Thank you so much for this discussion! I don’t have much to add except to say that, as you mentioned earlier, linguistic skills for certain key languages like Chinese are something often forgotten in the cause of global animal welfare, but they’re crucial to EA work around this internationally. More presence in China would benefit EA work as a whole, although that’s obviously easier said than done.
I also agree with the idea of extending existing legislation for animal welfare, even though my ultimate goal is the abolition of animal agriculture. Considering the existing economic and sociopolitical realities, outright bans on animal agriculture or slaughter are unfortunately not politically possible at the moment.
Existing legislation has the advantage of already being on the books, and if we can clearly frame the issue as addressing what such legislation was originally intended to address, as well as ways expanded laws benefit humans, it may be the best way of getting those with low prior commitments to animal welfare onboard.
Yes, if there is one key takeaway from the report, I think it would be that someone with more local knowledge on China should investigate the Shandong guidelines in more depth. I was quite excited to see these guidelines and my research seems somewhat promising, but this needs to be validated further.
It seems like we are also aligned on the other points :)
This is the third in a sequence of posts taken from my recent report: Why Did Environmentalism Become Partisan?
Summary
Rising partisanship did not make environmentalism more popular or politically effective. Instead, it saw flat or falling overall public opinion, fewer major legislative achievements, and fluctuating executive actions.
Public Opinion...
This post presents the executive summary from Giving What We Can’s impact evaluation for 2025. At the end of this post we share links to more information, including the full report and...
Why building and backing Welfare Tech companies may be one of the most promising things we can do for billions of animals.
I used AI to assist in writing this post, but I’ve rewritten it extensively and endorse it.
* Announcing the launch of Spring Innovation Fund, a not-for-profit venture philanthropy studio and fund built specifical...
This report was conducted within the pilot for Charity Entrepreneurship’s Research Training Program in the fall of 2023 and took around eighty hours to complete (roughly translating into two weeks of work). Please interpret the confidence of the conclusions of this report with those points in mind.
For questions about the structure of the report, please reach out to [email protected]. For questions about the content of this research, please contact Moritz Stumpe at [email protected].
Thank you to Karolina Sarek and A. K. for their review and feedback.
Executive summary
This research report was conducted as part of Charity Entrepreneurship’s Research Training Program. The aim of this report was to explore the potential of extending current animal protection laws, conventions, and directives to adjacent areas, which might be more feasible than proposing entirely new laws. This research focused on identifying and evaluating laws in various geographic regions and prioritising ideas based on their potential impact.
The key findings of the report are as follows:
The Shandong guidelines on chicken handling, transport, and slaughter, passed in 2016, could provide a highly promising area for extending legislation. Several extension ideas are proposed. These issues should be investigated in more depth by consulting with existing animal advocacy groups and experts in China to determine next steps.
The UK’s Animal Welfare Act 2006 may also be a promising law to extend. Potential extensions to fishing and/or invertebrates should be investigated further.
The Ohio Administrative Code, Section 901:12, currently only bans caging practices in production. This ban could be extended to sales, thus also affecting state imports. This intervention idea should be passed on to existing animal advocacy groups in the U.S., which they may pursue or investigate further.
EU Regulation 1/2005 and Directive 98/58 could be extended to (farmed) fish. This intervention idea should be passed on to existing animal advocacy groups at the EU level, which they may pursue or investigate further.
Other laws yield less promising ideas for extension.
Overall, these ideas have only been investigated in a relatively shallow manner. This report should act as inspiration for further work and research to determine the real merits of the proposed ideas.
1 Aim
The topic for this report is a scoping exercise, with the goal of looking at existing animal protection laws, conventions, directives, and other regulatory frameworks (called only ‘laws’ from here on) and see how they could be extended to adjacent areas. This was chosen as a research area because extending existing laws might be more tractable than proposing completely new ones.
The idea was to investigate relevant laws and geographic regions, find potential ideas in this context, and then prioritise those ideas in terms of their promisingness. The most promising ideas were selected to undergo a quick review, based on which recommendations for further research were made.
2 Research process
The basis for this report is this spreadsheet, which I set up to structure my research. The most relevant, but not all, findings from the spreadsheet are included in this report. Additionally, the report includes findings that were not included in the spreadsheet. Interested readers may thus consult the spreadsheet for further information and details regarding the entire research process. However, this report acts as a standalone resource and is more relevant than the spreadsheet, summarising the most crucial and action-relevant information from my research. In this section, I describe the process I followed to set up the spreadsheet and arrive at the findings of this scoping exercise.
First, I tried to find the most relevant animal laws in this short period of time. In my search, I prioritised the United States (U.S.), the European Union (EU), a few major European countries, and some major low- and middle-income countries (LMICs) (China, Brazil, India, Indonesia), since these should be the countries where legislative changes would have the biggest impact (i.e., countries with the most animals killed (Our World in Data, n.d.)) and/or should be most tractable. I came up with a list of 38 laws, most of which were from the U.S. and the EU.
Second, I brainstormed potential ideas for extending these laws to adjacent areas, for instance by strengthening regulations (e.g., space requirements or transport times), applying them to further animal groups or geographic regions, or covering other parts of the supply chain or market (e.g., applying rules to imports or extending production bans to sales). I excluded 15 laws that did not seem promising in this respect, as I did not see any ideas for extending those laws that would be highly promising. This left me with 23 laws for further investigation.
Third, I listed all the specific ideas that resulted from my brainstorming for these remaining laws - a set of 39 ideas (usually 1-2 ideas per law, in rare cases more). I scored these ideas on the dimensions of scale, tractability, and neglectedness and converted this into an overall score. I spent roughly 5-10 minutes per idea on this scoring, using some evidence, but generally only doing very quick intuitive reviews.
Fourth, I reviewed the list and scores in full to ensure that my ratings were consistent and reasonable, and tried different ways of computing the final score to perform sensitivity checks.
Finally, for the top nine ideas (scores of 30 or larger), I consulted my advisor and listed crucial considerations in order to ensure that I did not miss any important factors and to get a more holistic perspective on each intervention. Based on the scores and crucial considerations, we decided on to proceed with different the laws and ideas.
In the following section, I discuss the findings of this research regarding the most promising laws and ideas that emerged from this process. I list some initial pieces of evidence and crucial considerations for the extension of each of the laws, based on quick reviews. I then make recommendations on how to proceed further with these ideas, which can serve as starting points for further research.
