COMPASSION IN WORLD FARMING - IRELAND
SUBMISSION TO THE FOOD SAFETY AUTHORITY OF IRELAND
CONSULTATION PROCESS ON FOOD LABELLING IN THE EU

Introduction

Compassion in World Farming - Ireland, the leading farm animal welfare organisation in Ireland, fully supports clear labelling of all food products of animal origin with regard to animal welfare standards during production. An EU-wide animal welfare labelling system would need to be simple, clear, standardised and compulsory to ensure effectiveness and fairness.

An animal welfare labelling scheme would give consumers additional information on which to base their purchasing choices. It would allow consumers to differentiate, on the basis of animal welfare standards during production, between products that appear similar. In addition, animal welfare labelling would provide clarification of some price differences (i.e. where producers rearing animals in systems with high animal welfare standards incur extra costs that are reflected in the retail price).

Compassion in World Farming (CIWF) is of the opinion that there is growing consumer interest in farm animal welfare. Therefore we are sure that animal welfare labelling of all foodstuffs would be met positively. By giving consumers the possibility of informed choice, they then have the option of using their “consumer power” to encourage high animal welfare standards in food production.

CIWF notes that a recent Eurobarometer survey* found that almost three quarters of those surveyed believed that their purchasing behaviour can influence the welfare of farm animals. However, about half of those surveyed said that they can very rarely or never identify from the label whether the production system is animal welfare friendly.

(* “Attitudes of consumers towards the welfare of farmed animals, June 2005”, pages 31 & 45.)

Present situation regarding animal welfare labelling

At present, some animal welfare labels are seen on food items. These are almost always on food produced from animals reared in high animal welfare systems, e.g. “Free range”, where the labelling is (rightly) used as a selling point. Food produced from animals reared in low welfare systems (e.g. intensive indoor industrialised production systems) rarely, if ever, carry any animal welfare labelling to describe the system of rearing.

The exception to this is eggs. Under EU law, all egg boxes must be labelled with one of three terms that describe the method of production: “Eggs from caged hens”, “Barn eggs” and “Free range eggs”. These terms, provided they are printed legibly, located in a visible position on the box, and are not diluted by misleading images, are an effective way of communicating to consumers the range of animal welfare standards in egg production.

There is also a system of labelling for organically produced food. Such production has its own standards and, with regards to organically produced meat and dairy products etc, these include animal welfare criteria. However, as the labelling of organic produce is a separate system, it will not be discussed in this submission.

Suggestions with regard to a labelling system

CIWF suggests that consideration is given to extending the principle of the EU egg labelling system to all food products from animal origins, i.e. meat, dairy produce, etc.

Consideration could be given to adopting 3 or 4 suitable terms that denote a range of animal welfare standards applicable to the rearing of animals for meat etc., from low to high. Maybe broadly similar terms to the egg labelling terms could be used as the public are already familiar with these. For example, the terms could be: “Industrially farmed” (denoting low animal welfare standards), “Barn reared” (to denote medium indoor rearing systems with good welfare); and “Free range” (to denote high welfare systems where animals have access to outdoors).

Looking at an example: meat from super-fast-growing chickens reared indoors at high stocking densities would carry the label “Industrially farmed”; meat from slower-growing birds reared indoors at lower stocking densities and in an enriched environment would be labelled as “Barn reared”; and meat from slower-growing birds with access to outdoors would be labelled as “Free range”.

As in the egg labelling scheme, each of the terms would be closely defined with regard to the rearing systems it applies to. This would ensure that the animal welfare label truly reflects the animal welfare standard on the farm.

CIWF believes that a standard system of animal welfare food labelling should be as simple as possible. It should be easily understood without reference to further explanations or “de-coding”. It should also be suitable for translation into all EU languages.

Possibly symbols could be used instead of words, thus getting around any need for translation into different languages. CIWF would stress that if symbols are used, then these must be clear and self-explanatory (without reference to a separate guide). For example, a pictorial symbol denoting “Free range” could be a representation of an animal on grass.

CIWF argues that simplicity is essential if an animal welfare labelling system is to be meaningful to consumers. We are aware that there are some complexities that could lead to difficulties, e.g. what label would be given to the meat from intensively reared piglets from free range sows? However, we believe that efforts to provide higher animal welfare standards should be encouraged and that labelling should reflect this.

Labelling must also apply to all processed food and imported products

Animal welfare labelling should be compulsory and should appear on all items of food of animal origin that are on sale in the EU. The labelling scheme should also apply to all processed foods that contain animal ingredients and, ideally, to food being served in restaurants and other eating establishments.

The EU labelling scheme should also apply to all imported foods containing animal products, both unprocessed and processed. CIWF believes that the WTO rules would permit compulsory animal welfare labelling of imported products provided that the label is fair, non-discriminatory and transparent.

Clarity

At present, the good scheme of labelling eggs is in some cases totally undermined with regard to battery eggs. As these are produced from a low welfare system, the label gives no selling advantage. The producers try to minimise its impact by putting the label “Eggs from caged hens” in tiny print on the back of the box where it is not easily visible. Sometimes misleading rural images are shown on the top of the box.

This is totally unacceptable. For any animal welfare label to be effective, it must be clear, of adequate size, and in a position that is easily visible. Misleading images should not be permitted.

Conclusions

CIWF calls on the Food Safety Authority of Ireland to do all it can to encourage EU-wide animal welfare labelling of all food products of animal origin to indicate the level of animal welfare standard during production. The label should indicate a range of animal welfare standards from low to high. This labelling should apply to all such foodstuffs sold in the EU, including processed food and imported food. Ideally, it should also apply to animals products sold in restaurants etc. The system should be standardised throughout the EU and the labels defined in a specific way so that they truly reflect the animal welfare standard in any system of rearing. There is increasing consumer interest in animal welfare and such a labelling system would allow informed choices and would ultimately encourage high animal welfare standards.