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VIER PFOTEN International

FOUR PAWS

VIER PFOTEN is an animal welfare organization that campaigns for the protection of animals in distress and promotes science and research in animal welfare.

Lobbying Activity

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

8 Dec 2025

FOUR PAWS welcomes the opportunity to provide feedback on the Commissions draft delegated Regulation supplementing Regulation (EU) 2016/429 of the European Parliament and of the Council, as regards animal health requirements for non-commercial movement of pet animals. Please find our detailed feedback attached.
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Meeting with Tilly Metz (Member of the European Parliament, Rapporteur) and Humane World for Animals Europe and Danish Shipping

12 Nov 2025 · Animal transport

Meeting with Andi Cristea (Member of the European Parliament)

29 Oct 2025 · European Citizens' Initiative: Fur Free Europe

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

20 Oct 2025 · Animal transport

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

1 Aug 2025

FOUR PAWS International welcomes the opportunity to contribute to the European Commissions Fur Free Europe Call for Evidence. In our submission, we outline why Option 2a comprehensive ban on fur farming and on the placing on the market of farmed fur products, including imports from non-EU countriesis the only viable and future-proof solution. Our position is grounded not only in the well-documented animal welfare issues inherent to fur farming but also in the significant public health risks and environmental harm associated with the industry. The submission presents compelling evidence of overwhelming societal support for a ban, along with data illustrating the economic decline and long-term unviability of fur production. It further argues that a market ban is essential, demonstrating how such a measure aligns with the European Unions broader policy objectives and remains fully compatible with World Trade Organization (WTO) rules.
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Response to Modernisation of the EU legislation for on-farm animal welfare for certain animals

16 Jul 2025

FOUR PAWS much welcomes the opportunity to contribute to the Call for Evidence. There is growing consensus among scientists, policymakers, and the public that the EUs animal welfare legislation is outdated and no longer reflects modern ethical, scientific, and societal expectations. The Fitness Check concluded that legislation is outdated and not fit for purpose - thus failing to adequately protect farmed animals, notably in light of modern science and mounting public concern. Today, animals are still confined in cages, unable to perform even their most basic natural behaviors, despite overwhelming scientific evidence that such systems severely compromise their physical health and psychological well-being . Modern ethology and veterinary science have consistently demonstrated the cognitive and emotional capacities of farmed animals, and have identified serious welfare risks in practices like confinement, mutilations, high stocking densities, and inadequate environmental enrichment. EFSA has called for a phase-out of cages for laying hens, sows, and calves. Simultaneously, animal welfare has become a core concern for Europeans as evidenced in the findings of the 2023 Eurobarometer. In addition, FAO and WOAH studies stress that improving animal welfare is not just an ethical imperative but also central to sustainable food systems, biosecurity, and antimicrobial resistance reduction. Poor welfare conditions in farming are linked to higher disease burdens and greater antibiotic use. The economic case for reform is also viable. Impact assessments show that transitioning improved husbandry systems is feasible. Meanwhile, several Member States and leading companies have already begun transitioning to higher welfare systems, yet face competitive disadvantages in the absence of harmonized EU legislation. The Common Agricultural Policy could much support farmers in transitioning toward higher animal welfare, through the better use of existing instruments like eco-schemes, animal welfare measures, and investment aids - by linking subsidies to compliance with and progress beyond basic welfare standards. To enhance long-term planning and investment security, it is also essential to introduce an animal welfare benchmark a forward-looking framework outlining future minimum welfare requirements over a certain time horizon. This benchmark would help align subsidies with gradual legal reforms and prevent public funds from reinforcing outdated or harmful practices while clear targets and monitoring tools, coupled with financial incentives, are essential for farms to commit to animal welfare improvements with confidence and support. Not least, looking at the EUs international competitiveness, where the answer to ensuring the market advantage for EU producers lies in conditionality for animal welfare under grounds of public morals, accepted by the WTO. A comprehensive review and modernization of the EUs animal welfare laws is not only scientifically justified and publicly demandedit is also economically feasible and critical to aligning agricultural practices with the EUs environmental, health, and ethical goals. A non-exhaustive list of literature and scientific references to supporting the Call for Evidence is enclosed.
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Response to Modernisation of the EU legislation for on-farm animal welfare for certain animals

16 Jul 2025

FOUR PAWS much welcomes the opportunity to contribute to the Call for Evidence. There is growing consensus among scientists, policymakers, and the public that the EUs animal welfare legislation is outdated and no longer reflects modern ethical, scientific, and societal expectations. The Fitness Check concluded that legislation is outdated and not fit for purpose - thus failing to adequately protect farmed animals, notably in light of modern science and mounting public concern. Today, animals are still confined in cages, unable to perform even their most basic natural behaviors, despite overwhelming scientific evidence that such systems severely compromise their physical health and psychological well-being. Modern ethology and veterinary science have consistently demonstrated the cognitive and emotional capacities of farmed animals, and have identified serious welfare risks in practices like confinement, mutilations, high stocking densities, and inadequate environmental enrichment. EFSA has called for a phase-out of cages for laying hens, sows, and calves. Simultaneously, animal welfare has become a core concern for Europeans as evidenced in the findings of the 2023 Eurobarometer. In addition, FAO and WOAH studies stress that improving animal welfare is not just an ethical imperative but also central to sustainable food systems, biosecurity, and antimicrobial resistance reduction. Poor welfare conditions in farming are linked to higher disease burdens and greater antibiotic use. The economic case for reform is also viable. Impact assessments show that transitioning to improved husbandry systems is feasible. Meanwhile, several Member States and leading companies have already begun transitioning to higher welfare systems, yet face competitive disadvantages in the absence of harmonized EU legislation. The Common Agricultural Policy can support farmers in transitioning toward higher animal welfare, through the better use of existing instruments like eco-schemes, animal welfare measures, and investment aids - by linking subsidies to compliance with and progress beyond basic welfare standards. To enhance long-term planning and investment security, the introduction of an animal welfare benchmark - a forward-looking framework outlining future minimum welfare requirements over a certain time horizon - is essential. This benchmark would help align subsidies with gradual legal reforms and prevent public funds from reinforcing outdated or harmful practices while clear targets and monitoring tools, coupled with financial incentives, essential for farms to commit to animal welfare improvements with confidence and support. Not least, looking at the EUs international competitiveness - where the answer to ensuring the market advantage for EU producers lies in conditionality for animal welfare under grounds of public morals, accepted by the WTO. A comprehensive review and modernization of the EUs animal welfare laws is not only scientifically justified and publicly demanded - it is also economically feasible and critical to aligning agricultural practices with the EUs environmental, health, and ethical goals. We are therefore hoping for an ambitious, future-proof and inclusive animal welfare legislation. A non-exhaustive list of literature resources and scientific references to support the Call for Evidence is enclosed.
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Meeting with Tilly Metz (Member of the European Parliament, Rapporteur) and Humane World for Animals Europe

