This morning I was looking into Switzerland's new animal welfare labelling law. I was going through the list of abuses that are now required to be documented on labels, and one of them made me do a double-take: "Frogs: Leg removal without anaesthesia."
This confused me. Why are we talking about anaesthesia? Shouldn't the frogs be dead before having their legs removed? It turns out the answer is no; standard industry practice is to cut their legs off while they are fully conscious. They remain alive and responsive for up to 15 minutes afterward. As far as I can tell, there are zero welfare regulations in any major producing country.
The scientific evidence for frog sentience is robust - they have nociceptors, opioid receptors, demonstrate pain avoidance learning, and show cognitive abilities including spatial mapping and rule-based learning.
It's hard to find data on the scale of this issue, but estimates put the order of magnitude at billions of frogs annually. I could not find any organisations working directly on frog welfare interventions. Here are the organizations I found that come closest:
- Animal Welfare Institute has documented the issue and published reports, but their focus appears more on the ecological impact and population decline rather than welfare reforms
- PETA has conducted investigations and released footage, but their approach is typically to advocate for complete elimination of the practice rather than welfare improvements
- Pro Wildlife, Defenders of Wildlife focus on conservation and sustainability rather than welfare standards
This issue seems tractable. There is scientific research on humane euthanasia methods for amphibians, but this research is primarily for laboratory settings rather than commercial operations. The EU imports the majority of traded frog legs through just a few countries such as Indonesia and Vietnam, creating clear policy leverage points. A major retailer (Carrefour) just stopped selling frog legs after welfare investigations, showing corporate campaigns could work.
I'd hope to see something analogous to the Shrimp Welfare Project sprouting up in the near future.
Update: (disclaimer for the following link; the footage is some of the most horrifying I've seen) A PETA investigation found that some numbing is attempted using ice water but is not effective when tepid.
Very cool, thanks for doing this! It's a big and neglected topic for sure.
A few months ago, I actually spent a day looking into farmed frog welfare (so slightly different to what you point at, which is the painful procedures done to wild and farmed frogs). I'll post my exec summary below in case others are interested. You can see the full doc here.
Overall recommendation
Approximately 1 billion frogs are farmed each year for food, and there is a similar number alive on farms at any one time. Despite this, the vast majority of them (93%) are farmed in China, meaning it is very challenging to advocate for ways to improve their lives. The most promising approach would be via targeting US imports of frog legs, which amount to approximately 58-146 million frogs killed per year. However, there are very few organisations working on this and it’s not clear what leverage groups would have to affect US imports or sellers. Overall, I expect that there are more cost-effective ways to help other groups of very populous animals, such as chickens, fish or shrimp.
Executive Summary
Thanks for putting this together I’m actually working on understanding amphibians and reptile farming as part of my PhD research. From what I’ve seen, the data is rarely available in English — and the scale is unfortunately much more horrendous than most people realize. I have some primary data from 2017 and also published a paper on this not long ago: https://www.sciencedirect.com/science/article/abs/pii/S2590332225001022?dgcid=coauthor
(unfortunately the main industry report was removed from China's academy of engineering website no so long ago, although there should be plenty of info available in Chinese –– grey literature/government annoucements, etc)
If you (or anyone else here) are interested, we could maybe put together a short report to make a very basic estimation of the numbers of frogs being farmed in China, and the species involved.
This section from a previous research piece provides additional context on the scale of frog farming.
Sometimes, just when it seems like conditions for so many farmed animals basically couldn’t get any worse, one comes across yet another widespread industry practice that’s deeply disturbing.
A friend showed this to me. Unfortunately, this seems like a massive under-estimate as the vast majority of commercially traded frog legs still come from wild-caught frogs rather than farms.
Thank you so much for this important post. This could be a low-hanging fruit. And I hope I can shed some light on where the fruit trees might be located.
I am not sure about the non-Asian countries that export frog legs to Europe, but I quite certain that it's pointless to try to directly convince/force processing factories in Asia to kill frogs in more humane ways. The way to go is to affect how the demand side behaves.
