For the subsequent public consultation process I would again highlight that Alice DiConcetto, of Animal Law Europe recently published a short manual on how to submit feedback to an EU Public Consultation that I think will be valuable for advocates. IMO, feedback will be more impactful if it sends a consistent message but avoids sending duplicate submissions which the EU civil servants will just batch together as such.
Also worth flagging that the Commission included in its inception impact assessment two options for Animal welfare at the time of killing considering farmed fish (page 7 of the downloadable doc).
“Option 1: In the light of new scientific evidence, add species-specific provisions for the killing of the five main species of farmed fish (Atlantic salmon, common carp, rainbow trout, European sea bass and gilthead sea bream), and review current requirements which cannot be applied to farmed fish (such as individual monitoring and certain definitions) to better ensure the welfare of those species.
Option 2: In the light of new scientific evidence, add species-specific provisions for the killing of European sea bass and gilthead sea bream and review current requirements which cannot be applied to farmed fish (such as individual monitoring and certain definitions) to better ensure the welfare of those species.”
And on Animal welfare at the farm level noted (page 6) considering “New species-specific animal welfare requirements on dairy cows (and possibly on rabbits, pullets, layer breeders, broiler breeders and day-old chicks ) and with empowerments for the Commission to adopt at a later stage further, detailed rules on additional species – such as farmed fish – based on scientific evidence as it progressively becomes available.” This also mirrors recent comments by Commissioner Kyriakides in which she said “we cannot solve every issue by the end of 2023 . .. it is not possible to have updated EFSA opinions for all relevant species, so we must prioritise while paving the way for future actions. This is why when revising the legislation the Commission intends to propose empowerments allowing specific welfare requirements to be introduced to certain species at a later stage . . . we intend to agree a mandate with EFSA for future reports, . . . , allowing us to lay down rules at a later stage, should co-legislators grant us the relevant empowerments”.
As some examples, Open Wing Alliance, Compassion in World Farming, Humane Society International/Europe (HSI), and Animal Protection Denmark (Dyrenes Beskyttelse) have already submitted comments to this feedback period.
For the subsequent public consultation process I would again highlight that Alice DiConcetto, of Animal Law Europe recently published a short manual on how to submit feedback to an EU Public Consultation that I think will be valuable for advocates. IMO, feedback will be more impactful if it sends a consistent message but avoids sending duplicate submissions which the EU civil servants will just batch together as such.
Also worth flagging that the Commission included in its inception impact assessment two options for Animal welfare at the time of killing considering farmed fish (page 7 of the downloadable doc).
“Option 1: In the light of new scientific evidence, add species-specific provisions for the killing of the five main species of farmed fish (Atlantic salmon, common carp, rainbow trout, European sea bass and gilthead sea bream), and review current requirements which cannot be applied to farmed fish (such as individual monitoring and certain definitions) to better ensure the welfare of those species.
Option 2: In the light of new scientific evidence, add species-specific provisions for the killing of European sea bass and gilthead sea bream and review current requirements which cannot be applied to farmed fish (such as individual monitoring and certain definitions) to better ensure the welfare of those species.”
And on Animal welfare at the farm level noted (page 6) considering “New species-specific animal welfare requirements on dairy cows (and possibly on rabbits, pullets, layer breeders, broiler breeders and day-old chicks ) and with empowerments for the Commission to adopt at a later stage further, detailed rules on additional species – such as farmed fish – based on scientific evidence as it progressively becomes available.” This also mirrors recent comments by Commissioner Kyriakides in which she said “we cannot solve every issue by the end of 2023 . .. it is not possible to have updated EFSA opinions for all relevant species, so we must prioritise while paving the way for future actions. This is why when revising the legislation the Commission intends to propose empowerments allowing specific welfare requirements to be introduced to certain species at a later stage . . . we intend to agree a mandate with EFSA for future reports, . . . , allowing us to lay down rules at a later stage, should co-legislators grant us the relevant empowerments”.