15 Jul 2025 · Animal transport

Meeting with Patricia Reilly (Cabinet of President Ursula von der Leyen) and Eurogroup for Animals and Compassion in World Farming Brussels

30 Jun 2025 · to follow

Meeting with Patricia Reilly (Cabinet of President Ursula von der Leyen) and Eurogroup for Animals and Compassion in World Farming Brussels

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

Meeting with Antonella Rossetti (Cabinet of Commissioner Christophe Hansen)

26 Jun 2025 · Exchange of views on Animal Welfare and the Future CAP

Meeting with Antonella Rossetti (Cabinet of Commissioner Christophe Hansen)

23 Jun 2025 · Exchange of views on Animal Welfare and the Future CAP

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

12 Jun 2025 · Animal welfare during transport

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

22 May 2025 · to follow

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

27 Mar 2025 · Welfare of dogs and cats

Meeting with Marko Vešligaj (Member of the European Parliament)

12 Mar 2025 · Welfare of dogs and cats and their traceability

Meeting with Tilly Metz (Member of the European Parliament)

4 Mar 2025 · Global Health

Meeting with Pierre Bascou (Acting Deputy Director-General Agriculture and Rural Development)

22 Jan 2025 · CAP and animal welfare

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

22 Jan 2025 · Animal welfare during transport

Meeting with Benoit Cassart (Member of the European Parliament)

20 Nov 2024 · Prise de contact

Meeting with Jessika Van Leeuwen (Member of the European Parliament)

8 Oct 2024 · Cats and Dogs regulation

Meeting with Sebastian Everding (Member of the European Parliament) and Eurogroup for Animals

1 Oct 2024 · Networking Event: Exhibition Silent Suffering

Meeting with Lynn Boylan (Member of the European Parliament)

1 Oct 2024 · Animal welfare of companion animals

Meeting with Stefan Köhler (Member of the European Parliament, Shadow rapporteur for opinion) and Eurogroup for Animals and

1 Oct 2024 · Politischer Austausch

Meeting with Sebastian Everding (Member of the European Parliament)

4 Sept 2024 · Introductory meeting

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

14 Aug 2024

FOUR PAWS' appreciates the opportunity to comment on the draft Commission Implementing Regulation on the data to be provided for the reference year 2026 pursuant to Regulation (EU) 2018/1091 of the European Parliament and of the Council on integrated farm statistics as regards the list of variables and their description. Please find attached our opinion.
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Response to Protection of animals during transport

4 Apr 2024

The global animal welfare organisation FOUR PAWS has been working for years on the topic of the transport of live animals and welcomes the possibility of providing feedback on the proposal for a regulation on the protection of animals during transport and related operations. Despite some ameliorations, the proposal is insufficient to enhance the welfare of billions of animals transported each year within the EU and from the EU to third countries. Transport duration for animals destined for slaughter has been set at 9 hours. But this journey limit does not apply to animals transported for other purposes (e.g: breeding and fattening). In fact, those animals could still be transported for 21 hours and, if necessary, for an additional 21 hours after having been unloaded for a rest period of 24 hours at a control post. Journeys are still too long, and the welfare of animals cant be guaranteed. Therefore, we demand a ban on long-distance transport and that a maximum journey time of eight hours for cattle, pigs and sheep, independently from their use, be set. Journey times for poultry, rabbits, end-of-career animals are still excessive under the proposal. Those animals should not be transported for more than 4 hours and should not spend more than 6 hours in vehicles and containers. Moreover, the proposal does not only exclude a ban on live exports, but also omits any mention of duration limits for transport at sea. This is concerning as transport by vessel is harsh and numerous tragedies involving thousands of animals have happened at sea over the years. Exports to third countries pose a critical challenge, as adherence to EU legislation cannot be assured, particularly because of the impossibility of on-site inspections by independent EU inspectors. As certification bodies, attendants and animal welfare officers are too tied to the organisers of the journeys, an independent and neutral monitoring of the transport operations cannot be ensured. In light of these concerns, we call for a ban on sea transport and transport to third countries; veterinarians to be on board ships; independent checks and certifications by neutral EU bodies. The proposal misses the opportunity to ban the transport of unweaned animals, day-old chicks and animals in an advanced state of pregnancy. Bio-secure transport is exempted from the provisions of this regulation, but a set of rules to transport lab animals according to their species-specific needs is still missing. In addition, the proposal is not ambitious enough when setting the minimum age to declare certain animals fit for transport. Incomprehensibly, there are several elements in the text that propose lower standards than the current rules. These include: the removal of temperature monitoring inside vehicles; allowance of transport with external temperatures of less than 5°C or more than 25 °C; deletion of minimum air flows levels; less space allocated for pigs transported by vessel; allowance of painful practices such as the use of electric prods and carrying animals by the legs. Furthermore, the proposal does not guarantee continuous access to data essential for effective monitoring, reporting, official controls and the determination of infringements during the entirety of journeys. When it comes to serious infringements, above all related to space allowance and temperature limits, stricter provisions and more substantial sanctions would be needed. Finally, the proposal could have been more effective in its attempt to prevent the phenomenon of assembly centre hopping by demanding to keep animals at least four weeks at the place of departure and destination instead of just 7 days. When it comes to pets, the proposal could have been more ambitious in setting the minimum age of the animals transported, and in considering feeding/watering and species-specific needs of certain breeds. Please, for more details on our position on the proposal, see the attachment.
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Four Paws urges mandatory EU registration for pet breeders

