Back Response from the European Commission to the UPF-CAE on the report “EU Research & Animal Suffering. Scrutinizing the Horizon 2020 Programme”

Response from the European Commission to the UPF-CAE on the report “EU Research & Animal Suffering. Scrutinizing the Horizon 2020 Programme”

Barcelona, January 2023



On September 29, 2022, the UPF-CAE launched the study EU Research & Animal Suffering. Scrutinizing the Horizon 2020 Programme. This study concludes that EU research investment through the Horizon 2020 program is at odds with (i) scientific findings on the ability of nonhuman animals to suffer, (ii) the evolution of ethical positions in this regard and (iii) the level of awareness among citizens since the funds devoted to research projects that seek to reduce or eliminate animal suffering are anecdotal.

On October 3, 2022, the UPF-CAE sent the study results to the European Commission. The results were accompanied by a letter noting the abovementioned discrepancies and the hope that they might be reduced with increased funding for protection of the the welfare and interests of nonhuman animals in their research and innovation programs. This is the letter that was sent to the European Commission:

Dear Sir, 

As scholars and researchers in the fields of animal ethics and critical animal studies at the UPF-Centre for Animal Ethics, we are extremely concerned with the lack of research funding devoted to reducing animal suffering and phasing out animal exploitation. Having monitored your funding decisions closely, we have found that substantial sums are devoted to research that either does nothing to reduce nonhuman suffering or even increases it. In order to support this observation with objective, quantitative data, we have conducted the relevant research on your funding decisions taken between 2014 and 2020. Please find the results in the following link:

The scrutiny of Horizon 2020 Programme data shows that EU public research funding is at odds with both scientific findings regarding nonhuman animals’ capacity to suffer and the evolution of ethical positions on this matter. In addition, given the scientific data available on matters such as the disastrous climatic consequences of meat consumption, a consensus is emerging that taking animals’ interest into account is the most effective way of addressing the most urgent environmental and societal threats currently facing humanity.

We have worked hard to present our research in a clear and succinct manner, and very much hope you will not disregard our findings and call for action. We look forward to hearing back from you.

Faithfully yours,

Núria Almiron & Paula Casal

UPF-Centre for Animal Ethics, Directors


On December 13, 2022, the UPF-CAE received a response that did not correspond to our request. Instead, it focused on animal testing and the welfare of animals exploited in laboratories and on farms. This is the reply we received:

Dear Sir,

Thank you for your message.

We very much share your concerns on animal welfare. At the European Commission, we are committed to protect animals across sectors. Such endeavor is reflected in the Treaty of the European Union, which, since 2007, includes a protocol on this important topic. In this context, the Commission fully stands by the principle of replacing, reducing and refining animal use (3Rs), which is a key element of all related EU legislation. Examples of this are the Directive 2010/63 on the protection of animals used for research, which clearly states the end goal to phase out animal use, and the 2013 ban of animal testing for cosmetic products and ingredients. Remarkably, these acts constitute some of the most advanced pieces of animal welfare legislation in the world.

The European Commission is taking concrete actions to develop scientifically valid methods that replace the use of animals for research purposes or regulatory testing. In the past two decades, the Commission, through its Research and Innovation Framework Programmes (FPs), has provided over EUR 800 million to more than 230 projects for the development of animal-free alternative methods. Looking back into FP5 (1998-2002), the annual budget dedicated to this area was around EUR 11 million. This budget tripled from FP5 to FP6, and further increased by 50 % from FP6 to FP7. Of key note, the annual budget for the last 14 years (FP7-H2020) represents about EUR 48 million per year on average. In addition, industrial sectors have complemented this effort by providing at least an additional EUR 150 million. Our figures for H2020 are higher than those presented in your report, most likely because, in addition to the “animal” query term in CORDIS, we also use other searches, such as 3Rs for instance.    

Further to our research funding strategies, the Commission collaborates with stakeholders to promote the implementation of animal-free alternative methods. In this regard, the European Union Reference Laboratory for alternatives to animal testing (EURL ECVAM) – an integral part of the European Commission’s Joint Research Centre (JRC) – coordinates the validation of such methods, as well as facilitates regulatory acceptance though dissemination activities (with an annual budget of approximately EUR 5 million). Similarly, over the past 15 years the European Partnership for Alternative Approaches to Animal Testing (EPAA) – an alliance between the Commission and 7 European industry sectors – has been at the forefront of promoting alternative approaches as well as the 3Rs in the regulatory environment in Europe and beyond.