The laws are covered in descending order of expected promisingness. I conducted more detailed research on the laws listed first, especially on the top priority, the chicken welfare guidelines in Shandong, China.
3 Findings
The following table provides an overview of the different laws covered in detail in this report and the investigated ideas on how to extend them. Further laws and ideas can be found in the aforementioned spreadsheet and are mentioned in section 3.7.
Law
Extension idea
Recommendation
Guidelines on chicken handling, transport, and slaughter (Shandong, China)
Introduce other standards for chicken welfare
Further research and potentially fund existing groups
Extend to other animals
Extend to production in all of China
Extend to imports to Shandong from other provinces
Animal Welfare Act 2006 (United Kingdom)
Extend to fishing
Further research and potentially fund existing groups
Extend to invertebrates
Ohio Administrative Code, Section 901:12 (Ohio, United States)
Extend to sales
Recommend to existing groups for further investigation
Prevention of Cruelty to Animals Act 1960 (India)
Include mutilations in the definition of cruel practices
No further research/action
Extend to religious slaughter methods
Regulation 1/2005 (European Union)
Extend to farmed fish
Recommend to existing groups for further investigation
Lower the bar of 8 hours
No further research/action
Directive 98/58 (European Union)
Extend annex to fish
Recommend to existing groups for further investigation
Extend to imports
No further research/action
3.1 Guidelines for chicken handling, transport, and slaughter (Shandong, China)
In 2016, the Chinese province of Shandong introduced guidelines for poultry handling, transport, and slaughter (Huang, 2016; World Animal Protection, 2020a). There might be an opportunity to extend these guidelines beyond their current scope, which could have implications for animal welfare on a large scale. The standards for chickens could be made more comprehensive (e.g., introducing certain space requirements) or could be extended to other animals, to other regions of China, or to cover sales, not only production. As this is the most promising topic that emerged from this scoping exercise, I investigate it in more detail here than the other laws following afterwards. I first outline the current state of animal protection legislation in China (section 3.1.1) and the general potential for improving it (3.1.2), then describe the Shandong guidelines in detail (3.1.3) and list ideas for extending them (3.1.4), and finally summarise my findings and make recommendations for further research (3.1.5).
It is important to note that my shallow research on this topic is severely limited by language barriers. I primarily relied on World Animal Protection’s description and interpretation of Chinese legislation, trying to add links to the relevant laws in either English or Chinese, depending on what I found online. In general, I relied only on English-language sources. Some of the information may thus be inaccurate. For further research, Chinese language skills or translations of original sources would be helpful.
3.1.1 Animal protection legislation in China
Understanding the situation for farmed animals in China, particularly regarding legislative protection, is essential before delving into the specific topic of Shandong.
China farms animals on a very large scale. It leads the world in the number of animals slaughtered for meat per year and is by far the largest egg, fish, and seafood producer globally (Ritchie et al., 2019; Ritchie & Roser, 2021). At the same time, animal welfare standards and legal protection are low (World Animal Protection, 2020a). In an interview with Forbes (Tobias, 2012), Peter Li from the Humane Society International summarised the dire situation for animals:
“Animal suffering is unprecedented in China in magnitude in both numerical terms (having the largest number of nonhuman animals in farming units) and in welfare conditions. With regard to China’s ranking on a global report card, so to speak, I would not hesitate to say that it may be at the bottom, if not the very bottom. Why do I say so? Look at the facts: Mainland China does not have a comprehensive animal protection law. Animal cruelty is not a punishable offense. China has the world’s largest number of animals in the industrialized farms. China’s continuing development model gives priority to productivity increase defined in terms of material gains. China’s pro-business politics has made societal voices for animal protection a nuisance to policy-makers and the business communities alike. The overall political environment is against activism for animal protection, certainly in the foreseeable future.”
While China has certain regulations and standards when it comes to the farming of animals, most of these are weak and/or focused on food safety and public health concerns instead of animal welfare. This is evident in all areas of animal farming, from rearing to transport and slaughter.
When it comes to the rearing of animals, the Animal Husbandry Law of the People’s Republic of China is the most important legislation. However, its focus is primarily on the protection of genetic resources rather than on animal welfare. In addition, the Chinese Veterinary Medical Association, guided by the Ministry of Agriculture, has undertaken the development of General Principles of Animal Welfare. These principles serve as non-binding guidelines that encompass a range of animal categories, including farmed animals. They touch upon critical aspects, such as infrastructure, feeding environments, and health. However, these guidelines are not mandatory and specific legislation dedicated to the rearing of individual animal species remains absent, signifying a critical gap in animal welfare regulations. (World Animal Protection, 2020a)
Regarding transport, Article 53 of the Animal Husbandry Law of the People’s Republic of China stipulates that the transportation of animals must adhere to relevant by-laws and regulations, ensuring the safety and essential needs of livestock during transit. This legal provision emphasises the importance of providing adequate space, food, and water during transportation. Furthermore, the Animal Epidemic Prevention Law of the People's Republic of China and its associated documents encourage avoiding long-distance transportation of livestock, recognizing the potential for stress and harm during extended journeys. In sum, legislation focusing on the transport of animals appears relatively progressive when compared to other sections of the legislation dedicated to rearing conditions. (World Animal Protection, 2020a)
With respect to the slaughter of animals, the Ministry of Agriculture has issued supplementary documents with the intention of promoting humane slaughter practices, especially the practice of stunning before slaughter. However, it is important to emphasise that the use of stunning remains optional and not mandatory. (World Animal Protection, 2020a) Specific standards are in place for pig slaughter though, requiring humane slaughter (World Animal Protection, 2020a). Regulations such as Articles 8, 11, and 15 of the Regulations on Administration of Hog Slaughter and Article 13 of the Implementation Methods of Pig Slaughtering Management Regulation address various aspects of slaughter conditions and procedures for pigs. This includes the prohibition of injecting pigs with water to increase their weight prior to slaughter and a requirement for inspections of pig slaughterhouses pre-and post-mortem. Despite these regulations, there is a notable lack of clear enforcement mechanisms, leaving room for improvement in ensuring the humane treatment of animals during the slaughter process. (World Animal Protection, 2020a)
In addition, the Ministry of Agriculture has introduced regulations pertaining to veterinary medicine and daily veterinary practices. One significant measure includes the establishment of a veterinary medicine list, which restricts the use of medicines not included in the list, thus preventing the potential for drug abuse within the industry. (World Animal Protection, 2020a)
In sum, China’s legislative protection for farmed animals is weak. Pig slaughter and transport are the only aspects that somewhat stand out from this overall picture.