3 Apr 2024
Topic — The evaluation assesses if EU animal health rules effectively meet current objectives and needs.
Message — Four Paws calls for the mandatory registration of all cat and dog breeders to combat illegal trafficking. They propose creating interoperable databases to track microchips, ownership, and animal health status across Member States.12
Why — Stricter tracking would help the organization stop the sale of illegally bred animals from unauthorized holdings.34
Impact — Unscrupulous breeders lose the ability to hide intensive commercial activities under the guise of private keeping.5
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Response to Welfare of dogs and cats and their traceability

13 Mar 2024

FOUR PAWS is the global animal welfare organization for animals under direct human influence, which reveals suffering, rescues animals in need and protects them. We much welcome this Proposal for a Regulation and appreciate the opportunity to provide feedback to it. Please find attached our input, which we hope will prove useful in refining the Proposal, and in any further deliberations.
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Meeting with Maria Noichl (Member of the European Parliament, Rapporteur for opinion)

13 Oct 2023 · Soil health law and animal husbandry

Meeting with Thomas Waitz (Member of the European Parliament)

13 Sept 2023 · Animal Welfare

Meeting with Maria Noichl (Member of the European Parliament)

5 Sept 2023 · Überarbeitung Tierschutzgesetzgebung

Meeting with Anna Deparnay-Grunenberg (Member of the European Parliament)

10 Jul 2023 · Tierschutzpolitik

Response to Review of poultry marketing standards

19 May 2023

FOUR PAWS is pleased to comment on the revision of the marketing standards for poultry. Foie gras is a product for which geese and ducks have to suffer. It is not without reason that the production of this product is not permitted in many countries. We hope that such a ban will be implemented across Europe with the upcoming revision of animal welfare legislation, We would like to emphasise that the keeping of a minimum weight for the livers of ducks and geese for foie gras production, as foreseen in the draft revision of the Marking standards, can only be achieved by force-feeding the animals. Until the end of foir gras production, at least the minimum weight requirements for duck and goose livers should therefore be removed from the EU marketing standards. This would allow foie gras production to be achieved without force-feeding.
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Meeting with Giorgos Rossides (Cabinet of Commissioner Stella Kyriakides), Panayiotis Pourgourides (Cabinet of Commissioner Stella Kyriakides)

7 Feb 2023 · Exchange on the future proposals on the revision of the animal welfare legislation

Meeting with Annukka Ojala (Cabinet of Commissioner Stella Kyriakides) and Eurocities and

16 Dec 2022 · VTC Meeting: Sustainable Food Systems/Procurement

FOUR PAWS welcomes stricter livestock vessel record-keeping

6 Dec 2022
Topic — New EU rules for recording animal welfare controls and contingency plans on livestock vessels.
Message — FOUR PAWS welcomes new rules for recording and sharing official livestock control records. They support requirements for vessel approvals, contingency plans, and exit point standards.12
Why — Improved data sharing allows the group to monitor animal welfare standards more effectively.3
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Response to Specific requirements to verify compliance with animal welfare rules on livestock vessels.

6 Dec 2022

FOUR PAWS welcomes the draft Delegated Regulation supplementing Regulation (EU) 2017/625 of the European Parliament and of the Council as regards rules for the performance of official controls to verify compliance with animal welfare requirements for the transport of animals by livestock vessels and we would like to provide our comments. Please refer to the attached document.
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Response to Evaluation of UCPM

1 Jun 2022

VIER PFOTEN / FOUR PAWS welcomes the possibility to provide evidence on the evaluation of Decision 1313/2013 on a Union Civil Protection Mechanism (UCPM). FOUR PAWS is an animal welfare organisation responding to natural and man-made disasters. Providing feed and veterinary support to companion, farm and kept wild animals is among FOUR PAWS’ contribution to support local communities impacted by disasters, hence preventing further physical and mental health as well as financial impacts of disasters. Helping animal is helping the community they live in. Through the recent years, we could therefore accumulate experience of the UCPM. Please find more feedback in the attachment.
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Response to Empowering the consumer for the green transition

25 May 2022

VIER PFOTEN / FOUR PAWS International welcomes the opportunity to provide feedback to the European Commission’s draft Directive Consumer policy – strengthening the role of consumers in the green transition. As an animal welfare organisation, FOUR PAWS has a genuine interest in empowering consumers to make informed purchasing decisions that contribute to more sustainable consumption, including higher animal welfare. Hence, FOUR PAWS would like to provide comments on the Proposal for a directive – COM(2022)143 in the attachment.
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VIER PFOTEN urges livestock reform in EU nutrient plan

26 Apr 2022
Topic — The European Commission is creating an action plan for sustainable nutrient management.
Message — VIER PFOTEN highlights that livestock farming is a major environmental challenge. They urge the Commission to encourage changes in how animals are farmed.12
Why — Encouraging livestock farming changes would help the organization fulfill its mission of protecting animals.3
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Response to Soil Health Law – protecting, sustainably managing and restoring EU soils

