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Federation of Veterinarians of Europe

FVE

The Federation of Veterinarians of Europe represents veterinarians across Europe to promote animal health, animal welfare and public health.

Lobbying Activity

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

9 Dec 2025

The Federation of Veterinarians of Europe (FVE), representing around 330,000 veterinarians across 38 European countries, aims to enhance animal health, animal welfare, and public health and to protect the environment by promoting the veterinary profession. FVE welcomes the opportunity to contribute to the European Commissions initiative for feedback to set out detailed rules on animal health requirements for pets that are moved for non-commercial reasons with their owners from one EU country to another EU country, and from a non-EU country to an EU country. FVE strongly supports several positive developments introduced in the new rules. One notable improvement is the new definition of a "single non-commercial movement". This clarification helps prevent previous loopholes, for example situations where several pet owners could travel together in one vehicle with large numbers of animals while claiming separate non-commercial movements. Under the new definition, such situations would instead qualify as a single movement that exceeds the permitted limit and would therefore need to comply with commercial movement requirements. Further positive elements include the introduction of a written declaration requirement for pets entering the EU from third countries, which provides greater traceability and accountability. In addition, Article 4 introduces stricter documentation requirements for an "authorised person" transporting pets on behalf of the owner. This includes the need for a written authorisation signed by the owner to accompany the identification documents, as well as the requirement that the pets movement occurs within five days of the owner's own travel. The proposal also contains more detailed and harmonised rules for pet birds, which were previously covered under Delegated Regulation 2021/1933. It introduces also specific provisions for military dogs, law enforcement dogs, and search-and-rescue dogs. Other improvements include clearer definitions, stricter technical standards for transponder identification, and strengthened prevention measures against key diseases such as rabies, echinococcosis and avian influenza. Notwithstanding, the draft could be improved by aligning terminology and provisions with upcoming legislation for maximum coherence, strengthening veterinary capacity at border control points and clearly define which species and, if necessary, breeds may move under the framework of non-commercial pet movement referring to Annex 1, part B, Animal Health Law. Please see details in the document attached.
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Meeting with Tilly Metz (Member of the European Parliament)

2 Dec 2025 · Mental Health of Veterinarians

Meeting with Catherine Geslain-Laneelle (Director Agriculture and Rural Development) and AnimalhealthEurope

24 Nov 2025 · Representation in advisory groups, notably the Livestock workstream

Federation of Veterinarians backs broader emergency slaughter rules

30 Oct 2025
Topic — The consultation revises EU rules regarding emergency slaughtering conducted outside slaughterhouses.
Message — FVE supports the removal of the terms 'otherwise healthy' and 'accident' from the definition. They request clear, science-based definitions and a two-step veterinary oversight system.123
Why — Veterinarians would benefit from increased legal certainty and reduced waste of safe products.45
Impact — Consumers may face risks if new rules create loopholes for diseased animal meat.67
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European Veterinarians Urge One Health Integration in Crisis Planning

28 Oct 2025
Topic — The consultation concerns a new EU-wide plan for coordinating responses to cross-border health threats.
Message — The federation calls for the full integration of animal health and veterinary expertise into the EU's crisis management framework. They advocate for prioritizing preventive vaccination over mass culling and demand better data sharing between human and veterinary authorities.123
Why — This would formalize the veterinary profession’s role in EU policy and unlock new strategic investments.45
Impact — Human-centric health departments may lose exclusive control over crisis governance as other authorities gain representation.67
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Meeting with Niels Fuglsang (Member of the European Parliament)

2 Sept 2025 · Animal health and welfare

Veterinary federation urges EU-wide ban on fur farming

30 Jul 2025
Topic — Assessment of follow-up actions to the 'Fur Free Europe' citizens' initiative.
Message — The federation calls for a legally enacted phase-out of fur farming and trade. They support banning specific species and prohibiting all fur imports from third countries. This approach includes a transition period to coordinate the shift away from farming.12
Why — A ban eliminates high-risk zoonotic reservoirs that currently demand excessive veterinary resources.3
Impact — Rural workers lose their current livelihoods as fur farms are dismantled across Europe.4
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European veterinarians urge phasing out cages in farm welfare overhaul

16 Jul 2025
Topic — The European Commission is updating legislation to modernize welfare standards for farmed animals.
Message — The federation recommends a gradual transition to cage-free systems for hens and pigs. They also call for mandatory veterinary health visits and animal-based welfare indicators.123
Why — This would expand the professional role and workload of veterinarians across European farming.45
Impact — Farmers face significant technical difficulties and increased costs during the move to cage-free systems.67
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European veterinarians urge CAP focus on preventive animal health

15 Jul 2025
Topic — This consultation addresses simplifying the implementation of EU Common Agricultural Policy plans.
Message — FVE wants better integration of preventive care and formal veterinary oversight. They propose making preventive vaccination and biosecurity plans eligible for funding.12
Why — This would boost demand for veterinary services and provide subsidies for rural practices.3
Impact — Small farmers would lose administrative exemptions if basic health and environmental standards are applied.4
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European veterinarians demand EU funding for vital rural services

10 Jul 2025
Topic — This initiative addresses demographic challenges by attracting and supporting young European farmers.
Message — FVE requests treating veterinary services as public goods eligible for agricultural funding. They want workforce challenges integrated into the renewal strategy.12
Why — Proposed subsidies and grants would stabilize struggling rural veterinary practices' finances.3
Impact — Livestock sectors face increased disease risks and economic decline without veterinarians.4
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Response to Critical Medicines Act

5 Jul 2025

The Federation of Veterinarians of Europe (FVE), representing over 330,000 veterinarians across Europe, welcomes the European Commissions initiative to strengthen the resilience of the supply chain for critical medicinal products through the proposed Critical Medicines Act and appreciates the opportunity to contribute to this consultation. We strongly support the efforts to enhance the availability and resilience of the medicines supply in the European Union. It is crucial to align the Act with the EUs One Health approach, which recognises the interdependence of human, animal, and environmental health and the need for coordinated action across sectors. The veterinary and human pharmaceutical sectors share many interdependencies, including common sources of active pharmaceutical ingredients (APIs), excipients, packaging components, and manufacturing facilities. To ensure the effectiveness of the Critical Medicines Act, these interdependencies must be fully acknowledged and addressed in its design and implementation. Veterinary medicinal products (VMPs), including vaccines, play an essential role in preventing and controlling animal diseases, protecting public health, and ensuring food safety and security across the EU. Lack of availability of veterinary medicines is a significant problem for veterinarians across Europe. Many medicines included in the List of Critical Medicines, are not only critical for human health but also animal health. Their continued availability is vital not only for animal health and welfare but also for preventing zoonotic disease outbreaks and combating antimicrobial resistance (AMR). In particular, vaccination is a cornerstone of animal disease prevention. By reducing the need for antibiotic treatments, it contributes significantly to global efforts to curb AMRa threat that could endanger food security for billions and result in immense economic loss, as noted by the World Organisation for Animal Health (WOAH). However, persistent lack of availability and shortages of key veterinary vaccines undermine disease prevention strategies on farms, disrupt vaccination programmes, and increase the risk of disease spreadultimately threatening public health and the sustainability of the agricultural sector. We therefore urge the Commission to ensure that the Critical Medicines Act: Fully integrates the One Health approach by giving veterinary medicines, including veterinary vaccines, equal consideration to human medicines; By ensuring actions targeting human medicines do not compromise veterinary supply chains; Includes the animal health sector in all relevant impact assessments, supply chain analyses, and strategic interventions; Applies criticality criteria that reflect both animal and human health needs; Strengthens governance and coordination between human and veterinary regulatory authorities, the pharmaceutical industry, veterinarians, and primary producers; Develops robust systems for monitoring, early warning, and mitigation of veterinary medicine shortages. In conclusion, safeguarding the availability of both human and veterinary medicinal products is indispensable for human health, veterinary public health, sustainable farming, and food security. A truly integrated One Health approach must ensure that veterinary medicines are not overlooked, but recognised as a fundamental component of a resilient and responsive European health system.
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Meeting with Eva Maria Zamora Escribano (Head of Unit Health and Food Safety)

8 Apr 2025 · Implementation of Article 106(1) of Regulation (EU) 2019/6 on Veterinary Medicinal Products

Meeting with Antonella Rossetti (Cabinet of Commissioner Christophe Hansen)

18 Mar 2025 · Exchange of views on veterinarians’ contribution to the agri-food systems, rural resilience, public health, and sustainable farming practices.

European veterinarians urge inclusion of animal health in Medicines Act

27 Feb 2025
Topic — The initiative addresses supply chain vulnerabilities and dependencies of critical medicines across the EU.
Message — The federation requests that veterinary medicines be included in the Act to reflect shared manufacturing processes. They call for an ambitious mitigation plan to strengthen the resilience of animal health supplies. This includes investing in European production to reduce reliance on external suppliers.123
Why — A more resilient supply chain would prevent medicine shortages for diverse animal species.45
Impact — Food safety and security are threatened if animal medicine shortages remain unaddressed.6
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Response to Veterinary medicines – list of essential substances for equine species

11 Feb 2025

The Federation of Veterinarians of Europe (FVE) and the Federation of European Equine Veterinary Associations (FEEVA) welcome the update of the list of substances that are essential for the treatment of equine species or provide added clinical benefit. We appreciate the efforts of the European Medicines Agency (EMA) in developing the scientific advice under Article 115(5) of Regulation (EU) 2019/6 on veterinary medicinal products, specifically regarding the list of substances essential for the treatment of equines with a six-month withdrawal period (EMA/CVMP/159047/2023-Corr.1) published on 18 July 2024. However, based on real-world clinical experience and further publications, we believe that some additional substances should be reconsidered for inclusion due to their added clinical benefits. Please see the document attached for details.
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Response to Update on post-mortem inspection, food chain information and health marking