3.1.2 Possibility of legislative improvements in China
Enhancing the legal protection of animals in China, given its relatively rigid and closed political system, appears to be a challenging task. However, “government is the most effective means of change” (Levitt, 2013) in China and extending the Shandong guidelines on chicken slaughter would require policy lobbying. It is thus worth investigating the tractability of legislative improvements for animals in China. In this section, I will outline crucial considerations around this general issue, before turning to the Shandong guidelines in the next section.
Primacy of food security, economic development, and public health
In China, ensuring food security and maintaining social stability through low prices often takes precedence over animal welfare considerations and has done so for decades (The Economist, 2023; Tobias, 2012). This priority also seems to be deeply rooted in Chinese culture. For instance, in contrast to the Western ‘how are you’, the traditional Chinese greeting is ‘have you eaten’, and Peter Li from the Humane Society International argues that pork is as important to Chinese consumers as gasoline is to Americans (Tobias, 2012). The primacy of food security and public health is also evidenced by the heavy emphasis placed on these issues by China’s strong animal welfare science literature (Sinclair et al., 2020). This historical and continuing prioritisation of economic development and food security over social and environmental concerns, including animal welfare, has created a significant hurdle to enacting comprehensive animal protection legislation (Levitt, 2013).
However, an emphasis on non-animal-specific factors is not always detrimental to progress on animal welfare reforms. Food safety and public health are important concerns in China that can benefit from enhanced animal welfare standards. A wide variety of sources show that Chinese consumers have a preference for higher-welfare products, benefiting food security, public health, and individual health (Carnovale et al., 2021; Jiang et al., 2023; Levitt, 2013; The Economist, 2023; World Animal Protection, 2016; You et al., 2014). These factors seem more important than animal welfare concerns, when it comes to people’s consumption choices. In that sense, it seems fair to conclude “that the majority of the public in China take a stand of weak anthropocentrism” (You et al., 2014) and that “animal welfare is of importance to the Chinese consumer, in particular because of its connection to food quality” (Carnovale et al., 2021).
Overall, aspects that affect human wellbeing, like food security, public health, and economic development clearly dominate concerns among the Chinese public and legislators over specific animal welfare concerns. There is some potential for activists to leverage these issues though, as they can highlight that a lot of the issues that the public cares about are strongly negatively impacted by factory farming.
Low but growing concern for animal welfare
However, concern for animal welfare specifically for the sake of animals’ wellbeing seems very low in China. As The Economist (2023) writes, when it comes to farmed animals,
“China’s grim welfare standards are often as cruel as those of much poorer countries, where the idea that animals have feelings or rights is an unthinkable luxury. Opinion polls and consumer-spending habits indicate that one driver of continued poor treatment on farms and in slaughterhouses is widespread public indifference to such cruelty, including among besotted pet owners”.
Different studies (Carnovale et al., 2021; You et al., 2014) have shown that animal welfare is not a familiar concept to most people in China and “animal welfare as a societal concern is still at an early stage of development” (Carnovale et al., 2021). There is evidence that Chinese consumers show less compassion for the animals they eat than those in countries like Brazil, India, Russia, and the U.S. (The Economist, 2023). This indifference or insensitivity to animal suffering may be attributed to socialisation under Mao’s leadership (Tobias, 2012).
There are strong signs that public perception is changing though, especially among the younger generations and urban populations (Carnovale et al., 2021; Levitt, 2013; McGuinness, 2013). According to Peter Li (Levitt, 2013), young Chinese are exposed to new ideas like animal welfare, which were unknown or unimportant to their parents. Young people’s better economic situation allows them to care less about food security and more about ethical issues and non-material goods, making them more sensitive to cruelty and more charitable donors (Levitt, 2013; Tobias, 2012).
Economic progress generally brings about more demand for higher-welfare products. China's burgeoning middle class is increasingly willing to invest in higher-quality and organic food products (The Economist, 2023). Carnovale et al. (2021), Hinckley (2017), and You et al. (2014) all report that a majority of consumers are willing to pay more for food produced under better animal welfare conditions. “China is also changing the way it thinks about dog meat, animal testing, and the ivory trade” (Hinckley, 2017). Such shifts in consumer attitudes towards animal welfare also have an impact on economic incentives for producers. “Some analysts believe that there is an untapped market for food that can be shown to come from well-treated livestock” (The Economist, 2023).
Accordingly, World Animal Protection (2016) found strong indicators for consumers looking for higher welfare products. They quote their own campaign manager in China, Chu Xueqin, saying: “There is a growing awareness among Chinese people about the importance of animal welfare, and a growing demand for the food we eat to come from farm animals with a better quality of life” (World Animal Protection, 2016). Similarly, Jiang et al. (2023) find that “the Chinese public not only considers farm animals to be emotional and sentient but are also sympathetic toward farm animals that suffer inhumane treatment.” You et al. (2014) find that a majority of respondents agreed that rearing conditions for pigs and domestic fowls should be improved and that laws to improve animal welfare should be established. However, these concerns for animal welfare seem likely to be primarily driven by food security and (public) health concerns and are not necessarily indicative of people’s care for the animals themselves, as described above (Carnovale et al., 2021; Jiang et al., 2023; Levitt, 2013; You et al., 2014).
Looking at concern for animal welfare specifically, Carnovale et al. (2021) found that awareness of animal welfare was higher in their study compared to previously reported numbers. In general, attention to animal suffering seems to be at an all-time high in contemporary China (Levitt, 2013). The following passage from Levitt’s (2013) interview with Peter Li nicely illustrates the significance of the ongoing cultural shifts:
“Media attention on animal suffering is a radical revolution. In China’s pre-reform era, animal suffering or animal protection issues were never a report subject. Love of animals was condemned as bourgeoisie. Compassion for animals was considered counter-revolutionary. Pet ownership was believed to be the luxury of the exploiting class, having nothing to do with the life of the working people. Young people who have no recollection of the past and not influenced by the extremist ideological bias against pet ownership, are more likely to find cruelty to animals unacceptable.”
These changes in public perception have the potential to exert strong pressure for legislative change. While concern for animal welfare is at a very low base level in China, the rapid economic development of the country has brought about and will likely continue to bring about stronger demand for higher animal welfare.
