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World Horse Welfare

World Horse Welfare is an international charity dedicated to improving horse welfare through education and campaigning.

Lobbying Activity

Response to Modernisation of the EU legislation for on-farm animal welfare for certain animals

16 Jul 2025

The current Council Directive 98/58/EC, which sets out very general welfare requirements for farmed animals, is not fit for purpose. It lacks species-specific provisions, leaving key welfare needs of Equidae unattended and misaligned with current scientific understanding of their physical, behavioural, and mental needs. World Horse Welfares submission underscores the crucial need for revising the animal welfare legislation to recognise Equidae as species with unique and specific requirements. This recognition is vital to ensure effective, evidence-based protection of equine welfare across the EU and to prevent them from being excluded. We show the latest evidence and understanding of equine welfare, to ensure that the needs of all Equidae are adequately met and to highlight the key factors that must be considered to enable them to live a good live. Key considerations: There are minimum requirements that should be met in order for any Equidae, regardless of their purpose or use, to experience a life worth living. All Equidae should therefore fall within the scope of any future legislation that aims to protect equine welfare, whilst promoting opportunities for them to truly experience a good life. Full traceability of Equidae is crucial to protect their welfare and enable enforcement of existing rules. Species-specific provisions are crucial to ensure their welfare is protected and alignment with current evidence. Practical and clear provisions are key to facilitate equal implementation among EU Members states, better functioning of the internal market and enforceability of the rules. Effective animal welfare assessment is essential for developing and enforcing evidence-based legislation and policies that protect equine welfare. Equidae are highly social animals who rely on conspecific companionship for mental wellbeing. Equidae are grazing herbivores, evolved to consume a high-fibre, low-starch diet throughout the day. Equidae need space to move freely to maintain physical health and express natural behaviours. The importance of good nutrition, environments, health and behavioural interactions on the physical and mental welfare of Equidae. People involved in keeping, handling, caring or training Equidae must be able to adequately care for and meet the needs of all the equids they are responsible for. Harmonisation of the interpretation and enforcement of animal welfare laws across the EU is crucial to ensure consistent protection of animals, uphold shared ethical standards, and maintain a level playing field. Animal welfare legislation should be founded on the principle that every animal is entitled to a life worth living and, where possible, a good life. Legislation must provide clear guidance on how to promote positive welfare and minimise negative experiences, not just prevent suffering. Embedding the Five Domains model into the legal framework ensures a comprehensive, evidence-based approach to assessing and supporting welfare. In addition, equine-specific legislation must recognise the species core behavioural and emotional needs. These are captured by the well-established Three Fs: Friends, Forage, and Freedom - social companionship, access to appropriate forage, and freedom of movement. Together, the Five Domains and the Three Fs provide a strong foundation for meaningful, enforceable equine welfare standards. We urge the Commission to read the White Paper we produced in partnership with the Eurogroup for Animals, other leading animal welfare NGOs. It offers essential, evidence-based guidance on how to provide a good life for equids and this complementary information can be used to help guide the development of the new legislation.
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Meeting with Maria Noichl (Member of the European Parliament, Shadow rapporteur)

4 Jun 2025 · Animal Welfare Transport

Meeting with Nina Carberry (Member of the European Parliament)

11 Mar 2025 · Animal Transport

Response to Uniform rules on good manufacturing practice for veterinary medicinal products and active substances

