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Humane World for Animals Europe

Humane World for Animals Europe works to end animal cruelty and suffering across multiple species and geographies.

Lobbying Activity

Meeting with Anna Zalewska (Member of the European Parliament)

27 Jan 2026 · finansowanie rozwoju Non-Animal Methods

Meeting with Tilly Metz (Member of the European Parliament, Rapporteur) and Danish Shipping and VIER PFOTEN International

12 Nov 2025 · Animal transport

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

20 Oct 2025 · Animal transport

Meeting with Gerben-Jan Gerbrandy (Member of the European Parliament) and Pro Wildlife

14 Oct 2025 · MEPs for Wildlife

Response to Amendment of data requirements for applications for the authorisation of plant protection products

2 Oct 2025

Humane World for Animals appreciates the opportunity to provide feedback on the draft text of the Act on Plant Production Products. We acknowledge the efforts made to integrate scientific advances and updated procedures, such as the newly added Article 3 in Section 7, that represent important steps toward reducing reliance on animal testing. At the same time, we believe there are further opportunities to strengthen the draft by more fully embracing current and emerging scientific approaches. As a general observation, despite substantial progress in understanding chemical activities and mechanisms, the core data requirements for plant protection products (and their active ingredients) have remained largely unchanged for decades. We therefore welcome the chance to highlight additional areas for regulatory innovation in the attached document, and we look forward to further developments in the plant protection products regulations along the framework suggested by Bhuller et al., 2025, in the near future. Bhuller Y, Bishop P, Cope R, Corvaro M, Currie RA, Hilton GM, Jyotigna M, Puglisi R, Wolf DC, Deglin SE. 2025. Transforming the Evaluation of Agrochemicals: A Conceptual Model, Regulatory Toxicology and Pharmacology: 162:105889. ISSN 0273-2300. https://doi.org/10.1016/j.yrtph.2025.105889.
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Humane World for Animals Europe Urges Non-Animal Testing Priority

2 Oct 2025
Topic — This consultation updates data requirements for approving active substances in plant protection products.
Message — The organization requests that the regulation mandates non-animal testing methods whenever possible. They propose that animal testing should only be used as a documented last resort.12
Why — This would advance their goal of reducing animal cruelty through modern, human-relevant scientific research.34
Impact — Chemical companies would face higher administrative burdens to justify any continued use of animal testing.5
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Meeting with Sirpa Pietikäinen (Member of the European Parliament)

1 Oct 2025 · Fur Farming

Meeting with Tilly Metz (Member of the European Parliament)

16 Sept 2025 · Animal Testing

Meeting with Tilly Metz (Member of the European Parliament)

10 Sept 2025 · Fur Production

Response to Follow-up to the European Citizens’ Initiative “Fur Free Europe”

23 Jul 2025

Humane World for Animals Europe warmly welcomes this opportunity to contribute to the European Commissions Call for Evidence regarding the Fur Free Europe European Citizens Initiative. We unequivocally support the scenario outlined in Option 2, which proposes a ban, after a transition period, on the farming in the EU of mink, foxes, raccoon dogs, and/or chinchillas for their fur and a ban on the placing on the EU market of fur and fur products from such animals (including animals that have been farmed in non-EU countries). Attached please find our detailed submission to this Call for Evidence in PDF format, which supports this position.
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Response to Modernisation of the EU legislation for on-farm animal welfare for certain animals

16 Jul 2025

Humane World for Animals warmly welcomes this opportunity to respond to the European Commissions Call for Evidence concerning On-farm animal welfare for certain animals: modernisation of EU legislation. The revision of the EU animal welfare acquis is long overdue. An end to confinement for farmed animals is Humane World for Animals key priority for this legislative modernisation. We emphasise the fact that it is important that the transition period for phasing-out cages for all species should be as short as possible. This is not only to ensure better welfare for animals, but also to adequately respond to citizens concerns about the conditions under which sentient animals are being raised for food. The primary focus of this submission, which is attached here in PDF format, will relate to poultry and pigs, given that these are the species and sectors on which Humane World for Animals has the greatest expertise. In addition to presenting our vision of what the minimum welfare standards should be with respect to the keeping and breeding of chickens and pigs, we also share our ideas on how fair competition and economic viability could be achieved for farmers and why equivalent animal welfare standards should be imposed on the imports of animal products from outside the Union. Further to this, our submission also provides an overview of corporate action on animal welfare over the past couple of decades.
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Meeting with Tilly Metz (Member of the European Parliament, Rapporteur) and VIER PFOTEN International

15 Jul 2025 · Animal transport

Meeting with Tilly Metz (Member of the European Parliament)

15 Jul 2025 · Animal testing

Meeting with Per Clausen (Member of the European Parliament)

2 Jul 2025 · Animal testing in upcoming reach directive

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

12 Jun 2025 · Animal welfare during transport

Meeting with Maria Ohisalo (Member of the European Parliament) and International Fund for Animal Welfare

13 May 2025 · CITES resolution

Humane World for Animals Urges Non-Animal Life Science Strategy

17 Apr 2025
Topic — A new strategy to boost EU life sciences competitiveness and accelerate scientific innovation.
Message — The group wants the EU to prioritize non-animal testing methods across research and regulation. They recommend dedicated funding and a clear roadmap to replace animal models with advanced technologies.12
Why — Adopting human-relevant models would decrease drug development costs and reduce research failure rates.34
Impact — Facilities relying on animal models face financial losses as demand for traditional testing declines.5
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Meeting with Michal Wiezik (Member of the European Parliament) and Eurogroup for Animals

2 Apr 2025 · Protection of wolves

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

14 Mar 2025

Humane World for Animals (formerly called Humane Society International) welcomes this opportunity to provide feedback on the draft Implementing Regulation (EU) 2016/1141 to update the list of Invasive Alien Species of Union concern. As an animal protection organisation, our submission specifically focuses on the proposed inclusion of the American mink (Neogale vison) in the next update of the list. Please find our comments in the attached PDF document.
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Meeting with Anja Hazekamp (Member of the European Parliament) and Eurogroup for Animals and

