Eurogroup for Animals

Eurogroup for Animals’ answer to the EU Public Consultation on a Circular Economy Act While it is urgent to transition to sustainable and circular food systems, insect farming cannot deliver on enhancing circularity in EU agriculture. Authorising waste streams to be channelled to insect farms could threaten the safety of the food chain without sustainability benefits.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Eurogroup for Animals welcomes the opportunity to comment on the revision of the EU general pharmaceuticals legislation for human use, offering its full support to measures which will ensure access to affordable and effective medicines for all. Our submission joins the efforts and aligns strongly with ICAPPP, including also some individual comments and recommendations.

Eurogroup for Animals welcomes the Commissions proposal for a European Biotech Act, considering it a timely opportunity to place human-relevant, non-animal biotechnologies at the centre of the EUs biotechnology strategy. By doing so, the Biotech Act will better align biotechnology policy with European values, scientific excellence, societal expectations and public health priorities.

Eurogroup for Animals welcomes the European Commissions Biotech Act as a chance to unlock circular, sustainable, and competitive food systems as well as to embed ethical, impactful innovation in EU biotechnology.

Eurogroup for Animals welcomes the opportunity to provide feedback on the Revision of EU legislation on hazard classification, labelling and packaging of chemicals (CLP). We are the pan-European animal advocacy organisation representing more than 85 animal protection NGOs. We advocate for the protection of animals used for scientific purposes, including regulatory testing.

Eurogroup for Animals welcomes the possibility to contribute to the call for evidence on the European Biotech Act II. This initiative provides a valuable occasion to support biotechnologies that can unlock just, circular, sustainable, and competitive food systems and to expand upon the Biotech Act I, the EU Life Sciences Strategy, the EU Roadmap towards phasing out animal testing, as well as other pertinent EU…

Eurogroup for Animals welcomes the opportunity to provide feedback to the call for evidence on the European Innovation Act. We strongly encourage the prioritisation of non-animal, biologically-relevant innovations as a central pillar of the EUs innovation agenda.

Eurogroup For Animals welcomes the EU initiative aiming at further embedding sustainability into corporate governance, which would amend the reporting requirements of the Non-Financial Reporting Directive (NFRD). In that context, Eurogroup For Animals strongly believes that the concept of non-financial reporting currently developed at the EU level should encompass animal welfare.

Please find attached the submission of Eurogroup for Animals. Recalling that nature, biodiversity and wild animals are extremely fragile and have an intrinsic value that cannot be monetarily quantified, Eurogroup for Animals calls for extreme caution and transparency in the development and implementation of nature credits.

Eurogroup for Animals welcomes the Chemicals Strategy for Sustainability of the European Commission. As chemical policies affect the health, safety and welfare of humans and animals, these policies are of particular interest to Eurogroup for Animals and its 73 Member Organisations.

Eurogroup for Animals welcomes the European Commissions initiative and urges that the European Strategy on Research and Technology Infrastructures explicitly supports non-animal new approach methodologies (NAMs). To ensure Europes competitiveness and scientific leadership, the strategy should incorporate the following proposals: 1.

Eurogroup for Animals welcomes the planned revision of the EU marketing standards for agricultural products. European citizens clearly indicated that they want farmed animal welfare to be better protected and that they would like to have more information on the way in which animals reared for food are kept.

Eurogroup for Animals welcomes the occasion to contribute to the call for evidence on the revision of the European Institute of Innovation and Technology Regulation (EIT) and the Strategic Innovation Agenda (SIA). This revision comes at a decisive time for European research and innovation.

Eurogroup for Animals welcomes and supports the European Research Area (ERA) Act proposed by the European Commission, which offers an opportunity to foster an innovation-driven and humane research ecosystem as a central pillar of European competitiveness, sustainability, public health and values.

The Vision 2040 for Fisheries and Aquaculture should integrate aquatic animal welfare as a core pillar of a sustainable blue economy, consistent with the Eurogroup for Animals supporting evidence. The framework must reflect strong public expectations and evolving food demand, as 91% of EU citizens support better protection for farmed fish and 70% support stunning before slaughter.

Eurogroup for Animals response to the Commissions public consultation: Nitrates updated rules on the use of certain fertilising materials from livestock manure (RENURE) Relaxed rules on nitrates is a step in the wrong direction - reducing animal numbers and incentivising a dietary shift should be the key priorities The excess of nitrates is linked to high density of farm animals in intensive systems, in combination…

Eurogroup for Animals commends the Commissions initiative to review the Cosmetic Products Regulation (CPR) and welcomes the opportunity to contribute to this public consultation. This evaluation is essential for upholding the EUs high safety and ethical standards for cosmetic products.

Eurogroup for Animals welcomes the opportunity to provide feedback on the EUs framework for national climate targets. It will be important to set national climate targets for agriculture and food. National emissions reduction targets for agriculture will give a clear picture of where the EU is heading in the long term and provide predictability when farmers make investment decisions.