19 Feb 2025

World Horse Welfare welcomes the Commission Implementing Regulation (CIR) on good manufacturing practice for veterinary medical products (VMP) noting that these are essential for both equine health and welfare. The proposal contains reference to animal health, mainly in relation to the quality of VMPs but it does not highlight the need to protect animal welfare during the use of animals for testing nor during their use for production of VMPs. Whilst the use of Equidae in these situations is limited, pregnant mares are used for the routine production of equine Chorionic Gonadotrophin (eCG). Whilst the recombinant equine Chorionic Gonadotrophin (reCG) is under development, currently only eCG is commercially available. Although the welfare of animals used for experiments is covered by other EU legislation, the impact of methods of production on animal welfare are not laid out in the proposal and rely on the conditions of the marketing authorisation. We suggest three changes to the proposal to ensure the welfare of Equidae used for production of materials for VMPs. 1. The proposal should be revised to include good husbandry practices that ensure the welfare of the animals used for both the testing and the production of veterinary medical products is prioritised throughout their lives. 2. The proposal needs to be revised to ensure Member States include in the marketing authorisation specific requirements for the welfare of the animal producing a veterinary medical product. These would include the procedure being under Regulation 2010/63/EU and detail the accommodation, care, equipment, handling and define the schedule of procedures for taking materials, monitoring the procedures impact on the physical and mental welfare of the Equidae, and include a lookback procedure to improve welfare. Currently, it does not make specific reference to Regulation 2010/63/EU, in particular with respect to Equidae. It foresees that the welfare of an Equidae used for eCG production would rely on the particulars of the marketing authorisation. 3. As good manufacturing practice applies to collection of materials from animals, the site master file (Annex VI) should contain information on the animal premise facility, equipment, etc., and health and welfare procedures, monitoring, outcomes, audits and look back.
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Response to Veterinary medicines – list of essential substances for equine species

11 Feb 2025

World Horse Welfare supports both the addition of several new substances to the list, for example Bromfenac for the treatment of uveitis, a painful condition in horses with severe welfare implications, and the removal or amendment of a number of substances for which further data or alternative treatments are available. However, we note that Phenylbutazone has not been proposed as essential for the treatment of horses and, therefore, does not appear in the Annex to the draft regulation. World Horse Welfare supports the addition of Phenylbutazone to the list of essential substances and provides several reasons .
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Response to Protection of animals during transport

11 Apr 2024

World Horse Welfare welcomes the proposal for new rules to protect the welfare of live animals during transport. Council Regulation 1/2005 on the protection of animals during transport has proven to be not fit for purpose and out of date, so an update of the transport rules is required to ensure animal welfare is prioritised during transport. We recognise the very positive and encouraging provisions in the proposed transport regulation including. However, we believe there are many provisions which require revision as they are impractical, do not follow the latest scientific research, do not recognise species-specificities, are not fit for purpose, will not facilitate enforcement or ensure better compliance. Failure to address these concerns will mean that the provisions proposed will not adequately protect the welfare of equids and could pose a risk to their safety. World Horse Welfare detailed comments are in the document attached.
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World Horse Welfare urges digital IDs to stop horse smuggling

3 Apr 2024
Topic — Evaluation of EU animal health rules and their effectiveness in disease control.
Message — The organization calls for a shift to a fully digital identification system to replace vulnerable paper passports. They demand that all equine movements, including overnight stays and markets, be recorded in a centralized database. They also argue the distinction between registered and non-registered horses should be abolished for health purposes.123
Why — Digitalization would reduce administrative costs for compliant owners while improving enforcement against illegal trade.45
Impact — Smugglers and fraudulent traders would lose the ability to hide animal origins using falsified paper documents.67
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Response to Evaluation of the Consumer Programme

4 Sept 2023

World Horse Welfare is pleased to provide feedback to the open consultation on evaluating the EU Consumer Programme. The protection of EU consumers must be at the forefront of the priorities of the European Union. We welcome the Consumer Programme, which aims to protect, empower and place consumers at the heart of the single market. However, some of the programmes objectives have not yet been accomplished, such as strengthening product safety and improving information provided to consumers. This is particularly clear when analysing the horse meat situation.
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Meeting with Francisco Guerreiro (Member of the European Parliament)

21 Dec 2022 · Discuss Equine-related matters

World Horse Welfare demands vets on all initial livestock voyages

5 Dec 2022
Topic — Rules for recording official welfare controls during the transport of livestock on sea vessels.
Message — The group calls for an official veterinarian on board during the first journey and regular supervision. They also demand more detailed contingency plans and better recording of horse-specific welfare needs.12
Why — Detailed reporting requirements would allow the charity to better identify and address specific causes of injury.3
Impact — Transporters would face increased costs due to mandatory veterinary supervision and stricter licensing renewals.4
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World Horse Welfare urges tougher livestock vessel safety rules