5 Feb 2025

The Federation of Veterinarians of Europe (FVE) representing around 330,000 veterinarians across 39 European countries aims to enhance animal health, animal welfare, and public health and to protect the environment by promoting the veterinary profession. FVE welcomes the amendments to this regulation, which bring more coherence with already adopted regulations and clarify the requirements for domestic and emergency slaughter occurrences. FVE welcomes the opportunity to comment on this act which will facilitate official controls, thereby ensuring proper transmission of the Food Chain Information for traceability and food safety, EU consumers and food business operators benefit. Notwithstanding, the draft Regulation could be improved by clarifying a few points in the document attached. UPDATE OF THE TERMS TUBERCULOSIS AND BRUCELLOSIS The scientific names of tuberculosis and brucellosis were respectively changed to infection with Mycobacterium tuberculosis complex (M. bovis, M. caprae and M. tuberculosis) and infection with Brucella abortus, B. melitensis and B. suis by Regulation (EU) 2016/429 of the European Parliament and of the Council. Commission Delegated Regulation (EU) 2020/6894 sets out the criteria for granting disease-free status as regards infection with Mycobacterium tuberculosis complex and infection with Brucella abortus, B. melitensis and B. suis. That status is to be granted at the level of the establishment where the animals are kept rather than at herd level, pursuant to that Delegated Regulation. Implementing Regulation (EU) 2019/627 refers to animals that have not been declared officially free of tuberculosis and brucellosis. For reasons of consistency, it would be desirable to amend Articles in order to refer to the specific provisions of Regulation (EU) 2020/689 on the disease-free status. DEFINITION OF EVEN-TOED GAME MAMMALS The classification of species falling under the definition of farmed even-toed game mammals posed challenges since the coming into force of Regulation (EC) 853/2004. Major efforts have been made to provide clarity in accordance with Recital 10 of COMMISSION DELEGATED REGULATION (EU) 2021/1374 limiting farmed even-toed game mammals to Cervidae and Suidae. However, Annex I of Regulation (EC) No 853/2004 defines farmed game as farmed ratites and farmed land mammals, other than domestic bovine (including Bubalus and Bison species), porcine, ovine and caprine animals but does not exclude lagomorphs (who have four digits at their hind-legs). The limitation to non-domesticated members of the suborder Ruminantia, Tylopoda and Suina may lead to a clear-cut, simplified, yet more inclusive monitoring approach in this context and provide a legally binding definition. INCLUSIVE LANGUAGE FVE welcomes the opportunity to advocate for the use of inclusive language in this amendment and move from the use of his/her to they. As language evolves, we encourage the consequent adaptation of the terminology used in regulations undergoing amendments.
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Meeting with Salvatore De Meo (Member of the European Parliament, Shadow rapporteur)

16 Jan 2025 · Welfare of dogs and cats and their traceability

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

16 Jan 2025 · Animal welfare during transport

Response to Authorisation of lumiVAST Trichinella for Trichinella testing

1 Jan 2025

The Federation of Veterinarians of Europe (FVE) representing around 330,000 veterinarians across 39 European countries aims to enhance animal health, animal welfare, and public health and to protect the environment by promoting the veterinary profession. FVE welcomes the new equivalent method lumiVAST with an outstanding sensitivity and specificity authorised for the detection in examining samples from domestic pigs from controlled housing for Trichinella while maintaining the sample size requirements of the gold standard. FVE welcomes the opportunity to comment on this act which facilitates the Trichinella diagnostic due to its relatively ease to use and speed compared to methods based on digestion and automatisation, which reduces the risk of human mistakes. Notwithstanding the core considerations could be improved by aiming at a more risk-based testing approach and more coherence with international standards as outlined below. VALIDATION FOR ADDITIONAL SPECIES FVE welcomes this alternative method for domestic pigs, which will be particularly useful for domestic pigs in non-controlled housing conditions, including backyard and free-range husbandry systems. However, we must highlight the need for validated rapid tests for meat from other than domestic pigs, which are known to show positive results in the EU, especially wild boars, to enhance broader applicability. HARMONISATION OF SAMPLE WEIGHTS FVE applauds the harmonised approach of sample sizes to allow for consistent sensitivity and harmonised testing across Member States. However, the risk stems not from the lifecycle stage of the pig but rather from housing conditions. A risk-based revision of the Commission Implementing Regulation (EU) 2015/1375 should be considered to harmonise the sample size from all animals from controlled housing to e.g. 1g, including breeding sows and boars. RISK-BASED TESTING & NEED FOR COHERENCE IN TRADE STANDARDS Commission Implementing Regulation (EU) 2015/1375 states that testing ought to be risk-based and concentrate on pigs kept in housing that do not fulfil the requirement of controlled housing. As a transition, all breeding sow and boar carcasses, or at least 10% of the carcasses from each holding that is formally recognised as controlled housing, must be tested for Trichinella every year. WOAH states that Trichinella-safe trade in pig meat can be established without testing. More coherence with international trade standards is desirable to improve efficiency. ENSURE CAPACITY BUILDING AND MAINTENANCE While equipped laboratories are now widespread, capacity building and resources, where necessary, should be foreseen as the method (i) requires specific apparatuses as the Superflex that need regular maintenance and (ii) does not allow for the morphological identification of the species. In the second step, in case of positive results, suitably trained staff and the gold standard methods must remain accessible and available at the NRLs.
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Meeting with Tilly Metz (Member of the European Parliament, Shadow rapporteur)

11 Dec 2024 · Welfare of dogs and cats

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

21 Nov 2024 · Animal transport

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

6 Nov 2024 · Welfare of dogs and cats and their traceability

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

14 Oct 2024

The Federation of Veterinarians of Europe (FVE) is the u umbrella body for veterinary associations from 38 European Countries. We represent, through our Members, around 330 000 veterinarians working in different fields of the profession, such as veterinary practitioners (UEVP), state officers (EASVO), food safety and veterinary public health (UEVH) and veterinarians working in education, research and industry (EVERI). FVE fully supports the ECCVT proposal for the revision of the EU Directive and Annex V to adapt to the latest developments in veterinary medicine and to promote the mobility of new graduates to better meet the evolving needs of society. The proposed changes are in line with the ECCVT List of subjects and Day One Competences (Annex II of the SOP, page32 https://www.eaeve.org/esevt/sop), which is endorsed and implemented by all 96 EAEVE member Veterinary Education Establishments in Europe. Furthermore, the proposed changes will ensure the new competences in Article 38 are also reflected in Annex V to avoid contradictions and remove some outdated subjects in Annex V. You can find the specific proposals in the attachment. More information on the ECCVT feedback can be found here: https://eccvt.fve.org/eccvt_response_mintrainingreq/ Members of the European Coordinating Committee on Veterinary Training (ECCVT) are the European Association of Establishments for Veterinary Education (EAEVE), the European Board of Veterinary Specialisation (EBVS), the International Veterinary Students´ Association (IVSA) and the Federation of Veterinarians of Europe (FVE).
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Response to Monitoring and reporting of molecular analytical data within foodborne outbreaks

18 Sept 2024

The Federation of Veterinarians of Europe (FVE) representing around 330,000 veterinarians across 39 European countries aims to enhance animal health, animal welfare, and public health and to protect the environment by promoting the veterinary profession. FVE welcomes the general rules that require EU countries to do whole genome sequencing analysis and, during investigations into foodborne outbreaks of infectious zoonotic diseases, report on the analysis results, in line with Directive 2003/99/EC on monitoring zoonoses. FVE welcomes the opportunity to comment on this act which will facilitate investigations into foodborne outbreaks and help find their cause, thereby limiting cases in humans and recalls/withdrawals of food, for EU consumers and food business operators benefit. Notwithstanding the draft Regulation could be improved by clarifying some points and aiming at more coherence with already adopted regulations as outlined in the document attached.
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Response to List of antimicrobials forbidden for cascade use in animals, or authorised for cascade use subject to certain conditions

20 Jun 2024

The Federation of Veterinarians of Europe (FVE) representing around 330,000 veterinarians across 39 European countries aims to enhance animal health, animal welfare, and public health and to protect the environment by promoting the veterinary profession. FVE welcomes the opportunity to comment on this initiative which draws up a list of antimicrobials that must not be used in animals outside the terms of their marketing authorisation; and that may be used in animals outside the terms of their marketing authorisation, subject to certain conditions. FVE welcomes that the implementing regulation takes into consideration the scientific advice of the European Medicines Agency and continues to allow for general rules professionally justified choices to treat animals including uses in accordance with Articles 112 and 113 of Regulation (EU) 2019/6. In general, available alternative antimicrobials should not pose a risk of worsening the resistance patterns (i.e. increased use of other, more critically important antibiotics) or increased use of antibiotics with a risk to potentially increase co-selection), which will have counterproductive results for public health or the environment. Notwithstanding, the draft Regulation could be improved by clarifying some points and aiming at more coherence with already adopted regulations as outlined below. ART. 1 SCOPE Art. 1 shall refer, in line with Recital (5), to food-producing aquatic species and exclude them form the scope of this implementing act. ART. 2 CONDITIONS OF THE USE Art. 2 (1) and (2) The Union Data Base does not yet allow for a sufficient overview of the market authorisation of a veterinary medicinal product authorised in the European Union. The veterinarian must constantly review all market authorisation holders and their products, as delisting of an antimicrobial throughout the EU results in an antibiogram requirement for use in minor species, too. FVE recommends that AST shall be required only for cattle, pigs, chickens, dogs and cats if the listed substances are used outside of the terms of their marketing authorisation. Alternatively, the regulation could require AST solely for substances that are not approved for animals at all, with the exception of cattle, pigs, chickens, dogs and cats. The annex reference to Substances used solely to treat tuberculosis or other mycobacterial diseases" should be narrowed down. The active substances that fall under this group should be spelt out to avoid any legal uncertainty. ART. 3 CONDITIONS OF PATHOGEN IDENTIFICATION AND SUSCEPTIBILITY TESTING Art. 3 (1) The judicious conditions, which veterinarians shall demonstrate to prove that the performance of prior target pathogen identification and susceptibility testing is not possible, must be defined. FVE believes that these conditions include, but are not limited to, if: Sampling would be harmful to the animal (e.g. anaesthesia would be required) Pathogens cannot be cultured in routine systems (e.g. intracellular organisms) No accredited identification methods and/or AST panels or interpretation criteria (e.g. EUCAST breakpoints) are available for the pathogen Art. 3 (1) should read : It shall be deemed that the performance of prior target pathogen identification and susceptibility testing is not possible where the veterinarian responsible can demonstrate that such identification or susceptibility testing is not possible.
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Response to Compartments for terrestrial animals

