Select Committee on Environment, Food and Rural Affairs Minutes of Evidence
Memorandum submitted by Compassion in World Farming (X10)
1. Compassion in World Farming (CIWF) welcomes the inquiry by the EFRA Committee's sub-committee as the poultry industry presents a range of serious animal welfare problems. CIWF's evidence looks separately at the farming of (i) egg-laying hens and (ii) broiler chickens for their meat.
Desirability of maintaining prohibition on conventional battery cages and prohibiting "enriched" cages
2. The EU's 1999 Hens Directive prohibits conventional battery cages from 2012. This ban was based on a considerable body of scientific research showing that, in the words of the EU's Scientific Veterinary Committee, the battery cage has "inherent severe disadvantages for the welfare of hens" (our emphasis).
3. To our regret, the EU Directive does not prohibit "enriched" cages. Scientific research shows that "enriched" cages offer no worthwhile welfare benefits to hens as compared with conventional cages.
4. Under the Directive, the floor space and height required in "enriched" cages is only marginally greater than that which is stipulated for conventional cages. "Enriched" cages are also required to provide a tiny nest box, a perch and litter for dust-bathing, all of which are largely inadequate.
5. In the cramped confines of the cage, competition for the nest box is likely to lead to aggression among cagemates and to hens spending much less time at the nest than they would like to.
6. Too little litter and inadequate physical space, together with disturbance from cagemates leads to dust-bathing in cages often being abnormally short and incomplete and failing to satisfy the hens' strong behavioural need to dust-bathe. Indeed, the facilities are so meagre that most dust-bathing in "enriched" cages occurs not in the dust-bath, but as sham or vacuum dust-bathing carried out on the wire floor.
7. From a welfare viewpoint, very little will have been achieved by the Hens Directive if it leads to hens being moved from conventional cages to "enriched" cages. CIWF believes that instead farmers should change to perchery or free-range systems which, if well-designed and well-managed, can provide good welfare standards.
8. Germany has prohibited "enriched" cages from 2012.
9. Not only does much of the industry want to move to "enriched" cages rather than free-range or perchery systems, but many farmers both in the UK and the rest of the EU are pressing for the ban on conventional battery cages to be overturned. CIWF is fully opposed to this. The prohibition is based on sound science. It is inconceivable that we, as a humane society, should be prepared to accept the continued use for an indefinite future of so cruel a system as the battery cage.
10. CIWF hopes that when the Hens Directive is reviewed in 2005, the UK will take the lead in persuading our EU partners to:
(a) maintain the prohibition on conventional battery cages; and
(b) prohibit "enriched" cages as scientific research indicates that these cages offer no worthwhile welfare benefits to hens.
Economic implications of prohibition of battery cages
11. The ban on the battery cage will result in a small increase in production costs. The amount of that increase is often assumed to be greater than is in fact the case. Nonetheless, UK and EU farmers will be at risk of losing some market share. However, the right approach to this is not to abandon the ban on cages; instead, Government and industry must devise a strategy to ensure that UK and EU farmers are not undermined by imported battery eggs or imported egg powder from battery eggs.
12. The Government, acting as catalyst and facilitator must persuade consumers, the supermarkets, the fast-food caterers and the food manufacturers to support EU hen welfare standards by only buying eggs produced to those standards. In particular, DEFRA should establish a Working Group with representatives from all sectors to examine how to effectively address the economic implications of the ban on battery cages, a ban which we hope will be extended to "enriched" cages.
13. Clearly farmers should not be left to bear, on their own, the extra costs involved in changing to free-range and perchery systems. They must be helped by consumers, both individual consumers and the corporate consumers such as supermarkets, the big fast-food caterers and food manufacturers. All these players must be enthused to play a part in ensuring that a future without cages can become an economically viable reality.
14. Egg consumers, both individual and corporate, can help by being prepared to pay the small extra amount needed to cover the additional costs involved in producing free-range or barn (perchery) eggs rather than battery eggs.
15. National Farmers Union figures show that a free-range egg costs just 1.5 pence more to produce than a battery egg, whereas a barn egg costs just 0.83 pence more to produce than a battery egg. UK consumers eat 180 eggs per person per year; this figure includes the eggs used in processed foods, etc., (Poultry World, September 2002).
16. On the basis of these figures, we could change from battery to free-range eggs for just #2.70 per person per year, provided that retailers charged no more extra for free-range eggs than is needed to cover their additional production costs. Similarly, changing from battery to barn eggs would add just #1.49 to each person's annual expenditure on eggs, subject to the above proviso about retailers' prices.
