Plans by the European Union (EU) to review its regulations for the transport of animals was borne out of well-meaning intentions. Around 1.8 billion animals are destined for slaughter each year in the EU, some of them transported in abominable conditions. The European Commission’s (EC) announcement of a new Farm To Fork strategy in 2020 was designed to tackle those issues head on and hopefully improve the wellbeing of such animals in the process.

Unfortunately the European bloodstock industry now finds itself embroiled in the issue. For while racehorses and other elite equestrian disciplines have been granted an exemption from the proposed regulations, Thoroughbred bloodstock has not despite being a high-health breed registered within a stud book.

The bottom line is that should these revisions be passed without the bloodstock industry receiving a derogation, then breeders will be forced to rethink how they operate.

Why? The new proposals include the following:

  • A compulsory seven-day residency requirement for monitoring following travelling or journeys of eight hours or more, meaning that any horse coming into a sales complex anywhere in the EU will have to remain resident at that property for seven days.
  • The prohibition of the transport of mares once they have passed the 80 per cent point of gestation.
  • The prohibition of the transport of foals during the immediate post-partum period.
  • Compulsory unloading and vet checks at all border crossings.

While this is primarily a matter for EU countries, it is naive to think that Britain won’t be affected given the amount of business it conducts with Ireland, France and Germany among others.

If these EU proposals are implemented, it would basically bring the breeding of racehorses to a halt

“If these EU proposals are implemented, it would basically bring the breeding of racehorses to a halt,” says Kirsten Rausing (below), chair of the International Thoroughbred Breeders’ Federation (ITBF) and honorary president of the European Federation of Thoroughbred Breeders’ Association (EFTBA). “To some extent I understand where they are coming from because some of these horses destined for slaughter across the EU are transported in dreadful conditions.”

She adds: “A derogation has been agreed on Thoroughbred racehorses and other sports horses, but they seem to be unwilling to agree a similar exemption for Thoroughbred breeding stock. So by that, the Thoroughbred industry is being equated with the lowest denominator – horses destined for slaughter.”

Paull Khan has been involved in the lengthy and ongoing discussions with Brussels in his role as secretary-general of the European and Mediterranean Horseracing Federation (EMHF). He also sits on the board of the World Horse Network, and as such has been a key contributor when it comes to arguing for the importance of a derogation.

“The aims are laudable, in that it seeks to improve animal welfare and ensure laws are based on scientific evidence,” he says. “The specific focus on welfare in transport was aimed primarily at improving the lot of animals being transported to be slaughtered. While the review covers several animal species, the Commission did ask the body that gives it scientific advice on such matters – the European Food Safety Authority (EFSA) –  to give an opinion on the transport of horses on long journeys to slaughterhouses.

“Under the current legislation, which has served us well for the past two decades, our sector’s horses, be they racehorses or breeding stock, are defined as ‘registered’ and thereby enjoy derogations from many burdensome administrative requirements. Over the past three years, we at the EMHF have been keeping a close eye on what was happening in Brussels, and made a number of submissions, both in writing and in person, where we argued that those freedoms of movement must be retained in future legislation to allow our economically-important industry to continue to thrive. We did this in conjunction with EFTBA and called specifically for derogations to include the breeding and sales sectors.

“The Commission’s proposals changed the basis for derogation, from the classification of the horse (as ‘Registered’) to the purpose of the journey. The good news was that travel for racing or training purposes was given substantial derogations – the bad news was that travel for breeding and sales was not.”

The potential implications of the new regulations are obviously far-reaching. Like Paull Khan, Des Leadon and Joe Hernon have lobbied hard on behalf of the Thoroughbred industry with Brussels. Leadon, who bred top Hong Kong performer Dinozzo and Classic-placed Arrest with his wife Marionn Klay at Swordlestown Little Stud in County Kildare, is also the veterinary advisor to the Irish Thoroughbred Breeders Association (ITBA) and chairman of the veterinary advisory committees of EFTBA and ITBF.

