ISO/TC23/SC19/WG3/N223
Letter of AFNOR to Mr Eicher, Secr. General of ISO/Geneva, dated: 17/08/1999
Dear Secretary General,
As members of the French "Agrotique" Committee, the mirror committee for the work of ISQ'TC 23/SC 19 "Agricultural Electronics't, we wish to assure you herewith of our support for the standards ISO 11784 :1996 and ISO 11785 :1996 relative to the electronic identification of animals.
We have indeed been informed that a destabilisation campaign in favour of the cancellation of these standards, was again being conducted at the initiative of the sole manufacturer of transponders who does not apply them, backed by the ISO Member Bodies who do not use them.
Consequently, we would like to inform you of our technical analysis of the arguments put forward by Russia and recall to mind, as a preamble, that all of them have already been examined in depth during the course of the work, without any new elements having been put forward in order to justify this approach
V the standards ISO 11784 and 11785 would not guarantee the unicity of the codes : the protection of the identification does not reside in the choice of the selected technology, but in all of the regulatory texts which will have to be jointly introduced by the member states. The advanced transponders currently under study will offer additional protection
V the current standards would not be applicable to both livestock and companion animals : natural scale experiments which are aimed at checking the reliability of electronic identification by radiofrequency are currently being conducted, both on cattle/sheep and on dogs/cats. For the record, it is a question of the IDEA project which concerns 2 million sheep/cattle and for example the experimentation currently being carried out in France on approximately 10 000 dogs/cats
V the current standard would include 2 incompatible technologies according to the studies conducted by IMAG-DLO, it turns out that the majority of existing readers integrate without difficulty the 2 technologies (FDX and HDX);
V each standard should define per species the best identification means (eartags and bolus for livestock and transponders for companion animals) : it is a matter of user choice, in this case the authorities, which is outside the scope of standardisation
V the current standard does not allow sufficient compatibility : with the aim of progressively passing from the different transponders available on the market to those complying with ISO 11785, it has been possible to use transponders conforming to the requirements of annex A of the said standard during a provisional period (2 years as from the publication of the 1$t edition of the standard).
To conclude, the standard isation work under way on advanced transponders (lSO/WP 14223) constitutes an extension of the both ISO standards involved.
Taking these elements into account, we can only but renew our total support for these 2 standards - ISO 11784 and 11785 - and request you to kindly take our position into consideration when examining this dossier.
We remain, dear Secretary General,
M. Gourmellen, Chairman of the French "Agrotique" Committee
c.c.: M ABRAM (ISO/CS)
M ZENS (ISO/TC 23/SC 19 Secretary)
M VAN'T KLOOSTER (lSO/TC 23/SC 1 9/WG 3 Convenor)
