Extending the use of the non-penetrative captive bolt stunning method for additional categories of animals

The Comité régional porcin des Pays de la Loire (Regional Porcine Committee of the Pays de la Loire) highlights the manual on the emergency killing of pigs published in autumn 2025. This document produced by IFIP and SNGTV has been validated by the French authorities. This reference manual is applied by farmers, after exchange with their veterinarian.

Filed in French · English published by the European Commission

The French pig sector has been working for many years to improve farming conditions, with concrete progress such as castration under local anesthesia, going beyond European requirements, and the mandatory designation of an animal welfare focal point on farms. More recently, in November 2025, a manual on emergency killing in pig farming was validated under the auspices of the French authorities.

French pig producers recall their long-standing and constant commitment to animal welfare, with practices that go beyond European requirements (castration under local anaesthesia, mandatory training of a welfare officer in livestock farming). As first responders of the animals, farmers are confronted with emergency situations requiring rapid intervention to avoid unnecessary suffering.

Filed in French · English published by the European Commission

To the members of the European Commission, Thank you for giving us the opportunity to express our views on this proposed amendment to Regulation (EC) No 1099/2009. For all methods, it is essential to ensure adequate training of farmers so that they can select the method(s) best suited to their practices and implement them under optimal conditions, while ensuring a high level of animal welfare.

The new methods included in the new proposal (captive bolt and high expansion nitrogen foam) are a very welcome complement to the methods that can be used to euthanise sick or injured pigs on the farm. However, in a breeding sow holding, piglets are euthanised before the 14 kg laid down in the legislation. There are three critical periods in piglets of these weights. 1.- post-partum period.

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Pig producer organisations currently rely on the manual for killing pigs on farms, validated by the French authorities. This allows farmers to refer to a recognised document and to apply the methods authorised for animals which are suffering and cannot be treated within their holding.

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The Œuvre dAssistance aux Bêtes dAbattoirs (OABA) welcomes the opportunity to contribute to this public consultation on the draft implementing act amending Annex I to Regulation (EC) No 1099/2009 on the protection of animals at the time of killing.

Copa Cogeca welcomes the opportunity to comment on the draft Implementing Regulation amending Annex I to Regulation (EC) No 1099/2009 regarding the authorisation and extension of certain stunning and killing methods. Our organisations broadly support science based updates of Annex I that provide farmers and operators with additional, practical tools while maintaining a high level of animal welfare.

We welcome the focus on animal welfare at the time of killing. We note that Annex I to Council Regulation (EC) No 1099/2009 may be amended to take account of scientific and technical progress on the basis of an opinion of the European Food Safety Authority, provided that the new method ensures a level of animal welfare at least equivalent to that ensured by the existing methods.

Lav recognises the importance and urgency of updating the rules on the protection of farmed animals, including Regulation (EC) No 1099/2009, in line with constantly evolving scientific knowledge. The objective of preventive stunning is to ensure the greatest possible protection of the animal at the slaughter or killing stages, avoiding suffering and pain.

Filed in Italian · English published by the European Commission

We welcome the opportunity to provide input on the proposed amendment to the annex I of regulation (EC) No 1099/2009 through this public consultation. As an organization committed to the protection of animal welfare, we acknowledge the importance of continuously improving stunning methods in light of evolving scientific evidence.

In Arvet Veterinaria SL, a company in the Spanish livestock sector, we maintain that the application of nitrogen foam from the first day of life is essential, as this is the most critical period, during which the highest number of incidents and non-viable animals are identified on the farm (including congenital deformities, abscesses, diseases, hernias, and feeding problems).

For the High expansion foam method, the scope could also concerned turkeys, guinea fowls and ducks. We would like to share the following opinion about Commission's proposal regarding adding high expansion nitrogen foam as a method for depopulation: The inclusion of high-expansion nitrogen foam as an additional method for killing could provide a valuable tool for managing outbreaks of diseases such as avian influenza…

Contribution to the Consultation Draft Implementing Regulation amending Annex I of Regulation (EC) No 1099/2009 on the protection of animals at the time of killing, to update the list of approved stunning and killing methods.

We support the inclusion of stunning by non-penetrative strike in the head, as scientific evidence shows that EFSA can ensure immediate loss of consciousness and possibly death when properly used. We do not support the introduction of a high nitrogen expansion foam mixture (NEFS).

Filed in Slovak · English published by the European Commission

The European Institute for Animal Law & Policy welcomes the opportunity to provide feedback on a draft Implementing Regulation amending Council Regulation (EC) No 1099/2009 on the protection of animals at the time of killing. Please see our comment attached.

Non-penetrative captive bolt method may be considered an effective method of stunning for piglets weighing less than 5 kg, but should not be used as a method of slaughter (dt.: Tötung). After stunning, death must be induced by exsanguination. The device must be used correctly, its size must be adjusted to the animal, and animal welfare requirements must be met.

In certain situations of disease or injury, farmers have no alternative but to kill their productive animals, the viability of which is seriously compromised. This option is part of the responsibility for the profession of breeder, subject to veterinary monitoring. Killing animals on the farm avoids situations of animal suffering.

Filed in French · English published by the European Commission

We support the inclusion of non-penetrative captive bolt stunning, in line with the scientific evidence provided by the European Food Safety Authority (EFSA), which demonstrates that, when applied under appropriate conditions, it can ensure immediate loss of consciousness and, in certain cases, death. We do not support the introduction of nitrogen high-expansion foam (NEFS) for stunning and killing pigs.

Igualdad Animal considers that, although this regulation is presented as an advancement in animal welfare, it contains significant structural deficiencies that effectively expand the use of killing methods with insufficient safeguards. Participation in this process does not imply endorsement of the current regulatory framework.

Non-penetrative captive bolt (NPCB) The Humane Slaughter Association (HSA) is in favour of using non-penetrative captive-bolt devices for dispatching lambs, kids, and piglets. We agree with the inclusion in EC 1099/2009, bringing it in line with Englands legislation. This method is humane when applied correctly.

Law making in animal welfare at the time of killing must be guided by robust scientific evidence. EFSA assessments indicate that non-penetrative captive bolt and nitrogen high-expansion foam stunning can, under certain conditions, achieve welfare outcomes comparable to or better than currently authorised methods.

Interbev, the French interbranch organisation for the livestock and meat sectors, supported the proposal to authorise the use of a non-perforating bolt pistol as a method of killing lambs and kids under 4.5 kg. This development is consistent with the 2024 EFSA Opinion on the welfare of sheep and goats at killing for purposes other than ploughing, but also with the technical knowledge and expert opinions gathered…

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Spanish food cooperatives appreciate the new stunning methods included in this proposal to amend Council Regulation 1099/2009. However, we believe that the conditions for applying captive bolt pistols that do not penetrate piglets, lambs and kids in Chapter II of Annex I can be interpreted very restrictively.

Filed in Spanish · English published by the European Commission

The Department of Agriculture, Livestock, Fisheries and Food of the Generalitat de Catalunya welcomes the new stunning methods and the establishment of specific requirements for their use, which this draft amendment to Council Regulation (EC) No 1099/2009 adds.

Filed in Spanish · English published by the European Commission

We have previously given feedback on the amendment of Annex I on the use of non-penetrative captive bolt to stun piglets and the use of nitrogen high expansion foam to stun certain species. We support the new amendment concerning stunning of lambs and kids with non-penetrative captive bolt as it is in line with EFSA's assessment.