Consultation responses

The development of a roadmap towards phasing out animal testing – January 2025

In Januari 2025, Project 1882 offered views on what should be included and/or considered in the development of a roadmap towards phasing out animal testing in chemical safety assessments, that will be proposed by the European Commision. 

According to Project 1882, the roadmap should be flexible and capable of adapting to evolving needs and scientific advancements. EU legislation on chemical safety assessment needs to be revised and harmonized to promote and facilitate the use of non-animal approaches while keeping pace with scientific progress. Immediate actions should be taken to maximize the use of existing non-animal methods and minimize reliance on animal testing within the current regulatory framework.

Evaluation of the Animal Health Law – October 2024

In a survey intended to support the European Commission in the ex-post evaluation of the Animal Health Law, Project 1882 participated with our input.  

The objective was to evaluate the functioning and performance of the Animal Health Law regarding effectiveness, efficiency, relevance, coherence, and EU Added Value. 

Project 1882 stressed the importance of including animal welfare as a holistic concept and involving non-profit animal welfare organizations more. It is also important to get society behind the legislation, as civil society keeps up standards in the food industry. It is important to explain why animal welfare needs to be taken into account to increase compliance with legislation. 

Trade in seal products – August 2024

To check the effectiveness of the EU regulation, in place since 2009, the Commission launched a public consultation on the trade with seal products. 

Project 1882 recognizes that seal hunting decreased significantly after the implementation of the legislation. This has had a positive effect on animal welfare because fewer animals are killed or at risk of being injured in hunting, and because they have a more stable population trend. However, many of the seal populations in the Baltic Sea remain small compared to before large-scale hunting began in the 20th century. It is therefore essential that the legislation remains in place, and that other efforts, such as reducing overfishing (their food), are made.

Better protecting sharks through sustainable fishing and trade – May 2024

The European Commission initiated a consultation as a way to follow up the European citizens’ initiative “Stop Finning – Stop the Trade”, where 1.1 million European citizens requested the European Commission to stop EU trade in loose shark fins. 

Project 1882 calls for a ban on the trade with shark fins, in order to remove the incentive to catch sharks to mutilate their fins. The EU regulation on the removal of shark fins on board vessels should be extended to cover the export, import and transit of shark and ray fins.

Protection of animals during transport – April 2024

Project 1882 is of the impression that the legislation proposed by the European Commission on animal transport is seriously flawed. It does not reflect the scientific evidence available in this area, such as material from EFSA. 

There are also no proposals for legislation to restrict animal transport. The Commission must recognize the importance of replacing the transport of live animals with the transport of meat and genetic material as one of the objectives of this new legislation. Action plans must be developed, at EU level as well as on national level, for such a transition. There is a great risk that the current legislative proposal on transport will contribute to the continuation of the current system, where animals are transported long distances in completely unacceptable conditions, within the EU and to countries outside the EU, without significant changes. 

Project 1882 also urges the European Commission to publish a clear timetable in the near future for when new animal welfare legislation in other areas such as the keeping of animals, slaughter and animal welfare labeling will be presented.

Textile labeling – April 2024

In order to gather evidence on the importance and effectiveness of the Textile Labeling Regulation, the Commission launched a public consultation.  

Project 1882 notes that more and more manufacturers of animal skin and fur products want to divide their products into different levels of animal welfare. These risks being very misleading as there are no different animal husbandry systems in the fur industry, everything is based on cage farming unless trapping is used for wild fur. Fur and leather should also not be labeled as natural or environmentally friendly, as the production is actually unsustainable. In addition to contributing to animal suffering, the products need to be treated with chemicals in order to not rot.

New rules on dog and cat welfare and traceability – March 2024

The five domains are mentioned in the legislative proposal, which has not been done for any other animal species in the EU. This means that cats and dogs will have the right to good feelings, not just freedom from bad ones. The proposal would also ensure that anyone breeding dogs and cats for commercial purposes must be licensed and trained to do so. Unnecessary surgeries on the appearance of animals and inbreeding will also be banned.   

Project 1882 is cautiously optimistic that the proposed legislation will put an end to puppy mills, but there will continue to be problems with the online trade for some time to come. Regardless, it is welcome that dogs and cats will be protected at EU level for the first time.