Hernon is also a manager at Coolmore’s Castlehyde Stud.

Both have been instrumental in highlighting the issue to a wider audience. Leadon, in his role at the ITBA, wrote of the potential ramifications in this magazine last month and spoke again of it at the ITBA Breeding Preparation Seminar ahead of the Goffs February Sale. It is worth revisiting what has been said and written again here.

“EFSA published its report in September 2022 and stated that it had found no evidence to differentiate the effects of transport between registered horses and those destined for slaughter,” says Leadon (right). “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 journey durations, per movement residency requirements and on temperature ranges in which such movements can take place.

“The absence of a derogation for the breeding industry has multiple ramifications which will have significant adverse consequences.”

He adds: “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 to by EFTBA to the EU.

“The proposal to forbid the transport of pregnant mares beyond 80 per cent of gestation will prevent the transfer of mares from private stud farms to foaling units. This proposal failed to take account of the wide range of normal gestation in Thoroughbred mares – which makes it impossible to identify 80 per cent 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 equine herpes virus (EHV) infections.

“The proposal that young foals should not be transported post-partum would preclude foal heat coverings. 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 chose. They are always provided with a suitable bedding surface to enable them to lie down if and when they chose. 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 hrs post-partum. Thereafter, they are simply “little adults”.

“The proposals for mandatory state veterinarian inspection of all loading and unloading is unworkable. Those for compulsory unloading at all state border crossings does not take account of the facts that this creates biohazards and risks injury.”

 

Lobbying and correspondence

Various organisations within the industry have been aware of the looming issue since EFSA published its report in September 2022 and lobbying has taken place to that effect. In that, they have not fully been backed by World Horse Welfare; while the charity agrees that several of the proposals would be counter-productive, its feels that a derogation is not the way forward (see panel).

There has been numerous correspondence with the EU Commission, including a letter written by Hernon to which the Commission answered with a series of questions – some of them almost impossible to answer.

“Question one was ‘what are the routes and distances travelled by breeding horses’?” says Leadon. “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 two 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 around 35,000 mares and the global fertility figure of 55 per cent is accepted, then the average conception requires two journeys to and from the stallion, giving a global figure of 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.

“Question three 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.

“Question four sought information on guidelines for the transport of breeding stock. EFTBA has worked hard with the ITBF and the International Federation of Horseracing Authorities (IFHA) joint working group to produce a Welfare in Transport Guidelines for the breeding sector as Section 8 of a joint ITBF/EFTBA/IFHA document. These are based on the transport guidelines issued by both the IFHA and the Federation Equestre Internationale (FEI).”

Hernon adds: “We’re not anti this law in any way. We just know we don’t deserve to have our horses categorised alongside slaughter horses.

“They’re not familiar with the way we transport our horses. We all operate with a vested interest in value and our horses are transported to the highest standards. In fact some of the rules on the table are more anti-welfare than pro-welfare, like having horses unloaded at border crossing with no loading ramps for example.

“For us as an industry, the next step has to be improving traceability and to start operating with digital passports. The sooner that happens the better and I believe that’s something that Weatherbys are well on top of.”

He adds: “The French, who will also be affected, have also been proactive. About 700 mares come from France to Ireland per year and about another 200 to 300 go to England.”

Proceedings are at a critical juncture. The proposals have left the EU Commission and are now being considered by the EU Parliament and Council. From there matters head to the EU Parliament. There is some urgency to this in that the Polish presidency of the EU ends in July, when it is taken up by Denmark. Those involved would rather see this resolved before then. “We have good will under the Polish presidency and that comes to an end in July,” says Hernon.

“There is a growing swell of support but actually getting it through to the people who make the decisions is proving difficult. Phil Hogan, the Irish ex-European commissioner, has been very helpful. He’s helped put us in front of the right people – we went to Brussels and we were put in front of the heads of the Directorate-General for Health and Food Safety (DG SANTE; responsible for the monitoring and implementation of European Union policies and laws on health and food safety).”

