Limited progress: revision of Annexes III and IV of Directive 2010/63/EU restricted to a few species
In October 2023, the Scientific Committee on Health, Environmental and Emerging Risks (SCHEER) issued an opinion in support of a revision of Annexes III and IV of Directive 2010/63/EU, with Eurogroup for Animals contributing input in response to a call for information. Considering this opinion, the Commission launched a public consultation to revise Annexes I and III to VIII to ensure that they reflect the state of technical and scientific progress.
We particularly welcome the newly introduced provisions addressing appropriate housing and care standards for cephalopods, zebrafish and passerine birds, as well as appropriate methods of killing cephalopods. We also applaud the prohibition of using inert gases for killing rodents, a position that we have been advocating for several years. However, the revision failed to seize the opportunity to amend the provisions in these two annexes for other species, despite our repeated calls for an update in the light of recent technical and scientific advances.
In our response, we commented on the newly introduced provisions, while also emphasising the need to update other aspects of Annexes III and IV. In brief, we recommended the following:
For the revision of Annex III of Directive 2010/63/EU on the care and accommodation of animals used for scientific purposes:
- Water quality parameters specific to each stage of development for commonly used fish species (other than zebrafish) should be included.
- The minimum cage height for rats should be increased to 30 cm.
- Nursing rabbits should have a nesting box with an entrance that they can close to isolate themselves from their young in order to minimise stress and aggressive behaviour.
- Dogs should always be provided with access to an outdoor run, unless there is a scientific or veterinary justification for not doing so.
- The minimum time after birth that macaques are allowed to be separated from their mothers should be revised, to not less than 10-14 months.
For the revision of Annex IV of Directive 2010/63/EU on the killing methods of animals used for scientific purposes:
- Confirmation of death by rigor mortis is not appropriate and should be removed.
- Methods of killing zebrafish at stages <16 days post-fertilisation should be addressed. Based on the literature, we recommend that the use of a mixture of lidocaine hydrochloride, sodium bicarbonate and ethanol be included as a suitable method of killing.
- Birds can experience severe distress and suffering when killed by CO2 and decapitation. These methods should therefore be deleted.
- The use of a percussive blow to the head to stun fish can cause unnecessary suffering. Consequently, this method should be deleted.
- Rodents killed by decapitation may experience conscious pain before the onset of insensibility. As a result, this method should be deleted.