19 Feb 2025 · Event animal transport

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

19 Feb 2025 · Animal transport

Meeting with Per Clausen (Member of the European Parliament)

18 Feb 2025 · "From Resilience to Recovery: The Role of Animals in Humanitarian Crises",

Meeting with Sirpa Pietikäinen (Member of the European Parliament)

6 Feb 2025 · Fur Farming

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

28 Jan 2025 · Animal Welfare

Meeting with Arash Saeidi (Member of the European Parliament) and eu travel tech and L214 Ethique et Animaux

15 Jan 2025 · Echange de point de vue

Meeting with Cristina De Avila (Head of Unit Environment) and Eurogroup for Animals and

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

Meeting with Maria Noichl (Member of the European Parliament)

6 Nov 2024 · Broiler welfare

Response to Endangered animal and plant species – suspension of imports from specific countries

7 Oct 2024

Humane Society International/Europe (HSI) welcomes this opportunity to comment on the update of the EU "Suspensions Regulation". We note with concern that trade restrictions have been lifted for a number of animal species populations, and that for 7 of these, the discussions of the SRG and the scientific evidence considered for the species assessed are not publicly available. Recent research (Carpenter & Andreone, 2023) on the Malagasy amphibian trade shows that Mantella spp. are in high demand and that there are concerns 'over the appropriateness of the quotas set and the robustness of their underpinning NDFs'. Establishing up-to-date, science-based NDFs is a complex task that requires sufficient resources, and the reliability of NDFs should be investigated before a decision is made on trade. We insist that the Commission/SRG give due consideration to the precautionary principle when determining whether or not EU Member States should authorise imports of specimens of species protected under Regulation (EC) No 338/97. In addition, information on population sizes and impacts of threats on the Varanus species listed is generally lacking: for example, Varanus dumerilii is listed as Data Deficient on IUCN's Red List, and there is little known information on activity levels and viable population sizes across its range, and how this species is impacted by threats such as trade. In conclusion, we are concerned by the overall lack of transparency in SRG decision-making, and would like to see the evidence to support the decisions made.
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Meeting with Maria Noichl (Member of the European Parliament)

23 Jul 2024 · Animal Welfare

Meeting with Sebastian Everding (Member of the European Parliament)

18 Jul 2024 · Introductory meeting

Meeting with Tilly Metz (Member of the European Parliament)

16 Jul 2024 · Animal Welfare

Meeting with Lukas Sieper (Member of the European Parliament) and European Federation of Pharmaceutical Industries and Associations and

16 Jul 2024 · Introductory meeting at networking event

Response to Protection of animals during transport

9 Apr 2024

Humane Society International/Europe (HSI) welcomes this opportunity to provide feedback on Commissions draft proposal to revise the existing EU Regulation on the protection of animals during transport and related operations. It is, however, regrettable that this proposal represents only a fraction of the legislative proposals to revise and expand the scope of the current body of EU animal welfare legislation, which the Commission committed to delivering in its 2020 EU Farm to Fork Strategy. Please find enclosed our feedback on the animal transport proposal in PDF format.
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Humane World for Animals Europe urges shift to non-animal testing

8 Nov 2023
Topic — Revision of EU pharmaceutical laws to improve medicine access and foster innovation.
Message — The EU should prioritize human-relevant technologies and treat animal testing as a last resort. The proposal must be amended to integrate computational tools and prevent any duplication of animal trials.12
Why — These reforms would lower drug development costs and improve clinical success rates.34
Impact — Animal testing facilities face reduced demand as the sector shifts to modern alternatives.5
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Humane World for Animals Europe urges prioritising non-animal drug testing

8 Nov 2023
Topic — EU consultation on revising pharmaceutical laws to ensure medicine affordability and foster innovation.
Message — The group urges prioritizing human-relevant technologies like laboratory and computer-based models. Animal testing should be a last resort and duplication must always be avoided. These updates would better address patient needs by modernizing the pharmaceutical sector.123
Why — This would reduce drug failure rates and lower costs for the pharmaceutical sector.45
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Response to Revision of EU rules on textile labelling

6 Sept 2023

Humane Society International/Europe (HSI) welcomes this opportunity to respond to the call for evidence with regard to the revision of EU rules on textile labelling. As an animal protection organisation, our focus will be primarily on the failure of Regulation (EU) No 1007/2011 on fibre names and related labelling and marking of the fibre composition of textile products to adequately protect consumers, particularly with regard to animal products that are placed on the EU market. Below please find our feedback in PDF format.
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Response to Suspensions of import into the EU of certain endangered animal and plant species from specific source countries

25 Aug 2023

Humane Society International/Europe (HSI) welcomes the opportunity to provide comments on the Commissions Draft Implementing Regulations for CITES. Firstly, we would like to express our concerns about the lack of transparency in forming the decisions to lift import suspensions for 15 wild animal species. This was based on recommendations from the Scientific Review Group on Trade in Wild Fauna and Flora (SRG), but the process for each of the species assessed was not transparent, nor open to civil society review or consultation. We note that an incomplete meeting agenda was published only several weeks after the SRG meeting where these decisions were taken had been held. Moreover, the short summary of conclusions published seven weeks after this SRG meeting provides no insight into the rationale for the decisions, nor any indications of the data on which they were based. This lack of transparency can be viewed as being in breach of Article 15 of the Treaty on the Functioning of the European Union. This lack of transparency extends to data on trade in wildlife into and out of the European Union. If civil society organisations and researchers were granted access to data on wildlife traded into and out of the EU, including data on seizures of illegal wildlife specimens, it would enable greater oversight and facilitate assistance in ensuring sustainability. Secondly, while we applaud the decision to prohibit trade in Piliocobulus temminckii from Guinea, we express concerns about the proposed termination of import suspensions of 15 wild animal species into the EU. We believe the Commission should better consider the precautionary principle in its decision-making and its own broader commitments in the framework of the EU Biodiversity Strategy to halt biodiversity loss across the globe. For example, we note that the suspension of imports of Ursus arctos imported from Canada, BC has been in place in the EU for 18 years due to concerns on the validity of NDFs issued by British Columbia. The Commission has not provided evidence or rationale to justify the ending of this import suspension. It is also pertinent to observe that the (trophy) hunting of this species is widely opposed by Canadians. A recent study found that 79% of Canadians oppose killing animals for fur, and 81% are opposed to trophy hunting.1 We recommend that the Commission considers the sentiments of range countries when forming trade regulations. 1. Canesco, M. (2022). Most Canadians Oppose Trophy Hunting, Fur Farming and Rodeos. Research Co. https://researchco.ca/2022/04/08/animals-canada-2/
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Humane World for Animals Europe urges meaningful reporting standards