28 May 2024

The Federation of Veterinarians of Europe (FVE) representing around 330,000 veterinarians across 38 European countries aims to enhance animal health, animal welfare, and public health and to protect the environment by promoting the veterinary profession. FVE welcomes the opportunity to comment on this act supplementing the EU Animal Health Law (Regulation 2016/429). FVE welcomes the general rules that EU countries must follow for the EU to recognise the disease-free status of compartments for terrestrial animals and the specific rules for poultry to prevent and control highly pathogenic avian influenza and Newcastle disease. Notwithstanding, the draft Regulation could be improved by clarifying some points and aiming at more coherence with already adopted regulations as outlined below. COMPARTMENTALISATION APPROACH Art. 3 (1) (d) (i) We acknowledge that the compartmentalisation approach provided for in Regulation (EU) 2016/429 is in line with the international standards of the World Organisation for Animal Health, and in particular Chapters 4.4. and 4.5. of the Terrestrial Animal Health Code. In addition, the understanding of the epidemiological unit definition may be harmonised with the Annex 1 and the Art. 4 of Regulation (EU) 2016/429 a group of animals with the same likelihood of exposure to a disease agent. Art. 5 (3) The kept registers should be ideally digital and sharable between competent authorities within and beyond the issuing Member State. COMPARTMENT MANAGER Art. 3 (2) The compartment manager should be ideally an independent person, qualified in the subject matter, including an appropriate set of technical skills and experience, sufficient knowledge of infectious disease epidemiological and animal disease control concepts. It would be helpful to specify the minimum qualifications required for compartment managers. DISEASE SURVEILLANCE Art. 5 (1) b Freedom of disease demonstration that is complete, up-to-date and accurate can be inherently challenging as this depends on the sensitivity and specificity of the sampling approach and limits of the applied analysis. Disease or outbreak-specific dynamic models including all relevant epidemiological variables where appropriate are useful to calculate conditions and confidence intervals. A specification of requirements would be helpful. Annexe 1, Part I, (c) (iv) The analysis shall be performed by accredited laboratories only. Coherence to the Annex II Part II Section 1, Para 2 (c) which refers to the lab specification for testing to comply with EU Regulation 2017/625 would be helpful COMMON BIOSECURITY MANAGEMENT SYSTEMS Annex 1, Part II Biosecurity management systems are critical for preventing the introduction and spread of harmful biological agents that can affect human health, agriculture, and the environment. While the key elements of biosecurity management systems are covered, a plan providing necessary equipment and human resources for effective biosecurity management would be beneficial. In addition, a contingency plan developing emergency response plans for biosecurity incidents, including training personnel in response protocols and emergency procedures, coordinating with relevant authorities for rapid containment and mitigation as well as establishing recovery plans to restore normalcy post-incident would be beneficial.
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European veterinarians urge stricter limits on animal transport

12 Apr 2024
Topic — Revision of EU regulations to improve animal welfare and safety during transport.
Message — The federation advocates for shorter journeys and rearing animals closer to slaughter locations. They demand a ban on exports to countries with poor welfare protections. They also call for independent veterinary supervision and specific training for welfare officers.123
Why — This proposal would expand the professional influence and oversight roles of European veterinarians.45
Impact — Maritime transport operators face financial losses from the mandatory phasing out of sea exports.6
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Response to Evaluation of the European Food Safety Authority (EFSA) 2017-2024

8 Apr 2024

The Federation of Veterinarians of Europe (FVE) representing around 330,000 veterinarians across 38 European countries aims to enhance animal health, animal welfare, and public health and to protect the environment by promoting the veterinary profession. FVE appreciate the opportunity to contribute to the discussion and evaluation of the functioning of the EFSA consultative process. FVE is grateful to be part of the Stakeholder Forum, and to sit in the StaDG-ER and to be an invited expert for several welfare opinions (transport and cattle). The FVE strongly supports EFSA's mission and goals in underpinning EU regulations with scientific evidence and recognises the crucial role EFSA plays in safeguarding public health and ensuring the safety of the food chain. In the document attached, FVE listed suggestions to improve NGO involvement.
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European veterinarians urge better implementation of animal health visits

3 Apr 2024
Topic — The EU is evaluating if current animal health rules remain fit for purpose.
Message — The organization calls for more consistent implementation of mandatory animal health visits. They also demand streamlined paperwork to reduce administrative burdens on practitioners.12
Why — Reducing administrative requirements would improve service quality and veterinary mental well-being.3
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Response to Welfare of dogs and cats and their traceability

14 Mar 2024

The Federation of Veterinarians of Europe (FVE) and the Federation of European Companion Animal Veterinary Associations (FECAVA) welcome the EU proposal for a Regulation on the welfare of dogs and cats and their traceability. For many years, FVE has been advocating for European legislation to protect the welfare of dogs and cats including mandatory identification and registration. The sharp rise in demand for dogs and cats in recent years has led to an enormous increase in trade within and beyond the EU and ownership of these animals, exacerbated by the COVID-19 pandemic. The protection of the welfare of these animals is unsatisfactory due to differing animal welfare standards within the Member States, such as on breeding and keeping of dogs and cats, which results in high numbers of illegal trade. Therefore, harmonised EU rules on breeding and placing on the market of these animals and the establishment of minimum animal welfare standards is an important step towards better animal welfare, improves competent authorities monitoring of breeding, keeping and trade and enables owners to verify the origin of their future dog or cat. However, FVE and FECAVA call on the European institutions in some respects to go further, to ensure that 1. The welfare of all these animals is protected 2. All dogs and cats will have mandatory identification and registration and 3. The fight against the illegal trade of dogs and cats is enhanced. Please see our specific comments in the document attached.
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Response to Rules on appropriate measures to ensure effective and safe use of veterinary medicinal products for oral administration

10 Jan 2024

The Federation of Veterinarians of Europe (FVE) represents around 300,000 veterinarians across 38 European countries. FVE aims to enhance animal health, animal welfare, and public health and to protect the environment by promoting the veterinary profession. Todays livestock husbandry practices include the rearing of animals for food production in groups of similar-aged individuals, often stemming from different litters on farm or even origins. Major efforts have been made by the veterinary professionals and auxiliary animal health professionals to reduce the need for antibiotic use in farmed animals, resulting in a 53% decrease of antimicrobial veterinary products sales in the European Union between 2011 and 2022 (https://www.ema.europa.eu/en/documents/report/sales-veterinary-antimicrobial-agents-31-european-countries-2022-trends-2010-2022-thirteenth-esvac-report_en.pdf). Yet, animals can become sick even under the best rearing conditions and may need to be treated. Therefore, oral medication remains an imperative! For species like pigs, poultry and aquatic animals, which are often kept in groups, it is challenging to separate and treat individual animals, as repeated catching, contention and isolation is burdensome and stressful to gregarious animals. Furthermore, veterinary medicinal products formulated for individual treatment are less available for these species, and availability and administration routes very much differ between countries. However, if oral medication is used inappropriately, undesirable effects may occur impacting animal health and welfare, public and occupational health. Some Member States established and implemented blueprint guidelines for oral medication, such as Germany (https://www.bmel.de/SharedDocs/Downloads/EN/_Animals/Leitfaden-Orale-Medikation.pdf?__blob=publicationFile&v=2), which manage the associated risks successfully. The Federation of Veterinarians of Europe welcomes therefore this important initiative that introduces rules for veterinarians and animal keepers for the oral administration of veterinary medicines mixed in with water, milk or feed. Notwithstanding, the draft act could be improved by clarifying some points and aiming at more coherence with already adopted regulations as outlined in the document attached.
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Response to Uniform rules on the size of small immediate packaging units for veterinary medicinal products

15 Dec 2023

The Federation of Veterinarians of Europe (FVE) FVE represents veterinary organisations from 38 European Countries and veterinarians working in all different Sectors and strives to enhance animal health, animal welfare, public health and the protection of the environment by promoting the veterinary profession. FVE welcomes uniform rules on the size of small immediate packaging units intending to contribute to reducing the administrative burden for marketing authorisation holders, improving the functioning of the internal market and increasing the availability of veterinary medicinal products in the Union. Although there is a 60-month compliance window, it will be of utmost importance to avoid a cease of products, especially old and low-volume products, due to the costs of changing packaging units. The transition period should be coherent with other regulations, that imply changes of VMP packaging. In the future, e-leaflets may offer additional opportunities for small immediate packages.
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Response to List of abbreviations and pictograms to be used on the labelling of veterinary medicinal products

15 Dec 2023

The Federation of Veterinarians of Europe (FVE) FVE represents veterinary organisations from 38 European Countries and veterinarians working in all different Sectors and strives to enhance animal health, animal welfare, public health and the protection of the environment by promoting the veterinary profession. FVE welcomes the use of common abbreviations and pictograms to reduce the text on the labelling of veterinary medicinal products and facilitate the use of multilingual packaging. To assure public and animal health, it is of utmost importance that the abbreviations and pictograms used on veterinary medicinal products are unambiguous and understandable for retailers, veterinarians and animal keepers. Given the constant progress in the development of veterinary medicines, it would be beneficial to envisage regular updates and amendments of the Implementing Act or an alternate format as well as pictograms for every species which has and will have a product licensed for it, as applicable (e.g. different fish species, game- and waterfowl species, or ferrets).
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Response to Waste Framework review to reduce waste and the environmental impact of waste management

