Moving animals across borders Contents

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1Moving Pets

Changes to pet travel rules

6.Since 2014 the movement of cats, dogs and ferrets in and out of Britain has been regulated by the EU Pet Travel Regulation (576/2013), known as PETS.8 Under this law an individual may travel with up to five companion animals. Having left the EU, the UK may now set its own rules around the movement of companion animals.

7.Our predecessor Committee wrote to the Government in 2019 asking it to reduce the number of pet animals that can travel into the UK with one person.9 In May 2021, during this inquiry, animal welfare stakeholders repeatedly told us they wanted to see the number reduced to three animals per person.10 The consensus was that three was the correct amount as most owners have three or fewer pets.11

8.In June 2021 the Government introduced the Animal Welfare (Kept Animals) Bill.12 Part 3 of the Bill will introduce “new powers to tackle the unethical trade of puppy smuggling” by reducing the number of animals that can travel into the UK, from five to three per individual, with a limit of five per motor vehicle.13 The Committee sees the introduction of this new regulation as an important step in preventing pet smuggling and is pleased the Government has acted on our recommendation.

9.Animal welfare groups like Dogs Trust, the RSPCA and Blue Cross outlined their support for several other statutory changes, including:

• Increasing the minimum age of pets that can be brought into the UK from three months to six months. They argued that this would reduce the demand for animals which have been smuggled into the country because of buyer demand for young animals.14 Furthermore, a higher age limit would be easier to enforce at the border as it is easier to distinguish age when the animal is more developed.15
• Banning the import of heavily pregnant animals. Moving an animal while it is pregnant, especially in the later stages of its pregnancy, is very traumatic for the animal and can increase the death rate at birth.16
• Banning the import of animals that have been subject to ‘low animal welfare practices’. These include ear cropping in dogs or declawing in cats, both of which are illegal in the UK.17

10.In the Animal Welfare Action Plan the Government committed to using the Kept Animals Bill to bring in powers to ban the import of young animals, heavily pregnant animals, and animals which have been subject to poor welfare practices through secondary legislation.18 Lord Benyon, Parliamentary Under Secretary of State at the Department for Environment, Food and Rural Affairs, told us that introducing further restrictions via secondary legislation, rather than putting a ban on the face of the Bill, allows the legislation to be “enabling”. He explained that it will “give future Ministers the opportunities to amend legislation” as “science and intelligence on illegal trade changes.”19

11.In August 2021 Defra launched a public consultation asking for views on; increasing the minimum age at which dogs can be brought into Great Britain to six months; prohibiting the movement into Great Britain of dogs which have been subjected to mutilations, such as cropped ears and docked tails; and, prohibiting the import of heavily pregnant dogs into Great Britain.20 The consultation noted that these proposed changes would be introduced “through secondary legislation under the enabling power included in the Animal Welfare (Kept Animals) bill.”21

12.We welcome the Government’s commitment to ban the import of pets younger than six-months-old, heavily pregnant pets, and pets that have been subject to poor animal welfare practices. We recognise the argument that ministers should be able to adapt regulations as science and intelligence evolve. However, we see no future where the movement of young animals, heavily pregnant animals or the import of animals which have been subject to poor welfare practices is acceptable. The need to prevent pet smuggling is serious and urgent, introducing these bans through later secondary legislation will only create further delays, enabling this illicit trade to continue. The Bill should maintain the flexibility to allow ministers to adapt to future science and intelligence, but Defra should include a ban on animals younger than six months, heavily pregnant animals, and animals which have been subject to poor welfare practices on the face of the Bill, rather than secondary legislation. It should include a clear definition of ‘heavily pregnant’. Putting these prohibitions in primary legislation would be a serious and sincere statement about the value the Government attaches to animal welfare.

Pet Smuggling

Sentencing and prosecution

13.This Committee and its predecessor have both considered pet smuggling,22 and a recurring theme has been that pet smuggling is low risk and high reward. A lack of accurate data makes it hard to put a value on the trade in smuggled pets. However, in November 2020, Dr Maher of the University of South Wales estimated, using research based on online advertising, that the value is around £130 million over a three month period.23 During our current inquiry David Bowles, Head of Public Affairs at the RSPCA, told the Committee that “You can buy a dog in Romania for €40 and sell it here for £400 or even £1,000.”24 Paula Boyden, Veterinary Director at Dogs Trust, said that it is “not uncommon to see adverts for puppies being sold for £3,000, £4,000, £5,000.”25 Furthermore, Dr Maher told us that enforcement agencies and NGOs link pet smuggling with organised crime gangs, “whether that is tax evasion or more serious types of criminality.”26

