EU PUBLIC CONSULTATION ON ANIMAL FEED
The association Nos Amis Les Animaux 85480 has been registered in the EU Transparency Register which gives it the opportunity to participate to public consultations of the EU. In April 2021 Nala85480 has replied to the public consultation on an EU proposal for the "Authorisation to feed non-ruminants with ruminant collagen / gelatine and with proteins from insects, pigs and poultry." We oppose to this proposition with the following reasons:
The basis of this proposal is reducing the dependency of the EU on other countries for its plant protein supply. This is based on this document (https://ec.europa.eu/info/sites/info/files/food-farming-fisheries/plants_and_plant_products/documents/report-plant-proteins-com2018-757-final_en.pdf)
However the major problem with this report is the assumption that it's desirable and even possible to continue with the large scale raising of livestock. Any actions taken should take into account the unavoidable reality that climate change is a major problem and that livestock makes a significant contribution. As it is focused on animal feed the report ignores the contribution of cereals to the supply of plant protein even though for a significant proportion of the human population they are their major source of protein. The report therefore only looks at what it considers high protein plant crops and acknowledges that 93% of them are fed to animals.
It is not a secret that livestock are a source of proteins, but they don't create them. They get them from the food that they eat. The conversion process means that you get less proteins out of an animal than you feed to it. As the topic under consultation shows there are also significant amounts of protein in the waste products after slaughter.
So there are effectively four issues: climate change, biodiversity, dependency on third countries for plant proteins and disposal of waste animal products. The proposal under discussion is perhaps an elegant solution to the last two issues but it ignores the much more important first two issues.
There is also a wiser, more elegant solution... reduce the number of animals that need to be fed. We have already seen initiatives in member states to reduce the size of their flocks and herds by offering farmers a "soft landing": compensation for permanently reducing the number of animals that they raise. Encouraging this would be a more sustainable and safer alternative to authorising inter species consumption. This proposal will inevitably reduce costs for the livestock sector which will lead to more consumption of meat.. exactly what we should be trying to discourage. In addition, as the current pandemic shows, zoonoses that cross the species barrier pose a threat to us all. Although the risk of a new TSE is considered low, what about other diseases?
For the above reasons we give a negative opinion to this proposal and instead encourage the DGs implicated in this proposal to look at the bigger picture and work together towards a more sustainable and resilient approach.