And I think it's not the best strategy to try to use education/adovcacy to try to reduce frog leg consumption. At least not as a standalone strategy. But it could be part of other work like corporate engagement and lobbying.
I also think corporate engagement work, like the Carrehour win PETA seems to be associated with, won't have a significant effect on the number of frogs beings raised and killed inhumanely. I believe the reason is that the demand is simply way higher than supply (and prices are like super high because of that), meaning that whatever amount of frog legs that Carrefour gives up would be picked up by someone else. This is pretty much regardless of how large of a purchaser Carrefour are, because other supermarkets and restaurants can't buy enough anyway, they would just likely pick those up.
I think the way to go is to get European countries (main target would be France) or EU at large to ban frog legs that were killed inhumanely. And I think a strategy that can be tried is to get charities other than PETA to do basically the same investigations and then protests.
This is really helpful and thoughtful. I agree with you that bans are probably the way to go but I worry they may be difficult to enforce. I think importers could easily circumvent restrictions through relabelling. There's already widespread mislabelling of frog species—though, to be fair, much of it doesn’t appear to be intentional.
I think Switzerland’s new welfare labelling law will be interesting to watch. Many of the practices now required to be documented are already banned locally, so the law will primarily affect imports. It may offer useful lessons on enforcement (or lack thereof).
Insightful strategy analysis!
An element worth considering is whether EU countries are (legally) competent to unilaterally impose import bans for products outside EU. In the EU, certain campaigns for national import bans have stranded once NGOs realised their country could simply not impose it (e.g. Belgian judiciary stopped the Flemish import ban on horse meat from South-America). At first sight, I would think EU law allows national bans for frogs (ChatGPT said no but I disagree).
If EU countries are not competent, it could still be a good lobbying priority at EU level as the ban does not seem to hurt local farmers or producers, but only local economy (mainly importers and restaurants so turnover should be low i think?). As far as i know (correct me if i am wrong) there is no precedent of an EU import ban on animal products that was not inspired/preceeded by national bans? I think the seals products ban was first in other countries (like Belgium)?
Thank you for this important post!
I'd like to add that another important aspect of frog welfare is the welfare of frogs living in the wild, of which there might be something like hundreds of billions[1] to hundreds of trillions[2].[3]
I think the most tractable way to improve the welfare of as many wild frogs as soon as possible is to invest in efforts to establish the foundations of wild animal welfare science, explore avenues for translating wild animal welfare science into real-world policy change, and build grassroots support for such policies. Relevant orgs include:
[1] What's a few Humanities' worth of minds, between friends?
[2] Time flies when you're counting seconds for hundreds of millennia!
[3] These estimates come from taking the total amphibian population estimates from Tomasik (2009) and Bar-On, Phillips, and Milo (2018) (Supplementary Material, page 39) and dividing them by 10. I don't know if that's reasonable -- I just know there are way more salamanders out there than you'd think. My guess is it's conservative, i.e., that frogs account for more than 10% of amphibians.
Hi Cameron,
Did you see Chytrid Fungal Infection and Frog Welfare — EA Forum?
It would be great if you can respond to it too.
This is fascinating. Thank you for sharing!
This is potentially an incredibly valuable post. Great work!
Wow, this is completely horrifying. Why are they not killed first? Not that that wouldn’t be horrifying too, but obviously this is worse.
Its worse than I thought. Frogs are cut open, skinned and have their snouts and rear legs cut off with scissors or a blade while still alive. It seems the primary reason for this is because freshness is perceived as important for taste, although I couldn't find much information. Truly horrifying indeed.
"Freshness" being perceived as important for taste is definitely true in China. In some wet markets in China, frog vendors try to skin the frogs first and keep the head intact, and only cut the heads off when a customer verifies that that frog is alive, and then buys the frog.
(You might already be aware but I think that website you linked is just LLM-generated articles. They're quite difficult to avoid on search engines these days. The information might still be accurate of course.)
