The Swedish Horse Industry Foundation (HNS)
The Swedish Horse Industry Foundation (HNS) is a coordinating organisation that works with and for the Swedish equine sector.
ID: 460701191554-62
Lobbying Activity
Response to Protection of animals during transport
12 Apr 2024
The Swedish Horse Industry Foundation (HNS) is a politically independent coordinating organisation in the Swedish equine sector. HNS main areas of focus are breeding and rearing, education and to provide forums for all organizations within the Swedish equine sector to come together and work with common questions. HNS has collected this feedback from 13 national organizations within the Swedish horse industry. - It is important with good animal welfare during transport. We welcome the ambition that a new regulation should aim to reduce long-distance transport of live animals for slaughter. Horses that are transported long distances to slaughter within the EU must have good conditions. The goal should be that the slaughter of horses and other animals takes place in the member state where the animal is held via short and direct journeys. - Horses are generally transported to a greater extent, more often and for more different purposes than other food-producing animals. These transports are in different ways crucial to be able to run different horse activities, carry out equestrian sports and competitions based on the current structure, as well as a range of different leisure and hobby activities. A mutual EU regulation must consider the need for differences in the transport of horses for slaughter or for sport & competition, breeding & rearing, the performance of community services and other business activities. - Most of the horse transports between Member States and domestically is for purposes other than slaughter. These are horses that are generally used to being transported, with high-quality transports and frequent supervision. Good conditions when transporting horses is important for welfare, but new regulation and animal welfare standards must also be balanced against practical and economic conditions. The proposal lacks a full impact assessment regarding effects these proposed changes will have on the European horse industry. - The proposed changes are very far-reaching. Applied in their entirety, these will entail very large costs and administration and are in parts also not practically feasible, e.g. due to the current vet shortage. - For the Swedish horse industry, it is a crucial that relevant purposes of horse transport (excluding transport of horses to slaughter) are included in Article 2, paragraph 2 (c) and that only Article 4 of the regulation is applied for these purposes. Horses for breeding purposes need to be included in Article 2, paragraph 2 (c) as well as horses transported for for various community services and other relevant purposes. It is irrational that a sport horse transported to a competition one day and to a test or breeding evaluation the next, is exempted from the main rules in the regulation on one day, but not the next. - Sport horses are transported for the purpose of performance (work) and their well-being is therefore of great importance. These horses are generally used to being transported, it uses high-quality transports, and there is therefore of large interest that the transport is done under high standards. - We advise to not use the term "equestrian sport" in Article 2, paragraph 2 (c). This definition is normally used for the sport disciplines within national-, European- and international equestrian federations. It is far too narrow and excludes other sports within the horse industry, e.g. trotting, horse racing, western etc. It is crucial to use a term that cover horse sports in a broad sense, regardless of disciplin. - The majority of proposed dimensions do not match today's commercial manufacturing dimensions for various types of horse transport. - The proposed veterinary supervision during loading/unloading of transport is not practically feasible given the strained situation regarding veterinary access in Sweden and (as far as we understand) also within several EU countries. Detailed comments are attached as a separate file.
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