EURCAW Ruminants & Equines has published its response to a question received in relation to the provision of feed to cattle during lairage in abattoirs.

The requester raised a question concerning the interpretation of feeding requirements under Regulation (EC) No 1099/2009. In abattoirs, this regulation stipulates that bovines must be provided with feed and bedding if they remain in holding pens for more than 12 hours. French reports, particularly BOUV’ALIM (2015), suggest that, in practice, slaughterhouses comply with this requirement by supplying digestible pellets or fodder. However, the regulation does not clearly define what constitutes “feeding,” thereby creating a degree of regulatory ambiguity. Although straw may act as a dietary supplement that encourages rumination and provides bulk, it is nutritionally insufficient to ensure satiety due to its low levels of nutrients, calcium, and overall feed value.

EURCAW Ruminants & Equines answer:

In short, the question concerns whether feeding cattle with pellets or straw can be considered to be in accordance with current EU legislative requirements. The Regulation (EC) No 1099/2009 states that “Animals which have not been slaughtered within 12 hours of their arrival shall be fed, and subsequently given moderate amounts of food at appropriate intervals.” The legislation does not specify the type of feed to be provided.

According to the BOUV’ALIM report, which studied feeding and bedding for cattle kept in holding areas at abattoirs for more than 12 hours in France, feed can consist of pellets or roughage (hay or straw). The document specifies that:

• Pellets can be used alone as a feed source if they are palatable, high in fibre, have a protein level <15 %, and are preferably large in diameter to prevent overconsumption.
• Feeding pellets alone is possible but sometimes questioned because it could induce metabolic disorders in the animal (e.g., acidosis, bloating).
• Roughage can also be used alone if it is of good quality and palatable.

The report does not prescribe a mandatory combination of pellets and roughage.

Conclusion

It should be noted that the provision of pelleted feed to ruminants during lairage is not prohibited; however, such feed should be offered only as a supplement to roughage, with careful consideration of the balance between fibre-rich feeds and more readily digestible components. Although straw does not provide sufficient nutritional value to serve as a sole feed source, it may be effectively combined with other feeds to extend feeding time and promote natural feeding activity, thereby contributing positively to animal welfare during lairage.

Examples from EU Member States

Sweden: The Swedish Board of Agriculture stipulates in national legislation (SJVFS 2020:22) that “If the total time for transport to and stabling at the slaughterhouse exceeds twelve hours, the animals shall be fed with feed that is suitable for the species and in sufficient quantity. Ruminants shall be provided roughage.” It should be noted that the total time of 12 hours includes both transport and lairage at the abattoir. According to a statement from the Swedish Centre for Animal Welfare [23], for a feed to function as roughage for ruminants, it must possess adequate physical structure, contain sufficient fibre, stimulate chewing activity, keep the animals occupied, and maintain the rumen microflora in a satisfactory condition. Pelleted feeds do not fulfil these criteria and therefore cannot be considered roughage.

Finland: Under the Finnish Animal Welfare Act (2023), the physiological needs of animals must be taken into account when feeding. The Finnish Food Authority [24] states that pellets are primarily intended as a supplementary feed rather than a replacement for roughage. When used as the sole feed, pellets do not satisfy the chewing needs of ruminants and may increase the risk of digestive disorders. Consequently, when pellets are provided, the feeding instructions and recommendations issued by the feed manufacturer must be followed, and as a practical principle, pellets alone should only be used as a stand-by feed, i.e., for animals that are lairaged for such a short period that they only need to be fed once at the most.

For more see: Q2E-Ruminants-Equines-2025-006

This query was submitted through the “Questions to EURCAW” (Q2E) service, which is available to Competent Authorities and government policy officials from EU Member States.