7 Jul 2023
Topic — The consultation concerns mandatory sustainability reporting standards for large companies across the EU.
Message — The organization requests that animal welfare be meaningfully addressed and defined clearly. They recommend requiring specific animal welfare commitments, implementation timetables, and third-party certifications.12
Why — Standardized reporting would allow the organization to better monitor and compare corporate welfare practices.3
Impact — Animal agriculture companies would face stricter oversight regarding their environmental and welfare impacts.4
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Meeting with Maria Noichl (Member of the European Parliament)

6 Jun 2023 · Pig Welfare

Meeting with Martin Häusling (Member of the European Parliament)

23 May 2023 · Allgemeiner Austausch

Meeting with Maria Noichl (Member of the European Parliament)

23 May 2023 · Überarbeitung Tierschutzgesetzgebung

Response to Review of poultry marketing standards

10 May 2023

On behalf of Humane Society International/Europe, I am hereby providing our feedback regarding the modernisation of current poultry marketing standards. The focus of this submission is on the reprehensible practice of forced-feeding of birds to produce a luxury product, namely foie gras. Foie gras is the product of significant animal cruelty. The production of foie gras involves force-feeding ducks and geese by placing a long tube down the birds oesophagus and pumping an excessive quantity of food directly into their stomach. As a result, the liver swells to six to ten times its normal size. Force-feeding leads to steatosis of the liver, a condition in which large fat globules accumulate in the liver cells to an extent not seen in any normal bird. This causes great suffering. The enlarged liver also forces the legs outwards so that the birds have difficulty standing and their natural gait and ability to walk can be severely impaired. Force-fed birds are more likely to suffer from bone fractures, liver lesions and respiratory disorders. Force feeding is arguably already illegal under EU law. Council Directive 98/58 provides that No animal shall be provided with food or liquid in a manner... which may cause unnecessary suffering or injury (paragraph 14 of the Annex). Force-feeding clearly causes suffering and injury. The insertion of the feeding tube into the oesophagus can result in accumulated scar tissue in, and serious injury to, the oesophagus of ducks. In particular, insertion of the tube can result in inflammation of the birds neck and bruising and even perforation of the oesophagus. It is reprehensible that the current provisions of Regulation (EC) No 543/2008 the marketing standards for poultry meat are helping to keep the practice of force-feeding alive. This legislation increased the minimum weight of duck and goose livers required for a product to be defined as foie gras, which mean that it is impossible to market products that have been produced without the cruelty of force-feeding. In short, the legislation more or less obliges producers to use cruel methods in order to market bird livers as foie gras. It is no wonder that the majority of EU Member States have already chosen to prohibit the force-feeding of poultry. The last Eurobarometer study on animal welfare (2016) found that 94% of EU citizens thought it was important to protect the welfare of animals on farms. We are failing our citizens by mandating animal abuse to produce fatty livers. We therefore urge the Commission to take this opportunity to delete the minimum liver weights requirement for duck and goose livers. Doing so would not mean prohibiting the production of foie gras, but it would make it possible to eliminate animal cruelty and raise animal welfare standards for ducks and geese.
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Meeting with Caroline Roose (Member of the European Parliament) and Eurogroup for Animals and PETA Science Consortium International e.V.

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

Meeting with Maria Noichl (Member of the European Parliament)

1 Mar 2023 · Pig welfare

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

11 Jan 2023 · Wildlife

Meeting with Virginijus Sinkevičius (Commissioner) and

25 Oct 2022 · To discus Humane Society’s position concerning EU legislation on trophy hunting and EU position for the upcoming CITES CoP19.

Response to Introducing new hazard classes–CLP revision

18 Oct 2022

HSI/Europe welcomes this opportunity to comment on this initiative. Please refer to our comments attached.
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HSI Europe urges ECHA to prioritize phasing out animal testing

10 Oct 2022
Topic — Updating the governance and funding rules for the European Chemicals Agency.
Message — HSI Europe recommends a formal mandate to promote non-animal methods and eventually phase out testing. They propose a new expert committee to guide the transition toward ethical safety assessments. Dedicated funding should support the development and regulatory use of these new approaches.123
Why — A formal mandate would cement their goal of ending animal testing.4
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Meeting with Caroline Roose (Member of the European Parliament, Rapporteur for opinion) and European Environmental Bureau and

1 Sept 2022 · Environmental Crime Directive (Protection of the environment through criminal law )

Humane World for Animals urges EU to drop testing mechanism

16 Aug 2022
Topic — The initiative aims to improve chemical data access and transparency for safety assessments.
Message — The group wants the new data-generation mechanism eliminated to prevent redundant studies. They argue that if retained, a full impact assessment is mandatory.12
Why — The group would prevent unnecessary animal suffering by blocking a broad new testing mandate.3
Impact — Animals and welfare advocates suffer if the proposal enables virtually limitless new animal testing.4
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Meeting with Tilly Metz (Member of the European Parliament)

14 Jul 2022 · Trophy Hunting

Meeting with Sylwia Spurek (Member of the European Parliament)

5 Jul 2022 · climate catastrophe

Meeting with Marie Toussaint (Member of the European Parliament, Shadow rapporteur)

5 Jul 2022 · Environmental Crime

Meeting with Ville Niinistö (Member of the European Parliament)

26 Apr 2022 · CITES (staff level)

Meeting with Anja Hazekamp (Member of the European Parliament) and Eurogroup for Animals and The Born Free Foundation

20 Apr 2022 · Animal Welfare

Response to Application of EU health and environmental standards to imported agricultural and agri-food products