22 Nov 2023

Veterinarians are committed to sustainable food systems by assisting and supporting farmers in preventing and reducing food losses and food waste (FVE position paper- Veterinarians commit to sustainable food systems - https://rb.gy/e6d9iq) Veterinarians of Europe are well aware of the 59 million tonnes of food waste (131 kg per inhabitant) generated annually with a market value of around 132 billion euros. For this reason, FVE supports the European Commissions ambition to further address the reduction of food waste across supply chains, thus contributing to the implementation of the United Nations (UN) Sustainable Development Goal (SDG) 12.3 to halve per capita food waste at the retail and consumer level by 2030. Generally, veterinarians have an important role to play in reducing waste in agri-food production and distribution because of our expertise and influence in the livestock sector. This includes promoting improved animal genetics, animal feed, animal housing (structural factors) and husbandry (routines), biosecurity, prevention and appropriate medical treatment of diseases, food safety assurance systems and hygienic food processing for food safety and durability, and delivering a vital role in underpinning international trade in products of animal origin (POAO) so that food supply chains work effectively to minimise waste. FVE recognise that a well-managed surplus of food production enables the food and feed supply chain to respond to variations in harvest yields and other disruptive events to prevent absolute and geographical shortages of food for the citizens and feed for the animals. FVE therefore recommend that activities and targets for waste reduction must be considered carefully within the global agri-food system. FVE is also supportive of improved labelling (date marking) as well as for circular economy since food waste reduction is not only a social and environmental responsibility but also an economic opportunity. However, FVE noticed that there is a need for a clear food loss definition that can make the overall goal clearer. In addition, FVE calls for: Ensure that the legislative proposal is consistent and aligned with the other EU policies (e.g., labelling, climate action, Common Agricultural Policy) in particular the future EU Framework for Sustainable Food Systems and with the foreseen development of sector-specific European Sustainability Reporting Standards (ESRS);. Acquire more reliable data on food waste from food processing and manufacturing, as well as improve definitions of food waste and animal by-products; Promote safe bio-circularity of waste resources; Consider that the targets should allow for a certain degree of flexibility to avoid downscaling European production, reducing our food security and competitiveness vs imports; Support opportunities to further facilitate and raise awareness about the possibilities to redistribute the surplus food by promoting local or regional food hubs; Support MSs in developing specific guidance on food waste measurement at a national level to consistently interpret food waste data and reporting requirements as set in the Delegated Act on Food Waste Measurement; Support MSS in exchange for best practices and reduce food waste at the EU and also at a global level. Please open the full document attached.
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Response to Cross-contamination levels and analytical methods for antimicrobials in feed

9 Nov 2023

The Federation of Veterinarians of Europe (FVE) is the umbrella organisation of the veterinary profession with members in 38 European Countries and represents veterinarians working in all fields of the profession. FVEs mission is to enhance animal health, animal welfare, public health and protect the environment by promoting veterinary medicine and the veterinary profession. FVE appreciates the balanced approach taken towards establishing maximum levels of cross-contamination for listed antimicrobial active substances in non-target feed and methods of analysis, along with the proposed methods for analysis and minimum achievable levels of quantification (LOQ) for these antimicrobial active substances in feed. The rise of antimicrobial resistance (AMR) has become a European and global health threat. While total antimicrobial sales in animals in Europe have almost halved in the last decade, FVE recognises the need for continued action, joint forces, and ongoing efforts in order to preserve existing antimicrobials efficacy for the future treatment of humans and animals alike and to sustainably balance and optimise the health of people, animals and ecosystems. FVE underscores the preference for individual treatment over group treatment whenever feasible. However, it is essential to acknowledge that in specific scenarios, such as involving groups of animals living in the same epidemiological unit together, collective treatment may be essential. This occurs particularly in the context of pig, poultry and fish farming. In certain cases, the administration of oral medication can be the safest and most effective method to combat infections, especially when other routes of administration are unavailable or unsuitable. It should be up to the veterinarian to decide, prescribe and communicate the optimum way and conditions to administer antimicrobials. Whilst FVE acknowledges the importance of preventing cross-contamination, it is vital to not be blind to the economic investment and logistic costs associated with these measures. Overly stringent regulations in this regard may render small and medium-sized feed manufacturing plants unable to produce medicated feed, potentially harming animal health and welfare. Consequently, FVE welcomes establishing a maximum level of cross-contamination that is stringent but also feasible to achieve by applying good practices to minimise cross-contamination to maintain medicated feed as treatment option, where indicated by veterinary prescription. Establishing a sampling plan and a staged evaluation approach of samples from a defined time period for large scale manufacturers will be beneficial, e.g. following the approach of Commission Regulation (EC) No 2073/2005 on microbiological criteria for foodstuffs. To facilitate a smooth implementation for feed manufacturers in complying with the new regulations, FVE recommends providing them with an appropriate transition period of at least 12 months. This will help ensure that the industry can adapt and meet the necessary requirements while continuing to provide effective medicated feed options.
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European veterinarians demand EU resources for profession's mental health

2 Feb 2023
Topic — New EU initiative addressing mental health promotion, prevention, and policy integration across Europe.
Message — The FVE urges the Commission to recognize veterinary mental well-being as a public health issue. They request specific resources to tackle high levels of burnout and work-related stress.123
Why — This would provide necessary funding and institutional backing to improve veterinary occupational health.45
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European veterinarians demand stricter antimicrobial rules for food imports

23 Dec 2022
Topic — Regulation banning specific antimicrobial use in animals and animal products imported to Europe.
Message — The federation insists that all imported animal products meet European health standards. They also recommend better training for inspectors and clear penalties for violations.12
Why — Equal standards prevent imported products from having an unfair advantage over EU producers.3
Impact — Non-EU exporters will face increased costs and potential delays due to certification.4
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European Veterinarians Urge Phase-Out of Long Sea Animal Transport

6 Dec 2022
Topic — New requirements to verify animal welfare compliance on livestock vessels during transport.
Message — FVE recommends phasing out long sea journeys while strengthening inspections and veterinary supervision. They demand independent animal welfare officers on board and strict vessel technical standards.12
Why — This proposal grants veterinarians greater authority and oversight over sea transport operations.3
Impact — Exporters and vessel owners face increased costs and the eventual total ban.4
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Response to EU strategic Framework for Global Health

16 Sept 2022

The Federation of Veterinarians of Europe (FVE) is representing the veterinary profession in Europe. Veterinarians contribute to overall public health by ensuring animal health and safe food for people. In that respect, FVE has at the heart of our mission the promotion of animal health and welfare, the important contribution to public health and the protection of the environment, which makes us leading advocates of One Health in the EU. FVE, therefore, welcomes in particular that the EU reiterates its commitment to bring forward a strategy based on human rights and health equity as well as highlighting the importance of the interconnection between people, animals, plants, and their shared environment (the ‘One Health’ approach). Further to this, the EU must facilitate and promote cross-sectoral collaboration at all levels to enhance the health and wellbeing of European citizens by strengthening both healthcare and veterinary visits, in particular by supporting the implementation of regular veterinary visits in farms as foreseen in the EU legislation (EU 2016/429). One Health approach is also fundamental in proper crisis preparedness and response to different public health threats, such as infectious and non-infectious diseases, foodborne diseases, etc. Ensuring the availability of safe food contribute to both the health and wellbeing of people. Most farms are located in rural areas. It is therefore important that the EU strives to support rural development via appropriate policies as well as overall policies on employment and social affairs. Such policies should equally encompass incentives for medical and veterinary healthcare in such remote areas (More information on https://fve.org/shortage-of-veterinarians-in-rural-remote-areas/) Implementation of One Health and cross-sectoral collaboration need proper education at all levels. FVE has indicated the need for developing a One Health culture in education and training - https://fve.org/promoting-one-health-in-the-professional-practice/ - to facilitate interdisciplinary collaboration in practice. Further to this, FVE is the first to give the example together with our counterparts - the European doctors. The two organizations have since long established an ongoing collaboration striving to facilitate understanding One Health understanding and promote intersectoral collaboration in practice (More information on https://fve.org/cms/wp-content/uploads/CPME-FVE.Memorandum_of_Understanding_2022_FINAL_.pdf) FVE highlights that the EU should give priority above all to “Apply the 'One Health' approach comprehensively”, as this action will affect the level of success for any other action to be taken. Additionally, the EU should lead discussions internationally with confidence by promoting our European values and regulatory frameworks that place the EU as a best practice region in the world. EU should engage with interdisciplinary representation in all international forums and initiatives and be a leading advocate of One Health and use transparency, open-minded decision-making on fit-for-purpose health solutions. FVE remains at your disposal for a further contribution where appropriate.
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Response to Use of veterinary medicinal products for diseases in terrestrial animals

2 Sept 2022

The Federation of Veterinarians of Europe (FVE) welcomes the opportunity to comment on this consultation. FVE welcomes this proposal for a Regulation allowing the use of veterinary medicines, including importantly vaccines, for the control of certain listed diseases in the Animal Health Law. FVE has been widely advocating for the benefits of vaccination in animals. Vaccination of animals against diseases greatly contributes to animal health and welfare as well as to public health and human well-being. Vaccines are very important instruments in the veterinary toolbox (https://www.fve.org/cms/wp-content/uploads/Vaccination-of-animals-Veterinary-Act.pdf). The wide implementation of vaccination and when used together with other best practices - such as proper biosecurity, good housing, husbandry and nutrition, genetic selection and regular health checks of animals by a veterinarian - can prevent diseases, reduce the need to treat with antibiotics, ensure sustainability and contribute to maintaining good human and animals health (https://fve.org/cms/wp-content/uploads/061-AHL-visits_adopted.pdf). Seen the devastating losses experienced recently in Europe, due to highly pathogenic avian influenza (HPAI) outbreaks, FVE highlights the need for ensuring the availability of authorised vaccines throughout the European Union and underlines the importance for their responsible use (see EPRUMA https://epruma.eu/wp-content/uploads/2019/04/Best-practice-framework-on-vaccines_23-APRIL-2019.pdf). Challenges remain with correct handling, correct administration, vaccine hesitation movement as well as trade-related issues.
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Response to New requirements for transport and storing of fishery products.

