principle, we agree with the proposed list of transmissible diseases. Nevertheless, we would like to stress that this list is the first step of implementing the Animal Health Law. It is a key act that indicates which transmissible animal diseases are priority at European level. Therefore, we are a bit surprised to see Surra on the list, all the more as the EFSA assessment was not conclusive with regard to compliance with the requirements for listing.
We express our gratitude to the COM for the comprehensive work that is carried out and for the determination to make sure that the new AHL will become a success. We do, however, deplore the complexity of the process. We know that the COM is obliged to follow certain legal requirements like the distinction between delegated and implementing acts that, as a consequence, cannot be discussed in a single legislative process. But without information about the categorization of these diseases, the scope of this consultation is limited. For instance, our Federation will pay a great attention to the consequences of the inclusion of Q fever and Paratuberculosis in the list. Therefore FESASS looks forward to the draft act on the categorization of diseases and the related acts on surveillance, eradication, movements etc.
It would have been appreciated if the COM in the explanatory memorandum had given more information about the practical consequences of the new listing, e. g. which diseases are now included that have not been regulated on EU level before (e. g. BVD, Q fever, Paratuberculosis). Given the very tight timetable, there will not be too much time before the application of the AHL to create and implement new EU monitoring and control programmes for too many newly included diseases. Furthermore, while we can understand that it is interesting form an animal or public health point of view to list a disease, we have to bear in mind, that every listed disease will be a “disease E”, i. e. it will have to be monitored (surveillance). The COM, Member States and the European Parliament shall ensure that enough funds are available to fulfil these obligations. On the other hand, we have some questions about some non-listed diseases, for which existing provisions have been taken on EU level to protect our farmers. For example, what will happen to CID 750/2014 and CR 2015/9 in regard to PED?
We also hope that de-listing will not have negative consequences for animal health certification in case of exports as the official veterinarian has to certify the status of disease freedom and his ability to do so depend on the provisions for surveillance and control.
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