I was not aware. Thank you for flagging that. I just did some more research and I'm not able to find more credible information about why they are not killed first. I'm glad @Fai was able to corroborate "freshness" being a driver in the Chinese context but it's now unclear to me why they are not killed first for European imports.
To be "fair", some processing factories in Asia who exports to Europe cut the heads of the frogs first, so those frogs suffer way less (but still horrifically).
I am not sure why there is a high variety of methods for killing frogs for the same product. But I guess it might be because different factories just try to find different ways for killing frogs in the quickest ways, and it happens that it largely depends on their workers' hand skills and their equipment?
This comment prompted some further research. It seems the order of operations varies significantly between facilities and even between workers in the same facility:
The variation in methods is concerning, but even more disturbing is what happens regardless of the sequence chosen. Another thing I uncovered was that there is weirdly strong evidence that frogs can remain conscious after decapitation.
Mammals lose consciousness within 10-20 seconds of decapitation when blood pressure drops and oxygen delivery ceases. Amphibians, adapted for low-oxygen aquatic environments, respond differently. When oxygen is cut off, frog brain cells reduce their metabolism by 80-90% through "channel arrest" - shutting down ion channels to conserve energy. This metabolic suppression allows neurons to maintain electrical activity using residual oxygen and stored ATP in the severed head for 10-15 minutes. This physiological adaptation, beneficial for surviving in oxygen-poor ponds, means frogs likely remain conscious long after decapitation rather than losing awareness within seconds like mammals.
So even facilities that decapitate first—thinking it's more humane—likely aren't preventing suffering as intended. AVMA guidelines state that decapitation must be followed by "pithing" (the physical destruction of the brain and/or spinal cord by inserting a sharp probe and scrambling the nervous tissue). This procedure is not documented in any commercial operations
"Frogs: Leg removal without anaesthesia." is an understatement of what could happen to frogs used to produce frog legs endure. A lot of them in processing factories in Asia are skinned alive first and put or hang (using a hook piercing through their eyes or feet) there, until another worker has time to cut off their legs.
I didn't put up links to videos about the practice, but if you want to know the extent of suffering, it should be easy to find. (I just realised the OP put up a video too, after typing the comment)
I will write another comment related to strategy.
Thank you for bringing attention to this insane issue.
And thank you @Chad Brouze for your comments further shedding light on why they aren't decapitated first (and why that probably wouldn't be enough).
As horrifying as this issue is, I'm grateful I don't have to learn and deal with it alone. Please don't hesitate to let me know if there anything I can do to help support the solution.
Thank you for suggesting that you are willing to support a potential solution to this.
This gave me an idea, maybe if enough of us signaling that we are willing to donate/work/volunteer for this potential new charity, we can make it come true?
I am certainly willing to allocate the majority (see update below) of my next years' donations to this potential charity (or this year, if this charity can come this fast), and provide free advisory service to it.
UPDATE: On reflection, maybe it was too quick a decision to pledge that it should be the "majority" of my next years donations before further investigations on other alternatives. But I am very sure it will be significant (if this charity do come into existence).
I would also be willing to contribute my time and money to support this cause. My money would be limited, but I can help with research, advocacy and outreach. Message me and maybe we can talk about ways to get this off the ground because this seems really important and completely neglected
I am glad that someone has noticed this. In fact, I am also concerned about policies related to animal welfare. But I want to say, it's difficult to achieve. Because there is no interest driving them to improve this. Unless it is profitable or the cost of animal abuse increases, it will not be easily changed
This is a very enlightening and clever-to-make post: billions annually for a species I'd never even thought about giving special attention to, or thought about much at all, three years in amateur EA and nine in veganism.
For what it's worth, I could see them being more "personally relatable" than fish, about on the level of chickens, even. I've seen fellow zoomers walk around with frog-themed stuff like beanies, hoodies, and backpacks, which seems important when assessing tractability.