Animal Welfare Labelling

International Animal Law (IAL) has referenced attention to the issue of food labeling by governing bodies such as the OIE on previous occassions.

The following article which further addresses this issue is produced by CIWF, one of the leading non-government organisations who focus on the issue of farm animal welfare. (http://www.ciwf.org.uk)

Animal Welfare Labelling

Compassion in World Farming (CIWF) sees labelling as an important supporting mechanism to legislative and market reform on farm animal welfare. It enables consumers to make informed choices and provides producers with the means to clearly differentiate higher welfare products in the market place.

In summary, CIWF believes that:

• All food derived from animals should be labelled as to farming method of production
• Such labelling should be word-based rather than involving symbols or logos
• Such labelling should be mandatory, not voluntary
• Visibility of labelling should be assured by including guidance on the prominence of terms in marketing rules
• Such labelling should apply not just to fresh food, but to all meat, eggs, dairy and related products used in processed food (such as ready meals) and in the foodservice sector
• Such labelling should extend to imports as well as to domestically produced food.

Public perception
If a market is to work effectively, consumers must be able to judge the quality differences between similar products that are on sale. If they are unable to assess the difference in quality, for example between two joints of pork, they will tend to buy the cheaper.

The 2005 and 2007 Eurobarometer studies establish that consumers are often unable to differentiate between high and low welfare meat, dairy products and eggs. The 2005 survey found that 51% of EU citizens can very rarely or never identify from the label if the meat, milk or eggs that they are buying come from a production system that is animal welfare friendly. Similarly, in the 2007 study 55% of consumers report that current labels do not enable them to identify welfare-friendly products.

Producer benefit
Labelling enables higher welfare producers to highlight the benefits of their products compared to those of their competitors. This can help in persuading consumers to pay a higher price and enable producers to recoup the extra cost of producing welfare-friendly products.

Labelling should not be misleading
The label should not mislead consumers into thinking that products derived from industrial farming have acceptable welfare standards.

Products that merely conform to minimum legal standards should not carry a label that implies good welfare
Labels that imply good welfare should not be given to products that merely conform to minimum legal standards as EU legislation still fails to protect animals from many major welfare problems.

This is of particular concern if symbolic labels (e.g. stars or bronze/silver/gold medals) are used. Even awarding one star or a bronze medal implies that the product is acceptable from the welfare viewpoint. That implication would mislead the consumer when applied to products raised only to minimum legal standards, unless in a particular sector legislation does indeed set good welfare standards.

What type of labelling?
CIWF strongly recommends word-based labelling that describes the method of production for meat, milk and eggs and related products. CIWF is sceptical about ‘outcome’ labelling and strongly prefers method of production labelling.

Labelling should be simple, clear and convey the chief characteristic of the production system. In generic terms, this lends itself to a three-tier approach; ‘indoor intensive’, ‘indoor extensive’ and ‘outdoor/free range’. The EU egg labelling regime provides a good example of just such a hierarchy, using terms that are short and easily understood by consumers, i.e. “eggs from caged hens”, “barn eggs” or “free range eggs”.

Whilst understanding that symbols or logos avoid the need for translation in Europe, CIWF fears that it may be difficult to develop symbols that clearly represent the different welfare standards. CIWF therefore prefers word-based labelling to symbols such as stars or bronze/silver/gold labelling as we believe that ‘bronze’ or one star could be used to confer undeserved merit on food produced using industrial production methods that offer poor standards of welfare. Such labelling would only be acceptable if the bronze label or one star could only be attained by producers who achieve welfare standards higher than those of industrial production.

CIWF is similarly sceptical of the use of ‘outcome’-based labelling within systems of production with low welfare potential such as highly intensive poultry production. There is a risk that such labelling could be abused to show such systems in a good light despite the wealth of scientific evidence that establishes their detrimental impact on welfare.

