Brussels, 8 September 2025
Re: Submission to European Commission Public Consultation on (TRIS/(2025) 1633) Proposed Act by the Member Ouwehand amending the Animals Act in connection with limiting the suffering of animals at the time of slaughter,
on behalf of the European Jewish Association (EJA)
The European Jewish Association, representing over 650 Jewish Communities across Europe – including the overwhelming majority of Jewish Communities in the Netherlands such as Rotterdam and Amsterdam – notes the ‘Proposed Act by the Member Ouwehand amending the Animals Act in connection with limiting the suffering of animals at the time of slaughter’, and raises our deep concern and strongest opposition to it.
For Jews the laws governing Shechita (kosher slaughter) are codified, defined and binding.
Shechita is performed by a specially trained expert (shochet) using a flawless, razor-sharp knife to make one swift and precise incision in the animal’s neck. This method ensures immediate loss of consciousness and a rapid death with minimal suffering.
Comparison with Stunning Methods
Stunning methods, although often presented as more humane, frequently fail or only partially succeed, causing animals prolonged distress before death. It has been noted in studies that there are significant percentages of animals slaughtered in abbatoirs in which the stunning procedure was not correctly carried out, causing unnecessary pain and suffering. By contrast, properly conducted Shechita is instantaneous, efficient, and avoids the risks of failed stunning procedures.
Scientific Evidence
Numerous veterinary studies confirm that when carried out correctly, Shechita leads to a very rapid loss of consciousness and is not more painful than conventional methods of slaughter. Some research further demonstrates that failed stunning can cause significantly greater suffering than Shechita.
The practice of Shechita, marked as it is by compassion and consideration for the welfare of the animal, has been a central pillar in sustaining Jewish life for millennia. In Judaism we practice “Tsa’ar Ba’alei Chayim.” This law clearly states that we are forbidden to be cruel to animals and that we are to treat them with compassion. Judaism goes further still: one must not eat before first providing for one’s animals, nor withhold feeding an animal even if it is to be slaughtered that same day.
Infringing the laws of Shechita, including by pre-stunning, renders the meat unconditionally forbidden as food to Jews. The proposed amendment to the Animals Act that would require all animals to be stunned prior to slaughter would render an animal treifa or “torn”, therefore unable to be eaten by Jews.
The implications of this proposed amendment would stigmatise kosher slaughter as inherently cruel – which we unequivocally and vehemently refute – and constitute a slur on Jewish practice and on our deep concern for animal welfare.
Additionally, the effect of this amendment – if adopted – on Jews in the Netherlands and indeed on the many thousands of Jewish tourists to the country, would be devastating. If you remove access to a central tenet of Jewish faith and practice, you are removing Jews from the Netherlands, effectively legislating Jews out of Dutch life and society.
On behalf of the European Jewish Association, we submit that an exception must be made for kosher slaughter, thus safeguarding Jewish practice and Jewish life in the Netherlands.
Signed on behalf of the Association,
Rabbi Menachem Margolin
Chairman
Appendix I – Selected Scientific References:
Grandin, T. (1994). Euthanasia and Slaughter of Livestock. Journal of the American Veterinary Medical Association.
Gregory, N.G. & Wotton, S.B. (1984). Time to loss of brain responsiveness following exsanguination in calves. Research in Veterinary Science, 37(1), 141–143.
Schütt-Abraham, I., Wormuth, H.J., & von Mickwitz, G. (1983). Schächten von Rindern und Schafen unter besonderer Berücksichtigung des Tierschutzes. Bundesgesundheitsblatt.
European Food Safety Authority (EFSA). Scientific Opinions on Animal Welfare at Slaughter (2004, 2013).