16 Mar 2022

FOUR PAWS welcomes the initiative to create an EU legal framework for soil protection. As identified in the call for evidence, soil health plays a vital role in the production of food, the protection of biodiversity and the carbon cycle. Many farming practices such as crop rotations, nutrient amendments and the degree of tillage, have climate benefits. They can also have negative consequences, as is especially the case for intensive agriculture, which is reliant on external and synthetic inputs that further impact soil health and fertility. This is especially relevant to livestock farming and FOUR PAWS wishes to provide more details in the attachment.
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Response to Application of EU health and environmental standards to imported agricultural and agri-food products

15 Mar 2022

FOUR PAWS welcomes the possibility to provide evidences on the application of EU health and environmental standards to the imports of agricultural and food productions. In particular, we are convinced that it would be both desirable and feasible to introduce animal welfare regulations for imports. Benefits of an introduction Greater consideration of European animal welfare legislation on imports can ensure that: 1) European consumption of animal products only includes accepted production methods - thus preventing imported animal cruelty - and 2) complements so-called "Brussels effect"[https://scholarship.law.columbia.edu/cgi/viewcontent.cgi?article=1275&context=faculty_scholarship] - the process of unilateral globalisation of regulation that results from the European Union de facto externalising its laws through market mechanisms by creating an incentive to use production methods that meet European standards outside the EU in order to have access to the European Economic Area. This is also in line with the wishes of European citizens. According to the Eurobarometer survey "Attitudes of Europeans towards Animal Welfare" 2016 [https://europa.eu/eurobarometer/surveys/detail/2096], over 90% of EU citizens would support this. Feasibility Article XXIV of the GATT [https://www.wto.org/english/tratop_e/region_e/region_art24_e.htm] allows WTO Members to negotiate a regional trade agreement. The risk that a measure negotiated in a free trade agreement between the EU and a partner country would lead to a WTO dispute is low. But even if the measures were challenged before the WTO, the EU would have good arguments to defend them. Past examples of WTO disputes (e.g. seal case [https://www.wto.org/english/tratop_e/dispu_e/cases_e/ds400_e.htm) have shown that a well-constructed measure is possible if it is to pass the WTO tests also outside of an FTA. The EU could thus rely on WTO case law that allows for differential treatment in cases where consumers see two products as different and are not willing to substitute one product for another. The EU could argue that a high welfare product is not the same as a low welfare product, relying on consumer preferences to allow low welfare products to be treated differently for trade purposes (the obligation of non-discrimination is only applied in relation to "like products": thus, if a foreign animal-unfriendly product is not a "like product" and differentiation becomes possible). Possible future use cases In response to the successful ‘End the Cage Age’ European Citizens’ Initiative the European Commission committed in 2021 to phase-out caged systems for farmed animals in the EU. Such a measure will have to be inevitably accompanied by a ban on the sales of imported products produced in caged systems. If, for whatever reason, such a ban was not rate as an internal measure rather than an import ban (and a non-discriminatory measure, as many EU consumers are unwilling to substitute cage-free animal products for caged products), it could still be justified on the grounds of public morality, as EU case law has recognised that in the EU animal welfare is an issue of public morality. See also the event of the French Presidency and Eurogroup for Animals "Animal Welfare and International Trade: Looking into the mirror" (https://www.eurogroupforanimals.org/files/eurogroupforanimals/2022-03/Agenda%20-%20Animal%20Welfare%20and%20International%20Trade_%20Looking%20into%20the%20mirror%20%281%29.pdf ; and https://www.eurogroupforanimals.org/library/bye-bye-cages)
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Response to Updating the list of invasive species threatening biodiversity and ecosystem services across the EU

13 Dec 2021

FOUR PAWS welcomes the possibility to provide feedback to the Proposed update of the list of invasive alien species threatening biodiversity and ecosystems across the EU. Please find our detailed feedback in the attachment.
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Response to Updating Member State emissions reduction targets (Effort Sharing Regulation) in line with the 2030 climate target plan

2 Nov 2021

VIER PFOTEN/ FOUR PAWS International welcomes the opportunity to provide feedback on Commission's proposal on the Effort Sharing Regulation. Please find a more detailed answer in the attachment.
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Response to Sustainable food system – setting up an EU framework

25 Oct 2021

VIER PFOTEN / FOUR PAWS International welcomes the opportunity to provide feedback to the Inception Impact Assessment (IIA) on the EU Sustainable food system framework initiative. Food is a common good. It does not belong to any particular type of businesses or productors but on contrary, it concerns everyone in the society from consumers, civil society representatives, politicians, administrations, to the industry in charge of producing food. However, over the last decades, food production increased its negative externalities, including on the environment, on rural desertification and on animal health and welfare and became one of the main drivers of climate change. FOUR PAWS regrets that over the last years this debate drifted towards consumers responsibility, while many primary producers try to compete on the lowest tier of standards of production, with detrimental effects on farmers incomes, animal welfare, public health and the environment. For this reason, FOUR PAWS welcomes the European Commission’s initiative to launch a horizontal framework law looking at all aspects of the sustainability of the food chain and would like to provide additional remarks on the IIA in the attached document.
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Response to Restoring sustainable carbon cycles

7 Oct 2021

FOUR PAWS welcomes the opportunity to provide feedback to the Commission Roadmap on Restoring sustainable carbon cycles. Please find our more detailed feedback in the attachment.
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Response to Amendment of the Catalogue of feed materials

5 Oct 2021

VIER PFOTEN / FOUR PAWS International welcomes the opportunity to provide feedback to Commission’s draft Regulation amending the Catalogue of feed materials. As an animal welfare organisation, FOUR PAWS has a genuine interest in the sustainability of the entire food chain, and its impact on animals. Hence, FOUR PAWS would like to provide more comments on the catalogue of feed materials in the attachment.
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Response to Animal welfare labelling for food