31 May 2022

The Federation of Veterinarians of Europe (FVE) - representing around 300 000 veterinarians across Europe - welcomes the EU Commission Delegated Act amending and correcting Annex III to Regulation (EC) No 853/2004 and amending Commission Delegated Regulation (EU) 2019/624 as regards certain bivalve molluscs. Concerning the Chapter I of Section X of Annex III to Regulation (EC) No 853/2004 laying down hygienic rules for the production and minimum durability (a best before date) for eggs, FVE notices that the EFSA panel “recommends conducting further studies on risk assessment exploring the effect of different temperatures of storage of eggs on the risk posed by egg borne pathogens such as S. Enteritidis, and to investigate the occurrence and control of microorganisms during industrial production of egg products, including pasteurisation, if the storage of eggs is prolonged, and suggests a re-evaluation of the current chemical indicators, considering the possibility of using more relevant ones”. Therefore, considering that some countries have a recognized negligible risk for Salmonella spp. (Norway, Finland, Sweden, Denmark), FVE would like to point out that longer shelf life for table eggs should be considered for these countries. FVE asks to consider this point carefully as the outcomes are threefold: 1 - preserving the EU legislation risk-based approach; 2- ensuring sufficient flexibility; 3 - rewarding countries that have a recognized low prevalence of Salmonella spp. and cooling systems for transport and storage of eggs.
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Veterinary federation supports science-based human-only antimicrobial list

16 May 2022
Topic — The European Commission is listing specific antimicrobials reserved exclusively for human use.
Message — They advocate for science-based assessments instead of political bans of antimicrobials. The group requests specific derogations for companion animals and endangered species.12
Why — This ensures veterinarians can continue providing care without facing restrictive medicine bans.3
Impact — Animals and owners suffer if life-saving medicines are banned without clinical justification.4
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Response to Recommendation for strengthened actions against antimicrobial resistance

22 Mar 2022

FVE welcomes the European Commission’s call for evidence without an impact assessment on antimicrobial resistance (AMR). Such an EU action should encompass a holistic and balanced ‘One Health’ approach that puts emphasis on safeguarding human health by ensuring animal, plant and environmental health. While antimicrobials include antibiotics, antivirals, antifungals and antiprotozoals, the threat stemming from the resistance to antibiotics is of FVEs utmost importance. FVE highlights that over the last years a lot of efforts have been made and an important amount of science-based evidence has been collected on AMR and potential transmission between animals, humans and the environment. That would provide the necessary background for an informed Council recommendation on One Health actions and initiatives to fight AMR. The political context of this initiative correctly acknowledges a series of actions taken within the European Health Union but disregards the important contribution the new veterinary regulations will have on human and animal health. Both the Regulation on veterinary medicinal products (EU) 2019/6 and the Regulation (EU) 2019/4 on manufacture and placement on the market of medicated feed introduce a multitude of provisions to support prudent and responsible use of veterinary medicines and ensure safety of public health. While recent scientific, technological, societal and policy developments – both at EU and global level – show the need to improve our response to AMR, we must be clear on the target such an initiative aims to tackle. The ultimate goal remains to reduce antimicrobial resistance. Setting targets therefore must encompass a balanced and holistic approach via coordinated actions fully in line with the One Health concept. That being said, we have to acknowledge that AMR in humans is mainly driven by the mis- and overuse of antibiotics in humans and by suboptimal hygiene practices in healthcare settings. Cassini et al. (2019) estimated that about 75% of the total burden of infections with antibiotic-resistant bacteria in EU and EEA countries (i.e., 127 DALYs per 100 000 population) were associated with health care. Adequate infection prevention and control measures, as well as antibiotic stewardship in hospitals and other healthcare settings and more public transparency on AMR data in hospitals and other healthcare settings are therefore essential to reduce the burden of AMR in humans. AMR has also a global dimension, which is rightly indicated in this call for evidence. In that respect it must be recognised that European Union has succeeded to become a best practice region worldwide, especially as regards farming practices and food safety. Whereas the over- and misuse of antimicrobials in animals has been identified as an additional driver for AMR, it is particularly important to ensure that the safety of food on the plate of European citizens is always of the same quality. As specified in the Regulation, the EU should prohibit the import of animal products coming from animals subjected to unregulated use of veterinary medicinal products. Further to this, it has to be acknowledged that ‘One Health’ approach provides opportunities for better prevention from health threats in humans through better management of animal health. That is why we need new economic models and incentives for the development of - both therapeutics and preventive tools, - rapid and accurate diagnostics – including novel pen-side, fast-tracked, inexpensive antimicrobial susceptibility testing methods, - alternative therapies to antimicrobials, that holistically address health issues and equally ensure availability of tools for diagnosis and treatment in animals and humans. A better collaboration between the future AMR roadmap and the Common Agricultural Policy to support investments in prevention is needed. FVE agrees on the practical need for EU action that will encompass a holistic and balanced approach.
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Response to Application of EU health and environmental standards to imported agricultural and agri-food products

16 Mar 2022

The Federation of Veterinarians of Europe (FVE) - representing around 300,000 veterinarians across 38 European countries - aims to enhance animal health, animal welfare, public health and to protect the environment by promoting the veterinary profession. FVE welcomes this proposal and favours the implementation of a strong reciprocity policy in the EU trade with third countries, especially in light of the reinforcement of the EU legislation in respect to veterinary medicines and animal welfare. FVE also supports the objective of the French Presidency to strengthen coherence between the Green Deal, the Common Agricultural Policy, and trade policy to support the transition towards sustainable food system. Successful examples already exist, such as the ban on the import of animals and products derived from animals to which antimicrobial growth promoters have been administered; the Sanitary and Phytosanitary (SPS) measures that allow to refuse the entry of food when MRLs are exceeded; and the soon to be adopted antimicrobials reserved for human health, as laid down in Regulation (EU) No 2019/6, Art. 118. The EU has also already successfully concluded a number of bilateral free trade agreements with partner countries and regions across the globe. FVE supports that all import requirements laid down in the EU law should be firmly rooted in science and subject to a risk assessment to fully understand the benefits for health and the environment. Negotiations with WTO will also be needed. Unilateral measures in trade have to be carefully assessed. Specific provisions have to be integrated in the different EU laws, e.g. in legislation on animal welfare at the time of killing and animal transport in line with the objectives of Green Deal, Farm to Fork Strategy, EU Action Plan on Antimicrobial Resistance and linked policies, where applicable. The ongoing revisions of several pieces of EU legislation (i.e. those ones on feed additives, animal welfare, food labeling, pesticides, veterinary medicines and the Trade Policy Review) provide an opportunity for increasing sustainability, but specific provisions should be carefully assessed when it comes to setting a common baseline, to ensure fairness and allow for proper implementation and enforcement in the EU. Reciprocity policy cannot work without a strong control plan. A robust control system should be set up in the country of origin, allowing for full traceability without too excessive burden on the national as well as on EU control authorities. Responsibilities should also be well defined, e.g., who is responsible for checking and who will pay for the controls in the EU Member States, while rules should maintain fair trade conditions for all, including small and medium producers.
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Response to Format for the collection of data on antimicrobial medicinal products used in animals

20 Dec 2021

FVE welcomes the possibility to provide comments on the annex of the upcoming implementing act establishing the format of the data to be collected and reported in order to determine the volume of sales and the use of antimicrobial medicinal products in animals in accordance with Regulation (EU) 2019/6. FVE believes that actions have to be taken to avoid double reporting of use data - Correction of the data reported in relation to movements of animals or exports to other MS. Please see the attached PDF for details.
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Response to Sustainable food system – setting up an EU framework

26 Oct 2021

The Federation of Veterinarians of Europe is committed to leading the transition of food systems towards a more sustainable way of producing and processing food. FVE fully shares the main objective of the Farm to Fork Strategy however, as part of the European Green Deal, the Farm to Fork Strategy should approach the climate and environmental-related challenges considering and making proper use of the developments and outcomes achieved in the livestock sector (e.g., reduction of the use on antimicrobials as for 34%, increased animal and welfare standards, the role of TRACES as a leading certification system of the European Commission, the European legislation and the role of veterinarians in contributing to the EU food as a global gold standard). Ref.: Council Conclusions on the Farm to Fork Strategy - Council Conclusions (19 October 2020) - https://data.consilium.europa.eu/doc/document/ST-12099-2020-INIT/en/pdf Therefore, FVE calls on the Commission to: 1. Further refine and align the F2F targets and indicators to common metrics (e.g., global indicator framework for Sustainable Development Goals and the 2023-27 EU CAP nine key objectives) when it comes to GHG emissions, agricultural and farming practices, circular economy and animal welfare standards to help and assist the agricultural sectors in the transition towards the F2F objectives; 2. Consider that prevention is better than cure – greater investments in prevention, in research and scientific advances, are key to improve the health and welfare of animals; 3. Apply a One Health approach which remains essential in preventing animal diseases, protecting the environment and the health of people; https://fve.org/animal-health-visits-add-value/ 4. Implement Article 25 of the European Union Animal Health Law, Regulation 2016/429, that empower animal health visits as a crucial tool to improve livestock health, enhance economic efficiency and sustainability, as well as to reduce the use of antibiotics; 5. Further set up subsidies/taxation policies to move towards a balanced approach assisting farmers, fishermen and aquaculture producers. Concerning the policy options Commission will assess, FVE suggests giving priority to the following: 1. Advising and supporting farmers through the transfer of knowledge, skills, and competencies; 2. Applying innovation and effective technologies throughout food supply networks; 3. Providing scientific support to policy-makers and decision-makers; 4. Implementing and enforcing the current EU legislation; The ultimate goal should be the co-creation of healthy economic growth and fair social development while strengthening and making the current EU food systems more effective.
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Response to Animal welfare labelling for food

20 Aug 2021

The Federation of Veterinarians of Europe (FVE) represents the veterinary profession in Europe. Members of FVE are national veterinary associations or chambers and through them FVE represents about 300 000 veterinarians in 39 countries. The veterinary profession is a multidisciplinary sector and veterinary medicine has a broad field of practice. That is also reflected within FVE, which also embraces 4 sections, each one of which represents a vital part of the profession, namely the practitioners, the Hygienists – Public Health Officers, the Veterinary State Officers and the veterinarians working in Education, Research and Industry. FVE strives to enhance animal health, animal welfare, public health and protect the environment by promoting the veterinary profession. Together with its members, FVE aims to support veterinarians in their daily practice. FVEs main comments • Animal welfare is increasingly recognised and gained great importance in our society. FVE believes that the current legislation needs to be updated to incorporate scientific advances in our understanding of animals and technical progress in farming practices, as well seen in a broader environmental, societal, and sanitary context. Changes must be made after scientific evaluation and with a view to meeting citizens’ needs, with due account for consumers’ choices and purchasing power. • The existing legislation was found to be broadly consistent with legislation on animal health, although it could be better integrated with other EU policies. As to the regulatory framework, the gaps that existed in 2012 remain, notably for the protection of certain farmed species for which no rule exists at EU level. In addition, the need to simplify existing rules and to improve their enforceability continues to be relevant. The new Animal Welfare legislations need to specify clear and concise objectives and indicators based on scientific evidence. • EU AW legislation has had positive effects especially also to bring countries more on the same level. However, some directives/regulations were more successful than others. The 95/58/EC is too general, it certainly is the basis of most national animal welfare acts, but would be worth checking how much they are based on it. Upgrading the general Directive into a clear Regulation could enhance standards uniformly in the EU, including the welfare of farmed animals. • The Transport Regulation needs revision as some critical issues compromised had to be made e.g. transport regulation taking over journey times and space allowances because no compromise could be reached. There are also problems with different pieces of EU legislation not being inline which each other, e.g., travelling times, animals and drivers hours. Furthermore, the enforcement of the Transport Regulation in third countries to the EU is almost impossible. The vague terminology does not allow for a harmonised interpretation, there is a lack of harmonised sanctions system and a lack of species-specific and category-specific provisions (e.g., fragile animals). • There are differences in the interpretation of the derogation to mandatory stunning and emergency killing and culling for disease control. All terms like ‘appropriate, sufficient, etc’ should be avoided in the legislation as varying interpretation of practices at slaughter challenge and compromise animal welfare significantly.
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Response to Good pharmacovigilance practice for veterinary medicines