8 Mar 2022

Humane Society International/Europe (HSI) welcomes this opportunity to respond to this initiative on the application of EU health and environmental standards to imported agricultural and agri-food products. Please find our feedback attached in PDF format.
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Meeting with Andrea Vettori (Cabinet of Commissioner Virginijus Sinkevičius) and ALTERTOX

23 Feb 2022 · Meeting with HSI and ALTERTOX on animal testing

Meeting with Andrea Vettori (Cabinet of Commissioner Virginijus Sinkevičius)

10 Feb 2022 · Meeting to handover a petition regarding animal testing

Meeting with Joan Canton (Cabinet of Commissioner Thierry Breton)

10 Feb 2022 · Meeting to handover a petition regarding animal testing

Response to Improving environmental protection through criminal law

9 Feb 2022

Humane Society International/Europe (HSI) welcomes the Commission’s proposal to revise the Environmental Crime Directive. Given the weaknesses in the current legislation and the disparities in its application by Member States, we are pleased that the legislation is being revised, rather than simply being amended. For the most part, HSI broadly supports the key elements of the proposal and intends to encourage MEPs and Member States to support the proposal during the legislative process. We believe that is indeed prudent to strengthen the implementation of the Directive through national strategies and reporting requirements, as well as establishing minimum requirements for resources, training and investigative tools. Furthermore, it is a good step to include both endangerment crime and serious negligence, plus more explicit provisions relating to aggravating and mitigating circumstances. We also welcome the reference to additional penalties and sanctions. Ensuring equivalency of sanctions would also assist data collection and comparison between Member States with regard to the implementation of the Directive. As an NGO, HSI also applauds the fact that the proposal includes provisions regarding the protection and involvement of civil society organisations and individual citizens given that they play an important role in detecting and combating environmental crime. While broadly satisfied with the proposal, HSI has the following concerns: With regard to scope, there is no general definition of what constitutes an environmental crime. Instead the proposal relies on a list of secondary legislation. This is problematic because it does not make the legislation futureproof and the Directive will require amending each time new environmental laws are adopted. For example, HSI hopes that the EU will eventually adopt supplementary legislation to close the loophole in the existing wildlife trade Regulations making it an offence to trade in wildlife species that have been taken in violation of the laws of non-EU countries. Further to this, the inclusion of IUU fishing in the scope is desirable. Moreover, while there is a reference to ecocide in the recitals, this crime is omitted from the operational part of the Directive. With respect to sanctions, the minimum standards for maximum limits for penalties and sanctions are too low. These must be increased for the legislation to be effective and dissuasive. At present, environmental crimes, such as wildlife crime, are often viewed as being relatively low-risk and high income generating due primarily to the lack of severe penalties and low chances of being apprehended or prosecuted. As regards enforcement, it is important that there is a provision for the establishment of specialised coordination bodies in every Member State and jurisdiction should be extended as far as possible to increase environmental protection. Further to this, it is also crucial that raw statistical data from Member States be made public, instead of just consolidated versions thereof. Lastly, greater legal clarity is needed with regard to the definition of the term "substantial damage". It would be helpful to extend the list of elements to be taken into account when assessing what constitutes this.
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Meeting with Helena Braun (Cabinet of Executive Vice-President Frans Timmermans) and Eurogroup for Animals and

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

Meeting with Andrea Vettori (Cabinet of Commissioner Virginijus Sinkevičius) and Eurogroup for Animals and

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

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

1 Nov 2021

Humane Society International (HSI) welcomes this opportunity to comment on the Inception Impact Assessment – EU Chemicals Strategy for Sustainability - Revision of the Cosmetic Products Regulation. Please refer to our comments attached.
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Response to Sustainable food system – setting up an EU framework

26 Oct 2021

Humane Society International/Europe (HSI) welcomes this opportunity to comment on the Inception Impact Assessment for the Sustainable food system framework initiative. For the sake of the environment, biodiversity, animal welfare and human health, it is imperative that the EU takes action to transition to a more sustainable food system. Please find our feedback attached as a PDF file.
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Response to Preventing illegal trade in wildlife

26 Oct 2021

Humane Society International/Europe warmly welcomes the publication of the European Commission’s Roadmap for preventing illegal trade in wildlife. Although we already submitted comments to an earlier version of this Roadmap, we appreciate this opportunity to comment on this initiative once again in the light of more recent developments with regard to wildlife trade. Please find enclosed our feedback as a PDF document.
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Meeting with Camilla Bursi (Cabinet of Commissioner Virginijus Sinkevičius) and ALTERTOX and Lumina

21 Oct 2021 · To discuss the TOX Strategy

Response to Review of the EU school fruit, vegetables and milk scheme - EU aid

21 Jul 2021

Humane Society International/Europe (HSI) welcomes this opportunity to provide feedback on the Roadmap/Inception Impact Assessment on the Review of the EU school fruit, vegetables and milk scheme. We believe that it is important for EU school schemes to fully reflect and contribute to the primary goal of the EU Farm to Fork Strategy, which is to move towards a more sustainable food system. As the European Commission has explicitly acknowledged, this will necessitate a shift to a more plant-based diet and a reduction in the consumption of animal products. Attached please find our more detailed comments on the Roadmap/Inception Impact Assessment.
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Response to Animal welfare labelling for food

21 Jul 2021

Humane Society International/Europe (HSI) warmly welcomes this opportunity to provide our feedback on the European Commission’s Inception Impact Assessment on the revision of the EU legislation on animal welfare. We were delighted to see the inclusion of a concrete commitment to evaluating and revising the existing body of animal welfare legislation in the Farm to Fork Strategy, which was adopted last year. It is encouraging to see that such good progress is being made along these lines. The revision of EU animal welfare legislation is urgently needed not only to take the latest advancements in animal welfare science into account, but also to better reflect public, political and market demands for the better protection of animals in the EU. In this regard, we also applaud the Commission’s recent response to the European Citizens’ Initiative to End the Cage Age. The future of animal farming in the EU should indeed be one without caged confinement for all species kept for production purposes. In the attached submission, we will briefly respond to issues raised in each section of the inception impact assessment document. Kind regards, Dr Joanna Swabe Senior Director of Public Affairs Humane Society International/Europe
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Response to Clarification of requirements for the Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH)