23 Aug 2021

FOUR PAWS / VIER PFOTEN International welcomes the revision of the animal welfare legislation and the possibility to provide feedback on the Inception Impact Assessment. Please find the full feedback in the attachment.
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Response to Food chain spending programme (2014-2020) – final evaluation

26 Jul 2021

VIER PFOTEN / FOUR PAWS International welcomes the opportunity to provide feedback on the evaluation of the EU Food chain spending programme (2014-2020). First of all, we would like to recall the importance of this programme for the welfare and the health of animals. In particular, we would like to provide feedback on two specific parts of the programme: BTSF trainings and the EU reference centers for animal welfare. Trainings in the field of animal health and welfare are important ways to improve the enforcement of the legislation and harmonise controls. Still, the EU animal welfare legislation is poorly enforced. The EU Farm to Fork Strategy plans a fitness check of this legislation and the consultation could investigate whether further trainings in the field of animal welfare might therefore be needed. When it comes to animal health, FOUR PAWS regrets that many trainings concentrated on emergency measures and the implementation of eradication programmes. Hence, we would like to suggest that the consultation explores whether it would be better to increase the number of trainings aiming at preventing pandemics and other crisis. FOUR PAWS also welcomes the funding of EU reference centres for animal welfare through the food expenditure programme. As these reference centres are specialized on certain animal species, they are very important to ensure better enforcement of the EU animal welfare legislation, for instance by sharing knowledge and best practices. We would nevertheless like to highlight that the reference centres must focus on problems that are actually possible to solve. In this regards, as it is impossible to guarantee a satisfactory level of welfare for fur animals, we are of the opinion that spending money on a reference centre for fur animals is a waste of public money, as this practice should be prohibited.
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Response to Review of the EU school fruit, vegetables and milk scheme - EU aid

26 Jul 2021

VIER PFOTEN / FOUR PAWS International welcomes the opportunity to provide feedback to the Inception Impact Assessment (IIA) on the review of the EU school fruit, vegetables and milk scheme. We are glad that the EU Farm to Fork Strategy plans to review the existing school scheme. FOUR PAWS would therefore like to provide more information in the attached document.
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Response to Revision of the Directive on ship-source pollution

16 Jun 2021

FOUR PAWS / VIER PFOTEN welcomes the possibility to provide feedback on the Roadmap for the revision of Directive 2005/35/EC to bring its provisions on illegal discharges at sea into line with Directive (EU) 2019/883, which requires ships to deliver their waste in ports. As an animal welfare organisation FOUR PAWS / VIER PFOTEN is very concerned that dead farm animals like cattle are found washed up on the coasts and then generate a brief media attention. Randomly selected media reports from 2017 , 2019 and 2021 are among many examples. These are animals that are transported in large quantities by ship. It happens that animals die during the long crossing. The International Maritime Organisation regulations state that if an animal dies during a travel, the body must be opened, viscerated and chopped up before being thrown overboard and never closer than 100 miles from the coast. It seems that these rules are infringed by some transporters. In addition, the reason of the death is often unclear and it may well be that the animal died from a disease. For this reason, animal carcasses repeatedly found on sea shores are not only a strong indicator that the current practice of transporting animals by sea has a huge negative impact on animal health: they can also be a health hazard and a vector for epidemics and diseases. We recommend that the Commission take the planned revision of the legal basis as an opportunity to also address the issue of illegally disposed animal carcasses. A (at least random) check of the transport documents, which according to Regulation (EC) No 1/2005 must be available for each individual animal anyway, would be conceivable.
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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

FOUR PAWS welcomes the opportunity to comment on the draft legislation authorising to feed non-ruminants with ruminant collagen / gelatine and with proteins from insects, pigs and poultry. We are concerned that this proposal is contradicting the political aims of the Farm-to-Fork Strategy. If we are to address the serious climate and environmental impact of our current food and farming system, the Union must instead reduce its production and consumption of meat and dairy products. Please find a more detailed answer in the attachment.
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Response to Digital Services Act: deepening the Internal Market and clarifying responsibilities for digital services

31 Mar 2021

VIER PFOTEN / FOUR PAWS is an animal welfare organisation very active in the fight against illegal online sales of animals. In this regards FOUR PAWS welcomes the possibility to provide feedback on the Digital Services Act. Please find attached a more detailed feedback in the attachment.
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Response to EU Agenda to tackle organised crime (2021-2025)

15 Mar 2021

VIER PFOTEN / FOUR PAWS International animal welfare organisation is glad to provide feedback on the EU consultation on the EU Strategy 2021-25. Please find more detailed feedback in the attachment.
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Meeting with Camilla Bursi (Cabinet of Commissioner Virginijus Sinkevičius), Eglantine Cujo (Cabinet of Commissioner Virginijus Sinkevičius)

2 Mar 2021 · Wildlife & tigers trade

Response to Wildlife trade – alignment of EU rules with recent decisions taken under the CITES convention and changes to EU ivory trade rules

25 Feb 2021

VIER PFOTEN / FOUR PAWS welcome the opportunity to provide feedback on the alignment of EU rules with recent decisions taken under the CITES convention and changes to EU ivory trade rules. Please find a more detailed feedback in the attachment.
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Response to Revision of EU marketing standards for agricultural products

16 Feb 2021

VIER PFOTEN / FOUR PAWS welcomes the opportunity to provide feedback on the roadmap on the EU marketing standard. Please find a more detailed feedback in the attachment.
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Response to Setting of nutrient profiles

2 Feb 2021

FOUR PAWS welcomes the possibility to provide feedback to the Roadmap on the revision of the rules on information provided to consumers. Please find attached the detailed feedback.
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Response to EU strategy for sustainable textiles

31 Jan 2021

Please find attached FOUR PAWS' feedback to the Roadmap on the EU Strategy for sustainable textiles
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Response to Contingency plan for ensuring food supply and food security