7 Jun 2021

FVE welcomes the release of the draft proposal of the European Commission for the better regulation of the implementation of the Good Pharmacovigilance Practice (GPVP) via this implementing act. However, some points may need more attention, namely - Ref(7): The calculation of incidence (frequency and seriousness) of adverse events should allow for the comparison of different products, product groups or different periods for the same product. It is unclear what is meant by the term “different products”. Please include a definition of the term “different products”. - Art (NEW):The scope of the IA is not very clear. GPVP should include elements to promote good reporting, especially by veterinarians and other health professionals, and also to highlight the responsibilities of the competent authorities. FVE suggests including an article defining the scope of this act clearly. - Art 1: Add a new paragraph with a definition of “different products”. - Art 11: A medicinal product is composed of both the active substance and the excipients. Pharmacovigilance should apply for all the ingredients. We suggest a change in the text as following: “... their medicinal products, as well as active substance and excipients, and suspected ...” - Art 12, § 2(c): The scope of the act should be clear and concise also concerning the class/type of products it addresses. It would be weird that MAHs for veterinary medicinal products are asked to record the adverse events of human products. Nevertheless, we note that it is important to record adverse events associated with the use of human medicinal products in animals, e.g. national competent authorities could be tasked with the recording of this data. - Art 12, § 3: A medicinal product galenic formulation is composed of both the active substance and the excipients. We suggest a change in the text as following: “... name of the active substances and excipients shall be recorded...”. Please see similar comment above. - Art 12 (NEW): The veterinarians have a very important and responsible role in initiating a signal by reporting and additionally in supporting the investigation of each individual case. They have therefore to ensure that they are part of the GPVP process and have also to be in some way compensated for the time and effort they dedicate to contribute appropriately to the process, identifying, interpreting and reporting the possible adverse event of a veterinary medicinal product that was applied to an animal or group of animals according to his/her praxis. The IA should integrate incentives, such as the way that veterinarians should be compensated. - Art 13, § 3: We suggest a change in the text as following: “...active substance and excipients, type ...”. Please see similar comment above. - Art 17, § 4: Same comment as above. We suggest a change in the text as following: “...at active substance and excipients level and stratified analyses.” - Art 20, § 1: Communication about pharmacovigilance should specifically target the veterinarians as they are the prescribers. The other professional groups are secondary audiences. We suggest a change in the text as following: “Marketing authorisation holders shall have an overarching communication plan to inform primarily veterinarians who are the prescribers. They should also have a plan that identifies the other relevant stakeholders in the Union, such as other healthcare professionals, customers...” - Art 20, § 2(g): This point should be performed in priority. We suggest that it is mentioned as point Article 20, § 2(a). - Art 20, § 2(NEW): Feedback to veterinarians is another important incentive for veterinarians to motivate them in reporting any adverse event. We suggest adding a point as following: “(i) ensure feedback to the veterinarians and other health professionals about the outcome of their reporting in all cases.”
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Response to EU rules on official controls - update to allow controls of imports for the use of certain antimicrobials

5 May 2021

The Federation of Veterinarians of Europe (FVE) is the umbrella body for veterinary associations from 39 European Countries, representing around 300 000 veterinarians in Europe. FVE welcomes the proposal for a regulation - COM(2021)108. We very much agree with the need to modify Article 1(4)(c) of the Official Controls Regulation to allow controls to verify compliance with Article 118 of Regulation (EU) 2019/6. These controls are needed to ensure compliance of imports with the prohibitions laid down in the Veterinary Medicines Regulation - Article 118 (referring to art 37(5) - antimicrobials reserved for human use only and Art 107 (2) - use of antimicrobials for growth promotion or yield increase)). The proposed Regulation is necessary for the proper functioning of Regulation (EU) 2019/6. It is important that products or animals imported into the EU comply with the same standards we use for animal production in the EU. Not only does this help to create an equal playing field for our farmers on the European market, but it also aims to set an example of responsible and prudent use of antimicrobials worldwide.
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Response to Establishment of Criteria for the designation of antimicrobials reserved for human use

23 Apr 2021

FVE, the Federation of Veterinarians of Europe, welcomes the opportunity to give feedback on the Draft Delegated Act (DA). FVE is the umbrella body for veterinary associations from 39 European Countries, through our members, we represent around 300 000 veterinarians. This is an extremely important Act for veterinarians as it has the potential to limit the already very limited therapeutic toolbox veterinarians have to treat animals. Animals are sentient beings and deserve treatment too. When animals suffer a bacterial disease, treatment is a “medical act” to alleviate the health consequences and improve their welfare, not a productivity tool. Further to this, treatment of any bacterial disease in animals prevents the spreading of disease to other animals and/or people (for zoonotic bacterial diseases). Banning antimicrobials for use in animals is one of the most severe AMR risk management measures possible, and should be used with the greatest caution. We urge policymakers to use this only based on robust scientific evidence on the benefit for human health. FVE believes that the most effective way to fight antimicrobial resistance is to ensure the prevention of disease in order to avoid the need to treat animals and humans with antimicrobials, while ensuring prudent and responsible use, e.g. by using as much as possible the bacterial culture and antibacterial susceptibility testing (C&AST). FVE remains concerned over this Draft Delegated Act for the following reasons: 1. The “One Health principle” recognising that humans, animals and the environment are interconnected is overall ignored; 2. Animal health and welfare are not thoroughly considered; 3. Some new paragraphs deviate from the EMA advice and lack the support of sound scientific evidence; 4. Certain crucial terminology is unclear and vague; 5. This act will limit innovation and eliminates any incentive to authorise new antibiotic classes for animals in the future. You can find further details in the document attached.
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Response to Authorisation to feed poultry with processed animal protein derived from farmed insects or domestic porcine animals

6 Apr 2021

FVE welcomes the Commission proposed legislation to reintroduce porcine PAPs in poultry feed, avian PAPs in pig feed and introducing insect PAPs in pig and poultry feed. This proposal is based on the scientific evidence and on the EFSA advices. Porcine and avian PAPs represent a valuable source of highly digestible proteins and may contribute in reducing the reliance of the EU livestock feeding system on alternative proteins from third countries while advancing the EU circular agriculture. As regards insect PAPs, FVE would like to emphasize the following:  Definition A definition of “farmed insects” should be taken into account. Such definition should be as broad as possible since many more insects may serve as feedstuff and as a foodstuff soon;  Feeding insects It should be considered that insects could also be fed with insect PAPs. This can be done perfectly respecting the intra-species feeding ban (e.g., black soldier fly is a feedstuff for mealworms). The most interesting species like crickets, black soldier fly and mealworms are omnivorous while some local species of insects (e.g., grasshopper Ruspolia differens in East-Africa) grow much better in captivity if they prey on other insects.  EURL validated method Detection methods for insect PAPs are under development. Any validated method needs to be put in place in advance of any legislation adoption. FVE believes that more research & development should be supported in creating protocols for molecular verification of permitted insect species and confirmation of the absence of unpermitted species using, for example, real-time PCR or sequencing technologies to complement or replace the use of light microscopy.  Cross-contamination Keeping feedstuff production for ruminants and non-ruminants apart remains crucial. Therefore, when a slaughterhouse operates both types of animals - amendment, p. 5 (1) - FVE suggests considering applying appropriate hygiene and safety measures (e.g., FBOs should change clothes, gloves, boots, apron and utensils need proper cleaning and disinfection).  PAPs processing lines separation Keeping insect PAPs production lines separated from porcine and avian PAPs production lines are crucial (Section F (a) p. 5). A further precaution would be applying a separation between insect pure PAPs processing lines and those other than insect PAP processing lines. This would enable larger manufacturing enterprises to produce insect PAP properly. While FVE welcomes the opportunity to consider the improved use of insect protein, particularly in animal feed, appropriate HACCP processes must be incorporated, as for other food/feed supply network operations.  Market distortions By allowing insect PAPs for pig/poultry there might be a shift in the EU market and competition. This may increase the demand for insect PAPs for poultry and pig or even increase the supply of pig/poultry meat compared to other livestock supply meat. Insect and avian/porcine PAPs potential importers into the EU should also comply with the EU production and control regime. Besides, the ability of operators and of processors to comply with any further legal requirements and to manage the costs should be duly considered.
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Response to Update of the Reform Recommendations for regulation in professional services

31 Mar 2021

FVE comments to the DG GROW roadmap on Regulation of professional services - update of reform recommendations to the Member States FVE acknowledges the publication of the DG GROW - Update of the reform recommendations for regulation in professional services – aiming to issue an update of the guidance on specific professions to certain Member States as to civil engineers, architects, accountants, lawyers, real estate agents, tourist guides, patent agents and notaries. FVE agrees that the digital transition and the recovery from the COVID-19 crisis are key priorities however, as regards the veterinary profession, FVE wants to restate the following: - The veterinary profession is a liberal profession practised on the basis of professional qualification, in a personal, responsible and professionally independent capacity. Veterinarians provide intellectual and conceptual services; - The veterinary profession is a health profession aiming to protect animal health & welfare, public health and the health of the ecosystems; - The veterinary profession is a regulated profession. Pre-requisites for being a member of the veterinary profession lay down in acquiring a relevant professional qualification, getting a licence to practise and keeping continuing professional development up-to-date; - The statutory bodies or the Competent Authorities allow graduates to access the profession, supervise their professional behaviour and ensure that they comply with the standards of good veterinary practice and professional ethics. In most countries, these standards are laid down in a Code of Practice. For FVE policy on this issue, please consult the following policy: • European Veterinary Code of Conduct • Regulation of the veterinary profession • The Official Veterinarian’s role in food hygiene: an essential public good • Veterinarians – vital for animals, vital for people
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Meeting with Sarah Wiener (Member of the European Parliament)

