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Position Paper


Request of FOUR PAWS

VIER PFOTEN/FOUR PAWS is asking the EU Commission to establish a clear ban of live plucking with regard to ethical reasons (Animal Welfare), and economic reasons (restriction to the Common Market and Competition distortion), Public Health and Social effects. Moreover there has to be a legal certainty, creating the same conditions for the market of geese and geese products all over Europe.


The European Market of Geese Meat

The goose production in Europe is mainly attuned to the production of meat for the Middle European market. All retailers and major wholesalers as for example Rewe, Selgros, Lidl, Aldi, Kaufland, Real, Norma, Hofer, Tengelmann, Kaisers, Tegut, Coop CH, Edeka, Spar, Metro and Kaufhof do not allow the acquisition of meat that originated from live plucked animals.
The ten major Polish, Hungarian and German goose producers do not practice plucking in the moulting season and are committed to a unique initiative led by the European poultry industry for a strict ban on any removal of feathers and down from live animals in the European Union. 


Social conditions

It is estimated that as for today 800.000 to 1.000.000 geese are plucked alive in Europe. In 2010, 20 of 500 farms practiced plucking in Hungary. Due to the fact that the plucking is not performed by employees of the farms but by mobile plucking brigades the reduction of employment at the farms is rather improbable. The plucking brigades are constituted of season workers for whom plucking is a side job on weekends. FOUR PAWS received information that these workers often go moonlighting and work when having another job or work, despite the fact that they receive social or unemployment benefits. 
By introducing hand plucking after slaughter of the geese in the slaughterhouses additional jobs could be created. In opposition to the frequently practiced mechanical plucking at the slaughterhouse, hand plucking after slaughter allows to obtain an identical or even better quality of down, which is desired by the down industry. Additionally it allows the creation of long term steady jobs. An exploitation of workers in terms of uncontrollable plucking brigades would be then put to an end and the workers could be incorporated into the organised environment of a slaughterhouse i.e. worker protection, employee benefits and professional development. This step was already successfully undertaken by ANIMEX, the biggest Polish goose producer. 
Finally, an end of live plucking would also re-evaluate the conventional mechanical plucking and make it more profitable. These products are not competitive because of live plucking. A ban would undoubtedly trigger new investments into the manufacturing technology which would, in consequence, improve the quality and prices. 


Diseases and hygiene (public health)

The hand plucking of live animals imposes a considerable risk of spreading infectious diseases to humans and animals. The workers from the plucking brigades did not abide by the hygiene regulations in any of the 20 cases documented by FOUR PAWS. The fact that a brigade which consists of up to 60 people may work on 20 farms increases enormously the risk of spreading diseases. 
It has to be stressed that employees come in diverse contact with companion animals and livestock in their home environments. Therefore there is almost no prevention of the working people carry germs and pathogens into the industrial goose farms or other farms they work at. Veterinaries in Hungary and Poland are familiar with this problem and advise the pre-emptive use of medication. 
In the last couple of years several outbursts of H5N1 have been recorded in goose farms that practice live plucking. 


Proof / statistics

Live plucking and its causes have been documented unannounced by FOUR PAWS many times. FOUR PAWS holds footage of 20 such cases. The footage shows live plucking of over a 100.000 animals. Only in 2010, the live plucking of over 20.000 animals has been documented. Footage from Hungary, Poland and Germany is available (in Germany cases of mechanical live plucking have been documented). The last live plucking that is known to FOUR PAWS took place on the 6-8th November 2010. 
Moreover FOUR PAWS is in possession of inquiries and testimonies of people involved into the procedure, as well as interviews with goose producers from Hungary and Poland who substantiate the claims of FOUR PAWS.