5 Dec 2022
Topic — The consultation establishes requirements for official controls to verify animal welfare on vessels.
Message — The organization calls for detailed emergency plans covering delays and heat stress during transit. They propose requiring rest stops within two hours of the port for animal safety. Additionally, they advocate for uploading all inspection photos to a central electronic database.123
Why — Better coordination between port and maritime agencies would improve oversight of animal welfare.4
Impact — Transporters would face increased costs to secure emergency rest facilities near departure points.5
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World Horse Welfare backs science-based antimicrobial restrictions

17 May 2022
Topic — The EU initiative designates specific antimicrobials reserved exclusively for treating human infections.
Message — World Horse Welfare welcomes the proposed legal text and its science-based approach to antimicrobial resistance. They support maintaining medicine efficacy for humans while ensuring treatment remains available for equines.12
Why — Securing access to effective treatments preserves horse health and protects equine welfare.3
Impact — The public loses protection against cross-species diseases if equine treatments are unavailable.4
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Response to Animal welfare labelling for food

6 Aug 2021

World Horse Welfare welcomes the opportunity to provide feedback on the European Commission’s initiative to update EU animal welfare rules. Equines have a unique position in society as they are one of the most versatile animals. Equines play many different roles in society across Europe. The categorisation of equines varies among EU Member States. In some, equines are protected under companion animal legislation, while in others they fall under laws for agricultural animals. This uniqueness suggests that equine animals should be considered in a different category from other pets and farmed animals, and that legislation should be tailored to their particular needs, which differ from those of pets and farmed livestock. We believe the review of the EU animal welfare legislative framework brings the opportunity to ensure equines’ needs are included in every piece of legislation, ensuring high levels of protection and welfare. We would like to highlight the fact that the word ‘equine’ does not appear anywhere in the document. Equines face various welfare hazards throughout their lives that must be addressed in the legislative proposal on review of legislation of animal welfare in the EU. That is why we have provided suggestions to ensure that risks to equine welfare are included in the legislation assessment as well as recommendations to efficiently address those risks and provide legal measures to mitigate them.
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Response to Laying down rules on equine passports

4 Mar 2021

World Horse Welfare welcomes the opportunity to provide feedback to this draft implementing regulation. We have a few concerns on various of the suggested clauses. As general comments: We believe a key point is the need for the European Union to move towards a full digitalisation of the equine identification and registration system. Meaning rules should allow for digital identification documents to be issues ahead of paper lifetime identification documents. This would address some key aspects of the identification and registration procedure such as: - that the animal’s details are recorded on the database as soon as they are identified, - that the whole system is more efficient, making it more difficult to use documents fraudulently and avoid unlawful activities, - that there is better traceability and transparency through the whole life of the equines. To achieve this it is essential to bear in mind that earliest identification of Equidae is a cornerstone of equine traceability. - that when new passports are issued (e.g., duplicates) all information on previous versions will remain so it would be easier to identify which document version is the right one. That is why we believe that by initially introducing a clause stating that the single lifetime identification of equines could be performed either on paper or electronically would permit the EU to move towards this future where digitalisation is the rule.
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Response to Amendment of the IMSOC Regulation as regards the functioning of ADIS, EUROPHYT and TRACES

19 Jan 2021

There are several aspects of the TRACES system that can still be improved in order to ensure its optimal efficacy. In terms of verifying the person or company performing the movement, the system fails to ensure that the information logged into the system, such as the name, identification number and destination address among others, matches. Moreover, as equines are not currently fully traceable, the system is deficient in tracking the true number of movements of equines. This lack of traceability, therefore, makes it difficult to check whether the movement follows the journey plan. We highly recommend: - Further collaboration between competent authorities in terms of data exchange in order to ensure the system does not allow gaps that can lead to the fraudulent transport of animals. - There should be verification methods to ensure the person or/and the company performing the transportation provides real information in terms of name, address of destination, identification number, etc. The use of new technologies could facilitate this task. - In terms of equine transport, we believe implementing full traceability of equines would facilitate tracking their movements, avoiding fraud and therefore risks to food safety. - The Equines’ unique microchip numbers should be logged in the system at the time of performing the movement so that the complete movement of the equines can be tracked, which will discourage fraudulent movements. - The final destination address of the movement should be logged in the system, together with any other stops the consignment will perform, which will help with the tracking of equines transported at the same time that have different destinations. - Checks should be performed in order to ensure that the destination address exists, and it is capable of housing horses
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Response to Revision of ante-mortem inspection and post-mortem inspection