“We have been fortunate to have had the benefit of the experience of our political advisor, Cathy McGlynn,” says Khan. “At each stage, we have worked in conjunction with our sister organisations, such as EFTBA, recognising that the more we present a united front, the stronger our voice will be.”

 

AI resisted

The Thoroughbred industry has long resisted the use of artificial insemination (AI) due to a myriad of reasons. However, to those looking in on the business, it could well be viewed as an answer to the question of transporting mares for natural cover, especially as it is already utilised within the sports horse world.

Indeed, there is a line within a EU Parliamentary briefing document stating 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.

“That line is extremely alarming,” says Rausing. “The EU itself, some functionaries within the EU and some representatives of other equestrian disciplines are suggesting that ‘well we could solve all this with AI’. The problem is not that easily solved. AI is banned in the Thoroughbred industry worldwide – it’s a worldwide matter, not just in Europe. You cannot make any singular rules for AI; such rules also apply to all other artificial reproductive means such as embryo transfer, sexing of sperm, genetic manipulation of various kinds and other forms of artificial reproductive methods not yet identified. It opens the door for all kinds of issues.”

Leadon adds: “It would have very serious consequences in an industry with a declining stallion base and potentially increasing inbreeding.”

The EU has 27 member states and it has to be remembered that few of them entertain an interest in Thoroughbred racehorse breeding. For some, it could even constitute something of a ‘rich man’s club’.

Speaking at last month’s ITBA Breeding Preparation Seminar, Leadon described the issue as ‘a very real and imminent threat with a narrow window of opportunity’. But there remains hope that it will be resolved.

“The horse is but a small part of the bigger picture, and it is only through concerted lobbying that our voice will be heard in the cacophony of calls for changes,” says Khan. “But we must be optimistic. We have a good case: the current proposals would in fact be to the detriment of our horses’ welfare; they are illogical in that they are discriminatory against a well-regulated sub-population of horses which travel in identical conditions to the racehorses which have been given derogations. Undoubtedly, there will be occasional examples of breeding stock being travelled inappropriately – the answer is in enforcement of the law, rather than in creating new laws whose negative impact, both in welfare terms and economically, would be disastrous and completely disproportionate.”

 

 

Digital traceability key

World Horse Welfare are very much in favour with the idea of frictionless sport horse movement but would like to see digital traceability measures enforced to prevent any misuse. As such, while the charity shares some concerns over the EU transport proposals, it does not back a derogation.

“We are completely aligned with horse sport, we want horse sport to thrive and we’re aligned in that we feel the some of proposals would be counter-productive for that and horse welfare,” says Jessica Stark, director of communications and public affairs at World Horse Welfare. “We don’t agree on measuring external temperatures for example, or the residency requirements. There’s a lot that we have in common and we have been working with the European Horse Network on that, which is great.

“The big question is the issue of the derogation. It’s important to state that we’re not singling out racing or breeding on this, we just don’t believe in derogations because we know that people use them as loopholes that can make the law less enforceable.

“We think that the existing transport regulations can be improved and we’re excited to have an opportunity to look at that. But we’d like to see it bring in basic standards that can work for the sector and that can actually improve welfare for those horses who might not be so protected.”

That’s where digital traceability and how it can potentially strengthen the industry comes in.

“We fully support the principle of frictionless movement across borders for race and sports horses who are verifiably and individually traceable in real time,” says Stark. “That would include the legitimate and verifiable movement of breeding horses. We really think there’s an opportunity for the sport to self regulate, where it says ‘we want to have frictionless movement and have a system in place where we can monitor, enforce and make sure that nobody uses our sport as a cover to do the wrong thing’.

“We want sport to be able to move horses easily and if that system, whereby horses could be traced in real time, was in place, then we would fully support it. What we don’t want is people using sport and breeding as a cover to transport horses in poor conditions.”