Legal conditions

  • EU level 

There is an unclear legal situation in the EU in terms of the plucking of live geese. On one hand the so called live plucking is implicitly forbidden by the general EU Directive 98/58 on the protection of animals kept for farming purposes . 
A concrete ban on live feather plucking is implemented by the Council of Europe “Recommendation on Domestic Geese” , which is part of the “European Convention on the Protection of Farm Animals kept for Farming Purposes . This convention has also been signed by the Council of the European Union . In this recommendation the practice is considered inhumane, as animals are suffering and are injured by being live-plucked. 
On the other hand the so called plucking during the moult or harvesting is not forbidden . 
According to the Scientific opinion of the European Food Safety Authority (EFSA) it is considered as an indulgent form of plucking during the cyclic moulting process. In this case the animals are not hurt because they loose feathers and down are removed. In consequence, several Member States have interpreted this opinion as permission to live pluck geese. In this recent report on this issue EFSA recognizes at the same time that the traditional live-plucking methods during the moult provoke serious body injuries to the birds as well as stress, so it is therefore a problematic method at any case. 

 

  • National level 

Hungary is the only country having a legal regulation on plucking live animals and allows in consequence only one way of plucking. 20 cases of this plucking technique have been documented by FOUR PAWS. 

 

  • Enforcement:

Rules on distinction between plucking and harvesting are not workable 
Unfortunately the practice shows that a division between bad live plucking and good harvesting is impossible to maintain. Investigations conducted by FOUR PAWS unambiguously show that the animals are without any doubt being injured when they are plucked during the moult. The injuries range from follicle injuries to massive skin cracks and flesh wounds that have to be sewed, as well as wing and leg fractures. 
Additionally, plucking during the moult causes such a massive amount of stress that the animals injure or kill (strangle, crush) each other in panic. FOUR PAWS is in possession of a comprehensive four-hour video documentation of a plucking during the moult, that has been confirmed in a written form by a veterinarian and that brings evidence to all accusations. 
The claim that the feathers originating from an animal-abusive plucking would be impossible to sell, as they are covered in blood and filth (quote: VDFI) was proven false by FOUR PAWS. FOUR PAWS presented a sample of raw down and feathers of documented live plucking origin to a representative of the IDFL (authority on down/industry-related). It was considered to be of excellent quality. Additionally these products are washed and disinfected in special processing plants, which allows the removal of traces of blood and faeces. 
There are no analyzing procedures that would allow the differentiation between feathers that have been live plucked and feathers that have been plucked after slaughter. This statement was confirmed by notable experts, practitioners and people in charge from the down industry. Quality tests confirm that in terms of quality products of animal abuse cannot be told apart from other products. Even samples from the most atrocious documented live plucking met all the high quality requirements of the down industry. 
The Hungarian regulation on live plucking has to be regarded as highly questionable as it is not put into practice and is out of touch with reality. The regulation mentions the aruning of down which is unrealistic, as the acquisition of precious down is the purpose of plucking. FOUR PAWS filed a charge of violation of this regulation and of the Hungarian animal welfare act in one case of live plucking of 60.000 animals. The animals were plucked bald on the chest, belly, back and neck and many of them were severely wounded. The proceedings were stopped and despite the clear evidence presented, the authorities started an investigation against FOUR PAWS because of filing false charges. The plucking on the farm was performed in accordance with the law. (quote: police) 
To date no case of a farm that would have been punished for violations of the regulation or for animal abuse is known. This odd perfection of the Hungarian plucking of once five million animals at hundreds of farms has to be one of its kind. When questioned most of the farmers cannot recall of any state controls to have taken place. 
The Hungarian animal welfare act prohibits the plucking of all live animals except of geese. It is by coincidence the only animal whose plucking is economically reasonable and extremely profitable.


Biological aspects – Anatomy of the Geese

The moulting season that is the natural changing of the plumage, of geese happens every six weeks, in average. This process is controlled by hormones and lasts several days. This means that new feathers slowly push forward and replace the old ones. The plucking takes place under an enormous time pressure and without a break thus it is impossible to differentiate between new and old down and feathers. New down and feathers are torn out and wounds are ripped open. Old feathers that have not been loose enough also cause skin injuries. As the plucking goes on for about three or four days and the moulting of the animals is not synchronised, the animals that happen to be later or earlier in the cycle on the day the plucking takes place are at risk of injuries.