5 Nov 2020

World Horse Welfare has some suggestions on the proposed amendments: • As currently drafted, it may be difficult for veterinarians to issue a certificate as they may be unable to easily refer to the requirements that should be fulfilled in order to sign the certificate. Hence, the requirements should be easier referred into the legislation. • Vets may be challenged to establish the holding of provenance of some equines given that some equine holdings are not registered. • The model certificate at (EU) 2019/628 Annex IV Part III does not meet the principles of good certification as required by Regulation (EU) 2017/625 on the certification of animals and animal products. • There should be a better definition on what a risk for the handler means, in order to avoid vague requirements that could lead to a lack of compliance or to an excessive use of these provisions. For instance, by the insertion of a ‘whereas clause’ along the lines of where the holding does not have the facilities for the safe handling and loading of untamed animals or the animals that are not used to being handled by humans. • Within the legislation it should be defined what constitutes ‘regular’ veterinary inspections. • The word ‘concentrating’ should be replaced with ‘handling’ in the case of domestic ungulates, particularly solipeds as the word ‘concentrating’ is not accurate with these animals. • Unlike other livestock species, an owner is unlikely to be an food business operator in regard to equids. We suggest the wording to be replaced with ‘owner or operator’ within the legislation in order to avoid confusion. • We would like to highlight that the intention to slaughter cannot be at the expense of the animal – e.g. in an emergency situation the animal needs to be killed as soon as possible, without undue delay.
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Response to Laying down the medication record in the equine passport

22 Oct 2020

Unlike most agricultural livestock, many equines are bred for reasons other than for meat production. However, some horses can end up being slaughtered for meat although they weren’t bred for that purpose in the beginning. Substances that are not listed on the permitted substances list a food-producing animal can only be administered if the equine has been permanently excluded from the food chain. Whilst Phenylbutazone (Bute) is not currently on the list of essential substances for horses, it is one of the most commonly administered medicinal substances in equines. FSA and EMA2 examined the potential exposure to Phenylbutazone from horse meat consumed as such and, after the assessment risk, carcinogenicity to humans from exposure was considered very low, based on the available experimental data on organ toxicity and carcinogenicity, as well as on the low exposure levels and the infrequent exposure to phenylbutazone from horse meat. We conclude: 1. There is no strong scientific evidence on the negative effects of residues of Phenylbutazone in horse meat or milk on human health and food safety. However, due to the lack of evidence we advocate to improve research to help establish a safe withdrawal period of this substance. We advocate for a withdrawal period to be established for this substance to help ensure these animals can enter the food chain without compromising their welfare or food safety. Allowing the use of permitted substances has had a huge positive impact on animals around Europe by permitting many animals to enter to the food chain and avoiding potential welfare issues. That is why we believe that adding new substances to this list will enable these positive outcomes to impact favourably on the welfare of horses. 2. We also welcome the move to digital storage of passport information and look forward to its further development to include movements of equines as this would have both health and welfare benefits as well as huge implications on food safety and human health. We support the use of digital passports as a key tool to ensure an effective track of medical information – if this information is also held digitally alongside the identification information.
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Response to Fitness Check of the EU legislation on animal welfare

