EU Strategy for the Protection and Welfare of Animals (2012-2015): the European Commission’s evaluation is finally out
The evaluation shows that the Strategy’s implementation process clearly faced serious issues and did not deliver against its objectives or generate significant impact for animals. Given the evidence provided by the evaluation, Eurogroup for Animals appreciates the current Commission’s fresh approach: reviewing the animal welfare acquis among other actions as foreseen under the Farm to Fork strategy.
The evaluation confirms that 4 out of 6 overarching objectives of the strategy didn’t, or only partially deliver, including: a simplified EU legislative framework for animal welfare; providing consumers and the public with appropriate information; optimising synergistic effects from the current Common Agriculture Policy (CAP); supporting international cooperation. Very little or no results were delivered in these areas.
We did see some results on the objectives to develop tools to strengthen Member States' compliance with existing legislation, especially with regard to the compliance with the Laying Hens Directive and the group housing of sows. However, despite these efforts, the evaluation also admits that serious compliance issues still exist with regard to the implementation of the Transport Regulation and Pig Directive. This begs the question why the Commission did not apply similar approaches to all compliance issues, e.g. by launching infringement procedures.
With regard to the objective related to the welfare of farmed fish, although several studies were conducted, this didn’t lead to any measurable results or recommendations. The planned revision of the animal welfare legislation needs to take the newly found scientific knowledge and the consumer interest into account to ensure farmed fish species are better protected at EU level.
The lack of a monitoring mechanism and of data to effectively measure the progress or the impact of its activities, makes it very hard to measure the effectiveness of the strategy. In this respect, the strategy was ill-conceived and the Commission should draw lessons from this for the future. Although many reports and guidelines were delivered, the evaluation failed to demonstrate to what extent these have contributed to better lives for animals.
The evaluation presents the foundation of the EU Platform for Animal Welfare and the EU reference centers as indirect results of the strategy, however, although these initiatives are applaudable, they were initiated outside of the scope of the strategy.
The evaluation of the strategy acknowledges that consumer interest in animal welfare has increased significantly over the past decade and that the strategy has not been able to meet consumer’s expectations.
The evaluation shows that the Strategy failed to live up to its promises mainly due to a lack of resources, effectiveness, as well as the absence of appropriate tools to measure impact. Now it’s time to look forward though, and we agree with Commissioner Kyriakides: a lot more needs to be done to meet the expectations of EU citizens. The opportunities are there, one above all: the Animal Welfare aquis revision gives the EC a powerful tool to really change the lives of billions of animals.Reineke Hameleers, CEO, Eurogroup for Animals
A deep dive into the Evaluation of the EU Strategy on Animal Welfare
Terrestrial farmed animals
- Despite the overall aim of the Strategy was to improve animal welfare within the EU, the legislation gap was identified, but not addressed, setting the scene for a mismatch between the relevance of the problem and the overall irrelevance of the responses. Indeed the action designed to contribute to a more uniform protection of animals across the EU "lacked specificity which undermined its delivery".
- There was a lack of integration with the Common Agricultural Policy (CAP), one of the biggest financial instruments of the EU that can foster - or undermine - the implementation of existing animal welfare standards.
- The Strategy aimed at strengthening Member States’ compliance and the evaluation concluded that “the actions and activities designed to support Member States to improve enforcement and compliance (objective 1) were the most appropriate”. However, de facto poor implementation was still recorded with regards - at least - to the Council Directives 2008/120/EC (DG SANTE audits from 2017; and 2018) and 2007/43/EC (EC, 2017), as well as the Council Regulations (EC) No 1099/2009 (CJEU, 2018) and No 1/2005 (DG SANTE audits from 2017; 2018; and 2019).
- The evaluation highlights that the Strategy could have been more operational and it seems difficult to draw conclusions on its overall relevance. Doubts persist on its effectiveness and coherence, and lack of data makes it impossible to assess its efficiency. Nevertheless, we welcome the overall efforts of encouraging coordination and exchange of information and best practices among Member States and, indirectly, of setting the basis for the new European Commission’s work: we fully trust the EC’s commitment to take stock of the major shortcomings of the strategy and act upon them via the EU Farm-to-Fork Strategy, thus revising animal welfare legislation with the aim to make them 1) specific to all the animals being farmed for food production and 2) easy to enforce and implement.