Despite significant advances in the field, current alternative methods cannot totally replace the use of animal testing. In this context, the Commission has strict procedures in place to safeguard animal welfare. Research proposals undergo a rigorous scientific evaluation and a complementary ethics review. Proposals involving animal work only go ahead when: I) animal use is strictly necessary for the scientific objectives; II) the number of animals is duly justified; and III) measures to replace, reduce, and re-use animals are implemented. Projects are then followed up throughout their life cycle and when there are any doubts regarding the fulfilment of the project’s ethics requirements, additional assessments are conducted. In case that the highest research and ethics standards are not met, research activities may be temporally halted or even suspended. For further details on the European Commission’s ethics standards, please refer to the research proposal guidelines in the document “How to complete your ethics self-assessment” to be downloaded from a link at: Note in particular chapter 5, on the use of animals.

When it comes to farm animals, the European Commission has provided substantial support through successive Research and Innovation Framework Programmes, with a direct or indirect focus and/or impact on animal welfare, contributing to improve the sustainability of livestock production. In a system approach, such support goes from specifically addressing animal welfare, to addressing animal health, feeding, genetic resources and breeding, livestock farming systems including agro-ecological systems and organic farming. Under Horizon 2020 Societal Challenge 2, which focussed in particular on agriculture and food systems, some 50 projects related to animal farming were funded, for a total value of over EUR 300 million. This figure differs from the figure provided in the report referred to in your letter whereby EUR 100 million would have been allocated to projects focussed on animal interests according to a search performed by your group in the CORDIS database. Animal welfare is still being addressed under Horizon Europe; in particular a co-funded European Partnership on animal health and welfare is planned as part of the Cluster 6 work-programme 2023-2024. This can largely improve the lives of all farm animals and species kept for the production of food, wool, skin or fur, or for other farming purposes.

We hope that the above figures reassure you that the Commission remains very much committed to guaranteeing animal welfare as well as preserving the environment. Finally, you may be interested to know that the European Commission plans to revise the EU legislation on animal welfare in 2023, aiming to broaden their scope and ensure a higher level of animal protection.

Finally, we would like to inform you that the Network of National Contact Points (NCP) provides help on all aspects of Horizon 2020 and Horizon Europe in the national language. For contact details, please consult the following URL:

Please contact us again if you have further questions.


Kind regards,

Research Enquiry Service - Back Office


The answer or information contained in this message is based on the information provided by you, which may not be sufficiently detailed or complete to provide a full and correct answer or response to your question. The Commission is committed to providing accurate information through enquiry services; however, the information provided has no binding nature. The Commission cannot be held liable for any use made of this information or for its accuracy.

On December 21, 2022, we responded by reporting the error and requesting an alternative reply to our concerns and requests. This is the text we sent:

Dear Sir/Madam, 

We write in answer to "Europe Direct reply no 2022566", as the mail said we should contact again for further questions. 

Thank you for your reply but it seems that you have sent us a message written for somebody else. We did not send you a report on animal experimentation, nor have we written to you about this matter. Instead, we send you a report on the individuals of different species who may benefit from the funded projects. The reply suggests that even the abstract has not been read or perhaps our report has been confused with a different report. 

We look forward to your reply on our report on the beneficiaries of research.

SUMMARY:  The citizens of the European Union are very concerned by animal suffering and strongly support increasing protection for nonhuman animals. - EU research and innovation funding programmes are the main public tools for fostering scientific research in the European Union. - Horizon 2020, the research and innovation programme for the period 2014 to 2020, only supported 54 projects (0.15% of all funded projects) that directly considered nonhuman animal interests. - Horizon 2020 only devoted 0.14% of all its budget to funding projects with a direct benefit for nonhuman animals. - It is urgent that European Commission research and innovation programmes align with societal concern and scientific awareness by increasing their funding to projects devoted to the protection of nonhuman animals’ interests.  

Faithfully yours,


Núria Almiron & Paula Casal

UPF-Centre for Animal Ethics, Directors

On December 22, 2022, just one day later, the European Commission sent us the same reply they gave to our first message of December 13.



SDG - Sustainable Development Goals:

Els ODS a la UPF