17. In short, consumers could take the burden from farmers and absorb the cost of moving from battery cages to free-range at a cost of just 5.2 pence each per week. The equivalent figure for a change from battery to barn eggs is just 2.9 pence per person per week.
18. There is strong evidence that consumers are willing to pay extra for better welfare eggs. A supermarket survey carried out by CIWF Trust in 2001 found that in the case of five supermarkets, 50% or more of their egg sales were non-cage eggs, ie free-range, barn or organic.
Major corporate consumers should support EU and UK welfare standards by only buying eggs produced to EU welfare standards
19. It is, moreover, essential that the major corporate consumers fulfil their corporate social responsibility in this area by supporting UK and EU welfare standards. (I refer to EU standards, as laying hen welfare standards have been set at the EU, rather than just UK, level).
20. The corporate consumers can between them prevent UK and EU farmers from being undermined by battery egg imports once the EU prohibition on battery cages comes into force in 2012; they can do this by adopting a policy of only buying or using eggs produced to EU welfare standards, and refusing to import battery eggs from third countries.
21. For this policy to be effective in supporting UK and EU farmers, the corporate consumers must apply it not just to shell eggs (sometimes called "table eggs"), but to the eggs used in products such as ready-made meals, cakes and sauces. This is vital as an increasing proportion of eggs are used in a wide variety of processed foods. It would be damaging to UK and EU farmers if the corporate consumers imported egg powder from battery eggs for use in egg products.
22. The proposition that corporate consumers should adopt a policy of only buying eggs produced to EU standards is not mere wishful thinking.
23. McDonalds in the UK only uses free-range eggs and that applies both to their shell eggs and the eggs they use in their cakes, sauces, etc. If McDonalds, with their broad consumer base, can take this positive approach, it should be possible for all the chain restaurants to adopt a similar policy. Likewise, we should be able to look for a similar supportive policy to the food manufacturers who make the ready-made meals, etc., which have become a common part of our diet.
24. Turning to supermarkets, Marks & Spencer have a policy of only selling free-range eggs and only using free-range eggs in their processed products and ready-made meals. Waitrose only sells non-cage eggs.
25. As indicated earlier, CIWF wants "enriched" cages also to be prohibited. The industry asserts that "enriched" cages involve lower production costs than percheries. In fact, production costs for percheries stocked at 12 birds/m2 are only 23 pence more per bird per year than for "enriched" cages. Moreover, the slightly higher running costs in barn systems at 12 birds/m2 are partly offset by the higher capital costs of "enriched" cages. Moreover, barn (perchery) eggs will have a marketing advantage over cage eggs as, from 2004, eggs from cages"enriched" or batterymust be labelled by EU law as "eggs from caged hens".
26. Government, local authorities, schools, hospitals, the armed services etc., should also support EU standards by sourcing to those standards and not buying imported battery eggs.
27. The policy requiring public bodies to obtain "best value" may cause some difficulties. However, best value should not be equated with cheapest. The concept of best value should be expanded to include the desirability of public bodies supporting standards enacted by the legislature, and not undermining these standards by importing eggs produced in ways which are illegal in the UK and EU.
World Trade Organisation
28. It is generally assumed that under WTO rules, the EU could not restrict the import of battery eggs when its own cage ban comes into force. This thinking may be too pessimistic. Firstly, the UK and the EU must, during the current WTO negotiations, press for a change in WTO rules and policies to end their detrimental impact on animal welfare.
29. Secondly, WTO thinking is already shifting. The change in WTO shrimp-turtle rulings between 1998 and 2001 gives grounds for some optimism. CIWF is particularly heartened by both the Panel's and the Appellate Body's statement in shrimp-turtle in 2001 that an importing country may make it a condition of access to its markets that would-be exporting countries adopt a programme of environmental protection that is comparable in effectiveness (but not essentially the same as) that of the importing country. CIWF can see no reason why this approach should not be extended to animal welfare.
30. The Government and the EU should give careful consideration as to how they can properly rely on this thinking in their future trade policies. The EU may, for example, be able to rely on this approach in, in some way, restricting the import of battery eggs when its own prohibition comes into force in 2012, provided it takes the other measures referred to in the Panel's 2001 shrimp-turtle ruling such as providing technology transfer. The EU could, for example, offer to help egg exporting countries with the know-how as to how to successfully operate perchery and free-range systems.