13 Jan 2021

FOUR PAWS welcomes the opportunity to provide feedback to the consultation on the Roadmap on the future EU “Contingency plan for ensuring food supply and food security”. FOUR PAWS is an animal welfare organisation active in the humanitarian field. Providing feed and veterinary support is among FOUR PAWS’ contribution to support local communities impacted by disasters. Risk reduction is an important component of FOUR PAWS approach. For this reason, the shape of the future contingency plan, of the guidelines and of the permanent forum are of uttermost importance for FOUR PAWS. Please find more feedback in the attachment.
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Response to 8th Environment Action Programme

23 Dec 2020

FOUR PAWS / VIER PFOTEN welcomes the possibility to provide feedback to the consultation on the New (8th) Environment Action Programme - supporting the European Green Deal. As an animal welfare organisation human, animals and the environment form an indivisible whole. For this reason FOUR PAWS welcomes the new Environment Action Programme (EAP). FOUR PAWS would like to use this opportunity to reiterate the need to consider all dimensions connected to the Environment, which includes animals. Environmental protection cannot be done on the sake of animals and their welfare. On contrary FOUR PAWS would like to suggest that the EAP applies the ‘One Welfare’ approach, which embeds the ‘One Health’, in particular when defining future actions and indicators. Policy coherence is a key corner of any improvements for the environment. In this regards, we welcome the willingness to phasing out environmentally harmful subsides. In particular, we would value that this approach applies also to food systems, in particular to their resilience. Indeed, some developments have been rather contradictory. On the one hand, consumers are increasingly willing to buy local, as rightly pointed out by the Farm to Fork Strategy. This tendency has been exacerbated by the recent Covid-19 pandemic. On the other hand, regions have ‘specialized’ in certain farming, like for example the ‘pig banana’ in Germany or the French region of Britany welcomes most of the pork production in these countries. As a consequence, this specialization moves production away from consumers and makes European production more vulnerable to natural disasters and animal pandemics. EU Trade policy is another leverage to achieve the objectives that the EU has fixed under the EAP and which could benefit from additional coherence. In particular for fighting environmental crime. As an animal welfare organisation, illegal trafficking is an important issue, with an impact on humans, animals and the environment. In particular, FOUR PAWS would welcome measures to step up actions against the trafficking of tigers, which is sometimes linked to the issue of commercial trade of captive bred tigers.
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Response to Improving environmental protection through criminal law

23 Dec 2020

FOUR PAWS / VIER PFOTEN welcomes the opportunity to provide feedback to the consultation on the Roadmap on Environmental crime - improving EU rules on environmental protection through criminal law. For an animal welfare organisation like FOUR PAWS, wildlife trafficking constitutes one of the most immediate threats to biodiversity. The European Union (EU) has an important role to play in addressing wildlife trafficking, as it constitutes a destination market, a hub for trafficking in transit to other parts of the world, as well as the source region for illegal trade in some species. Trafficking has an impact on animals, plants, the environment and even on humans (directly and indirectly as the money from wildlife trafficking may support other criminal activities). For this reason, FOUR PAWS welcomes EU activities to step up actions against environmental crime. Please find a more detailed feedback in the attachment.
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Response to EU humanitarian action: new challenges, same principles

21 Dec 2020

FOUR PAWS welcomes the opportunity to provide feedback to the consultation on the Roadmap on the “EU’s humanitarian aid in the context of the COVID-19 pandemic and beyond.” FOUR PAWS is an animal welfare organisation active in the humanitarian field. Providing feed and veterinary support is among FOUR PAWS’ contribution to support local communities impacted by disasters. Most recently, the Organisation has for example been responding in Beirut after the explosion in the port of August 4. Helping animal is helping the community they live in, hence preventing further physical and mental health as well as financial damages. Furthermore, risk reduction is an important component of FOUR PAWS approach. This is the reason why FOUR PAWS is for instance working with the World Animal Health Organisation (OIE) to implement OIE’s Guidelines on Disaster Management in the Balkan Countries. Please find a more detailed feedback in the accompanying document.
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Response to Revision of the EU geographical indications(GI) systems in agricultural products and foodstuffs, wines and spirit drinks

23 Nov 2020

VIER PFOTEN / FOUR PAWS welcomes the opportunity to provide feedback on the roadmap on the revision of the EU Geographical indications schemes. As the name already clearly implies, EU quality labels, including geographical indications scheme, are designed to inform consumers about a product of value. Even if the label currently only provides information on the place of origin, consumers have higher expectations about the product. The European Commission rightfully identified that citizens’ sustainability concerns e.g. regarding animal welfare are not sufficiently reflected in the EU geographical indications schemes. Therefore, for products of animal origin, the higher expectations of consumers should be taken into account. The first step should be to prevent that animal-unfriendly production methods are getting labelled. We recommend that the European Commission explores the different options to reflect animal welfare concerns through the label, whether through animal welfare components or by linking it to animal welfare labelling to be established at European level or through other alternatives.
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Response to Port State control - Further improving safety, security and sustainability of maritime transport

20 Nov 2020

VIER PFOTEN / FOUR PAWS welcomes the opportunity to provide feedback on the Inception impact assessment on the Port State control - Further improving safety, security and sustainability of maritime transport. As an animal welfare organisation, FOUR PAWS is particularly concerned about the poor conditions in which animals are transported by sea. On port investigations show different breaches to European transport rule and in particular noncompliance towards Regulation 1/2005 on the protection of animals during transport and related operations. Among them, improper equipment of the boat (many livestock carriers were not designed to transport animals but are still approved after their original function), defective feeding and watering equipment, improper loading and unloading – including missing facilities on the ports themselves, overloading, hidden compartments, lack of staff and of training of the staff, etc. (see for example DG SANTE Audit Report 2019-6835 https://ec.europa.eu/food/audits-analysis/overview_reports/details.cfm?rep_id=137) In addition, following recent accidents with livestock carriers such as the ‘Queen Hind’ which capsized in the port of Capu Midia on 24 November 2019 with more than 14.600 sheep on board might suggest that some of these accidents are linked to the use of substandard or inappropriate vessels. Approval of livestock carriers seems to be very unharmonized between Member States, with the example of the Julia LS, that at the same time of the capsized of the ‘Queen Hind’ tried to enter the port of Capu Midia after being denied permission to load in Portugal. As a consequence, FOUR PAWS would like to suggest paying a particular attention at the poor enforcement of the different EU rules by livestock carriers.
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Response to Sustainable Products Initiative