Eurogroup for Animals, Cruelty Free Europe and the European Coalition to End Animal Experiments welcome the publication of the proposal to establish a common data platform on chemicals data (the proposal), and very much support the objectives, as initially expressed by the Commission, to: improve access to chemicals data by removing technical and administrative obstacles.

Eurogroup for Animals believes that the EU should use the revision of Regulation (EU) No 1308/2013 as an opportunity to expand its scope to horse meat and introduce specific marketing standards. Such marketing standards would contribute to strengthening intra-EU supply chains against imports from third countries as well as improving consumer protection and food safety.

Eurogroup for Animals (EfA) welcomes the European Commissions initiative to revise the MSFD following its evaluation, emphasizing that aquatic animal welfare must be explicitly recognised as a key component of marine environmental protection.

Eurogroup for Animals, Cruelty Free Europe and the European Coalition to End Animal Experiments welcome the opportunity to share their views on the Commissions proposal to re-attribute scientific and technical tasks and improve cooperation among EU agencies in the area of chemicals.

Eurogroup for Animals welcomes this impact assessment with the purpose of reviewing some of the provisions of the Cosmetic Products Regulation in light of the objectives of the Chemicals Strategy for Sustainability.

Eurogroup for Animals welcomes the European Commissions proposal to modernise the mandate and governance of the European Chemicals Agency (ECHA). We are pleased to have the opportunity to provide input and would like to take this opportunity to emphasise the need to further strengthen the integration of non-animal approaches within ECHAs mandate, strategic planning, reporting, and operational practices.

Eurogroup for Animals welcomes this initiative which aims to align the basic legal provisions establishing ECHA with its future roles. We support actions that can harmonise safety assessments across EU legislation, but this must reflect the EU’s commitment to reduce and replace animal testing for safety and risk assessment, and be based on full exploitation of the toolbox of New Approach Methodologies (NAMs).

For more than four decades, Eurogroup for Animals has brought together animal advocates throughout Europe to significantly enhance the welfare and protection of animals. This proposal for a Regulation on the welfare of dogs and cats and their traceability has been extremely well-received, introducing much-needed measures regarding the traceability of cats and dogs, breeding practices, and imported animals.

Eurogroup for Animals welcomes the European Commission's proposal on the revision of the geographical indications (GIs) scheme for wine, spirit drinks and agricultural products. Why Animal Welfare in GIs Matters The proposal identifies limitations in the existing framework, including the need to integrate sustainability and animal welfare considerations.

Eurogroup for Animals notes the Commissions proposal on the postponement of deadlines under the Accounting Directive for the adoption of European Sustainability Reporting Standards (ESRS). We hope the postponement provides sufficient time to develop high-quality ESRS, including on animal welfare.

CAP 2023-2027 mid-term evaluation: Animal welfare instruments are insufficiently used The contribution focuses on the continued relevance of the CAP in terms of addressing current needs. More than one million citizens have called on the Commission to end the use of cages in animal farming and there is an urgent need to update the animal welfare legislation in line with citizens expectations and scientific evidence.

We at Eurogroup for Animals appreciate the opportunity to contribute to the discussion and evaluation of the EFSA functioning. Please see our feedback below. Enhancing NGO engagement and dialogue within EFSA One of the challenges in our engagement with EFSA has been participating in stakeholder forums that often prioritise information dissemination over actual dialogue.

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.

Regulation (EU) 2019/6 of the European Parliament and of the Council of 11 December 2018 on veterinary medicinal products in its Recital (68) exposes that: The good manufacturing practice for the purpose of this Regulation should take into account the Union and international standards of animal welfare when active substances are prepared from animals.

We welcome the Commission's proposal for a new Directive on the protection of the environment through criminal law that intends to increase environmental protection and requires Member States to implement stronger criminal provisions more likely to dissuade potential criminals. Eurogroup for Animals and Four Paws call on the European Institutions to support this strong proposal and the necessary improvements.

Eurogroup for Animals recognises the importance of maintaining local slaughter capacity, particularly where it can contribute to reducing transport times and improving animal welfare before and during slaughter.

Eurogroup for Animals welcomes the European Commission efforts to ensure the availability of local slaughterhouses, particularly where they can contribute to reduced transport distances and the associated welfare risks.

Eurogroup for Animals notes the evaluation assessing the impact of the Economic Partnership Agreement (JEEPA) with Japan after five years of implementation. We hope the findings of this evaluation will help the EU and Japan fully activate the cooperation mechanism on animal welfare, which has yet to be utilised. JEEPA only started to be implemented in 2019, but some effects can already be witnessed.

Eurogroup for Animals welcomes EUs support to Ukraine through the Ukraine Facility mechanism. Despite the protracted war, we believe that Ukrainian people need their lives to be rebuilt today. We also support your idea that recovery and reconstruction is not only about rebuilding what was destroyed in the country, but it is about investing in the transition of Ukraine towards a green and sustainable economy.