31. Indeed, the EU has recently decided that it is consistent with the WTO rules for it to ban the testing of cosmetics on animals and, crucially, also to ban the sale of animal-tested cosmetics in the EU, with the sales ban applying to both imported and domestic cosmetics. A similar approach could be taken in the case of eggs. The EU could extend its ban on cages to a ban on the sale of cage eggs in the EU, such sales ban to apply to both imported and domestic eggs. This would prevent EU farmers from being undermined by imported cage eggs.
32. CIWF welcomes the European Commission's recent proposals to integrate animal welfare into the CAP. Farmers could be helped with the costs of moving away from cages under two Commission proposals. These are that financial assistance could be given to help farmers:
(i) meet demanding legislative standards;
(ii) who want to introduce the best of systems which go significantly beyond legally required standards.
Planning permission difficulties
33. Government and local planning authorities must develop a sympathetic approach to farmers who wish to adopt free-range or other extensive systems. Farmers cite difficulties in obtaining planning permission as one of the main obstacles in changing to extensive systems.
BROILER (MEAT) CHICKENS
34. Over 800 million broilers are reared each year in the UK, making them by far the most numerous of farm animals. However, despite this and the severity of the health and welfare problems experienced by these birds, there are virtually no species-specific laws protecting broilers on-farm.
35. The Sub-Committee's terms of reference refer to the impact of new regulations on the industry, but it may be many years before there are any on-farm regulations which affect the broiler industry. The European Commission plans to publish a proposed Directive, but some of the main parts may not come into force until 2019 as it could take three years to be enacted, and major EU welfare provisions tend to have a phase-in period of around 13 years.
36. Far-reaching reforms are needed as the broiler industry is responsible for widespread health and welfare problems. Nearly all UK broilers are industrially farmed. They are kept in huge, windowless sheds which can hold 30840,000 birds. They are so overcrowded that, as the birds grow bigger, one can barely see the floor so thickly is it "carpeted" with chickens.
37. The UK industry stocks at 38 kg/m2 (about 19 birds) or over. Such high densities lead to increased leg disorders, breast blisters, contact dermatitis, hock burns and infections.
38. The 2000 report by the European Commission's Scientific Committee on Animal Health & Animal Welfare (SCAHAW) concluded that "stocking density must be 25 kg/m2 or lower for major welfare problems to be largely avoided and that above 30 kg/m2, even with very good environmental control systems, there is a steep rise in the frequency of serious problems."
Leg disorders and heart failure
39. Modern broilers have been selectively bred to reach their slaughter weight in just 41 days, which is twice as fast as 30 years ago. What grows quickly is the muscle. The supporting structure of legs, heart and lungs fail to keep pace with the rapid body growth. The legs often buckle under the strain of supporting the overdeveloped body. As a result, each year millions of UK broilers suffer from painful leg disorders. Millions a year also die of heart failure.
Chronic hunger in breeding flock
40. The broiler breeders cannot be allowed to grow as rapidly as the ordinary broilers as, if they did, many would die before sexual maturity or be too unhealthy to breed. To avoid these problems, the industry has to slow down their growth rate. This it does by the use of restricted feeding regimes. In some cases, the breeders are given just 25%50% of what they would eat if given free access to food.
41. Mench (2002) reports that breeders may be fed as little as one fifth of the quantity they want to eat and concludes that the breeders are "chronically hungry". The SCAHAW states that the "chronic quantitative food restriction" to which broiler breeders are routinely subjected leads to them being "very hungry" and that "the severe feed restriction .... results in unacceptable welfare problems."
42. The only proper way of avoiding leg and heart problems and hunger in the breeders is to halt the use of fast-growing breeds and replace them with slower-growing chickens.
43. CIWF also wishes to see a greater proportion of UK broilers being reared free-range. Only a very small proportion (2%) are free-range, whereas in France, the EU's largest broiler producer, 12.5% are free-range. The UK industry should be encouraged to move towards the French figure.
Economic implications of any future welfare improvements
44. The cost of moving to better welfare is often assumed to be greater than it is. The SCAHAW report states that reducing stocking density from 38 kg/m2 (around 19 birds) to 30 kg/m2 (15 birds) or 25 kg/m2 (13 birds) would lead to an increase in production costs of 5.3% and 10.2% respectively. However, the SCAHAW pointed out that this increase in costs would be partly offset by decreased mortality rates and improved feed conversion at lower stocking densities.