29 Jul 2020

World Horse Welfare welcomes the aim of the Fitness Check to identify further shortcomings in the design, scope and implementation of the legislation and identify gaps and areas that should and must be improved. Both the transport and the slaughter regulations haven´t addressed the welfare issues identified at the time of adoption and they aren’t pursuing the objectives of ensuring a high level of animal welfare in the context of the F2F Strategy. The following are some examples of the inadequate compliance and enforcement of these pieces of legislation: - Some horses destined for slaughter can be moved through Europe under unacceptable transport conditions. This makes the animals more susceptible to fatigue, exhaustion, injury, disease and dehydration. - The welfare of Equids may be threatened due to a lack of appropriate space allowance since the frequency of horses injured is normally greater in higher density compared with lower density transport. - There is a lack of training and competence among transporters, control post operators, OVs and other people who handle the animals throughout the journey. - There is lack of research on the best management method for ensuring the welfare of equines at the time of killing. We suggest some recommendations that could aid in alleviating some of these negative outcomes for Equine welfare: - Ensure that any individual (veterinarians, drivers, control post staff, etc.) involved at any stage of a horse’s journey receives adequate guidance and training. - Equidae must be provided with constant access to fresh water, along with good quality forage, prior to the journey, during rest stops and upon arrival at destination. - Equidae should be reclassified separately from other farm animals species. - Given that horses differ in shape, size and temperament and have differing experiences of handling, methods of stunning should therefore be adaptive to allow for these variations, ensuring that high welfare is maintained, and stunning is effective. - Introduce a short, finite journey limit, which would reduce the exhaustion and exacerbation of other welfare problems experienced by Equidae going to slaughter. - Introduce mandatory CCTV in slaughterhouse facilities. This can aid the OV in monitoring welfare and serve as an excellent training resource for slaughterhouses to help make all processes as welfare friendly as possible. - Legislation on the transport and slaughter of animals needs to be clearly developed in order be to fit for purpose and to aid enforcement. - Legislation should be open to review when future research shows that it does not adequately protect welfare. - Slaughtering facilities licensed for Equidae should be designed to be suitable for Equidae. - The definition of fitness to transport should be amended to broaden the scenarios in which equines not fit for transport might be found. - The references to “Registered” Equidae should be removed to ensure that the exemptions are not open to abuse, with consideration given to including certain derogations for equines moving direct to high-level competition. - The EC should seek alternatives that reduce live animal transport and go for a carcass- and meat-based trade. - The recently launched Reference Centre for ruminants and Equines should be used to develop further knowledge and scientific evidence regarding Equine welfare, especially in those areas where there are gaps.
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Response to Farm to Fork Strategy

16 Mar 2020

World Horse Welfare welcomes the opportunity to provide feedback on the Farm to Fork Strategy roadmap. We appreciate EU willingness to be the front runner on implementing the 2030 Sustainable Development Agenda, which is essential to address the climate crisis we are currently facing. For many years, EU citizens have demonstrated a strong interest in animal welfare and support for effectively delivered animal welfare. The initiative to reform the Common Agricultural Policy (CAP) provides a useful opportunity to promote higher animal welfare standards and develop a more sustainable livestock farming system. However, we would like to highlight a significant gap that should be further considered when developing this strategy. Firstly, this initiative must consider the importance of Equidae to the EU economy and society. Since Equidae are versatile animals, they can fall into gaps between laws designed for farm or companion animals, often to the detriment of their welfare. When drafting animal welfare policy, the specific needs of Equidae should be considered, rather than covered by broad regulation pertaining either to livestock or pet animals. For instance, - ensure a consistent approach to establish how Equidae are defined and treated within EU law, by clarifying which species are counted as Equidae for the purposes of all relevant legislation, - guarantee that those slaughterhouses licenced to take Equidae can meet the welfare needs of these animals, in their facilities and the training of their personnel, - conduct research in order to acquire better knowledge on the welfare of horses at the time of slaughter, - support the production and dissemination of information on how to meet Equidae´s needs, - expand educational resources on farm animal welfare to encompass equine welfare, - consider the essential role of working Equidae in agriculture. Secondly, we call for a revision and update of the Regulation (EC) No 1/2005 as it currently does not reflect scientific evidence regarding the impact of long-distance journeys on horse health and welfare. The need to improve welfare of animals should encourage the Commission to find solutions to facilitate better enforcement of the transport legislation. The welfare problems associated with these journeys are well-evidenced; and the environmental impacts are clear as more horse meat can be transported in one consignment than live horses. The revision of this legislation must include an environmental impact analysis and a maximum, finite, short journey limit for the transport of horses intended for slaughter, as well as the promotion of meat and carcass transport. Thirdly, as regards consumer information, it is crucial for the next strategy to help consumers to make better informed choices and improve their confidence when purchasing horse meat. Key to this will be to extend mandatory method-of-production labelling basing it on key animal-based indicators, and labelling of country of birth, rearing and slaughter, so that consumers are informed of the meat’s origin. Moreover, in order to ensure improved consumer information, it is essential to promote an EU-level animal welfare labelling scheme that informs consumers about the welfare of animals during food production.
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Response to Rules on operations to be carried out during and after the documentary check identity and physical checks at the border