14.While profits are high, sentences and prosecution rates are low. Paula Boyden explained that “the maximum penalty for illegal importation is just a year”27 because it is not classified as an animal welfare offence. This means it is not covered by the Animal Welfare (Sentencing) Act 2021 which, increased sentences for animal welfare offences to a maximum of five years.28 David Bowles told us that the UK’s current sentencing rules do not act as a deterrent to puppy smugglers:

We prosecute puppy dealers who have been earning £2 million or £3 million a year, and they go to prison for 10 weeks. They are still puppy dealing in prison and, when they come out, they immediately start up again. We have to get that balance of deterrence right.29

15.Paula Boyden explained that since 2015 Dogs Trust have looked after over 1,500 dogs thought to have been smuggled into the UK.30 From these 1,500 dogs there have been “two prosecutions, both of which were a low monetary fine, with no custodial sentences, so frankly, it is worth taking the risk.”31 This was mirrored by evidence from the Animal Plant and Health Agency. It said between November 2020 and June 2021 there had been 41 referrals from carriers about pet smuggling, only three of which were being investigated by local authorities.32

16.Steve Dann, Director National Operations HQ at Border Force told us that Border Force would like to see the Kept Animals Bill provide “opportunities” for a “focus on outbound cash and seizing assets of organised crime networks” as “a way to really hurt”33 those responsible for pet smuggling.

Enforcement at the border

17.It is the responsibility of the carriers, meaning the ferry companies or the Eurotunnel, to undertake checks on pets as they move across the border.34 In response to our call for evidence Defra said “We operate one of the most rigorous and robust pet travel checking regimes in Europe. All non-commercial dogs, cats and ferrets entering Great Britain (GB) on an approved route will undergo 100% documentary and identity checks.”35 ‘Documentary and identity checks’ means the pets papers and microchip are checked. However, as explained by Dogs Trust, there is no requirement for the carriers to “visualise” the animal.36 This means that there is no requirement to look at the animal to make sure it matches its papers and microchip.

18.There is well recorded evidence that smugglers will put a fraudulent microchip into the collar or carry case of an animal to pass the inspection.37 Within this context, the absence of any requirement to visualise the animal is seen as a failing by animal welfare stakeholders. Paula Boyden said that without a requirement to look at the animal these checks “are not fit for purpose […]it is a bit like you or I walking through an airport with a paper bag over your head.”38 David Bowles, said that Defra’s assertion that pets undergo 100% checks was a “little disingenuous” and that without a requirement to look at the animal the checks are “meaningless”.39

19.However, when we asked Lord Benyon about the lack of physical checks he said,:

Any APHA staff checking an animal will do a physical check of the animal. The documentation check by anybody who is checking it is important, but they also have to check the microchipping.”40

20.Ian Hewitt, the Interim Chief Executive of APHA told the Committee that he is “confident that the carriers are doing a good job.”41 However, Dogs Trust stated:

there is great variation in the knowledge of the carriers and our experience … is that intelligence sharing between the carriers and APHA is often left to individual relationships.”42

The City of London Corporation, Dogs Trust and The Canine and Feline Sector Group said that asking carriers to check the pets of its customers is a conflict of interest because they are commercially incentivised to get as many passengers travelling as possible. These groups suggested that the responsibility for checking animals at the border should be shifted from carriers to an independent Government agency.43

21.In February 2020 Lord Goldsmith, the Minister of State at the Department for Environment, Food and Rural Affairs, told us that “no funding was provided to Border Force or local authorities specifically to tackle pet smuggling in each of the last 5 financial years.”44 In May, Steve Dann, Director National Operations HQ at Border Force , said that when it comes to enforcing the rules on pet smuggling the challenge for them is “prioritisation” and that they have “massive competing priorities in various areas.”45 We asked Border Force and APHA if they had made an assessment of how their workload would be affected by the Bill. Steve Dann, said, “I do not think we have really assessed the impact at all.”46 Ian Hewitt said he ‘expected’ the Bill to lead to more physical and desk-based checks47

22.Currently pet smuggling is viewed as a low-risk and high reward crime. The UK must improve its deterrents against pet smuggling. The Government should increase the sentences given to pet smugglers, including greater consideration of custodial sentences. Increasing prosecution rates must also be a priority, as prosecution rates are proportionately low given the estimated size of the trade. The Government should make use of its full suite of investigatory and enforcement powers to pursue the money generated from pet smuggling.