16 Nov 2020

FOUR PAWS / VIER PFOTEN welcomes the Commission’s intention to further develop the sustainable products policy and the opportunity to provide feedback to the Inception Impact Assessment. Please find FOUR PAWS feedback in the attachment.
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Response to EU Methane Strategy

5 Aug 2020

FOUR PAWS welcomes an integrated EU Strategy on Methane to reach the climate goals and the opportunity to provide feedback on the roadmap of the above mentioned strategy. Please find more about FOUR PAWS' feedback to the roadmap in the attachment.
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Response to Fitness Check of the EU legislation on animal welfare

28 Jul 2020

VIER PFOTEN / FOUR PAWS International welcomes the opportunity to comment on the roadmap on the evaluation of EU rules on animal welfare (fitness check). We appreciate the recent approach taken by the European Commission in the field of animal welfare, among which this fitness check, the long overdue evaluation of the animal welfare strategy 2012-2015 and the recent announces part the EU Farm to Fork Strategy and more generally of the Green Deal. We sincerely hope that these engagements will lead to ensuring the welfare of billions of animals farmed in the European Union, in accordance with the specific needs of their specie and to the different phases of their life. Over the last years, both animal welfare science and some sectors of the animal production have greatly evolved. Increasing the welfare of animals can contribute to support the sustainability and resilience challenges of the EU Green Deal. On contrary, it is important to acknowledge the dramatic effects on animals, humans and the environment of producing meat at the lowest cost possible. The EU needs to embrace a holistic approach on how a sustainable animal farming and consumption Europe could look like and have it enforced. Having this in mind, FOUR PAWS stays ready to provide more details on possible changes in animal farming and animal welfare legislation in the EU. Please find additional feedback in the attached document.
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Response to Trade policy review, including WTO reform initiative

14 Jul 2020

VIER PFOTEN / FOUR PAWS International welcomes the roadmap published by the EU on Trade policy review, including WTO reform initiative. The COVID-19 crisis has shown the limits of a system which substantially relies on goods produced on other continents. It is now the opportunity to rightly re-evaluate EU’s Trade policy principles and take a more holistic, sustainable and eventually more local approach for humans, animals and the environment, as presented in the EU Green Deal and more precisely in the Farm to Fork and Biodiversity Strategies. In this regards, it could be interesting to analyse the impact of some vague provisions of trade agreements, especially in the TSD Chapter. There have been some positive developments in the field of animal welfare in trade agreements lately. There is however little consistency in EU’s approach towards animal welfare in the trade agreements, as recently shown during the negotiation on the EU-Mercosur FTA where for instance cheaper meat can enter the EU and therefore endangering meat produced in the EU under higher animal welfare standards. For this reason, we regret that the roadmap doesn’t recognise that EU Trade policy can also have a negative impact. In this regards, it would be important that the roadmap evaluates all possible impacts of EU Trade policy – positive as well as negative. It cannot be limited to finding new markets and at the same time, allow products of lower quality to enter the EU market. This is certainly the pathway towards more autonomy and resilience in Europe. The EU might want to reconsider the role of international trade versus optimising local consumption in some commodities, at least for the most important commodities like feed and food, including at WTO level. The Farm to Fork Strategy mentions that Covid-19 highlighted the trend to consume more local. It is therefore of uttermost importance that the consultation and the future trade policy is not designed in silos but that it is fully in line with the recent commitment of the EU concerning climate, the environment, biodiversity and animal welfare.
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Response to Wildlife trafficking - EU action plan (evaluation)

18 Mar 2020

VIER PFOTEN International / FOUR PAWS welcomes the opportunity to provide feedback on the evaluation of the EU Action Plan Against Wildlife Trafficking. FOUR PAWS recognises the value of the EU Action Plan Against Wildlife Trafficking. Please find attached our complete feedback in the attachment.
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Response to Farm to Fork Strategy

16 Mar 2020

VIER PFOTEN International / FOUR PAWS welcomes the opportunity to provide feedback on the future Farm to Fork Strategy. It is broadly recognised that the meat consumption in EU-countries is way too high and the current so-called conventional animal farming agriculture is one of the main drivers of the climate crisis and cause major damages to the environment . The responsibility for a transformation towards an ecological and economical sustainable, healthy and animal-friendly agricultural system lies in the hands of politics, industry and consumers. Therefore, FOUR PAWS appreciates the holistic approach on the entire food chain which has been chosen by the EU Commission to design the strategy as well as the fact that the EU food system is selected as one of the main pillars of the EU ‘Green Deal’. In order to be truly effective, coherence between the strategy and other policies that effect food production, such as the Common Agriculture Policy, should be ensured. FOUR PAWS' entire feedback to the consultation lies in the attachment.
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Response to Animal health requirements for movements of terrestrial animals and placing on the market of products of animal origin