24 Sept 2019

World Horse Welfare welcomes the intent of this legislation, to ensure equines are correctly identified and traceable and comply with EC 1/2005, and fully support all documentation being checked at border inspection posts. However, we have concerns that this legislation is too prescriptive as currently written and could be detrimental to the welfare of the animals it seeks to protect. We would propose that a more proportionate, intelligence-led and risk-based approach is taken. Research has shown that loading and unloading causes stress in equines and an increased risk of injury to both the equine and to the handler, irrespective of whether the animal is trained or untrained. We would therefore urge that consideration is given to changing the requirements under Articles 3(4a) and 4(3) for equines to be unloaded or partially unloaded unless there is good reason to do so at a port BIP (for example, an animal is injured, the vehicle is overloaded, horses don’t match their passports, documentation is not correct, their country of origin is a high disease risk or they have travelled a long-distance). From an identity perspective, we would strongly suggest that identification takes place on the vehicle as far as practicable, including using silhouettes/photos for initial identification and scanning the microchips of all those that are accessible. If the vehicle is identified as being high risk based on previous compliance issues, which may not be solely based on health status, or equines do not match their passports then a decision may be taken to unload the full consignment and do a more thorough check. If (as under Article 3.5 and 4.2) consignments do need to be partially or fully unloaded then we would urge that this is done in a safe and controlled environment, with CCTV in all areas where equines are present, and experienced handlers, who are used to loading/unloading both trained and untrained animals (i.e. mares with foals at foot and semi-ferals). Furthermore, if the equines are not deemed fit for onward transport there must be adequate facilities available to hold them for as long as needed (in isolation if necessary). In addition, we would urge that these facilities are also made available in the event that equines are refused entry to the European Union and must be returned to their place of origin, to give them somewhere to rest – if necessary - before they make the journey back. These facilities should be species specific and staffed by personnel trained in that species (similar to control posts which are licenced and inspected for that particular species). We also note these checks could happen at a designated place away from the port and would ask that consideration is given to ensuring that the transporter is not able to make a stop and swap the equines before these checks take place. However, if the BIP is at an airport, where horses have to be unloaded, then we have no concerns about identification and physical checks being undertaken on the full consignment, so long as the above criteria are met regarding personnel and the facilities hold horses awaiting inspection. Finally, we would like to ask for clarity on Annex III/1. It is not clear here whether it is 10% of registered horses and/or 10% of ungulates (including unregistered horses) which need to be sampled. In other words, do registered horses need to be sampled?
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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