16 Jul 2021

Thank you for the opportunity to comment on this draft regulation. We believe that the proposed changes to REACH Annexes VII to X are premature and should be subject at least to a full impact assessment, or maybe more appropriately, only proposed as part of the revision of REACH. The Commission is currently planning the revision and has committed to assess the impact of any measures proposed on animals used in tests. By contrast, these changes – which are wrongly described as “clarifications” – would, if adopted, considerably increase animal data requirements without the benefit of either an impact assessment or Parliamentary scrutiny. There is also reason to question whether the changes would actually result in any improvement in protection of human health or the environment. Throughout the process leading up to this consultation, the Commission has maintained that the proposed changes will not have an impact on animal testing. This is simply not the case. Several of the proposed changes alter the meaning of the original legal text and present a real possibility of increased testing on animals, for example: • Introducing an in vivo genotoxicity study as mandatory requirement at Annex VII in case of a positive result in any of the in vitro genotoxicity studies. • Introducing in vivo germ cell studies as standard information requirements at Annexes IX and X. • Introducing QSARs and in vitro data as specific triggers for extended one generation reproductive toxicity and/or prenatal developmental toxicity tests at Annex VIII. • Specifying oral route of administration for reproductive toxicity tests throughout the Annexes. • Adding language to suggest that a long-term fish test can be proposed or required in addition to a short-term test at Annex VIII. Some changes have been proposed to bring the legal text in line with ECHA’s practices that are already in place, but this is the wrong way around – ECHA’s practices must be dictated by the legal text. If there is a discrepancy, it is for the European Court of Justice to reconcile the legislators’ intention with the legal text, or for the Commission to propose changes based on an impact assessment where appropriate. Similarly, it is inappropriate to use these updates to cement in the legal text a number of controversial issues that have not yet been settled by the European Court of Justice, for example: • Whether a prenatal developmental toxicity test on a second species is required at Annex X. The intention of legislators is not clearly conveyed by the current REACH text, but the proposed text would cement a second species prenatal developmental toxicity test as a mandatory requirement. • Whether both long-term Daphnia and fish tests are required at Annex IX. Previously, the decision has been made based on the outcome of the chemical safety assessment, but proposed changes to the wording of Annex IX, section 9.1, column 2 would make long-term tests on both fish and Daphnia mandatory. In many cases, a high level of protection of human health and the environment will be achievable using strategies that do not involve new tests on animals, so the legal text must be flexible and pragmatic enough to accommodate use of such strategies. Since Directive 2010/63/EU requires implementation of the 3Rs and Articles 13(1) and 25(1) of REACH require that non-animal methods be used wherever possible and that animals be used only as a last resort, this is not just an ethical obligation but a legal one too. Disappointingly, our suggestions to use these updates as an opportunity to improve animal protection were ignored, and there is no indication that any of the proposed changes will lead to a reduction in animal testing. The Commission’s apparent lack of consideration for this issue calls into question its commitment to the 3Rs and the promotion of alternative methods for assessment of hazards of substances (Article 1(1) of REACH). Please see the attached document for further information.
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Response to Revision of EU legislation on hazard classification, labelling and packaging of chemicals

1 Jun 2021

Humane Society International (HSI) welcomes this opportunity to comment on the Inception Impact Assessment – Revision of EU legislation on hazard classification, labelling and packaging of chemicals. By ensuring that the EU regulatory approach for chemicals is based on up-to-date science, the EU can contribute actively to reductions in animal use through a robust implementation of Directive 2010/63/EU – but it is only by significant improvements in the uptake of NAMs that the goals of the Chemical Strategy for Sustainability are achievable. Please refer to our comments attached for our feedback in full.
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Response to Revision of EU legislation on registration, evaluation, authorisation and restriction of chemicals

1 Jun 2021

Humane Society International (HSI) welcomes this opportunity to comment on the Inception Impact Assessment – Revision of EU legislation on registration, evaluation, authorisation and restriction of chemicals. By ensuring that the EU regulatory approach for chemicals is based on up-to-date science, the EU can contribute actively to reductions in animal use through a robust implementation of Directive 2010/63/EU – but it is only by significant improvements in the uptake of NAMs that the goals of the Chemical Strategy for Sustainability are achievable. Please refer to our comments attached for our feedback in full.
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Response to Pact for Research and Innovation in Europe

13 May 2021

The Humane Society International welcomes the European Commission’s plans to deepen the European Research Area (ERA), as a chance to modernise research methodologies in the EU, further embodying its values and principles. Article 13 of the Treaty mandates that animal welfare be taken into account when formulating policies on “research and technological development”. However, according to the Commission’s statistical reports, animal use in scientific experiments over the last decade shows no decline. Transition to non-animal based research is not only an ethical, but also a scientific imperative: animal models often fail to produce the necessary data to understand human diseases. According to the Commission’s Joint Research Center, “over 90% of new candidate drugs fail to make it through clinical trials and gain market approval” and “limitations of animal models to capture critical aspects of human physiology and disease are being increasingly cited as a critical issue.” However, as of today, Europe has yet to commit itself to a transition towards non animal based research. It seems timely to promote this objective as a priority area for joint action in the Pact for Research and Innovation in Europe. It is an aspirational goal, because promoting the development and implementation of non-animal methodologies will improve biomedical science and foster the deepening of the ERA around its core principles such as the pursuit of scientific excellence, increasing freedom of research and ensuring socio-economic returns. Increasing investment in emerging technologies Replacing the use of animals in research requires targeted funding dedicated to innovative technologies. These include microphysiological systems; induced pluripotent stem-cells; molecular and high-content analyses, pathway-based approaches and in silico models. Horizon 2020 proved instrumental in supporting projects focused on developing non-animal methods, but their representation in the budget amounted to a small percentage. The Pact offers the chance to strengthen Europe’s commitments to the development of non-animal approaches by establishing closer cooperation with Member States. This could take the form of common objectives to invest in infrastructure, equipment and funding to support the development and application of these technologies. Better education and training The Bonn Declaration on Freedom of Scientific Research, a key element of the ERA, aims to guarantee researchers’ right to “employ sound academic methods” and “bring forward new ideas”. However, too often researchers fall back on animal models due to a lack of knowledge in other methods. The ability to choose the most suitable among a variety of approaches is essential to freedom of research and promoting training and education in non-animal methods as part of the Pact would contribute to this objective. Some initiatives have been launched by the Commission, for example the recently developed e-learning modules to facilitate the development and use of non-animal methods. But more efforts are required and the Pact is an opportunity for greater coordination with Member States in this area. Enhanced Socio-Economic Returns Many non-animal methods are game-changing technologies, with the potential to improve our understanding of human diseases, and lead to considerable public health benefits. This could lead to an increase in the success rate of novel drugs, which will beneficially impact the whole pharmaceutical sector and public health systems. Additionally, with a 12% per year growth for innovative products and services, advanced non-animal methods represent a booming market. Embedding the development of non-animal methods as a priority area for joint action, enables the Pact to endorse an aspirational objective and prepare the EU for the future by stimulating investments in emerging technologies, training its workforce, and ensuring that Europe can be competitive in this dynamic sector.
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Response to Information and promotion measures for agricultural and food products in the internal market and in non-EU countries