17 Mar 2021 · Antimicrobial Resistance

Response to Laying down rules on equine passports

4 Mar 2021

Please find enclosed the feedback from FVE, the Federations of Veterinarians of Europe and FEEVA, the Federation of European Equine Veterinary Associations.
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Response to European Health Emergency Response Authority

24 Feb 2021

The Federation of Veterinarians of Europe (FVE) very much welcomes that establishment of the European Health Emergency Preparedness and Response Authority, with a mission to strengthen the EU’s preparedness and response in terms of medical countermeasures for serious cross-border threats to health, both of natural and intentional origin. Undoubtedly the Covid-19 pandemic, likewise SARS and MERS indicate that health of humans, animals and the environment are inextricably linked. Our planet becomes more populated, more interconnected via the increasing global trade and challenged by climate change. This leads to increasing contacts between wildlife and intermediate hosts, animals and humans, which enhances the possibility for outbreaks of zoonotic diseases. The majority (72%) of emerging diseases of humans are caused by zoonotic pathogens, with most originating in wildlife, especially non-human primates, rodents and bats, rather than in livestock. This crisis revealed the need for a paradigm shift, including holistic consideration of our environment and the intersectoral collaboration between doctors, veterinarians and environmental experts using the One Health approach The veterinary profession in Europe has been long advocating for the value of One health in tackling efficiently health threats in animals and people. It is important to ensure that mandates and new policies fully embrace the ‘One Health concept’ at the core and that new legislative proposals clearly consider One Health as part of the solution in response to the public health problems. One Health provides solutions for a holistic and more efficient emergency preparedness and should not be ignored. A true implementation of the One Health approach encompasses: - The inclusive use of all available knowledge and expertise of experts in the human, veterinary and environmental field, e.g. veterinarians can make an essential contribution to the management of the current and future pandemics (i.e. viral surveillance in animal reservoirs, epidemiological models, testing strategies and in research) - Setting up proper surveillance systems and sharing of information, data and laboratory genomic analysis between veterinarians, researchers and healthcare professionals via integrated informative systems - A communication plan that includes direct exchange between public health colleagues, governments, stakeholder organisations and the general public - R&D requirements for funding to promote and integrate veterinary and medical professional studies. While prevention of human health relies at large extent to prevention and control of zoonotic diseases in animals, so far all important grants are available for research only in human healthcare (e.g. epidemiology, diagnostics, vaccines). It is imperative to ensure equal and adequate allocation of EU funds for veterinary research (e.g. epidemiology, vaccines or treatment for animals) to prevent disease in humans - Intersectoral collaboration between healthcare, veterinary and environmental field integrated in daily practice, education and research starting in peace times We urge the EC to take into account the Berlin principles as presented on www.sciencedirect.com/science/article/pii/S0048969720364494?via%3Dihub Please find more information on the attached communication.
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Response to Method for the Collection of data on antimicrobial medicinal products used in animals

18 Dec 2020

The Federation of Veterinarians of Europe (FVE), representing about 300 000 veterinarians across Europe, welcomes the possibility to comment on this draft delegated act. We found this draft a balanced proposal and support the legal basis given to the ESVAC project on data collection in respect to the new Regulation. However, we note that a lot of information is requested in this draft, and that this may pose a significant burden on for all involved parties, e.g. the national agencies, veterinarians, farmers and industries. It should be facilitated as much as possible in an automated way and via the existing channels for the collection of data in each member State. A connection between the AMU data collection system and the UPD would be beneficial.
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Response to Production rules concerning feed and veterinary parasite treatments in aquaculture and sprouted seeds

16 Nov 2020

The Federation of Veterinarians, representing veterinary organisations from 39 countries and around 300 000 veterinarians across Europe, welcomes the possibility to give feedback on this amended rules on feed and parasite treatments for organic fish farms. As general note, we want to underline that parasite infections are a main cause of concern in all the fish species and fish farming examined. Treatment to common parasites often lacks efficacy or is not available. When parasite infections cannot be treated, secondary bacterial infection can occur between parasitic and bacterial diseases. To prevent bacterial diseases occurring (and the need to treat with antibiotics) it is necessary to be able to effectively treat parasitic infections. In addition, treating fish for parasite infections is very important from an animal welfare point of view. For more information on the different parasite infections in fish and (lack of) treatment options, see here: https://fve.org/cms/wp-content/uploads/Gap-Analysis-Outcome-Final2.pdf For more details on our feedback see the attached file.
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Response to Long term vision for rural areas

9 Sept 2020

FVE , the Federation of Veterinarians of Europe, very much welcomes the EU long term vision for rural areas. Rural areas face unique challenges while they are crucial for our society and economy. In the EU, rural areas are where most farms are located, they supply our food, provide ground for our livestock, and are crucial to fulfilling the green deal and farm to fork ambitions. Over the years, FVE has been noticing an increasing shortage of veterinarians in rural and remote areas in Europe. The reasons for the lack of veterinary professionals in rural and remote areas are diverse, such as unfavourable working conditions, long distances, difficulties to achieve the desired work/life balance and economic hardship of farmers. This has serious consequences for the health and welfare of animals, farmers and veterinarians alike. It also limits the economic development of rural areas. The increased workload for the remaining veterinarians tends to lead to burnout and further retention problems. Many EU countries already recognised this problem and are taking measures to limit the problem. The EU long-term vision should underpin this to ensure a European approach to make sure we can keep farming in rural areas and that animals can receive preventive care to protect their health and welfare and to make farming more profitable. For more information, see: https://www.fve.org/shortage-of-veterinarians-in-rural-remote-areas/
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Response to Fitness Check of the EU legislation on animal welfare

29 Jul 2020

The Federation of Veterinarians of Europe (FVE) represents around 300 000 veterinarians across Europe, including all EU Member countries. The promotion of the welfare of animals is an important part of FVE’s mission. Through their daily work, veterinarians contribute to assuring the health and welfare of animals and people. European citizens, Member States and veterinarians are more and more concerned about animal welfare issues. We welcome that the Commission has now recognized this and welcome the ambition to revise EU Animal Welfare legislation, especially for better enforcement plus the need to revise the transport and slaughter Regulation, and to provide a minimum level of protection for all animals. We welcome that for livestock, this is done in the framework of moving towards more sustainable animal production. Our main points are: - Prevent harm to all animals, including companion animals and wild animals. Many economically important species or groups of animals lack currently minimum animal welfare standards. Welfare requirements are needed for cattle over six months of age, farmed rabbits, pullets, dogs, cats, turkeys, broiler, dairy cattle and laying hen breeders, sheep, goats and farmed fish. The language of the General Farming Directive is too general, should be more clear. - Companion animals, close to the hearth of many European Citizens should not be forgotten. Illegal or irresponsible trade of dogs & cats is a huge problem. We welcome the Infographics and Leaflets endorsed by the Animal Welfare Platform, which now should be spread as widely as possible. Obligatory identification and registration of dogs is crucial. - We should move forward from protecting animals against negative experiences (pain, suffering, prolonged hunger, etc) to providing that animals have a life worth living and for as many as possible a good life. - Legislation should be based and updated to take into account the latest scientific evidence and new animal welfare concepts; particularly, the emphasis on providing opportunities for positive welfare and the use of key, validated, reliable, robust and feasible indicators. The priority is on updating the transport and slaughter Regulation, but other acts should follow. - Strengthen the focus on improving implementation and enforcement on national level. An implementation scoreboard could be considered as a tracking tool. - Continue efforts in animal welfare education, following the motto ‘everybody is responsible’ and using Art 11 of the Animal Health Law which lays down the knowledge needed by operators and animal professionals on ‘c) the interaction between animal health, animal welfare and human health; and (d) good practice of animal husbandry for the animal species under their care;’ - Make better use of the CAP to promote good welfare and increasing welfare conditions - Work on providing EU citizens with accurate, transparent and impartial information on welfare issues, so they can make an informed choice. - Continue international activities, taking a leadership role worldwide on animal welfare. - Continue the EC Platform on Animal Welfare with more support and recognition given to the own-initiative subgroups. Continue the reference centers on animal welfare, but enlarge target audience to all veterinarians & animal keepers. There are both societal & professional expectations for veterinarians to provide leadership in animal welfare through actions that stimulate and contribute to public discourse, build community trust, and support community consensus regarding appropriate animal use, care, and treatment. The role of the veterinary surgeon must be recognised by the EU and a clear Member States commitment must be given. A clear description of expectations, roles and responsibilities of all relevant parties is essential. As veterinary profession, we look forward to assist the EU and its MS to be leading advocates for animal welfare in a continually evolving society.
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Meeting with Stella Kyriakides (Commissioner)

22 Jul 2020 · Topics discussed: Farm to Fork Strategy One Health – improving animal health, prevention of diseases and AMR Veterinary medicines legislation and AMR Animal Welfare

Meeting with Stella Kyriakides (Commissioner)

22 Jul 2020 · Farm to Fork Strategy, Veterinary Medicines, Animal Welfare

Response to Farm to Fork Strategy

16 Mar 2020

FVE, the Federation of Veterinarians of Europe, is the umbrella body for veterinary associations from 40 European Countries. We represent around 300 000 European Veterinarians. The European veterinary profession is a health profession with a special focus on the One Health agenda - the integrated approach of the health of people, animals and the environment. FVE very much welcomes the EU Commission Green Deal and the intention to address food sustainability and move towards environmentally-friendly farming systems. A ”business as usual” approach is not sufficient to meet the challenges, a paradigm change is needed. FVE agrees with the Political guidelines of President von der Leyen for the need to provide EU citizens with nutritious, affordable food and to support our farmers and fishers with a new strategy to produce, process and sell sustainable food. In the attached paper, you can find the detailed comments of FVE.
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Meeting with Janusz Wojciechowski (Commissioner) and

4 Feb 2020 · CAP and animal health; Antimicrobial Resistance; vision for rural areas

Response to Rules for establishments keeping terrestrial animals and hatcheries and their traceability