World Horse Welfare welcomes the opportunity to provide feedback on the delegated act on Animal disease prevention – updated rules on movement of land animals within the EU. As we have raised in previous submissions, we are concerned with the categorisation of equines as registered or unregistered, as from a health perspective we do not believe it adds any value (i.e. an ex-racehorse registered with a breed society could be of a lower health standard than an ID only cob). We believe that if an animal is registered as in training for racing or has an FEI passport that gives it some greater measure of protection, as at that time in its life it is likely to be high value and therefore kept to higher health/welfare standards. However, it does not mean these horses are not at risk. If there is to be derogation for these horses, then we believe the industry regulatory bodies need to ensure that those competing at their events are putting the health of their horse first. Furthermore, we have evidence that the health of these horses, once they are no longer competing and of ‘high value’, can be adversely affected and therefore should not be treated as ‘high health’. In summary, our position is that a registered horse should not be treated any differently to an unregistered horse and therefore this categorisation should be removed. We also note that the difference in terminology between the different Delegated Acts may cause confusion – for example Article 8 (e) of the Delegated Act for rules of entry uses the term ‘regular’ with regard to the number of animal health visits from a veterinarian, whereas Article 92 2(a) of this legislation uses the term ‘frequent’. In addition, the terms low health risk/high health are used interchangeably. Article 46 – our understanding is that this allows for competition horses not be stabled on site if they are competing or to take part in linked competitions in EU countries over the season (e.g. the show jumping and dressage ‘sunshine tours’ in Spain), which we support if the animals are certified and not of a lower health status. However, we are concerned that the terms used are too loose and need further definition, in particular ‘exhibitions and cultural events’. Article 92 2(a) – While we appreciate that the benefits of this horizontal legislation gives the Member States the opportunity to use disease control measures applicable to their specific conditions, we would like to highlight our concern that some of the species-specific detail that would help ensure requirements are not too onerous or too relaxed has been lost. For example, in the absence of a legal definition the term ‘frequent’ will be what it means in plain English and it needs to be loose to allow for the fact different sectors have different levels of disease risk and mitigation of risk (which will require different frequency of animal health visits). However, as it is open for Member States to interpret it differently, we suggest that it should be risk based i.e. following a full risk assessment in every case. Harmonisation in the specific details for each Member State may not be necessary but the outcomes in terms of disease control must be the same.
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Response to Animal disease prevention and control measures

19 Jul 2019

Please find attached World Horse Welfare's response.
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Response to Rules for establishments keeping terrestrial animals and hatcheries and their traceability

22 May 2019

We found it challenging to provide comprehensive feedback on this piece of legislation without having seen the Implementing Acts. We assume that the following will be included in the IA on Animal Identification: - Transfer of ownership - Smart cards - Equidae imported into the Union - Equidae intended for slaughter for human consumption and medication records Registration of premises: Support the registration of all premises where horses are kept as it will improve biosecurity. We would suggest that the extent of the record keeping will differ dependent on whether equines are habitually kept at the establishment or if they are only moving onto it for a very short time. However, we believe ‘habitually’ should be defined as ‘permanent or regular overnight stay’. We suggest that premises such as show grounds, competition events and markets should be registered and at the very least the identification number of each animal at the event should be retained by the event organiser. Animal Movements and Records We believe Art 64 could be interpreted in a number of different ways with regard to which movements need to be recorded and suggest that the wording is changed to provide greater clarity. We also believe that there is a need for all key movements to be recorded so that in the event of a disease outbreak horses that may have been exposed can be easily identified. We take the view that this should capture all movements except in those cases where animals are moved off the premises for exercise in the vicinity of the registered premises or for animals that are moved off and return the same day. It follows that we have concerns about the exclusions in article 64(c) since this would run counter to our proposal that all key movements should be recorded and suggest they are deleted. Smart Cards and IDs Paper passports can be easily tampered with or reproduced and if it can be demonstrated that electronic forms of ID are even more secure then the legislation should allow for their use and should not to restrict the form this electronic ID may take. High Health Status We believe that a category for high health status should be included, which ideally should be linked to the status of the premises as well as the horse. While we understand the Commission’s reasoning for retaining ‘registered’ horses, these equines are not always high health and should not necessarily be treated differently to unregistered horses, particularly with regard to movement. Notifying Transfer of Ownership We would suggest that notification of transfer of ownership should be legislated for by the EU and propose that both parties should hold joint responsibility as we believe this will increase the chances of a PIO being notified of a change of ownership. Article 59 (3)b -suggest application deadlines for identification documents should be harmonised to reduce the opportunity for confusion and increase uptake and compliance amongst operators. Article 60 (1) - given the nature of certain derogated areas, they have found it challenging to comply with the need to have all equines fully identified before they are moved off the derogated area. Suggest that consideration is given to allowing the movement to be permitted if equines have a transponder inserted and are accompanied by a copy of the application for the lifetime document (online or paper). Art 61(1) - suggest rump stickers are permitted for the movement of ponies under 12 months of age from the derogated areas to slaughter. We also strongly recommend that any reference to ear tags be removed from a welfare, biosecurity and food safety perspective. Article 65 2 (a) - we are concerned that a pictorial and verbal description of the animal is not required for unregistered equines. Until there is a viable secondary method of identification that enables a quick identification check of the horse we would recommend that a requirement for a pictorial description is retained.
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Response to Amendment of the list of transmissible animal diseases and amendment/repeal of acts in the Animal Health Law area

