We gave feedback on draft delegated regulation rules on establishments and tracebility.

For non commercial bird-keepers the registration of locations where birds are kept, as laid down in article 18, would become a new obligation in many member states. We talk about millions of locations in the EU where birds are kept for shorter or longer time.

We expect that in implementing acts derogations will be mentioned. However in this delegated regulation nothing is mentioned about derogations for small holders.

There are arguments to doubt the value of the registration of every bird keeping location for the prevention and control of animal diseases.

Therefore, we strongly plea for an exception for the registration of every location where birds are kept as is formulated in the delegated act and also for the obligations of record keeping by the operators.

We plea to leave it to the member states to formulate in contingency plans risk-based measures for non-commercial bird keepers. There are small differences between member states in today contingency plans who are related to the structure of commercial and non-commercial keeping and breeding of birds in their country. It is important that these flexibility for member states can be continued.

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NBvH (Dutch Hobby and Smallholders Association)
Erichemsekade 11
4116 GD Buren
The Netherlands
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