4 Mar 2021

On behalf of Humane Society International/Europe, please find attached our feedback on the Inception Impact Assessment on the review of agricultural promotion policy for EU farm and food products. For the sake of the environment, biodiversity, animal welfare and human health, it is imperative that the EU takes action to transition to a more sustainable food system. The Farm to Fork Strategy acknowledges that this transition is not going to happen without a shift in people’s diets. It explicitly states that “moving to a more plant-based diet with less red and processed meat and with more fruits and vegetables will reduce not only risks of life-threatening diseases, but also the environmental impact of the food system.” We believe that it is vital for the agricultural promotion policy to be fully aligned with the EU’s political priorities, such as the objectives of the Farm to Fork Strategy, the EU Biodiversity Strategy, Europe’s Beating Cancer Plan and the EU’s climate change goals. In sum, the enclosed document maintains that that policy option 3 would be the most effective policy strategy to ensure that the promotion of agricultural products is aligned with the Commission’s political priorities and fulfils the objectives of the Farm to Fork Strategy and other EU policy goals. Introducing conditional requirements and eligibility criteria that fully reflect and are coherent with the Commission’s European Green Deal policies is essential. It is vital that EU funds are no longer used for the promotion of meat and other animal products derived from intensive animal production systems.
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Response to Wildlife trade – alignment of EU rules with recent decisions taken under the CITES convention and changes to EU ivory trade rules

24 Feb 2021

On behalf of Humane Society International - and in cooperation with the signatories in the document enclosed - we would like to submit the following joint NGO statement on the EU proposal to tighten further the EU ivory trade regime. While we are supportive of the Commission’s proposal, there are a number of concerns about the measures proposed. Indeed, we believe that these can be even further strengthened. Our concerns are summarised below. 1) It is notable that the trade restrictions on worked ivory are only partially addressed in Commission Regulation 865/2006 (with the rest being in the guidance document), while those on raw ivory are currently only included in the guidance document. To ensure consistency and enforceability of the rules, we would urge the amendment of Commission Regulation 865/2006 to solve this problem. 2) The requirement that antique ivory can only be traded with a certificate is problematic because it is still too broad. A de minimis provision further restricting the issuance of certificates for antique ivory is needed. This would help to preclude the authorities becoming inundated with applications for certificates, which could increase the risk of illegal or poached ivory being laundered through the system and sold as antique. 3) The exceptions regarding pre-1975 musical instruments should be further tightened and should only apply when the volume of ivory in the instrument is less than 20% of the total volume of the material of which the instrument is made. 4) The proposal that a witness statement/affidavit or signed declaration from an applicant for a certificate to trade antique worked ivory is accepted as a satisfactory proof of legal acquisition is highly problematic. It is vital that any declarations made in support of legal acquisition/origin should be provided by independent approved/recognised experts only. We hope that the Commission will take these issues into consideration and remedy these problems in its final text.
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Response to EU strategy for sustainable textiles

1 Feb 2021

On behalf of Humane Society International/Europe, please find enclosed our comments with regard to the EU Strategy for Textiles Roadmap.
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Response to Clarification of requirements for the Registration, Evaluation, Authorisation and Restriction of Chemicals

16 Nov 2020

Draft regulation: chemicals - clarification of requirements for registering, evaluating, authorising and restricting chemicals Comments from Cruelty Free Europe, Humane Society International/Europe, and PETA International Science Consortium Ltd. The requirement for member states to “ensure that, wherever possible, a scientifically satisfactory method or testing strategy, not entailing the use of live animals, shall be used instead of a procedure” involving animals (i.e. implementation of the 3Rs;Article 4(1); Directive 2010/63/EU); the requirement to use non-animal methods wherever possible, and to conduct tests on vertebrate animals only as a last resort (Article 13(1) and Article 25(1); REACH) are ethical and legal obligations within the EU. Any amendments to the REACH Regulation must not violate these obligations, and should in fact encourage movement towards the EU’s final goal of fully replacing tests on animals (Recital 10; Directive 2010/63/EU). However, many of the proposed amendments to Annexes VII – XI could further restrict the use of non-animal approaches under REACH, leading to the data requirements being considered even more as a tick-box exercise and could result in additional testing on vertebrate animals. Therefore, the proposed amendments raise significant concerns regarding the Commission’s commitment to the 3Rs and the application of non-animal methods for safety assessment. This is out of step with other regions which are making strong commitments to phasing out tests on animal for hazard and risk assessment. For example, the Netherlands National Committee for the Protection of Animals Used for Scientific Purposes has published an advice report on the country's transition to animal-free innovation in which it concluded, among other things, that toxicity tests on animals for chemicals, food ingredients, pesticides, veterinary medicines, and vaccines could be phased out by 2025. More recently, the US Environmental Protection Agency announced in 2019 that it would provide additional funding for the development of non-animal methods and reduce tests on mammals by 30 per cent by 2025, with a view to eliminating these tests completely by 2035. We strongly urge the Commission to make a similar commitment to the use of non-animal approaches for regulatory testing and would welcome the opportunity to work with ECHA and the Commission to implement such a strategy. In the attachment, we outline our primary concerns related to the proposed amendments to the proposed text for Annexes VII to XI.
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Response to Fitness Check of the EU legislation on animal welfare

