Last week, as part of the Irish Farmers Journal/Irish Farmers Association Brazil investigation, we exposed the lack of oversight and checks on the sale and use of critically important antibiotics on Brazilian beef farms.

Much of that lack of oversight and inability to monitor antibiotic usage lies in the fact that there is no national database for animal identification or requirement to identify or tag animals from birth.

As part of the investigation, we visited four Brazilian states earlier this month, seeing farms, marts and other agricultural businesses.

The investigation is against the backdrop of European and Irish farmers arguing that for beef to enter the European market, the Brazilian production rules and regulations need to be the same as the ones European and Irish farmers adhere to.

Gulf in standards

This week, we outline the gulf that lies between the Irish system and the Brazilian one.

In order to provide the assurances required by the citizens of the EU as to the safety and production standards of the beef allowed for sale within the union, there is a long list of animal identification and traceability that are required.

These rules are outlined by Tomás Bourke, IFA senior policy executive for livestock, in Table 1 - see below - and demonstrate the huge differences that lie between the Brazilian system and the Irish system.

Systems that fall short of this level of traceability are merely mechanisms that facilitate cattle laundering, where decisions on identification, timing of identification and notifications to an incomplete database are done on a voluntary basis.

There is currently very little oversight or governance on tagging rules within Brazil, with no official individual records of animal movements being kept by the government, farmers or processors.

EUDR

The Regulation on Deforestation free Products (EUDR) is also causing issues for Brazilian beef exports to Europe. In June 2023, the regulation was introduced however the application of the law has been delayed on a number of occasions, with the most recent date for compliance being pushed out by another 12 months to the end of 2026. The main driver of deforestation is the expansion of agricultural land linked to the production of commodities like cattle, wood, cocoa, soy, palm oil, coffee, rubber and some of their derived products, such as leather, chocolate, tyres, or furniture. Europe sees itself as a major economy and consumer of these commodities that are linked to deforestation and forest degradation, so the EU sees itself partly responsible for this problem.

Under the regulation, any operator or trader who places commodities on the EU market must be able to prove that the products do not originate from recently deforested land or have contributed to forest degradation. In beef, the problem lies in identifying what farms the animals were reared on before they entered the large feedlots.

In August 2025 Reuters reported that IBAMA the Brazilian environment agency, had notified 12 meat factories, two of which were operated by JBS, that it had evidence that cattle were purchased from illegally cleared land in the Amazon rainforest. JBS denied the allegations. IBAMA said that part of the claim was that the parties being investigated were “acquiring suspicious cattle which were being triangulated with clean farms to disguise their illegal origin”.

In a separate investigation, IBAMA had seized 7,000 head of cattle that were on 2,100ha of land, that was blocked from commercial use due to illegal deforestation.

Farmer view

Several farmers we spoke to in Brazil don’t want to go down the road of full life traceability, with many highlighting that the scale of the operations just won’t make it feasible to happen. One farmer said: “Look at Europe, it has regulated it’s farmers out of business with its controls and checks, why would we want to go down that road for such a small proportion of our export market. We have lots of markets that are very happy to take our beef without all this regulation, so why bother.”

Brazil has a target of getting its national database, which will involve tagging all animals from birth, up and running by 2032, but farmers say it won’t happen and it’s not possible. The scale of operations in Brazil is one of the main reasons it won’t happen. Animals aren’t housed in Brazil. Instead, they roam across vast areas, grazing all year round. Cows calve outdoors unsupervised.

Implementing an all-life traceability system would be extremely difficult with the style of farming employed in Brazil.

Brazilian system

The European Commission has requirements in place for ’traceability’ of animals in Brazil in order for the beef to be eligible for export to the EU. This requires animals to be tagged by 10 months of age or, in some cases, just 90 days before slaughter.

There are 238 million cattle in Brazil with no traceability system, no tagging requirements for farmers and no national database of animals. Tags in Brazil can be purchased without any controls, and are sold freely along with the device to remove them which is completely at odds with the rules and regulations Irish and European farmers must abide by.