- We welcome the fact that the increased consumer interest and understanding for fish welfare has been recognised and that follow-up actions for fish welfare, under objective 3, are called for.
- Since 2012, the stakeholder view has changed drastically and the need to protect so far inadequately protected species, especially farmed fish species, is seen as a crucial factor for the upcoming revision of the animal welfare acquis to ensure implementable and enforceable legislative provisions for farmed fish.
- Although unrelated to the Strategy’s outcomes, the referenced guidelines by the Platform of Animal Welfare sub-group for farmed fish are a major accomplishment for fish welfare and need to be taken into account for the fitness check for the revision of the animal welfare legislation.
- We welcome that the shortcomings in terms of enforcement, non-compliance and uneven playing field have surfaced in the consultations. As a next step we would like to see specific actions from the EC to mend these shortcomings such as expansion of training activities for competent authorities, comprehensive sets of rules for equines as well as improved enforcement of penalty schemes and infringement procedures.
- In terms of transport legislation, in order to evaluate the impact of the initiatives it is necessary to take a more quantitative approach stepping away from the questionnaires and remote evaluations, and moving towards a more experimental and comprehensive approach including animal and environment based indicators. Ultimately only embedding guidelines in a legislation accompanied by adequate and comprehensive training will give more desired outcomes.
- A great omission is the lack of recognition of the other equidae beyond horses. We would like to see recognition of the EU PAW work on the topic, and see the outputs of the platform to be recognised in the EU Reference Center on Welfare of Ruminants and Equines.
Cats and Dogs
- The general objective of achieving welfare for all animals has not included cats and dogs, hence we hope that a number of already existing recommendations will be recognised in the future work of the European Commission, e.g. TRACES, transport, breeding and online sale recommendations of EU PAW.
- Despite the study undertaken revealing a series of gaps, since 2012 no efforts have been made to fill in these gaps, e.g. to improve the collection of statistics on cats and dogs movement across the EU.
- Trade of pets is currently not dealt with. In order to ensure a safe pet market for EU consumers that is monitored and where animals, sellers and breeders are traceable, there is a need for rules on EU pet trade.
- We welcome that the evaluation recognises that the EU had a strong influence on slaughter standards in third countries, “as EU legislation contributed to changing the methods used in third country slaughterhouses”. This is a confirmation that the EU should look into imposing more EU animal welfare standards on imported goods. Such an approach would also contribute to address the concerns expressed by businesses regarding the lack of level playing field.
- We also welcome that the Commission recognised that “the challenges to the inclusion of more specific requirements on animal welfare in trade agreements are linked to the fact that animal welfare is not explicitly recognised under the World Trade Organization General Agreement on Tariffs and Trade (GATT)”. This should also motivate the EU to include these considerations in its strategy around the modernisation of the WTO. We welcome the recognition that there is a need to improve coherence of trade policy with the objectives expressed by the strategy.
- We welcome that the objective of international cooperation is seen as a long-term objective and that actions on this should continue.
- While the evaluation states that “the issue of coherence with the trade policy has been addressed by consistently including commitments on animal welfare cooperation in Free Trade Agreements”, it does not look at the concrete result of this animal welfare cooperation started by the EU with third partners under FTAs. The reference to the case of Chile is outdated as it occurred before the period covered by the strategy.
- The welfare of wild animals, even though vaguely mentioned in the Strategy, has not been addressed by any of the Strategy’s actions.
- So far, the EU has failed to address the impact of wildlife trade on animal welfare, both at EU level and in the context of CITES. Only two CITES Resolutions address the welfare of traded animals and no efforts have been made to fill in these gaps.
- We welcome that most stakeholders stressed that this lack of protection for wild animals was a major issue for the implementation of the Strategy.