“UNREALISTIC AND INADEQUATE”: ERA’s stance on Animal Transport Proposal
In December 2023, the European Commission published a legislative proposal on the protection of animals during transport. In this context, the Commission opened a public consultation, the results of which will be summarized and presented to the Parliament and the Council to feed into the legislative debate. In this regard, the European Rabbit Association (ERA) shared its preliminary remarks on the proposal.
ERA and all operators of the rabbit sector attach great importance to transporting animals in the best possible conditions. However, we want to alert EU policy makers on the significant detrimental consequences that the new legislative proposal will have on the economic, social, and environmental sustainability of the EU rabbit sector; a sector whose competitiveness is already undermined by the fierce competition of China which produces more than 50% of world’s rabbits. ERA is convinced that achieving better enforcement of the current EU legislation should be the priority rather than adding new legal requirements.
Moreover, the proposed Regulation includes provisions which will inevitably create more administrative burden at a time when one of the demands of the EU agricultural sector is less bureaucracy.
The keys elements we wish to highlight:
Specific Impact Assessment: ERA calls for a specific impact assessment tailored to the rabbit sector before any definitive decisions are made. With the current impact assessment of the European Commission focusing solely on the "main species," ERA questions the feasibility of making decisions without first evaluating the costs, benefits, and broader impacts on the rabbit sector.
Journey Time Limits: ERA considers the proposed maximum journey time limit for breeding rabbits unrealistic and warns that it will lead to the death of the European rabbit genetics sector and of the European rabbit sector as a whole. Furthermore, when it comes to slaughter rabbits, the 12 hours should only include the time when the truck is on the road.
Stocking Density and Vertical Height of the containers: ERA criticizes the proposed stocking density as excessively low, arguing that increasing space allowance does not necessarily provide more welfare for rabbits, given their natural behaviour to gather in groups. Furthermore, the current vertical height of the containers is adapted to the needs and morphology of rabbits which can therefore remain in a natural and comfortable position during transport. Finally, ERA warns that drastically reducing stocking density could lead to significant adverse socio-economic, animal welfare, and ecological impacts, including increased CO2 emissions.
Handling Practices: Contrary to the legislative proposal, ERA emphasizes that rabbits should not be caught, lifted, and carried by their legs due to animal welfare concerns. Instead, ERA recommends handling rabbits by the skin of the back.
Food and Water during transport: ERA is strongly opposed to the provision laying down that suitable feed and water shall be available for growing rabbits in adequate quantities. Rabbits should be kept on an empty stomach during the journey to reduce contamination of meat during evisceration. Furthermore, it will not allow to limit urine and faeces falling on the animals placed underneath.
Veterinary Presence: While ERA acknowledges the importance of animal welfare, it considers that mandating the presence of a veterinarian at all loading and unloading operations is impractical and economically burdensome, especially given the current shortage in the veterinary profession.