As part of our investigation, we visited farms, marts and factories, finding no evidence of any credible individual animal identification systems. We found cattle of all ages with no tags, holes in ears where tags were removed and no coherent numbering system. We found evidence of tag removal on farms, including boxes of old tags that had been cut out to replace with a farm’s individual tags.

The intakes at the marts had no system in place to identify animals, with animals placed in pens straight from unloading after a paint brand was applied.

Over 50% of cattle in Brazil originate from farms with fewer than 50 cattle. These animals then move to large scale feedlots, where they are finished on an industrial scale – with some of the feedlots at 50,000 head capacity.

The Brazilian System of Individual Identification of Cattle and Buffaloes (SISBOV) is the official system of individual identification of cattle and buffaloes, and only farms that are part of this system can export to the EU. The list of farms approved for export to the EU by Brazilian authorities takes this into account.

This system allows animals to be chosen by the feedlot owner as being eligible for the EU market before they slaughter the animals, by purchasing tags and applying them to their animals with no correlation to where they were born or moved to the feedlot from.

In reality, animal identification in Brazil remains rooted in ‘branding’, to associate the animal with a ranch as is evidenced from our farm, factory and mart evidence. Claims that some small cohorts of animals out of the 238m cattle population are or can meet the full extent of the requirements for a credible traceability system for cattle do not stack up.

The lack of farmers support, the lack of infrastructure, the scale of the cattle herd, the diversity of production systems are all critical factors that will inhibit it’s delivery.

Brazil has a plan to have mandatory individual traceability for all animals by 2032. Launched in December 2024, the plan aims to enhance the sanitary security of the livestock sector, meet international market requirements, and strengthen transparency throughout the supply chain. The system will require electronic identification, but the cost and required infrastructure are huge challenges, particularly for small producers.

As part the investigation these proposals were discussed with large- and small-scale Brazilian farmers with many pointing to the plans on tagging as not being workable or deliverable by 2032. Without the strong support of all farmers a traceability system of the scale required in Brazil does not seem feasible.

European Commission on residue testing and hormone use

The Irish Farmers Journal asked the European Commission what level of residue testing is completed on beef that enters the EU from Brazil. In response, a spokesperson said that only non-EU countries that have already provided guarantees and evidence of compliance with EU requirements can export animals and products of animal origin to the EU.

“The Commission has drawn up lists of such non-EU countries. Each third country wishing to export to the EU products of animal origin is subject to this rigorous listing procedure. It covers public and animal health aspects, and the chemical safety of the products.”

They added that third countries must also test the chemical safety of their food for export and that such countries must submit residue control plans and results of testing from the previous year. These are then scrutinised by the Commission.

The Commission also said it regularly carries out audits and that samples from consignments are tested at borders.

When asked if the European Commission can guarantee that beef containing hormones like oestradiol 17ß doesn’t enter the EU food chain, the spokesperson said: “All food products entering the EU must comply with the same high standards for food health and safety as those produced here. To ensure that products entering our market comply with our rules, we have an audit system, which regularly carries out checks and controls at our borders and in third countries.”

It has also committed to increasing the number of audits in third countries.

In 2024, a European Commission audit found that it could not guarantee that Brazilian beef imports to the EU were from hormone-free cattle.

Each third country wishing to export to the EU products of animal origin is subject to rigorous listing procedure, the Commission said when asked how the EU can analyse medication given to animals from birth.

“This also applies to medicines, as pharmacologically active substances.”

It said that while animals can be treated with medicines over their lifetime for public or animal health reasons, as well as to ensure animal welfare, the EU prohibits the use of antimicrobials for growth promotion or increase yield, as well as those reserved for treatment of certain infections in humans.

“This ban applies throughout an animal’s lifetime. Consignments of animals and corresponding products intended for human consumption and exported to the EU must comply with the EU requirements on the use of antimicrobials. However, non-EU countries can apply their own standards for domestic production.”

Maximum residue limits (MRLs) are established to safeguard human health and ensure fair trade practices by setting legal limits for residues of veterinary medicines in foods. These MRLs apply to both member states and imports from non-EU countries. National authorities are responsible for conducting controls on imported commodities to verify residue levels, it said.