Animal activism
Accordingly, animal activism is also growing in China. According to Jill Robinson from Animals Asia Foundation, the number of animal welfare organisations in China has grown from only one in the 1980s to hundreds in 2017 (Hinckley, 2017).
However, the Chinese government seems to overall pay relatively little attention to animal advocates in comparison to other interest groups, as they are no “immediate threat to social or political stability” (Levitt, 2013). Different sources mentioned a need for more work on educating the public and changing perceptions around animal welfare (The Economist, 2023; You et al., 2014).
Western influences on Chinese culture
One watchout in this context is that the concept of animal welfare is sometimes seen as a Western import and as incompatible with Chinese culture (The Economist, 2023). This viewpoint has led to resistance against adopting comprehensive animal protection legislation in China (Levitt, 2013). However, it seems similarly reasonable to argue that factory farming is itself a Western import (The Economist, 2023), whose practices (like gestation crates, battery cages, or tail docking) were enthusiastically adopted in Chinese farms over the last decades (Tobias, 2012). China has strong traditions that emphasise compassion for animals, like Daoism and Buddhism, even though interpretations of these cultural traditions likely vary widely. In addition, concern for animals is higher in Taiwan, a country with strong cultural and historical ties to China (The Economist, 2023; Tobias, 2012). So while there is some resistance to the import of animal welfare ideals from the West, there are good arguments against this view that can be leveraged by animal activists.
Positive momentum and next steps
My research revealed a promising sign that Chinese politicians might indeed be open to such arguments, creating a favourable political climate for animal activists.
“Yu Kangzhen, the Associate Minister of Agriculture, delivered a keynote speech on World Conference on Farm Animal Welfare in 2017. He acknowledged animal sentience and linked it to Chinese traditional culture. Yu Kangzhen stated that promoting animal welfare is an essential outcome of economic and social development, which contributes to green agriculture development, food safety and human caring embodiment. He also called on all the stakeholders in the Chinese animal husbandry industry to promote animal welfare, with an overarching plan fitting within the process of China’s economic and social development.” (World Animal Protection, 2020a)
Further positive momentum comes from the fact that China has already made relevant improvements to its animal welfare legislation over the past decade.
“In 2014 China repealed a longstanding law requiring animal testing for some cosmetics, and also implemented a law that makes eating endangered animals punishable by up to 10 years in jail. And while international ivory trade has been illegal since the early 1990s, China and the United States have continued to permit domestic sales, which animal activists say directly contributes to declining elephant populations. But in 2015, Chinese President Xi Jinping agreed to crack down on domestic sales, and in March, China closed 67 licensed ivory factories. The remaining 130 factories are expected to close by the end of the year.” (Hinckley, 2017)
Looking ahead, World Animal Protection (2020a) provides a cautiously optimistic outlook, emphasising many possibilities for legislative improvements. For instance, they see promise in the development of the General Principles of Animal Welfare for enhancing animal welfare practices in China. While these principles are not legally binding, they have the potential to raise awareness and concern for farm animal welfare across the livestock industry. Moreover, they can serve as practical guidance for incorporating animal welfare considerations into future legislation, thereby improving the implementation and enforcement of relevant laws. Additionally, the introduction of species-specific legislation dedicated to animal welfare within farm animal production systems is a crucial step, considering the non-binding nature of the General Principles. This legislative move would represent a significant stride towards improving the overall welfare of animals in China. Moreover, China's membership in the World Organisation for Animal Health (OIE) presents an opportunity for the nation to align with international standards. As China's current legislative landscape does not fully encompass all of the OIE's standards, ongoing efforts are essential to bridge this gap and bring Chinese legislation in line with international benchmarks. (World Animal Protection, 2020a)
Some positive developments outside of national/federal legislation are notable here as well. One of China’s largest agricultural producers voluntarily agreed to implement higher welfare standards for its pigs, like comfortable flooring and more space (Hinckley, 2017). The New York Times (Huang, 2016) reports that “major slaughterhouses in Beijing [...] already stun chickens by dipping their heads into electrified water”. They also state that Zhengzhou, the capital of Henan province, “requires slaughterhouses to allow pigs to rest at least 12 hours after being transported to the slaughterhouse before they are killed” and has penalties in place for violations of these rules. Henan was generally a first mover in terms of pig welfare requirements. Already in 2007, a pilot project in the province required pigs to be electrically stunned before slaughter and “that live pigs be spared from watching the slaughter of other pigs” (People’s Daily Online, 2016).
Summary
Overall, there is significant evidence that the current economic, political, and societal climate in China could be ripe for animal welfare legislation improvements. While I tried to keep my search for evidence as neutral as possible, my selection of sources is likely biassed towards positive views on this issue and I did not have time to more specifically check for negative examples (which future research could do). Still, this review updated me towards a more positive view on the tractability of legislative changes in China. These findings shape my perspective on the feasibility of expanding the Shandong guidelines, a topic I will explore in the following sections.
3.1.3 Scope and motivation of the Shandong guidelines
The province of Shandong decided to implement stricter guidelines on the welfare of chickens raised for meat production in 2016. These guidelines include specific requirements on different parts of the farming process. Regarding transport, they discourage the transport of chickens for more than three hours and prohibit the dragging of chickens by one of their wings or legs (Huang, 2016; People’s Daily Online, 2016). When it comes to slaughter, the standards mandate stunning by gas or electricity and recommend the use of soothing pads to calm animals down before slaughter (Huang, 2016; People’s Daily Online, 2016; World Animal Protection, 2020a). “Slaughterhouses must [also] avoid frightening or upsetting the poultry before they are dispatched for slaughter” (People’s Daily Online, 2016). Further requirements are defined with respect to the handling and living conditions of the animals (World Animal Protection, 2020a).
These guidelines should present a major step forward for farmed chickens in Shandong, as World Animal Protection (2020a) states that “humane slaughter is now legally required” for poultry in Shandong. However, I found conflicting evidence to this statement, as both The New York Times (Huang, 2016) and Sixth Tone (Li, 2016) write that the guidelines are not binding or mandatory. In contrast, Eurogroup for Animals (2023) writes that humane slaughter is mandated by law for poultry in Shandong. Frustratingly, my further research on this was somewhat inconclusive, with language barriers preventing me from accessing primary sources. As mentioned before, accessing and understanding primary Chinese-language sources should thus be a priority for further research. Based on my interpretation of the evidence, it seems that humane slaughter might be obligatory, while the other standards mentioned above (for transport, handling, and living conditions) are only recommendations. The fact that humane slaughter for animals is mandatory is also suggested by the phrasing used by Xinhua (2016), stating that “local rule on the humane slaughter of chicken took effect in east China's Shandong Province”. However, I remain uncertain about this and this is a crucial uncertainty that needs to be clarified in future research.
