Published name
Name of the organisation your response is on behalf of (if applicable)
Which of the following best describes your situation?
Which sector do you represent?
You may wish to upload your submission here:
28 February 2025
Australian Agricultural Traceability Assuring Sustainability Claims
Working Group (ASCWG)
Department of Agriculture, Fisheries and Forestry
GPO Box 858
Canberra ACT 2601
Online submission via: https://haveyoursay.agriculture.gov.au/sustainability-claims/survey
Dear Members of the ASCWG
Assuring agricultural sustainability claims: Discussion paper
Thank you for the opportunity to provide feedback on the Assuring agricultural sustainability claims: Discussion paper.
RSPCA Australia has been involved in the dairy, beef, and sheep industry sustainability frameworks since their inception and, to a lesser extent, in the pig industry sustainability framework. To date, we have not been invited to contribute to the Australian Agricultural
Sustainability Framework led by the National Farmers’ Federation.
Our role and aim in these sustainability frameworks are to advocate for inclusion of ambitious targets in the animal care pillars of the respective industry frameworks.
Clearly, as the Discussion Paper points out, animal welfare is a material topic for each of these sectors where failure to acknowledge and address animal welfare issues in a timely manner can result in significant impact and risk including to Australia’s international trade and reputation.
When considering sustainability claims around animal welfare, it is vital that all parties support a common definition of ‘animal welfare’ and that aspects of animal care and/or husbandry that are the subject of sustainability claims be articulated separately and as relevant to the industry. The World Organisation for Animal Health articulates this well in their soon to be adopted revised draft definition of ‘animal welfare’:
Animal welfare means the physical and mental state of an animal in relation to the
conditions in which it lives and dies.
An animal experiences good welfare if the animal is healthy, comfortable, well nourished,
safe, is not suffering from unpleasant states such as pain, fear and distress, and is able to
express behaviours that are important for its physical and mental state. Good animal welfare
is not only about avoiding negative experiences to animals, but also providing them with
opportunities to have positive experiences.
Good animal welfare requires disease prevention and appropriate veterinary care, shelter,
management and nutrition, a stimulating, comfortable and safe environment, humane
handling and humane slaughter or killing. While animal welfare refers to the state of the
animal, the treatment that an animal receives is covered by other terms such as animal care,
animal husbandry, and humane treatment.
An example of a material issue not mentioned in the Discussion Paper (consultation question 6a) is the use of antimicrobials in animal agriculture and the pending market access requirement to be imposed by the European Union (EU). In European Regulation 2024/399, it states that, from 3
September 2026, the prohibition on the use of antimicrobials that are reserved for treatment of infections in humans as well as the use of antimicrobials that claim to promote growth or increase yield in farmed animals, will be extended to certain animals and animal products entering the EU. This decision will affect Australian beef, dairy and sheep products exported to the EU as these sectors have access to and use antimicrobials that are registered with such claims.
Consistent recording and reporting of antimicrobial usage (including coccidiostats) by every livestock sector is currently not conducted in Australia (consultation question 8) and yet should be mandatory, as it would allow verification/ demonstration of industry claims, including in various sustainability frameworks, around antimicrobial stewardship and responsible antimicrobial use (consultation question 9). You may be interested in the FAIRR report which touches on the regulatory landscape and performance of publicly listed global food companies against a range of ESG indicators, including antibiotic usage and animal welfare.
To date, the dairy, beef, and sheep sustainability frameworks have relied on producer surveys to provide the data to underpin indicators within their animal care pillars (consultation question 9). We are not aware that similar animal husbandry-focused surveys are conducted and/or publicly available for the pig industry. Regardless, the RSPCA advocates for increased independent data collection and reporting on practices in animal use industries. There is significant need for greater independence, transparency, timeliness and objectivity in the provision of animal use data in Australia given the primary sources of data are peak industry bodies and rural research and development corporations.
Until recently, the Australian Bureau of Statistics (ABS) animal production statistics have been the only source of independent data with the five-yearly census data in particular, providing important information on specific production systems and practices. RSPCA Australia remains concerned that the ABS’ decision to cease the collection and reporting of animal agricultural data fails to reflect the government’s intention to improve animal welfare, and the community’s expectations that it will do so. If anything, data collection should be expanded to include all animal care indicators in the industry sustainability frameworks with these indicators being updated to ensure alignment with domestic and international trade and market access requirements (consultation questions 11 and 13). As such, the
ABS as well as the Department of Agriculture, Fisheries and Forestry should play a role in assuring sustainability claims (consultation question 5).
Following on from that, and in response to consultation question 12, the credibility and robustness of any data used to underpin sustainability claims depends on accuracy of input, thus warranting accreditation through a reputable third party or independent audits to verify compliance with claims.
As an example, the RSPCA Approved Farming Scheme is Australia’s leading independent farm animal welfare certification scheme, however, is not (yet) operational in the sectors within the scope of the national agricultural traceability work. The RSPCA Approved Farming Scheme requires producers to meet detailed animal welfare standards and be regularly assessed against these standards. In addition, traceability systems must be in place to ensure that RSPCA Approved products can be traced from the point of sale back to the farm of origin.
In the Discussion Paper, there is regular mention of compliance burden on producers and other participants in the supply chain. However, it is unrealistic to expect that with increasing customer expectations and market demands – be they international or domestic – there will be no impact on recording/reporting requirements along the supply chain (consultation question 8). Ideally, a
2
recording tool with which producers are already familiar (e.g. NLIS) would be adapted to allow for input of additional data relevant to sustainability claims (consultation questions 10, 11, and 13).
Alternative technologies, including artificial intelligence and recent isotope work by CSIRO
(consultation question 7a) for example, that are practical and simple to use should continue to be explored. However, consideration needs to be given to ownership of such data (preferably government rather than a commercial entity) and how data is verified and by whom (again, preferably government rather than a commercial entity). Fundamentally, in a sustainable food system, farmers are paid a fair price for the food they produce. This requires consumer awareness and acceptance of and willingness to pay for the true cost of food (i.e. a cost that considers all externalities, including any compliance burden) – a communication exercise that government and industry may consider embarking on in the not-too-distant future.
The point above on the EU’s requirements around antimicrobial usage, is an example of an emerging regulatory requirement not mentioned in the Discussion Paper (consultation question 1). With regard to similar questions where accurate in-country information is needed to inform your understanding of international markets (consultation questions 2, 3, and 4), we would strongly recommend that you engage with key animal welfare groups in the regions of interest to ensure you receive correct and up to date information (e.g. RSPCA UK, Eurogroup, World Animal Protection). It is indeed disappointing to note that not a single animal welfare group is represented on the ASCWG particularly given the fact that animal welfare was and is likely to remain a highly material topic for the livestock sector.
We look forward to being consulted on animal welfare matters and providing feedback on the discussion paper presenting the outcomes of Phase 1 when it is released for public comment.
Kind regards
Melina Tensen
Senior Scientific Officer (Farm Animals)
RSPCA Australia
SUBMISSION ENDS
3