23.It is the carriers not APHA staff who carry out most checks on pets at the border. Therefore, Defra should ensure that there is a legal obligation for the individual checking the animal to “visualise” the animal, making sure it matches the paperwork and microchip presented.

24.Moving the responsibility for checking pets at the border from carriers to a Government Agency will prevent the conflict of interests that is inherent within carriers checking the pets of their customers. The responsibility for checking pets at the border should be shifted from carriers to a Government Agency like APHA or Border Force to ensure smuggling is dealt with effectively.

25.Within Defra’s policies there is an increasing focus on the prevention of pet smuggling. However, this increased policy focus has not been matched by an increased prioritisation of the issue or increased funding within Border Force or APHA. Furthermore, we note above the need for responsibility for checking pets at borders to move from the carriers to Government agencies. Whichever of Border Force or APHA takes responsibility for checking pets must be properly resourced, and the Department should set out what steps it is taking within Government to ensure that this work is appropriately prioritised and resourced.

Taking pets from Great Britain into Northern Ireland and Europe

26.As an EU member state, the UK held ‘Part 1 listed status’ under the EU’s Pet Travel Scheme. This allowed pets to easily move across the EU’s borders if they had a pet passport. This changed at the end of the transition period on 1 January 2021, after which point the UK was granted ‘Part 2 listed status’ under the EU’s Pet Travel Scheme, designating it as a ‘third country’.48 Under ‘Part 2 listed status’ rules, each animal must be accompanied by an Animal Health Certificate (AHC) to travel into the EU or Northern Ireland.49 The Northern Ireland Protocol requires that when a pet is moved between Great Britain and Northern Ireland, its movement must comply with EU regulations.50 The AHC must be issued by a vet within 10 days of travel. It must include proof of a valid rabies vaccination and tapeworm treatment. Each new trip will require a new AHC.51 The Blue Cross has estimated that each AHC costs between £100 -£150.52 There are some non-EU countries which have ‘Part 1 listed’ status such as Switzerland, Andorra and Monaco. However, these countries have aligned with EU veterinary standards.

27.Paula Boyden called Part 2 listed status a “hindrance” for travellers wishing to take their pets abroad and noted it would create a financial “burden for the owner.”53 Beyond the additional costs, the RSPCA told the Committee that the new system is more “complicated than the previous pet passport scheme and places a greater responsibility on pet owners wishing to travel with their animal.”54 David Bowles also said that travellers may be unaware and unprepared for the changes. He was critical of the Government’s communication of the changes saying, “there has not been a lot of information about this, I think you could see people turning up, expecting to go away with their old pet passport and being turned back.”55

28.The RSPCA urged the Government to “make a concerted effort to publicise these changes to allow owners to take the necessary steps and avoid a situation in which people travelling with their pets are turned back at the border.”56 The need for more communications was supported by Maggie Roberts, Director of Veterinary Services at Cats Protection, who said, “There is a lot of confusion, both in the veterinary profession and among the public” and that Government should “get more information out there about what the regulations are.”57 When asked about the lack of public understanding Lord Benyon said that “information on websites is now absolutely accurate and easy to disseminate.”58 He said the Government had tested the public’s understanding of the new regulations with polling which “suggests that the public do understand it.”59

29.It is unclear whether travellers have understood the requirements of the new pet travel regulation. There is a risk that as travellers wishing to take their pets abroad will be sent home at the border. Defra should continue its efforts to ensure travellers understand the new pet travel regulations. The current reduction in travel provides an opportunity to ensure no pet owner is turned back home at the border once travel increases.

30.While clear communication is a short term and limited solution to pet travel, we were informed that the easiest way to overcome the barriers imposed by ‘Part 2 listed status’ would be for the UK to regain ‘Part 1 listed status’ under the EU’s Pet Travel Scheme.60 The need for an AHC to take a pet to Northern Ireland is particularly disappointing given Lord Goldsmith’s assurances that taking a dog to Northern Ireland from England would be no different to taking it to any other country in the United Kingdom, on 24 November 2020.61

31.The RSPCA told us that, given the current relationship between the UK Government and the EU Commission, “it is doubtful the Commission will grant Part 1 in the immediate future.”62 Defra told us that “The United Kingdom (UK) applied to the EU Commission to become a ‘Part 1 listed’ third country in relation to the EU Pet Travel Scheme in January 2019, and then again in February 2020.”63 Both applications were rejected. Defra said it “will continue to press the EU Commission on securing Part 1 listed status.”64 Lord Benyon said that there are “Ongoing discussions with the Commission” in order to achieve Part 1 status.65 He also suggested that the SPS Committee, which is meeting in the autumn, would be an appropriate forum to raise the issue.66 A specialised SPS Committee has been established under the UK/EU Trade and Co-operation Agreement, to see if further facilitations on sanitary and phytosanitary measures between the UK and the EU are available without compromising biosecurity.67