23 Jul 2019

FOUR PAWS/VIER PFOTEN welcomes the Commission Delegated Regulation regarding animal health requirements for movements within the Union of terrestrial animals and hatching eggs and the Annexes that will supplement Regulation (EU) 2016/429. We appreciate the opportunity to participate to this Public Consultation and would therefore like to invite the European Commission to examine the recommendations provided herein in its further deliberations. While Council Regulation (EC) No 1/2005 applies to the movement of dogs, cats and ferrets, there are still no harmonized guidelines for their transport. Species-specific guidelines and minimum conditions of safety and welfare before, during and after transport for dogs, cats and ferrets should be implemented at the EU level by completing Regulation 1/2005. These include standards for the cages and containers used for their transport, as the lack thereof can facilitate disease transmission. Overall it seems impossible that the conditions laid down in Regulation 1/2005 can be met when the vehicle used for animal transport is a passenger car or a van (as it is often the case). However, there is no system within IMSOC/TRACES enabling the cross-checking of licence plates with vehicle types. Conformity with the animal transport requirements therefore rests upon the authorities of the country of departure. A system for verifying the authorisation of the transporter and compliance of the vehicle used for the transport of animals with regard to the minimum standards of Regulation 1/2005 should be implemented. Overall, the need for the review of the 1/2005 was reiterated during the AGRIFISH Council Meeting on July 15th, 2019. Moreover, cconsidering the increasing number of animals crossing borders, we strongly suggest that derogation possibilities for the commercial movement of young animals not vaccinated against rabies comes an end. It is particularly interesting to underline that countries that still allow deviation with respect to the movement of unvaccinated dogs and cats are directly involved in the international illegal puppy trade networks. Stricter conditions regarding the non-commercial movement of unvaccinated young animals should be established too. Furthermore, it is fundamental that Member States ensure that they have a sufficient number of quarantine facilities, functional and adapted to the needs of the different species they might host. Finally, FOUR PAWS / VIER PFOTEN would like to point out that there is little value in the categorization of registered and unregistered equines from a health perspective, as registration does not guarantee the free-of-risk status of the animal and should not be considered a health indicator.
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Response to Evaluation of the EU Animal Welfare Strategy (2012-2015)

14 Jun 2019

The feedback is given on behalf of FOUR PAWS / VIER PFOTEN International animal welfare organisation. FOUR PAWS is the opinion that the EU shall continue to lead the improvement of animal welfare globally and should be proud of developing its EU legislation for the protection of animals. The EU has never been so active in the field of animal welfare than when it was conducting its action plan or its strategy on Animal Welfare. When there is a political commitment to effectively improve the welfare of animals in Europe, having an Animal Welfare Strategy for Europe is then a very efficient tool. Recently, European citizens expressed their wishes for the EU to continue to improve the welfare of animals. This was particularly the case with the Eurobarometer 442 and with the consultation for the future of Europe. The objective to improve the welfare of animals is therefore still very coherent. The Commission should be more ambitious in the field of improving the legal framework on animal welfare, either through an Animal Welfare Framework Law or a new Strategy with legal actions. Commission’s ambitions are however far below those of citizen. For instance, although it is very positive that the actions foreseen in the annex of the strategy have been delivered, it is regrettable that it took two mandates instead of one to deliver them. In addition, it is unwelcome that the Commission did not act further in terms of proposing legislations when reports were showing the need to improve the welfare of certain animal species. The strategy would have been more efficient with higher political ambitions (legislations). A perfect example is the labelling method of production: the EU Commission decided against the results of the survey although EU Citizens were in favor of such a system. Besides citizen’s demand, many animals farmed in Europe still live in poor conditions and deserve better legal protection. Moreover, certain species are very poorly or not protected by EU legislations. This is the case for rabbits for instance. Although the need to improve the welfare of these animals has been pointed out by the European Parliament, it was not initially covered by the strategy. The actions were coherent and covered a large scope of the animal welfare topics but there was still space for better effectiveness, and it is unfortunate that the actions and reports of the strategy have not been translated in legislation and actions to better protect the animals. Enforcement is one of the weaknesses of the EU Animal Welfare legislations. For this reason, the aim of the EU Platform on Animal Welfare is to improve compliance. Unfortunately, the platform wasn’t integrated in the strategy and, similar to other soft initiatives (Brussels Declaration on pig castration), it does not sufficiently support Member States to improve compliance. It is regrettable that there is often a lack of appetite from Member States to comply or that they often abuse of exceptions as a way to ignore legislation such as in the case of beak trimming or tail docking of pigs. The Commission should be a better guardian of the EU law and start more infringement procedures. Animal Welfare is often better integrated in other policies such as in trade and international cooperation. The EU has often a very beneficial and valued input, such as in the OIE Animal Welfare platform for Europe. In terms of agriculture, the EU failed to integrate the Animal Welfare Strategy. The CAP could have been a very efficient tool to enforce EU legislation or to further improve the welfare of animals. However, cross-compliance isn’t sufficiently constraining and cannot compensate for failures of national control bodies. In addition, farmers do not get enough incentives from the CAP for going beyond the legal requirements. FOUR PAWS would welcome a new Strategy if it includes political and legislative actions. The EU Platform should be part of the Strategy if the decision is to keep it.
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Response to Rules for establishments keeping terrestrial animals and hatcheries and their traceability

22 May 2019

FOUR PAWS/VIER PFOTEN welcomes the Commission Delegated Regulation for the registration of establishments keeping terrestrial animals (and hatcheries) and for the identification and registration of certain kept terrestrial animals, and the Annexes that will supplement Regulation (EU) 2016/429. FOUR PAWS/VIER PFOTEN appreciates the opportunity to participate at the Public Consultation and would therefore like to invite the European Commission to give thought to the following recommendations in its further deliberations. FOUR PAWS/VIER PFOTEN welcomes in particular: • The registration obligation for risk-posing establishments such as dog breeding facilities; • The extension of the registration obligation to transporters of dogs, cats and ferrets; • The requirement for granting approval to animal shelters and assembly centers that move animals to other Member States However, there are certain points where we would like to provide our input, also taking into consideration national constraints.
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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