Assuming that at least humane slaughter is mandated in Shandong, this would affect a very large number of chickens. According to People’s Daily Online (2016), “Shandong is the biggest chicken breeding provincial region in China, providing some 20 percent of the country's chickens”. Given that China killed roughly 11 billion chickens for meat in 2021 (Our World in Data, n.d.), the regulation could affect more than 2 billion chicken killings annually. Shandong is generally one of the biggest producers of animal products among China’s provinces and has a clear strategy to be a leader in modern animal agriculture (e.g. by implementing quality-standard centres and promoting standardisation). "By 2025, 15 million tons of meat, eggs, and milk are expected to be produced in the province, the proportion of large-scale farming is expected to reach 88 percent” (China Daily, 2021).
This also relates to the reasons why the stricter animal welfare requirements were passed. According to People’s Daily Online (2016) and The New York Times (Huang, 2016), the guidelines were “motivated at least as much by commercial considerations as by concerns for animal welfare” (Huang, 2016), since low meat quality has impeded exports to more welfare-conscious markets like Europe as well as sales in high-end market segments within China. In comparison to its total broiler meat production volume, exports from China are relatively low (Huang, 2016). So even though animal welfare is a somewhat rising concern in China, the guidelines seem to be primarily aimed at improving commercial competitiveness of Shandong producers, a perspective that is in line with the evidence cited in section 3.1.2.
3.1.4 Intervention ideas
Given the significance of these developments in Shandong, animal advocates should consider ways in which the new guidelines could be leveraged to achieve even larger animal welfare improvements. As written at the beginning of section 3.1, the standards for chickens could be made more comprehensive (e.g. introducing certain space requirements) or could be extended to other animals, to other regions of China, or to also cover sales, not only production. These intervention ideas are quickly reviewed below.
There is one kind of intervention idea that I did not include here, due to the significant uncertainties I still have around this issue. As described in the previous section, I am unsure whether the Shandong guidelines are mandatory at all, or which parts of them are mandatory. My current most likely interpretation is that humane slaughter is mandated, while other parts of the standards are only recommendations. If this is true, it could be worth investigating whether the other parts of the standards can also be made mandatory. If all of the guidelines (including those pertaining to slaughter) are found to be voluntary, we should probably first investigate whether there is the potential to make (parts of) the standards mandatory, before considering other ideas for extending the law. These uncertainties need to be kept in mind for my analysis of the different intervention options below. The perspective on them could significantly change, if my assumption above is wrong, and I suggest further research to resolve this uncertainty.
Including further welfare standards
Maybe the most promising idea for extending the Shandong guidelines is to broaden the scope of the regulations, including further requirements for chicken welfare like banning cages, defining more minimum space per animal, or prohibiting mutilations like beak trimming.
The scale of such additional welfare improvements for broiler chickens could be very large, given the massive numbers of animals farmed in the province. However, given that parts of the standards are likely not mandatory, the exact requirements to ask for need to be carefully considered, in order to make sure that they indeed have an impact on farming methods.
Such an extension might be tractable, given that there is already some momentum around introducing welfare standards that go beyond those of other Chinese provinces. Policy work at the province level might also be more tractable than at the national level. Overall, policy advocacy in China seems to be very difficult. However, section 3.1.2 found grounds for optimism on the potential for legislative changes for animals in China.
Given the significance of the Shandong guidelines’ introduction, animal advocacy groups should be aware of the issue and might already be working towards extensions of this law. As the Chinese representative of Compassion in World Farming praised the Shandong standards, we know for sure that at least this organisation is aware of and potentially working on the issue (Huang, 2016). Other organisations in the country are very likely to be aware of it as well. The issue might still be quite neglected, as this is a very specific intervention idea in one region of a generally relatively neglected country. Even if some organisations are already working on this, the idea might benefit from more attention and funding.
Extending the standards to other animals
Another idea is to extend the Shandong guidelines to other animals, apart from chickens.
The scale of the issue depends heavily on which animals would end up being covered by such stricter welfare standards. If fish were to be included, the scale would be very large, as Shandong does seem to have a significant aquaculture industry (Chen & Gao, 2023) and might have a strong fishing industry as well, due its coastal location. For other animals like cows or pigs, the scale would be modest, as Shandong seems to be a large producer of other animal products as well (China Daily, 2021), but these animals are generally farmed in lower numbers. It seems more likely to me that this extension would affect the latter group of animals, as they are typically better protected by laws, so the scale of this idea seems smaller than that of the first idea above.
The considerations around tractability and neglectedness are very similar here as for previous idea.
Extending the standards to other provinces or all of China
It might also be worthwhile to advocate for an extension of the Shandong guidelines to other provinces or the whole of China.
The scale of such changes could be enormous, given that China kills the largest number of chickens worldwide (Our World in Data, n.d.).
The considerations around tractability and neglectedness are similar here as for the first two ideas above. Work on the national level might be less neglected than work on the province level though. The issue might also be less tractable, given that this is a massive ask, especially when thinking about national legislative changes. Work in other provinces might be more tractable, but lower in scale. Some positive evidence on the tractability of such extensions comes from the case of the Henan province. From my reading of the sources, Henan introduced stricter pig welfare requirements in 2007 and national regulations were introduced one year later, in 2008. While any causal effects between these developments are highly uncertain, this provides at least some positive evidence that certain provinces can be first movers whose stricter standards are later adopted (to a certain extent) on a national scale.
Extending the standards to cover imports from other provinces
One final idea is that the current guidelines could be made to cover sales, not only production. The idea here is that stunning would not only be required for chicken meat produced in Shandong, but all chicken meat sold there, which might have been produced in other provinces.
The scale of this seems modest, given that I assume most of the chicken meat sold in Shandong to be produced there as well due to Shandong’s high production levels.
The considerations around tractability and neglectedness are once again similar here as for the first two ideas above. The idea might seem like a natural extension of the existing law and could therefore be tractable. However, this idea generally seems more like a long shot, given that the motives for passing the current guidelines seems to lie in modernising production and not satisfying consumer demand for more ethical products. Importantly, it might also be legally impossible to prevent/penalise imports from other provinces, as was contested in the case of Prop 12 in California (Bollard, 2023).
