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Full report (in PDF) available on the Rethink Priorities website. This is a follow-up to our report  "Strategic considerations for upcoming EU farmed animal legislation". 


  • The majority of fish consumed (in tonnes) in the EU are either wild-caught fish or farmed fish imported from non-EU Norway, Scotland, and Turkey. I don't see evidence that the EU will regulate imports of fish this decade and I'm less confident on interventions that affect wild animal welfare. So we narrowed the scope of the report to the species of fish farmed in the largest numbers of individuals and life-years in the EU: sea bass, sea bream, and small trout.
  • The report argues that the most promising EU fish policy ask right now is a fast transition to better slaughter conditions of sea bass, sea bream, and (small) rainbow trout. It's an option that EU policymakers already put on the table as part of their larger animal legislation reform package, animal advocacy organisations support it, it has real world implementation, and there are clear actions to make improvements to the ask, namely by providing evidence discussed in the report of short transition periods.
  • The EU's scientific agency, EFSA, has opinions on farmed fish welfare due 2024-2029 which will offer a beachhead for rearing reforms the movement may ask for in future that affect the whole life of an individual (e.g. water quality standards, stocking density maximums, enrichment especially for juveniles). There is a lot of economic and political precedent the aquatic animal advocacy movement needs to start creating years in advance to make the most of EFSA opinions on farmed fish welfare - the report discusses what sort of evidence the movement might need.
  • I worry that after the European Commission presents its reform proposal as planned in September/October 2023 (including a cage-free hen policy), little progress will be made before the June 2024 European Parliament elections put more conservative co-legislators in place, and a new European Commission 5-year term starts in November 2024. The longer the reform negotiations drag on, if the movement doesn’t pivot resources to building the case for rearing reforms, advocates may be left playing catch-up in a few years and fail to make the most of EFSA opinions. 
  • I argue the movement should make an effort over the next 10 months to pull together the evidence and coalitions in support of a fast slaughter transition and ensure it makes it in the final law if things are progressing quickly. However, given limited resources, the more time and resources that continue to go into fish slaughter the higher the risk that this cuts against building the case for the arguably highly expected value rearing reforms later this decade.
  • One could reasonably disagree and say even if the EU reform looks to be slowing, we should focus 100% of our fish policy advocacy efforts on slaughter to make sure the movement locks in a precedent for doing anything on commercially farmed fish at the EU level, and that this slaughter provision forms a beachhead for rearing reforms later. This may be compelling if you doubt that there will be opportunities to utilise EFSA opinions to create reform, especially in the absence of a fish slaughter precedent (e.g. if the opinions are dropped or delayed, or you don't believe we can gather sufficient evidence for EFSA to make bold rearing reform recommendations). Or you might think we should push for a lot more than slaughter right now, to mainstream those asks and hope at least one more of them make it onto the agenda. 
  • On the first, I argue the leaked draft impact assessment already signalled a willingness to explore fish reforms post EFSA-opinions, and to turn EFSA opinions into rearing reforms the larger reform package would need to include European Commission powers to update regulations via delegated/implementing acts for future reform anyway, regardless of the fish slaughter requirement being included now or not. Furthermore, if the EU reform on the whole is going poorly, I'm not sure a fish slaughter requirement is the hill advocates should want to die on, when reforms to egg-laying hens and broilers are also on the table. On the second, I have not seen much evidence of political appetite for rearing reforms yet nor the quality of evidence that would be needed to persuade policymakers to take these asks seriously now.

    Please reach out to neil@rethinkpriorities.org to arrange a call to discuss the report. Full report (in PDF) available on the Rethink Priorities website



This report is a project of Rethink Priorities–a think tank dedicated to informing decisions made by high-impact organizations and funders across various cause areas. The author is Neil Dullaghan. Thanks to Daniela R. Waldhorn for her guidance, Sagar Shah, Kieran Greig, Alice Di Concetto, Ren Springlea, Míriam Martínez, Doug Waley, Gautier Riberolles, and Dr Krzysztof Wojtas for their helpful feedback, and Adam Papineau for copyediting.

If you are interested in RP’s work, please visit our research database and subscribe to our newsletter.





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Thank you for the post! 

I wonder what a better slaughter of "small rainbow trout" looks like? It seems to me small fish are hard to handle and there are therefore bigger economic incentives for practitioners to refuse.

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