Thank you for writing this post! I worry it'll get neglected due to difficulty in measuring the scale of suffering. I agree with @Fai that this might be more important the the slaughter issue.

This is fascinating. Thank you for sharing!

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.

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).

This comment prompted some further research. It seems the order of operations varies significantly between facilities and even between workers in the same facility:

• Skinning → leg removal → decapitation - Some facilities skin frogs while fully conscious, then cut off legs, then decapitate
• Partial decapitation → leg removal → skinning - Workers "hack at" heads without full severance, then remove legs
• Leg removal → decapitation - Direct leg removal from conscious frogs, followed by decapitation
• Decapitation → skinning → leg removal - This appears to be less common in commercial operations

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

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. 

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.

Really helpful!