30 Jun 2020

Humane Society International/Europe (HSI) welcomes this opportunity to provide feedback on the Roadmap for the Fitness Check of the EU legislation on the welfare of farmed animals. We believe that this review of the existing body of EU animal welfare legislation is urgently needed not only to take into account the latest advancements in animal welfare science, but also to better reflect public, political and market demands for better protection of animals in the EU. Enclosed please find our comments in PDF format.
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Response to Chemicals strategy for sustainability

20 Jun 2020

Humane Society International (HSI) welcomes this opportunity to comment on the European Commission’s roadmap on a chemical strategy for sustainability, and the European Commission’s commitment to developing a strategic approach to chemicals that aims to reduce the risks associated with producing and using chemicals. Our comments and recommendations are underpinned by the principles laid out in Directive 2010/63/EU on the protection of animals used for scientific purposes, and on the imperative to take maximum advantage of cutting edge scientific advances that would greatly assist in achieving the aims of the Chemicals Strategy for Sustainability, and the overarching goals of the EU Green Deal. Please refer to the attached file with our comments.
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Response to Access to Justice in Environmental matters

1 Apr 2020

Humane Society International/Europe (HSI) welcomes the publication of the European Commission’s Roadmap on Access to Justice in Environmental Matters. For far too long, civil society organisations like HSI have faced difficulties in challenging administrative decisions and actions which affect the environment and the animals within. As the Roadmap acknowledges, the EU’s current Aarhus Regulation fails to properly implement the EU’s obligations under the Aarhus Convention. While the Roadmap makes several good recommendations on ways to improve the Aarhus Regulation, the changes it suggests fall short of delivering to EU citizens and civil society the access to justice required under the Aarhus Convention. In the attached submission, we give our comments on how the proposed targeted revision to the Aarhus Regulation achieves its goals and how it should be improved to fully implement the Aarhus Convention.
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Response to Farm to Fork Strategy

19 Mar 2020

Humane Society International/Europe welcomes the publication of the European Commission’s Roadmap for the Farm to Fork Strategy. For the sake of the environment, biodiversity, animal welfare and human health, it is imperative that the European Union takes bold and decisive action to transition to more sustainable food systems. We wholeheartedly agree that the European Green Deal cannot be achieved without the issue of food sustainability being properly addressed. In the attached document, we give our comments on some of the points that were raised in the Roadmap and provide input on issues that should be addressed in the future Farm to Fork Strategy. *** Please note that this is a second submission due to problems with attaching the document before the original deadline of 16th March ***
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Response to Wildlife trafficking - EU action plan (evaluation)

18 Mar 2020

Humane Society International/Europe welcomes this opportunity to contribute our feedback on the Commission’s Roadmap on the evaluation of the EU Action Plan against Wildlife Trafficking. Wildlife trafficking is today one of the most profitable forms of transnational criminal activity globally. A wide range of species, including mammals, birds, reptiles, amphibians, fish and insects, are used for pharmaceutical, ornamental, traditional medicinal purposes, food or trophies. The global pet trade also benefits from the illegal harvest and trade in wildlife. The EU is one of the top three destinations for illegal wildlife (alongside China and the US), while countries and regions rich in biodiversity are major suppliers. Low levels of awareness, low risk of detection and low levels of sanctions, all make the trade very appealing to criminal networks. Illegal wildlife trade not only poses a grave threat to the survival of species and biodiversity all over the world, but is also becoming an environmental, economic, and national security threat, particularly as the links between wildlife crime and other forms of organised crime and terrorist activity is recognised. In the attached document, we give our comments on some of the points that were raised in the Roadmap and provide input on issues that we believe should be addressed in the evaluation of the EU Action Plan against Wildlife Trafficking.
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Response to Adapting data requirements in the Annexes to the BPR to the ED criteria

12 Mar 2020

In light of the European Commission’s proposal to update Annexes II and III of Regulation (EU) No 528/2012 concerning the making available on the market and use of biocidal products (BPR), the Humane Society International would hereby like to present its recommendations to the proposed amendments of the legal text. Our recommendations are in line with the requirements laid out in Directive 2010/63/EU on the protection of animals used for scientific purposes and with Article 62(1) of the BPR which states that “In order to avoid animal testing, testing on vertebrates for the purposes of this Regulation shall be undertaken only as a last resort”, as well as in the interest of better protecting human health and the environment. We welcome changes introduced that represent incorporation of technical progress and a positive move towards the increased use of more efficient and effective non-animal methods. For other proposed changes, we provide scientific evidence and arguments that provide alignment with Directive 2010/63/EU and the 3Rs principles, and reduce the number of animals used whilst still adequately addressing potential hazards and achieving the same or greater level of protection. The Humane Society International urges the European Commission to allow for the maximum implementation of the principles laid out in Directive 2010/63/EU, and to seize this opportunity to do so. The Commission must also work to increase these opportunities by facilitating mechanisms that enable the continuous and expeditious updating of relevant data requirements, taking into account the latest scientific developments as they become available such that non-animal methods and approaches are accepted and appropriately prioritised to minimise animal use. Further details can be found in the document attached.
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Response to EU 2030 Biodiversity Strategy

17 Jan 2020

Humane Society International/Europe welcomes the publication of the European Commission’s Roadmap for the EU Biodiversity Strategy to 2030. In the attached PDF document, we comment on a number of points raised in the Roadmap and provide our input on issues that we believe should be addressed in the future EU Biodiversity Strategy.
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Response to Evaluation of the EU Animal Welfare Strategy (2012-2015)