3.1.5 Summary and recommendation for next steps
In sum, exploring the potential of extending the Shandong guidelines to other asks or other parts of China yields some promising intervention ideas. With the enormous amount of animals farmed in the region and their poor legal protection, improving animal welfare standards could have a large impact. While tractability of policy work in China seems generally low, I found promising signs that (at least some of) the proposed interventions might have a nontrivial chance of success. Given the high stakes, the remaining uncertainties seem worth exploring further, especially the question of whether (parts of) the Shandong guidelines are mandatory. Overcoming language barriers and consulting primary Chinese-language sources seems like a vital next step. Consulting with animal advocates and experts in China, like Peter Li of the Humane Society International, or Sun Jingxin, the author of the Shandong guidelines (Huang, 2016) also seems highly relevant. This can help to understand how neglected these issues are and whether there are certain organisations that could be funded to pursue such interventions. Supporting existing organisations generally seems more promising than incubating a new one, as I expect it to be hard for a new organisation from outside of China to make significant policy progress in the country.
In short, I suggest deeper research into this topic and consulting with existing animal advocacy groups and experts in China in order to determine next steps.
3.2 Animal Welfare Act 2006 (United Kingdom)
“The Animal Welfare Act 2006 [...], which came into force in April 2007, is the starting point in respect of the legal protection of vertebrate animals in England and Wales. Certain provisions of the Act extend to Scotland [...], and separate, similar, legislation covers Scotland and Northern Ireland” (Collinson, 2018). It includes the protection of farmed animals (World Animal Protection, 2020b). However, the standards do not apply to fishing (Collinson, 2018) and invertebrate animals (Crump, 2023). Extending the act’s scope to these areas could be a promising topic for campaigns.
The benefits of such extensions could be very large, as fishing and the farming of invertebrates involve large numbers of animals, even if this only affects the United Kingdom. However, one uncertainty surrounding these extension ideas relates to the Animal Welfare Act’s general nature. As an umbrella law, it might not be specific enough and further policies might need to be enacted on its basis in order to have a direct impact on animal welfare.
The tractability of achieving the proposed extensions is uncertain. As farmed fish are already included in the Animal Welfare Act, it seems relatively natural to extend the law to fishing / wild fish. However, opposition by the fishing industry can be expected to be strong, as the legislative change could greatly affect them. Also, the law currently only applies to animals that live under human control and it might be argued that fishing is thus not a suitable extension. The recent passing of the Animal Welfare (Sentience) Act 2022 suggests that invertebrate issues can benefit from some momentum in British politics, as the sentience of some invertebrates (cephalopods and decapods) was recognised by law.
Based on my very quick review of this topic, I am also unsure whether anyone is working on these topics already. Given that both fishes and invertebrates are usually among the more neglected animal groups, this issue might be neglected as well. However, I did find evidence that at least some people are already working on the invertebrate side of the issue (Crump, 2023). In addition, there already exist strong animal advocacy groups in the UK and they might be aware of and working on these issues. Aligning with existing groups seems like an important next step in investigating this idea. If they are not already working on it and the idea turns out to be promising upon further analysis, suggesting this intervention idea to them might be more promising than starting a new charity.
In sum, I suggest that potential extensions to the UK’s Animal Welfare Act 2006 be investigated further in a separate report and potentially suggested as an intervention idea to UK animal advocacy groups.
3.3 Ohio Administrative Code, Section 901:12 (Ohio, United States)
Several states of the United States have passed legislation against the use of cages in farming. The different state laws vary in terms of the animal groups they cover (calves, pigs, and/or chickens). In addition, some states only banned the use of cages in farming within their states, while others included both production and sales in their bans, extending the scope to products originating from other geographic areas that involve the prohibited caging practices. (CageFreeLaws, n.d.; also see the specific U.S. cage-free laws tab in the aforementioned spreadsheet) It could be promising to ask those states that have only banned production to extend their legislation to sales, as this seems like a natural step that has already been taken by other states. Focusing on chickens as the most numerous group of animals, we identified three states that already had a caged egg production ban that could be extended to sales: Ohio, Rhode Island, and Utah. Ohio is by far the most populous state of these three and should thus have the highest egg consumption among them. Therefore, an extension of the Ohio caged egg production ban to sales could be a promising idea.
However, the potential impact of such an intervention seems relatively modest. Firstly, Ohio has a population below 12 million (City Population, 2023a), a relatively small one compared to the other geographic regions considered for this scoping exercise (for comparison, Shandong’s population is above 100 million (City Population, 2022), while that of the UK is around 67 million (City Population, 2023b)). The sales ban would only apply to products from hens, sows, and calves that are consumed by this relatively small population. Secondly, and maybe even more importantly, given that a lot of the products consumed might also be produced in the state (for which a cage ban is already in place), a sales ban is likely to have a limited effect. As Ohio is a major egg producer itself (United States Department of Agriculture, 2023), it seems likely that a large share of eggs consumed would also be produced within the state.
It also does not seem like this issue is very neglected. Cage-free campaigns in the U.S. have received significant attention from the effective animal advocacy movement over the last years (Bollard, 2017), Proposition 12 in California was a recent very similar and high-profile case (Bollard, 2023), and there is a specific website dedicated to the cage-free laws in different U.S. states (CageFreeLaws, n.d.). It seems unlikely that a relatively populous state like Ohio would be neglected by animal advocates in the U.S.
Still, extending this legislation could be a relatively easy win that animal advocates could pursue. The issue seems highly tractable, given the successes of Prop 12 (in California) and Question 9 (in Massachusetts) and since a production ban is already in place (CageFreeLaws, n.d.).
Overall, this extension idea does not seem to warrant much further investigation. It could make sense to quickly check with relevant animal advocates in the United States whether anyone is working on this already and if not, suggest to them that this could be a potential quick win for the cage-free movement. Due to its relatively small scale and scope, this should not warrant a deeper investigation though.