32.Regaining ‘part 1 listed’ under the EU’s Pet Travel Scheme will make taking pets to the EU and Northern Ireland easier and less costly. The Government should engage with the EU and adopt a pragmatic stance in the pursuit of either ‘Part 1 listed’ status in the EU Pet Travel Scheme’, or an arrangement which is as close to ‘Part 1’ status as is possible within the current political context environment.

Pre-import health checks

33.There is a risk that pets imported from Europe, especially those which been smuggled into the UK, are introducing dangerous non-endemic diseases into the UK. Babesiosis, Leishmaniasis and Brucellosis, are all examples of non-endemic diseases affecting pets that have recently been recorded in the UK.

34.In 2019, the first case of leishmaniosis in a dog which had not been abroad, was diagnosed in Hertfordshire.68 Since the summer of 2020 there have been over 250 positive cases of Brucellosis infection in dogs, mostly directly imported into the UK from Eastern Europe.69 There were a cluster of babesiosis cases reported in Harlow and Romford in 2016, as well as more recently in Hertfordshire in 2017.70 More concerningly, in July 2020 the first known UK-acquired Babesiosis in humans was confirmed. Two people living on the south coast were hospitalised.71

35.The Canine and Feline Sector Group said:

“Vets are reporting that they are seeing puppies, that appear to have been legally imported commercially by ‘charities’ with questionable documentation regarding validity/accuracy, which are positive for leishmaniosis with the client having little understanding of the zoonotic potential of the disease.”72

The growth of these diseases is significant. Babesiosis and Leishmaniasis can be fatal, Brucellosis can prevent reproduction.73 Furthermore, as the diseases are all non-endemic to the UK, the native pet population have had no exposure to them and therefore have no natural resistance.74 More concerningly, these diseases are zoonotic, meaning they can be passed to humans, as shown by the individuals with hospitalised with Babesiosis in 2020.75

36.The Dogs Trust, RSPCA and Cats Protection explained that there is no requirement to screen animals for any non-endemic diseases as they move in and out of the country.76 They recommend that “consideration is given to introducing a requirement for disease screening for Brucellosis and Leishmaniasis, with dogs which test positive not being permitted to travel into the UK.”77 Ms Roberts said there should be a particular focus on street animals, brought into the UK because they “may not be in great bodily condition and may never have had parasite control before.”78

37.Furthermore, before the UK joined the EU pet travel scheme (PETS) there was a requirement for dogs, cats and ferrets to be given a compulsory tick treatment before entering or re-entering the UK.79 There was also a requirement for dogs, cats and ferrets to have a tapeworm treatment 24–48 hours before travel. Under current regulation no animal needs to receive a tick treatment and only dogs need a tapeworm treatment 24–120 hours before travel.80 Paula Boyden said that “One big error […] in my opinion, was to remove the necessary tick treatment on re-entry to the country and to increase the tapeworm window before coming into the country.”81 The Dogs Trust, Cats Protection and the BVA all argued for the reintroduction of mandatory tick treatment, for cats to also be required to receive a mandatory tapeworm treatment, and for the time period between receiving a tapeworm treatment and travel to be reduced.82

38.Witnesses were also clear that they wanted to see the reintroduction of the rabies titre test and extension of the wait time post rabies vaccination to 12 weeks.83 A rabies titre test checks that there are rabies antibodies in the animal’s blood and verifies that the animal has been vaccinated.

39.A number of non-endemic canine diseases are on the rise in the UK. These pose a serious health risk to the UK pet population. There is a particular risk from street animals being rehomed in the UK and dogs which have been smuggled in. Leaving the EU gives the UK an opportunity to introduce regulations that will provide increased protection for animal health and biosecurity. The Government should act on this opportunity. The Government should introduce pre-import screening for non-endemic diseases which threaten the UK pet population. This should be accompanied by the reinstalment of the UK’s tick and tapeworm treatment requirements that existed before the UK joined PETS. The UK should also introduce the rabies titre test as a way of ensuring animals have valid rabies vaccinations and the animal’s paperwork has not been forged. The UK’s biosecurity is being threatened now and these changes need to brought in as soon as possible.