7 Jun 2019

On behalf of Humane Society International/Europe, I respectfully submit our comments with regard to the European Commission’s Roadmap on the Evaluation of the EU Strategy for the Protection and Welfare of Animals 2012-2015. Please find these enclosed as a PDF document. Unfortunately this feedback form does not permit comments exceeding 4000 characters.
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Response to Update of the list of Invasive Alien Species of Union concern

2 Apr 2019

Humane Society International/Europe appreciates this opportunity to provide our feedback with regard to the draft Implementing Regulation (EU) No 2016/1141 to update the list of invasive alien species of Union concern. We have no objections to the inclusion of the species listed. However, we would like to express our consternation that the American mink (Neovison vison) has not been included in the list. There is abundant scientific evidence that this non-native mammalian species has had an extremely detrimental impact on European biodiversity. The American mink has, for example, been implicated in the displacement of the European mink and European polecat through competition for resources, and has also identified as a contributory cause of decline of some water vole populations. Moreover, there is concern about the species’ impact on breeding success of native birds and on domestic fowl. The Risk Assessment submitted by Portugal, which was approved by the Scientific Forum on IAS in 2018, indicated that the American mink should be an immediate priority for inclusion in the list. Prevention is a cost-effective strategy to deal with IAS and fur farming should be recognised as a common pathway of introduction for the American mink. Despite the scientific acknowledgement that the highly invasive American mink is a prime candidate for inclusion in the Union List, some EU Member States – primarily in the rapidly diminishing number of countries where fur production is still legally permitted as a commercial activity - have pushed to ensure that it is not included on the list. Humane Society International/Europe notes that Regulation (EU) No 1143/2014 already includes a permitting system that may allow existing commercial activities, such as fur farms, involving invasive alien species to continue to operate under a strict system of authorisation, if they are able to guarantee a strict biosecurity regime. These provisions, which effectively weaken the legislation, were introduced following heavy lobbying by the fur industry during the legislative process. It is unacceptable that a highly invasive species, such as the American mink, has not been included in this update when such legislative measures have already been taken to protect the commercial interests of the fur industry. We regard this as short-sighted and contend that it will lead only to greater threats to biodiversity in the long run. In addition, failing to urgently include the American mink – one of the most damaging invasive alien species in Europe - on the Union list represents a dangerous precedent and risks undermining the credibility of the IAS Regulation as a whole. Failure to list the American mink as an IAS of Union concern demonstrates a lack of commitment to protecting native biodiversity and tackling the problem invasive alien species, and would also be in conflict with the EU’s 2020 Biodiversity Strategy and achieving the Aichi biodiversity targets.
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Meeting with Marco Valletta (Cabinet of Commissioner Vytenis Andriukaitis)

19 Feb 2019 · The establishment of a second EU Reference Centre for animal welfare

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

22 Nov 2018 · CITES

Meeting with Tom Tynan (Cabinet of Commissioner Phil Hogan)

17 Sept 2018 · EU Protein

Response to Multiannual Financial Framework - CAP Strategic Plans

3 Aug 2018

Humane Society International/Europe would like to take this opportunity to express our disappointment that recommendations for policies to reduce EU production and consumption of animal products were not addressed in the CAP proposals. The Better Regulation Toolkit #54 states that the main points of identified public campaigns would be summarised in the synopsis report, yet this was not done, and the concerns seem to have been disregarded. Dismissing the responses of EU citizens who had been encouraged to participate in the consultation by an organisation that represents their concerns relating to intensive animal agriculture diminishes citizens’ participation in the important public consultation process. We are encouraged to see that healthy diets and increasing consumption of fruit and vegetables are a focal point in the reformed policy; however, there is a missed opportunity to promote plant-based proteins for human consumption over animal proteins. While increasing EU fruit and vegetable consumption is imperative for good health, consumption of legumes as a primary protein source should also be promoted by the CAP. Pulses are a rich source of minerals such as iron, zinc and folate, they are high in protein and fibre and low in fat and growing pulses can help contribute to climate mitigation and adaption. The consultation responses showed an overwhelming number of citizens indicated that protecting the environment should be a CAP priority. The FAO identified the farm animal sector as a top contributor to the most serious environmental problems and recommends reducing the production and consumption of meat, dairy and eggs should be a major agricultural policy focus when dealing with a number of environmental issues such as land degradation, air quality, water pollution and shortages, biodiversity loss and climate change. Meat and dairy companies are among the world’s largest greenhouse gas emitters, yet animal products will continue to be heavily subsidised in the reformed CAP, while more climate friendly plant crops will continue to receive only a fraction of the financial support. If the European Commission is to take seriously its commitment to tackle climate change, it must propose concrete measures to reduce production and consumption of animal products in the EU. The EU’s intensive agricultural model is designed to continue to meet high production and consumption volumes. Yet, due to increased awareness of the negative impacts of animal product production and consumption, the public is increasingly demanding alternatives to meat, dairy and eggs. While the CAP remains heavily weighted towards providing cheap animal products, it sustains a system of supply of products that are becoming increasingly unpopular with consumers. This presents an area of concern regarding the protection of the livelihoods of farmers who are currently dependent on animal farming and is another oversight in the CAP post-2020 proposals. The future of food and farming communication stated that the policy would help farmers adjust their production according to changing consumer demand. With the strong trend towards reduced meat diets and the growing popularity of plant-based alternatives to traditional animal products, the reform is an opportunity to allocate funds under Pillar II to a grant fund specifically designed to assist farmers in transitioning away from animal farming to the production of food crops for human consumption. Such a fund would allow for the provision of equipment and training in the new skills required, thus protecting livelihoods. To sum up, we feel that the views submitted by numerous members of the public were not taken into account in the CAP proposals, which continues to show short-sightedness by its support of industrial animal production. The reform continues to be biased towards the interests of the intensive farming lobby to the detriment of EU citizens’ health and environment.
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Meeting with Elina Melngaile (Cabinet of Vice-President Valdis Dombrovskis)

7 Feb 2017 · International Finance Institutions and Animal Welfare

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

13 May 2015 · REACH

Meeting with Vytenis Andriukaitis (Commissioner) and

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