This means that an animal will either be injured when the feather is still grown into the body or when the feather was already pushed out by a new feather or down which is also torn out. 
The average number of geese in a gaggle lies between 3.000 and 5.000. Farms with up to 30.000 animals are not uncommon. It is almost impossible to monitor the moulting state of every single animal, as it is tiring for the workers to observe every bird as time passes by. The days when the plucking will take place are planned in advance, as the plucking brigades have to be booked bindingly. Because of this reason it is impossible to take into account the moulting state of the animals with precision. 
The conditions are also harsh because of the age of the animals. Young animals and meat geese have to be regarded as such, which results into the fact that young animals suffer explicitly severe wounds, since their skin is still not developed enough. 
The weather conditions pose another problem. When the skin of the animals is softened by rain and moisture it is extremely vulnerable to plucking. In the case of bad weather the plucking is postponed until the weather outlook is better. In this way it is very hard to take the moulting of a whole gaggle into account.


Demands

FOUR PAWS demands

  • a) Politically: The inclusion of geese and ducks in the scope of the Animal Welfare Action Strategy (2011-2015) 
  • b) Planned EU Animal Welfare Law: to consider geese and ducks in the scope of the Animal Welfare Law
  • c) Legislation in general: An EU-wide ban on any kind of feather or down removal from live animals.

 

It is unacceptable that plucking methods that are out of reality like harvesting or scuffling are permitted. The problem may not be suppressed, suspended or be shelved by simply renaming it with a newly invented term (the EU speaks rather of gathering than harvesting right now)

 

FOUR PAWS’ request to the European Commission is a clear decision that respects the public opinion, point of view of practitioners and experts. Only a clear ban of this practice including harvesting would meet the general principle of animal welfare, laid down in Art. 13 TFEU and that has to be considered by all EU institutions and EU Member States.


Current status

Recent EFSA statements about live plucking do not show any change.

 

  • Combing / brushing

The combing of feathers is a completely unrealistic and unprofitable production method. This view is held not only by FOUR PAWS but also by all questioned representatives of goose producers (10 companies with a yearly production of about 8 million geese). The EFSA report does not specify whether such combing should be performed mechanically or manually. With this method only a very small amount of down and feathers can be obtained from every animal. This will result to the fact that the pluckers will use more severe methods to increase the profit from feathers and down.
Moreover when combing or brushing is used there is still a risk of animal injuries as the pluckers' pressure to perform will not decrease. Besides, it is highly questionable whether a goose can be combed and whether this method is suitable to reach the down which is hidden under the feathers. 
The desired effect that this unprofitable method could lead to, a cessation of live plucking, is impossible as the plucking of geese is not and cannot be regulated. This was unambiguously shown in the last 20 years by numerous failed attempts to improve the situation. 

 

  • Controls

The training and controls that are demanded by the EFSA are impossible in terms of plucking. Foremost there are the plucking brigades that are flexibly formed out of the local population. These brigades are not employed openly as they are usually paid under the table and the profits from the down do not undergo taxation as well. Efficient controls would mean that every single one of the thousands of pluckings would have to be accompanied for many days by independent experts who would monitor it. This would make the already economically unreasonable combing non-profitable. 
State controls are pointless because of bribery, lacking expert knowledge and expert commitment. This was already shown by investigations against massively illegal live plucking that have been foiled by the authorities. 
Controls carried out by agencies related to the down industry (like the IDFL) are not credible and because of the financial dependency biased by the rest of the down industry. 
Even controls of goose farms carried out by the TÜV Nord failed in the past. By now the TÜV Nord renounced any certification of goose farms. This failed quality and control offensive after the live plucking scandals in the 1990s predetermines the failure of this new attempt.


Conclusion

If the path proposed by EFSA is chosen the conditions will, unfortunately not change. The down industry will be set on fire every year by live plucking scandals, the insecurity for trade and the consumers’ choices will continue to rise and this will increasingly renounce any kind of down and other geese products. This is an extremely high price that the EU hopefully does not want to pay with regard to a small number of non-compliant geese producers. 


The consumers, retailers and wholesalers, 95 percent of the geese producers and notable experts and politicians agree on the only solution: a clear ban on any removal of feathers and down from live animals is the right decision in terms of animal welfare, consumer protection, market protection from competition distortions and reason.


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