3.4 Prevention of Cruelty to Animals Act 1960 (India)
“The Prevention of Cruelty to Animals Act 1960 is the main piece of animal welfare legislation in India. This Act recognises that animals can suffer physically and mentally, and is applicable to ‘all living creatures’.“ (World Animal Protection, 2020c)
Currently, the law exempts religious slaughter practices from the requirement of pre-slaughter stunning. World Animal Protection (2020c) highlights that such an exemption is not necessary for religious freedom though:
“The Government of India is urged to mandate the humane slaughter of all farm animals. Animals should be instantaneously rendered unconscious and insensible to pain and distress prior to slaughter. Today, there is growing consensus amongst religious authorities worldwide that pre-slaughter stunning is compatible with religious principles. Humane halal slaughter allows for the animal to be temporarily rendered unconscious via stunning prior to slaughter, as long as the animal's skull remains intact and the animal would regain consciousness in time should slaughter not occur. Therefore, animals should be unconscious before being bled, and no further processing should occur until irreversible loss of consciousness is confirmed.”
This passage suggests that removing religious exceptions is a promising idea for extending the scope of the Prevention of Cruelty to Animals Act 1960. However, I expect such an idea to be very intractable, as I am highly uncertain whether the view expressed by World Animal Protection is one that would meet acceptance among large shares of India’s Muslim population. Religious freedom should be an important right that legislators would not want to overturn and convincing politicians and the public that stunning is not in conflict with religious principles seems to be an uphill battle. Therefore I do not suggest this idea for further investigation.
Instead, there is another idea for extension that might be promising. As the name says, the Prevention of Cruelty to Animals Act 1960 is supposed to prevent cruelty to animals, including farmed animals. However, mutilations like castration, tail docking, and dehorning are not considered cruel under the law (World Animal Protection, 2020c). An extension of the definition of cruelty to include mutilations might thus be promising.
I am unsure whether anyone is working on this already and did not have the time to check this in depth. Since India is generally one of the more neglected regions globally, this idea might be as well.
The fact that India has relatively strong animal protection laws in place already and legislators might thus be open to animal advocates’ proposals suggests that this issue might be quite tractable. However, given the law's broad nature, a general proposal on mutilations might be more effective than specific bans or species-focused measures. Such a sweeping change in legislation is a big ask and reduces the tractability for this intervention.
The scale of this idea also seems large initially, given that India is a major producer of animal products worldwide (Our World in Data, n.d.) and mutilations affect almost all farmed land animal groups (FOUR PAWS, 2023; Nordquist et al., 2017). Mutilations are relevant to at least some marine animals as well (Crustacean Compassion, n.d.; Eurogroup for Animals, 2022). If the legislative change covered all mutilations, the potential effect for animals would be huge. As highlighted above, such a broad scope seems more fitting than a specific focus on certain animal groups. In addition, if the scope applied to only some kinds of mutilations or animal groups and excluded large-scale issues (e.g. beak trimming for chickens), the scale would be drastically reduced. However, the law’s general nature suggests that it may be too broad to have a specific impact. Current animal protection legislation in India is often not properly enforced (e.g. penalties are too low) (Kavuri, 2020; World Animal Protection, 2020c), which also makes it unlikely that additional requirements like a ban of mutilations would be properly enforced. On the positive side, there are some current efforts by legislators to strengthen enforcement and amend the legislation (FPJ Web Desk, 2022; Gopakumar, 2022).
Summarising, doubts about enforcement of the existing legislation lead me to question the promisingness of extending the law further. Even if mutilations could be included in the Prevention of Cruelty to Animals Act 1960, it might be a toothless tiger that does not have real impact for animals. For this reason, I recommend against pursuing this idea further.
3.5 Regulation 1/2005 (European Union)
Under Regulation 1/2005, the European Union sets comprehensive standards for commercial live transports of vertebrate animals (Simonin & Gavinelli, 2019).
One important aspect of the regulation is that stricter standards apply for transports with a duration of more than eight hours, in order to account for the higher strain on animals (Simonin & Gavinelli, 2019). One idea of extending this law might thus be to lower the bar of eight hours, such that higher welfare standards would also be applicable to shorter transports. A quick evaluation of this idea did not seem promising though and it does not seem worth investigating further. While the idea might be tractable (even though I did not investigate this in much detail), the scale of this issue seems small, as the bar could probably not be lowered too drastically (mostly due to industry opposition and economic considerations) and the change would thus only affect a relatively small share of animal transports in the EU. Also, legislative work in the EU is not neglected at all, even though I am uncertain if anyone is working on this issue specifically.
Another idea to extend this legislation relates to animal groups covered by it. “Most technical requirements [...] are designed for terrestrial farmed animals even if some administrative requirements remain applicable to other species (wild animals, dogs and cats, experimental animals, farmed fish, etc.).”
Extending the full standards to apply to farmed fish as well could have a large impact for animals, given the large numbers of farmed fish generally (Anthis & Anthis, 2019) and the fact that live fish transports seem common in the EU (Centro de Ciencias do Mar, 2021; Saraiva et al., 2021).
The research reports cited for the prevalence of live fish transports (Centro de Ciencias do Mar, 2021; Saraiva et al., 2021) also suggest that legislators have already expressed some interest in this topic. So while opposition from industry might be strong on this issue (due to its large impact), the idea should be modestly tractable.
Concerns around the low neglectedness of EU policy work mentioned above apply to this extension idea as well. However, to my knowledge, Eurogroup for Animals (probably the most prominent advocacy group for animals at the level of EU policy) does not focus much on fish. Fish transport is also not part of the initial scope of Charity Entrepreneurship’s soon-to-be incubated charity working on fish welfare in Greece.
Nevertheless, I decided against investigating this issue further, due to the strong ongoing policy advocacy efforts by other groups. It might be promising though to bring this idea to their attention as a potential policy proposal to consider in their future efforts.
3.6 Directive 98/58 (European Union)
Another piece of EU legislation that seemed promising to extend is Directive 98/58, containing general provisions for the farming of animals (Simonin & Gavinelli, 2019).
One idea for extension I considered was to push for the extension of these standards beyond production within the EU, such that imports would also be covered by them. I disregarded this idea fairly quickly though, as I found Eurogroup for Animals (n.d.) to already be working on the topic of imports. In addition, I was unsure whether Directive 98/58 could even be used to cover specific imports, as it seemed too vague and broad to be directly applicable here. It should be more promising to push for import coverage for other directives that apply to specific animals and farming practices.
Similar to Regulation 1/2005 described above, I did find a promising idea though when it comes to extending this directive to fish. Simonin and Gavinelli (2019) write:
“This directive contains general provisions applicable to all vertebrate farmed species but the annex to the directive does not apply to fish, reptiles and amphibians. This annex contains very general requirements (staff, record keeping, freedom of movement, accommodation, equipment, feed and water, mutilations and breeding procedures) which tend to reflect the principles of the five freedoms initially developed in the United Kingdom”.