22 May 2019

Please find enclosed in the attached file the public consultation feedback of FVE, the Federation of Veterinarians of Europe. Our comments mainly deal with definitions of veterinarians and the traceability of kept equine, dogs, cats and ferrets.
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Meeting with Anne Bucher (Director-General Health and Food Safety)

30 Jan 2019 · introductory meeting

Response to Establishing specific rules for official controls on meat & live bivalve mollusc production and relaying area

9 Oct 2018

The Federation of Veterinarians of Europe (FVE) welcomes the recent draft acts launched for public consultation. However, FVE is concerned that this revision of the legislation will be misused as an opportunity to save money rather than to strengthen the quality of the food chain. Such approach increases risks for animal welfare and for the environment and creates unnecessary risks for food safety, animal and public health. The ongoing competition based on low pricing of food of animal origin is of detrimental effect on the way animals are kept and treated, decreases consumers awareness about the high value of food of animal origin and increases of food waste. In light of the several animal disease outbreaks in Europe (e.g. African swine fever, tuberculosis), food frauds (e.g. illegally treated animals) and the frequent occurrence of food or feed risks (e.g. campylobacter, salmonella), FVE calls upon the EU Institutions to strengthen the consumer protection and the position of the veterinarian in the official controls. FVE calls the EU Institutions to consider the amendments we proposed.
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Response to Practical arrangements for official controls of food of animal origin

9 Oct 2018

The Federation of Veterinarians of Europe (FVE) welcomes the recent draft acts launched for public consultation. However, FVE is concerned that this revision of the legislation will be misused as an opportunity to save money rather than to strengthen the quality of the food chain. Such approach increases risks for animal welfare and for the environment and creates unnecessary risks for food safety, animal and public health. The ongoing competition based on low pricing of food of animal origin is of detrimental effect on the way animals are kept and treated, decreases consumers awareness about the high value of food of animal origin and increases of food waste. In light of the several animal disease outbreaks in Europe (e.g. African swine fever, tuberculosis), food frauds (e.g. illegally treated animals) and the frequent occurrence of food or feed risks (e.g. campylobacter, salmonella), FVE calls upon the EU Institutions to strengthen the consumer protection and the position of the veterinarian in the official controls. FVE calls the EU Institutions to consider the amendments we proposed.
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Response to Amendment of the list of transmissible animal diseases and amendment/repeal of acts in the Animal Health Law area

28 May 2018

The Federation of Veterinarians of Europe (FVE) has reviewed the proposed Delegated Regulation and supports the list of the transmissible diseases. FVE looks forward to the categorization of diseases.
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Response to Promoting Automatic Mutual Recognition of Diplomas and Study Periods Abroad

16 Apr 2018

The Federation of Veterinarians of Europe (FVE), representing the veterinary profession in Europe, welcomes the Commission’s intention to create European Education Area, in which people can move freely to study and carry out research. FVE recognizes the existing difficulties - with its slow or insufficient implementation, varying institutional practices and lack of uniformity and the underdeveloped mutual recognition at secondary education level - and welcomes the Council Conclusion of 14 December, inviting the Commission, Council and Member States to work on the promotion of cooperation on mutual recognition of qualifications by spring 2018. However, FVE also strongly believes that recognition of qualifications must go hand in hand with assuring the value of the underlying education programmes. Recognition of qualifications should always be based on a sound evaluation, qualitatively and quantitatively, of the education programme. FVE is of the opinion that a precondition for accepting EU-wide recognition of qualifications and study periods is the assessment and harmonisation of learning outcomes. The implementation of a European quality assurance system of education and training at all levels is critical for achieving the goals of a European Education Area that adds value for students, education institutes and society at large. The veterinary profession is one of the so-called regulated professions in the EU. It benefits from automatic recognition of competences and a minimum level of training is foreseen within the EU legislation (Annex V of Directive 2005/36). Since many years FVE advocates the harmonisation of learning outcomes for ensuring the training requirements set in European legislation as well as the need for implementing quality assurance of the veterinary training. FVE and its sister organisations EAEVE (representing the European Veterinary Education Establishments) and EBVS (representing the Colleges of Veterinary Specialisation) coordinate their views on veterinary education through the European Coordinating Committee of Veterinary Training (ECCVT - www.fve.org/education/eccvt.php). Together they promote the harmonisation of learning outcomes and quality assurance in veterinary training through the implementation of the European System of Evaluation of Veterinary Training (ESEVT). EAEVE together with FVE runs this professional peer evaluation system for veterinary educational establishments leading to the establishments’ “Accreditation”. ESEVT is based on the Standards and Guidelines for Quality Assurance in the European Higher Education Area (ESG 2015) and it is the only Europe-wide, profession-specific evaluation system. It sets the standards and promotes harmonisation of veterinary training in the European Union and beyond. That way it also provides assurance to the public that they can trust the quality of graduating veterinary surgeons and the services they deliver. FVE calls European Commission to endorse ESEVT and use it as an example for creating a system for harmonisation of learning outcomes and quality assurance of training in other areas of higher education as well. Further to this, European Commission is recommended to consider the development of a structure to allow regular update of learning outcomes in line with science developments and market needs. FVE and all ECCVT members regularly review and, if necessary, update the list of Day-1 competences for graduate veterinarians, which is now used within ESEVT. Last but not least we wish to repeat our call to the Commission to initiate the update of Annex V of the Directive 2005/36, which is largely out of date. It should be renewed and based on defined learning outcomes. The veterinary profession would gladly contribute to any activities for the update of learning outcomes for veterinarians, as well as share our experience from development and implementation of ESEVT.
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Meeting with Vytenis Andriukaitis (Commissioner)

11 Dec 2017 · Veterinary medicines; AMR; official controls; animal welfare

Response to Commission Decision EMAS reference document for best environmental management practice in agriculture

28 Sept 2017

The Federation of Veterinarians of Europe (FVE) represents the veterinary profession in Europe. Members of FVE are 46 national veterinary associations in 38 countries in Europe, including all member states of the European Union. Through them FVE represents about 240 000 veterinarians, active in many different positions: clinicians, researchers, academics, food hygienists, policy-makers, etc. FVE mission is to enhance animal health, animal welfare, public health and protect the environment by promoting veterinary medicine and the veterinary profession. FVE sees that humans, animals and the environment are interlinked. It is therefore important to ensure that best practices are implemented in agriculture, in the concept of the One Health approach. FVE is committed to promote best practices and has taken several initiatives towards that direction. FVE welcomes the decision on best environmental management practices, sector environmental performance indicators and benchmarks of excellence for the agriculture sector. Nevertheless we would like to draw attention on the following remarks: On page 37 – 38 under chapter 3.6.6., proposed text indicates that • producing a preventive healthcare programme, including routine preventive inspections (at least one preventative visit per year) and shared treatments with neighbouring farms; FVE agrees that the establishment of a preventive healthcare programme is fundamental to maintain animal health, reduce the need for veterinary treatments and minimise stock morbidity and mortality, which will have a direct impact on the environment. We also highlight that veterinarian is the appropriately educated professional for the establishment of preventive healthcare programmes and the implementation of routine preventive inspections for the animals under his/her care as laid down in the recently adopted EU Regulation on transmissible animal diseases and amending and repealing certain acts in the area of animal health (‘Animal Health Law’). We also see that epidemiology is an important part of biosecurity, which contributes to the health care programmes, but we do not understand what the meaning and benefit of ‘shared treatments’ could be. FVE suggests that the above sentence is amended as following: “producing a preventive healthcare programme, including routine preventive inspections (at least one preventative visit per year) by a veterinarian responsible for the animals and considering epidemiological data of the region;” • responsible use of medicines, such as reducing frequency of use to the minimum required and rotation of veterinary products to avoid resistance to diseases and viruses; To narrow responsible use of medicines to only viruses does not seem to be appropriate. Diseases can be a result of infection from different pathogens, such as bacteria, viruses, parasites, etc. Instead of ‘diseases and viruses’ is better to read ‘pathogens’. FVE suggests that the above sentence is amended as following: “…rotation of veterinary products to avoid resistance to pathogens” • avoiding mixing young and older animals on the same pasture: FVE suggests that the above sentence is amended as following “avoiding mixing of unrelated and unfamiliar animals on the same pasture” in order to be precise. • maintaining the animal welfare based on the five freedoms principle34 FVE agrees that five freedoms principle is important to be respected. Nevertheless in order to maintain animal health, reduce the need for veterinary treatments we need more than that. We have to ensure that best-practices, like biosecurity, good nutrition, implementation of healthcare programmes including vaccinations, regular inspections of health, etc. are implemented and that guidelines on good husbandry, such as national, FVE and EPRUMA guidelines are followed thoroughly.
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Response to Commission Implementing Decision on topical insecticide on livestock

24 Jul 2017

The Federation of Veterinarians of Europe fully supports the Commission Implementing Decision on topical insecticide on livestock. . We support the EC proposed decision to classify permethrin as VMP seen it is to treat ectoparasites, it is used to treat animal disease (lice in this case) and due to the needed withdrawal period. Furthermore, seen the possible occurance of permethrin poisining and the impact it can have on the environment, we advise this product only to be used as POM VMP. Some useful references: Arturo Anado´ n, Irma Are´ s, Marı´a Ara´nzazu Martı´nez, and Marı´a Rosa Martı´nez-Larran˜aga, Pyrethrins and Synthetic Pyrethroids: Use in Veterinary Medicine, Natural Products, DOI 10.1007/978-3-642-22144-6_131, # Springer-Verlag Berlin Heidelberg 2013 A. Anado´n *, M.R. Martı´nez-Larran˜aga, M.A. Martı´nez, Use and abuse of pyrethrins and synthetic pyrethroids in veterinary medicine, The Veterinary Journal 182 (2009) 7–20 XuWang a,b, María-AránzazuMartínez a, MenghongDai b, DongmeiChen b, IrmaAres a, Alejandro Romero a, VictorCastellano a, MartaMartínez a, JoséLuisRodríguez a, María-RosaMartínez-Larrañaga a, ArturoAnadón a,n, ZonghuiYuan, Permethrin-induced oxidativestressandtoxicityandmetabolism.A review, EnvironmentalResearch149(2016)86–104
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Meeting with Xavier Prats Monné (Director-General Health and Food Safety)

6 Jul 2016 · Discussion on AMR, veterinary medicinal products, animal diseases, official controls and animal welfare