25 May 2018

World Horse Welfare is an international horse charity that improves the lives of horses in the UK and around the world through education, campaigning, and hands-on care. Our approach is realistic, science and evidenced based, focusing on the practical to achieve what is possible now while mindful of the future. Freedom from pain, injury or disease is one of the five animal welfare freedoms and the prevention and control of diseases which affect equids is fundamental to their health, welfare and wellbeing. World Horse Welfare welcomes the amendment of the list of transmissible animal diseases in Animal Health Law Regulation (EU) 2016/429. As well as the major equine diseases to be listed, we particularly welcome the inclusion of contagious equine metritis and infection with equine arteritis virus. It is important that surveillance is maintained to control and prevent the spread of these diseases which also impact on welfare. We feel it would be helpful if the list at Annex II was set out by species and in a table showing the categorisation of the disease according to Article 9 of Animal Health Law Regulation (EU) 2016/429.
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Response to Entry into the Union of live animals of the equine species and germinal products

15 Feb 2017

World Horse Welfare has reviewed the model certificate for the importation of registered horses as an exemplar and have the following comments many of which apply to the other model certificates: 1. We suggest that the microchip and unique identification number should appear on the front face of the model certificate. 2. We note that there is nothing in this certificate on the administration of medicinal products that would restrict their entry into the human food chain. This also applies to the certificate for horses entering the EU for slaughter. We suggest that this omission needs to be remedied. 3. We have some difficulty with those paragraphs that refer to the date on which the animal is examined relative to the date of dispatch. It does appear that the animal should be examined and the certificate issued on the same day that the animal is to be dispatched. This should be made clear in the certificate. 4. We are concerned that some elements of the certificate do not comply with the 12 principles of certification which were adopted by the Federation of Veterinarians in Europe and which are reflected in Council Directive 96/93. In particular, could the Commission reflect on the first principle which states:-a veterinarian should be asked to certify only those matters which are within their own knowledge, can be ascertained by them personally or are the subject of a supporting certificate from another veterinarian. For instance, on Page 52 the Veterinarian is required to certify that the animal is dispatched from a country or part of a country directly to the European Union without coming into contact with other animals of a different status. It would not be possible for the veterinarian to certify this at the time of issue and this would not be in compliance with the principles of certification. 5. We understand that the conditions in this model certificate are intended to mirror the OIE guidelines contained in their Terrestrial Animal Health Code. May we suggest that the models be reviewed to ensure they are in full compliance. For example the Glanders freedom draft suggests that export may take place from a Third Country where there has been no case of Glanders for six months, whilst the OIE Code suggests that this figure should be three years. Where a case of glanders has occurred within the previous three years then the six months freedom clause would be sufficient so long as there is an effective surveillance programme in place. 6. We are concerned at the conditions in section 11.2 on residency prior to export. The veterinarian would find it extremely difficult within the principles of certification to attest that the animal or animals had not come into direct or indirect contact with Equidae not of equivalent health status in the 30 days prior to dispatch as this is unlikely to be within his or her own knowledge but should be based on a declaration from someone else. This is one more example of where a review of the wording might be appropriate. 7. It would be impossible for the owner or his representative to certify in accordance with the third indent in section III that the animal will be sent directly to the premises of destination without coming into contact with other Equidae not of the same health status since this would be outside the control of the owner or the exporter. 8. We note that in II.2.3 of the model health certificate for imports of consignments of semen there is a requirement that the Equidae are free of clinical signs of Equine Viral Arteritis and Contagious Equine Metritis. Since in most cases it is difficult to diagnose these diseases clinically we suggest that this requirement should be amended as follows: ‘contained only Equidae where there is no clinical or other evidence of Equine Viral Arteritis and Contagious Equine Metritis.’ We also suggest there should be a requirement that both these diseases are notifiable in the country where the equine semen is collected.
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