Extending the annex of this directive to also apply to farmed fish might therefore be promising. It is important to note however that I did not check the exact contents of this annex besides what is described above, given the shallow nature of this scoping exercise. Doing so is an important next step for further research.
Apart from this, the crucial considerations for this idea are similar as for the fish extension idea investigated for Regulation 1/2005. The scale of the issue is high, given the large numbers in which fish are farmed. EU policy work is not very neglected, but fish welfare work seems to receive less attention than other issues. Tractability seems slightly more uncertain here, as I have no signs that legislators are already interested in this issue, opposition from industry might be strong, and legislators will probably be hesitant to apply the same rules to fish as to farmed land animals.
Overall, my perspective on this is similar to Regulation 1/2005. I decided against investigating this issue further, due to the strong ongoing policy advocacy efforts by other groups. It might be promising though to bring this idea to their attention as a potential policy proposal to consider in their future efforts.
3.7 Other ideas
While the laws outlined above represent those that seem most promising for extension, the scoping exercise revealed many other interesting ideas for extensions of animal protection laws. The full list can be found in the aforementioned spreadsheet, but some interesting ideas seem worth listing here for illustration:
Brazil’s Normative Instruction No 46 of 2018, which provides minimum standards for live animal transports of cows, buffalo, sheep, and goats, could be extended to animal groups that are not already covered under the law (e.g. pigs or chickens), to impose stricter standards, or to even include a ban of live exports.
The United States’ Animal Welfare Act, which is the country’s primary federal animal protection law, could be extended to cover (at least some) farmed animals, as it currently mostly relates to pets, animals kept in zoos, and animals used in laboratories.
Indonesia’s Law 18 of 2009, which includes provisions for the proper slaughter of farmed animals, could be extended to mandate pre-slaughter stunning.
The United States’ Twenty-Eight Hour Law, which sets standards for farmed animal transports across state lines, could be extended to include farmed birds in its scope.
Germany’s ban of chick culling could be extended to the whole EU. This would require a completely new law at the EU level though and is less of an extension of an existing law.
Some of these ideas might be interesting for further research, but had to be deprioritised for this exercise, as other ideas for extending existing laws seemed more promising.
4 Conclusion and next steps
In this report, I have analysed a variety of existing animal protection laws that could be promising to extend to adjacent areas. This was chosen as a research area, as extending existing laws might be more tractable than proposing completely new ones.
The laws and ideas I examined were defined by a step-wise research process, gradually narrowing down the laws and ideas to arrive at a set that seemed most promising. I shallowly evaluated some crucial considerations for these topics, which forms the basis for the following recommendations for next steps:
Investigate potential extensions to the Shandong guidelines on chicken handling, transport, and slaughter in more depth, consulting with existing animal advocacy groups and experts in China in order to determine next steps. Based on the findings of this further research, potentially suggest this as an intervention idea to Chinese animal advocacy groups and fund their work.
Investigate potential extensions to the UK’s Animal Welfare Act 2006 in more depth. Based on the findings of this further research, potentially suggest this as an intervention idea to UK animal advocacy groups and fund their work.
Suggest a potential extension of the Ohio Administrative Code, Section 901:12, as an intervention idea to existing animal advocacy groups in the U.S., which they might pursue or investigate further.
Do not investigate potential extensions to India’s Prevention of Cruelty to Animals Act 1960 further.
Suggest potential extensions of EU Regulation 1/2005 and Directive 98/58 as an intervention idea to existing animal advocacy groups at the EU level, which they might pursue or investigate further.
Overall, this report aims to provide a foundation for further in-depth research and exploration of these topics.
Carnovale, F., Xiao, J., Arney, D., Descovich, K., Guo, W., Shi, B., & Phillips, C. J. C. (2021). Chinese public attitudes towards, and knowledge of, animal welfare. Animals, 11(3), 855. https://doi.org/10.3390/ani11030855
Chen, W., & Gao, S. (2023). Current status of industrialized aquaculture in China: a review. Environmental Science and Pollution Research, 30(12), 32278–32287. https://doi.org/10.1007/s11356-023-25601-9
Jiang, B., Tang, W., Cui, L., & Wei, Y. (2023). Factors influencing Chinese public attitudes toward farm animal welfare. Frontiers in Psychology, 14. https://doi.org/10.3389/fpsyg.2023.1049530
Nordquist, R. E., Van Der Staay, F. J., Van Eerdenburg, F., Velkers, F. C., Fijn, L., & Arndt, S. S. (2017). Mutilating procedures, management practices, and housing conditions that may affect the welfare of farm animals: Implications for welfare research. Animals, 7(12), 12. https://doi.org/10.3390/ani7020012
Sinclair, M., Zhang, Y., Descovich, K., & Phillips, C. J. C. (2020). Farm animal welfare science in China—A bibliometric review of Chinese literature. Animals, 10(3), 540. https://doi.org/10.3390/ani10030540
You, X., Yi-Bo, L., Zhang, M., Huo-Qi, Y., & Zhao, R. (2014). A survey of Chinese citizens’ perceptions on farm animal welfare. PLOS ONE, 9(10), e109177. https://doi.org/10.1371/journal.pone.0109177
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Thank you so much for this discussion! I don’t have much to add except to say that, as you mentioned earlier, linguistic skills for certain key languages like Chinese are something often forgotten in the cause of global animal welfare, but they’re crucial to EA work around this internationally. More presence in China would benefit EA work as a whole, although that’s obviously easier said than done.
I also agree with the idea of extending existing legislation for animal welfare, even though my ultimate goal is the abolition of animal agriculture. Considering the existing economic and sociopolitical realities, outright bans on animal agriculture or slaughter are unfortunately not politically possible at the moment.
Existing legislation has the advantage of already being on the books, and if we can clearly frame the issue as addressing what such legislation was originally intended to address, as well as ways expanded laws benefit humans, it may be the best way of getting those with low prior commitments to animal welfare onboard.
Thanks for your comment Hayven!
Yes, if there is one key takeaway from the report, I think it would be that someone with more local knowledge on China should investigate the Shandong guidelines in more depth. I was quite excited to see these guidelines and my research seems somewhat promising, but this needs to be validated further.
It seems like we are also aligned on the other points :)