Core problems with outcome-based labelling include:
• Which outcomes will be selected? Outcomes that are easy to measure may be preferred to those that are more important from the animals’ point of view.
• Good scores in, say, just two outcomes may disguise the welfare problems inherent in a particular system. For example, drafts of the Broilers Directive used just two outcomes: mortality and footpad dermatitis. Some Dutch producers stock broilers at 45kg/m2 and claim to have low mortality and footpad dermatitis scores. A labelling system that only considered these two outcomes would approve farms stocking at 45kg/m2 even though scientific research shows that such high densities are responsible for a wide range of welfare problems.
• The scores for the selected outcomes may be set so low that even farms with poor welfare may achieve the required score. Drafts of the Broilers Directive set the score for footpad dermatitis at a level where few farms would have ever attracted a grading of “deficiency” or “severe deficiency”. Under the proposed scores 25% of a flock could have severe footpad lesions and 50% minor footpad lesions and the flock would still not be considered to have a severe deficiency. (The Directive as adopted abandoned the idea of scoring footpad dermatitis.)
• Farmers will focus on the outcomes selected for the labelling scheme perhaps to the detriment of other factors. The Broilers Directive’s only outcome is mortality; as a result farmers may decide not to cull birds that should be culled in order to achieve a low mortality rate.

Mandatory EU labelling
At present the only mandatory EU labelling scheme for animal-derived food is that which requires egg packs and eggs to be labelled as to farming method. This scheme requires egg packs (the pack is more important than the egg as shoppers are much more likely to look at the pack than the egg for information) to carry one of three terms: “eggs from caged hens”, “barn eggs” or “free range eggs”.

Until 2004, the labelling of eggs and egg packs was voluntary. This voluntary scheme proved to be ineffective in providing information to consumers primarily because there was no requirement for battery eggs to be labelled as such. The scheme’s defects were recognised by Council Regulation 5/2001 which introduced mandatory labelling of egg packs and eggs as to farming method , stating that “clear and unambiguous compulsory labelling is the only way of ensuring that the consumer is able to make an informed choice between the various classes of egg on the basis of the farming method. Appropriate compulsory labelling is in line with the wishes expressed by consumers and consumer organisations.”

Supported by this welfare labelling, the consumption of eggs from non-cage systems has risen to 275% of its 1997 level. The success of the scheme has been largely due to the fact that it has been compulsory for all methods of production, including the lower welfare systems, to identify themselves to the consumer.

CIWF believes that this reasoning holds good for other animal-derived food. . If consumers are to be enabled to make informed choices, welfare labelling must be compulsory otherwise low welfare food will not be labelled as such.

Visibility
CIWF believes that labelling rules should specify a minimum size or prominence for the method of production marketing terms. To prevent these terms appearing so small as to be ineffectual, it is important that marketing rules insist that the method of production appears as the principal labelling term on any packaging or promotional material.

Marketing rules should also prevent the use of subjective information about the particular housing characteristics to be added to specified terms. In the UK, for example, wording such as “eggs from caged hens kept in carefully controlled conditions” (see wording in italics) has been used to detract from the clear, factual nature of the permitted marketing term.

Self-regulation versus compulsory schemes
The dangers of voluntary schemes or self-regulation are illustrated by certain quality assurance schemes. Some of these use terms such as “farm assured” that suggest high animal welfare standards, but in fact permit the use of highly industrial husbandry methods that have been criticised by scientific research as leading to poor welfare.

EU legislation on the labelling of both eggs and poultry meat already takes a prescriptive approach in order to prevent consumers from being misled. CIWF believes that future labelling regimes as to farming method must take a similarly prescriptive approach otherwise producers would be at liberty to use a high welfare label such as ‘free range’ even though their farm failed to meet the criteria commonly associated with a free range enterprise.

Labelling of imports
Mandatory labelling as to farming method of production should apply to imported eggs and meat as well as to food produced in the EU. Current EU legislation on egg labelling applies a weaker regime to imported eggs than to EU eggs.

CIWF believes that mandatory labelling for both imported and EU-produced food need not be incompatible with world trade rules. Any extension of labelling to imported products would have to be carried out in accordance with the trade rules’ principles of transparency and good faith.

Processed food and catering
So far labelling as to farming method has mainly been applied to shell eggs and fresh meat. However, an increasing proportion of meat and eggs are now being used in processed food and in the foodservice sector. This process is likely to continue.

If the EU is serious about facilitating informed consumer choice, raising animal welfare standards and safeguarding EU farmers from lower welfare imports, it is essential that mandatory labelling as to farming method should be extended to:
• Processed foods such as ready meals, and
• Food used in the foodservice sector.

Scope of labelling
• All food derived from animals should be labelled as to farming method of production
• Such labelling should apply not just to fresh food, but to all meat, eggs, dairy and related products used in processed food (such as ready meals) and in the foodservice sector
• Such labelling should extend to imports as well as to domestically produced food.

IAL thanks CIWF and Philip Lymbery ( CEO of CIWF) for providing this article.

Article added: 01/2009