Brussels, September 2021
Re: Motion puts the health and welfare of all animals at risk and would delay recently approved measures to combat AMR (antimicrobial resistance)
Dear Member of the European Parliament,
In September, you will vote on a motion for a resolution on the Commission Delegated Regulation supplementing Regulation (EU)2019/6 establishing the criteria for the designation of antimicrobials to be reserved for humans.
We share the global concern for antimicrobial resistance (AMR) and the need for coordinated action for the protection both of public and animal health. The Commission’s delegated act is designed to support the EU’s efforts to combat AMR. We support the delegated act as proposed, and consider it balanced, science-based and delivering upon the One Health approach.
If the Parliament were to adopt the motion for resolution objecting to the delegated act, it would counteract the EU’s efforts to combat AMR and may even increase pressure upon antimicrobials, exacerbating the risk of resistance development.
Therefore, we ask you to support the delegated act as proposed by the Commission and reject the motion.
Here are the reasons why:
The motion seeks to undermine the approved EU veterinary medicines regulation
The new Regulation on Veterinary Medicinal Products (Regulation 2019/6) requires seeking scientific advice to identify those antimicrobials that are to be reserved for human use only. It also introduces new additional restrictions for antimicrobial use. The aim of the motion is to change the recently adopted regulation.
The motion fails to acknowledge the extensive series of control measures on the use of antimicrobials on both individual and groups of animals in the new regulation and undermines the consensus reached by the co-legislators in 2019, in particular, regarding the restrictions on prophylactic and metaphylactic use of antimicrobials.
The new control measures range from collecting and monitoring antimicrobials use and resistance data on animals, to restricting and giving guidelines on prescribing and use. These measures would be delayed with the motion.
The motion would delay the approved measures to protect public health
The motion erroneously claims that the delegated act would not adequately protect public health. This ignores the delegated act’s criteria that allows case-by-case evidence-based decisions to reserve an antimicrobial for human use even when there is a need in animal health.
The Commission’s delegated act expressly offers this guarantee and delivers upon criteria that are designed to be very strict and are taking the interests of public health fully into account.
The motion puts at risk the health and welfare of farm and companion animals
The motion would:
• restrict the availability of appropriate antimicrobial treatments to all animals suffering or in need of treatment, including companion animals and equines,
• be a threat to animal health and welfare for the lack of treatment for both farm and companion animals,
• would challenge the One Health approach advocated by many EU and international bodies, including the European Parliament.
The motion can harm public health
The approach in the motion would mean imposing an excessive ban on antibiotics. It would do irreparable damage to animal health both on farms and in our homes and cause unnecessary animal suffering. Forcing the use of the small spectrum of antimicrobials left to treat animals, would increase the pressure upon those antimicrobials, favoring the faster development of resistance for this group of antimicrobials.
Having enough antimicrobials available in animals, is also important to protect public health, because more than 60% of infectious animal diseases are transmissible to humans (OIE).
There is a scientific consensus on the limited contribution of the use of antimicrobials in animals to the overall problem of human antimicrobial resistance. Several studies using modern tracking technologies have shown that the veterinary use of antibiotics has a significantly lower impact on the effectiveness of antimicrobial therapy in humans than originally assumed (EFSA, Nature, NIH)
The motion disregards scientific advice
• does not take into consideration the EU agencies’ scientific advice which was developed with input from both human and animal health experts, and built upon the international expert advice from WHO, OIE and EU scientific experts in human and animal health.
• does not take into account the global level WHO policy guidance. According to WHO, the list should not be used in isolation without the OIE list which categorises all antimicrobials important for animals. The WHO list is global, and in its general approach does not take into account the European reality.
• fails to take into account previous measures for the responsible use of antimicrobials that have led to a 34% reduction in the use of antimicrobials in animals, including critically important ones. This is a significantly lower use than in humans in Europe, as evidenced by the EU agencies’ ESVAC (European Surveillance of Veterinary Antimicrobial Consumption) and JIACRA (Joint Interagency Antimicrobial Consumption and Resistance Analysis) 2021 reports.
We the undersigned call on the Members of the European Parliament to reject the Motion for Resolution objecting to Draft Delegated Regulation on the criteria for the designation of antimicrobials to be reserved for the treatment of certain infections in humans (2021/2718(DEA)