THE European Union is in the process of revising its transport of animals regulations. These regulations are aimed at improving the welfare of the 1.8 million animals destined for slaughter in and from the EU.

The EU entrusted its European Food Safety Agency (EFSA), which is essentially a veterinary advisory body, with the responsibility for providing it with a scientific basis for the new proposals.

Importantly, the EFSA has multiple representative members, but there are no EFSA members who are experts in the horse industry in general and the thoroughbred industry in particular.

EFSA published its report in September 2022 and stated that it had found no evidence to differentiate the effects of transport between registered horses (thoroughbreds and other high value, high health breeds) and those destined for slaughter. The EFSA chose “to treat them as one”.

The EU responded by drafting welfare in transport regulations for all horses, which include inspection protocols at loading and unloading, at border crossings and stipulations on journey durations per movement, residency requirements and on spatial arrangements and temperature ranges, in which such movements can take place.

Welfare problems

These legislative proposals would create very significant welfare problems, where none exist at present. The EFSA is currently considering other issues, which have the potential to impact on the thoroughbred industry.

We must find a way to gain access to EFSA, either through membership or through a consultant advisory role, to ensure that there is an industry voice and presence on this increasingly important EU Committee.

Lobbying by the International Federation of Horseracing Authorities (IFHA) and the International Equestrian Federation (FEI) succeeded in obtaining a derogation (exemption) from these regulations for racehorses and elite competition horses.

Sadly and importantly, no such derogation was given to the thoroughbred breeding industry. When subsequently questioned, during intensive lobbying by the European Federation of Thoroughbred Breeders’ Associations (EFTBA), as to why this was not forthcoming, the initial EU response was that it was an “oversight” and subsequently “that it was too difficult”. The absence of a derogation for the breeding industry has multiple ramifications, which will have significant adverse consequences:

  • The seven-day residency requirement is incompatible with the current facilities and practices of thoroughbred auction sales. Documentary evidence of this fact, supplied by all of Europe’s major sales companies, has been sent by EFTBA to the EU.
  • The proposal to forbid the transport of pregnant mares beyond 80% of gestation will prevent the transfer of mares from private stud farms to foaling units. This proposal was ill-considered and failed to take account of the wide range of normal gestation in thoroughbred mares – which makes it impossible to identify 80% of gestation. Furthermore, there is no evidence that transport of pregnant mares beyond this arbitrary limit is deleterious. There are literally no reports, scientific or otherwise, of our mares aborting on vehicles or in the immediate aftermath of road journeys. The industry closely monitors and scrutinises abortion – all the more so because of the fear of spread of EHV infections.
  • The proposal that young foals should not be transported post-partum would preclude foal heat coverings. This too is without foundation. Mares with their foals at foot are always transported with enough space for the foals to move around the mare and suckle from either side as they choose. They are always provided with a suitable bedding surface to enable them to lie down if and when they choose. We have known for more than four decades, as a result of work of the late Dr Peter Rossdale and his colleagues work on neonatology, that thoroughbred foals have completed their postnatal adaptation by 72 hours post-partum. Thereafter, they are simply “little adults”.

    • A “plucked from the air” arbitrary definition of when they can be transported after neonatal adaptation has taken place has no scientific basis – and reflects badly on those who have literally imagined this limitation.

  • The proposals for mandatory state veterinarian inspection of all loading and unloading is unworkable.
  • The proposals for compulsory unloading at all state border crossings does not take account of the facts that this creates biohazards and risks injury.
  • The regulations, which restrict movement to specific temperature ranges, take no account of the differences between internal temperature within the vehicle and the external temperature.

    • In subsequent correspondence, aimed at further meetings with the EU, EFTBA was asked for responses to four specific questions to try to move towards a solution to these problems:

    Question 1 was “What are the routes and distances by breeding horses”?

    EFTBA responded that, as many of the racing centres of Europe are synonymous with its breeding centres, the routes and distances travelled were essentially the same and that racing had been given a derogation, but that breeding had not.

    Question 2 asked for the numbers of breeding-related movements

    EFTBA responded by stating that, if one takes the global population of European thoroughbred mares to be in the order of 35,000 mares and one accepts the global fertility figure of 55%, then the average conception requires two journeys to and from the stallion, giving a global figure of some 140,000 such movements.

    If the EU auction sales entries totals are then added to this figure, it rises to some 160,000 to 170,000 breeding-related movements. This figure is in line with the European race entry figure and, once again, racing has been given a derogation, but breeding has not.

    Question 3 asked for details of the vehicles and personnel used for breeding-related movements

    EFTBA responded by stating that, in essence, the same vehicles and type of personnel are used for the transport of breeding stock, as is the case for racing. Once again, racing has been given a derogation but breeding has not.

    Question 4 sought information on guidelines for the transport of breeding stock.

    EFTBA has worked hard with the ITBF and the IFHA joint working group and has now produced its Welfare in Transport Guidelines for the Breeding Sector as Section 8 of a joint ITBF / EFTBA / IFHA document. These are based on, and analogous to, the transport guidelines issued by both the IFHA and the FEI. Yet again, the racing and competition sector has been given a derogation in this context, but the breeding industry has not.

    There is no evidence that current practices for transport of breeding stock result in compromised welfare and it is entirely wrong to equate our practices with those of the slaughter horse industry.

    Furthermore and disturbingly, an EU Parliamentary briefing document on these regulations, states that a plan should be made to create a fund to facilitate the transition from transport for natural mating of breeding stock and replace it with transfer of semen and embryos. This too would have very serious consequences, in an industry with a declining stallion base and potentially increasing inbreeding.

    Next steps

    These proposals have now left the EU Commission and will next be considered by the EU Council of Ministers and then by the EU Parliament. The time available for obtaining a derogation for the breeding industry is finite and may realistically, be as short as six months, i.e. by the end of the current Polish presidency of the EU, EFTBA has joined with the European and Mediterranean Horseracing Federation (EMHF) and its CEO Paull Khan, in its efforts to redress these multiple problems and achieve a derogation for the breeding sector.

    Both EFTBA and the EMHF have sought the further help of the International Sport Horse Confederation (ISHC), which acts as a united voice for both the racing and equestrian sectors. Ultimately, it will be up to everyone in this industry to understand the magnitude of the problem that we face and to make their voice heard in every forum available to them.

    Our solution

    EFTBA and the EMHF have now drafted a joint letter for national parliamentarians and the Governments, the EU Commission, the EU Council of Ministers and EU parliamentarians, which contains a form of words which, if adopted, would resolve all of the difficulties outlined above.

    These amendments carry the support of a broad range of organisations in the racing, equestrian and broader equine sectors. We hope to significantly increase the list of important organisations that support this form of words, over the next few days. An EFTBA delegation will once again travel to Brussels next week to try to promote this form of words as a solution.

    Des Leadon is a veterinary surgeon and thoroughbred breeder. He is chairman of the European Federation of Thoroughbred Breeder Associations’ Veterinary Advisory Committee

    ROSAMENDMENTS Article 2

    “(c) “the transport of animals for the purposes of participation in training, exhibitions, competitions, horse races, cultural events, circuses, equestrian sport and leisure activities”.

    “(d) “equidae transported for breeding or rearing purposes, or, to and from auctions organised by approved houses.”