EuropaBio welcomes the review of Directive 86/609. Its members fully support the highest standards for animal care and animal welfare as well as the principles of replacement, reduction, and refinement in animal research. Animal research has played an instrumental role in virtually every major medial advance in the last century and today, no full replacement for animal research yet exist in finding ways to treat some debilitating and life-threatening diseases.
By potentially placing further red tapes on research and additional administrative burden for innovative biotechnology small and medium size enterprises (SMEs), the proposal, in its current form, could jeopardize Europe’s capacity to research and innovate. Europabio is particularly concerned with:
1. Restrictions on the use on non-human primates (NHPs) for research in life-threatening or debilitating diseases (Article 8)
2. Restrictions of re-use of animals (Art 16)
3. Restrictions on the use of second generation NHPs (Art. 10)
4. Lack of definition of severity classes and de-facto ban of severe studies (Art. 15)
5. Inclusion of embryonic and transgenic forms in scope (Art. 2)
6. Potential increase of administrative burden placed on SMEs