45. The SCAHAW also reports that using a slightly slower growing bird (slaughter age 51 days rather than the usual 41 days) would add just 5% to production costs. The SCAHAW points out that the use of such slower growing birds would improve several welfare criteria.
46. Thus, reducing stocking density from 38 to 30 kg/m2 and reducing growth rate (taking 51 rather than 41 days to reach slaughter weight) would each add about 5% to production costs, ie 10% in total.
47. This does not mean that retail prices need to go up by 10%. Any increase in on-farm production costs arising from welfare improvements will have a proportionately smaller percentage impact on retail prices. This is because on-farm costs are only one of a range of factors which determine retail prices. Distribution and marketing are also significant components of the final price. For example, a rise in the price of petrol may have as much impact on the retail price of chicken as a lowering of stocking densities.
48. Although the increase in costs arising from welfare improvements are often exaggerated, there will be an increase in costs. The answer to this is not to accept that the broiler industry must continue unchanged with its high level of welfare problems. Instead, a strategy must be devised as to how welfare improvements can be introduced without UK and EU broiler farmers being undermined by lower welfare imports.
49. As with eggs, that strategy must involve a "whole chain" approach in which all key playersconsumers, supermarkets, chain caterers, food manufacturers, the public sectorcommit themselves to supporting EU welfare standards by only buying chicken produced to those standards, and not importing chicken produced to lower welfare standards. This approach must apply not only to table birds but also to chicken meat used in processed foods, such as ready-made meals.
EXECUTIVE SUMMARY OF COMPASSION IN WORLD FARMING'S SUBMISSION
1. The use of cages for egg-laying hens and intensive broiler (meat) chicken production both impose serious health and welfare problems on poultry.
2. The EU Hens Directive prohibits conventional battery cages from 2012. Much of the industry, both in the UK and the rest of the EU, wants this prohibition to be repealed when the Directive is reviewed in 2005. Compassion in World Farming (CIWF) believes the prohibition, which is based on sound science, must stay in place as battery cages have inherent severe disadvantages for the welfare of hens.
3. "Enriched" cages should also be prohibited as these offer no worthwhile welfare benefits to hens. Farmers should instead change to perchery or free-range systems which, if well-designed and well-managed, can provide good welfare standards.
4. Free-range and barn eggs cost only a little more to produce than battery eggs. Consumers could change from battery to free-range at a cost of just 5.2 pence each per week, provided that retailers charge no more extra for free-range eggs than is needed to cover their additional production costs.
5. Nonetheless, when it comes into force in 2012, the ban on battery cages will make part of the UK and EU egg industry vulnerable to imports. The problem is likely to arise not from imported shell battery eggs, but from imported egg powder from battery eggs.
6. The answer is not to abandon the prohibition of the extremely cruel battery cage system. Instead, a strategy must be devised which enables the prohibition of all cages to go ahead without UK and EU farmers being undermined by cage egg imports.
7. Consumers, the corporate sector and the public sector must all be enthused to play a part in ensuring that a future without cages can become an economically viable reality. Supermarkets, the big fast-food caterers and food manufacturers must all fulfil their corporate social responsibility in this area by supporting EU welfare standards. This they can do by adopting a policy of only buying eggs produced to EU standards and not "running off" to buy imported battery eggs. This policy must apply both to shell eggs and the egg powder used in processed foods. It would be helpful if a similar approach was taken by individual consumers and the public sector.
8. Intensive broiler production's main welfare problems arise from overcrowding and the fact that today's broilers have been selectively bred to reach their slaughter weight twice as fast as 30 years ago. The legs, heart and lungs cannot keep pace with the rapidly growing body. As a result, each year millions of UK broilers suffer from painful leg disorders and millions die of heart failure.
9. As a civilised society, we cannot allow this inhumane system to continue. Welfare reforms, particularly the use of slower-growing birds and lower stocking densities, are essential.
10. Although the cost of improving welfare is often exaggerated, an increase in cost is indeed involved. A strategy must be devised which enables welfare improvements to be introduced without UK and EU farmers being undermined by lower welfare imports.
11. As with eggs, a "whole chain" approach is needed in which all the key playersconsumers, corporate consumers (ie supermarkets, the big fast-food caterers and food manufacturers) and the public sectorall commit themselves to supporting EU standards by adopting a policy of only buying chicken produced to those standards, and refusing to import chicken produced to lower welfare standards. This policy must apply not only to table birds, but also to the chickenmeat used in processed foods.
Compassion in World Farming 11 April 2003