In April, IATP Europe submitted feedback on the European Union's upcoming Livestock Strategy, outlining the changes needed to support Europe's farmers, farm workers, and rural communities in a fair, just transition to climate neutrality. Implementing these changes with appropriate support can streamline the transition and build resilience for farmers facing a warming climate, market volatility, and shifting consumer preferences.
View the PDF of the full submission here.
The Institute for Agriculture and Trade Policy (IATP) Europe welcomes the opportunity to provide feedback on the EU’s upcoming Livestock Strategy.
Europe’s livestock farmers face several challenges, from the damage caused to their animals from a warming climate, to possible regulatory requirements to cut climate pollution or changing consumer preferences for healthier, plant-based diets.
The Livestock Strategy can help to ensure that the needed changes to Europe’s livestock industry are implemented in a fair and well managed way that supports farmers, farm workers and rural communities. Specially, the Strategy should:
Quantify what EU animal farming within planetary boundaries means.
European livestock production is not operating within planetary boundaries (RISE Foundation, 2018). It is a key pollutant of Europe’s air, water and climate and does significant damage to nature (EEA 2025, ESABCC 2026).
To help farmers plan for the future and to ensure policy coherence across the EU, the Livestock Strategy should outline what animal farming within planetary boundaries looks like in 2040 and 2050 (Röös et al., 2016, RISE Foundation, 2018, Müller et al., 2025).
In so doing, it should outline the trajectory to reduce the number of animals farmed overall and align how many animals are raised in a particular region, with what the local environment can support. While some animals are needed to protect nature and conserving biodiversity through grazing, this number is significantly lower than today’s levels (Röös et al., 2016).
Shifting diets to more plant-based foods is needed in order to capitalize on the full environmental and health benefits of more sustainable animal farming. Supporting those changes in diet should be a core element of the Livestock Strategy policy twin: the EU Protein Plan.
Support farmers to transition away from industrial livestock production.
Diversifying production away from industrial livestock production will require significant investment and a substantial commitment by farmers, both of which should be matched by a societal commitment to provide financial support.
While the post-2027 CAP proposal requires that Member States provide support for transition planning to extensify livestock production, the level of financing that would be made available is not defined. The scope of transition planning should be broadened to include diversification into other agricultural, agroforestry or non-agricultural activities.
A fair transition to animal farming within nature’s limits will not take place overnight — not least of which because it takes time to establish alternative markets, supply chains, and infrastructure that will allow farmers to earn a fair living by growing more fruits, vegetables or legumes (from diversified systems), shifting to agroforestry, or even growing sustainable construction material on rewetted peatlands.
Beyond planning, farmers will need transitional income support to compensate for temporary production losses as they shift to alternatives and to allow for learning by doing (and the temporary reductions in income that may come with building up that new knowledge and skillset) (ESABCC 2026).
Diversifying production away from industrial livestock production will also entail significant changes for rural economies and workers throughout the agrifood system (CCAC 2024). Support for these transitions should be provided for in the CAP, broader National and Regional Partnership Plans (NRPPs) or the EU Competitiveness Fund.
The Livestock Strategy can play a key role in bringing all of these various sources of funding together and monitoring for gaps in support.
Acknowledge the importance of a just transition for the entire agrifood sector.
The EU’s commitment to a fair and just transition to climate neutrality should include farmers, farm workers, and rural communities.
A key objective of the Livestock Strategy should be to recognize the importance of a just transition for these groups and take steps to streamline this recognition throughout other EU initiatives.
In particular:
- The next EU budget should clarify that the concept of a just transition applies to all sectors — as historically it is often conceptualized only in relation to the energy transition. This recognition is particularly relevant for the objectives of the NRPPs and the Commission’s associated guidance for preparing these plans, as well as for the European Competitiveness Fund.
- The European Fair Transition Observatory should track best practices in the agrifood sector. It is unfortunate that consideration of the agrifood sector is missing from the stakeholder survey and assessment currently being undertaken.
Acknowledge the transformational scale of changes needed to future-proof EU animal farming.
Analysis by the European Scientific Advisory Board on Climate Change has found that to achieve the EU’s public health, climate, and environmental goals, systemic transformation of the agricultural sector is needed (ESABCC 2026). The regulatory actions envisaged in the Strategy should bear these findings in mind.
The potential expansion of the EU’s Carbon Removals and Carbon Farming (CRCF) regulation to include livestock is a prime example. While we have significant doubts about the ability of such a framework to deliver real climate benefits in a way that is workable for farmers and respectful of the wellbeing of farmed animals, any consideration of expanding this regulation to livestock needs to consider approaches to reduce production and whether that could be a viable funding stream to complement the public support for transitioning away from industrial livestock production (as discussed above), and not solely focus on questionable technical measures to cut climate pollution.
Avoid unnecessary and climate harmful manure-based biogas infrastructure build-up.
Manure-based biogas and biomethane can address some of the climate pollution created by animal waste and play a niche role in supporting the energy transition — but only if it is calibrated to the level and density of farmed animals that nature can support. Otherwise, policies and public money risk locking in, or even expanding, a broken and harmful factory farm system that pollutes the air, water, and climate (IATP 2022, Foodrise 2023, IATP 2025a).
Biogas and biomethane production require substantial subsidies to be viable (IDDRI 2025, IATP 2026b). In a time of scarce public resources, public money should focus on delivering public benefits in clean air, water, and nature, and not locking in unsustainable systems. The explicit reference in the post-2027 CAP proposal for the support of biogas production without any qualifiers runs contrary to such aims (EC 2025, Art. 4.1(b)).
The Livestock Strategy should provide guidance on manure-based biogas and biomethane’s limited role in line with the scale of animal farming planetary boundaries can support and take steps to ensure policy consistency across the EU. Appropriate accounting methods and regular monitoring for methane leaks are also needed to ensure that this technology delivers genuine climate benefits (IDDRI 2025, IATP 2026a).
Continue reading the full submission here.
