63.Since January 2021 and the end of the transition period, any live animal exports into Europe and Northern Ireland from Great Britain must move through a border control post (BCP).140 In April 2020 we heard that there were no BCPs in European ports approved to process live animals.141 This prevents the export of livestock into Europe, as flying livestock is too expensive to be commercially viable.142 Stuart Roberts, Deputy President of the NFU, said “There has been no trade in live animals between the UK and mainland Europe because there are no border control posts approved at the moment […] since 1 January there have been no movements.”143
64.Furthermore, the UK currently does not have any BCPs capable of processing live agricultural animals. However, animals being imported to the UK will not need to be checked at a BCP until March 2022.144 This has created trade asymmetry between the UK and the EU. It is possible to import animals by sea from the EU into the UK, but it is not possible to export animals by sea from the UK to the European mainland.
65.Beyond trade asymmetry the lack of BCPs generated concerns for animal welfare. James Russell, President of the British Veterinary Association said he would anticipate that livestock from Great Britain would move though Ireland into mainland Europe, following “longer routes of crossing from Cork down into north-western France or possibly even down into Spain rather than just those short straits crossings.”145
66.Stuart Roberts, was clear the construction of BCPs “needs to be raised up the political agenda.”146 He said “It would be really good to see the UK Government in talks directly with the French Government to help push that border control post on just outside Calais.”147 He continued that the lack of BCPs in Europe could have been caused by the industry interpreting the proposed ban on export for slaughter and fattening as a ban on the movement of all live animals, which has made commercial businesses “nervous” about investing.148
67.Mr Roberts told us that the export of British breeding stock is “extremely important in terms of trade as well as in terms of our own productivity and pushing productivity and helping others around Europe.”149 “In relative numbers, these are not huge numbers, but they are important in terms of value and in terms of what we are trying to achieve with our genetics and our breeding stock where we really lead the world.”150 He asked for a “very clear statement from Government around the future of breeding stock”151 including that their export would not be banned.152
68.Gareth Baynham-Hughes, Director, Animal and Plant Health and Welfare, Defra, said that the Government is in “conversations with a number of member states, including on this issue of BCP availability.”153 He also explained that Defra has been providing “information about data flow and the value of these sectors”154 so that commercial enterprises can make decisions about BCP construction.
69.In written evidence, Defra told the Committee that there will be:
[…] capacity for checks on live animals from the EU at the [GB] border. This will include BCP facilities for all types of animal imports at Dover and Holyhead. At Sevington, we will have facilities for all animal imports carried by Eurotunnel. In addition to existing provision at UK airports, there will be live animal capacity at Cairnryan, South Wales and a small provision for commercial pets at Tyne. It is also expected that other inland sites will have animal facilities, as well as at some commercial ports.155
However, they provided no detail about when these BCPs are expected to open.
70.The BVA and the NFU both highlighted Portsmouth as a case study of a port which has not been able to build a BCP because of a funding shortfall caused by a reduction in the grants offered under the Government’s Port Infrastructure Fund.156 Lord Benyon told the Committee that he knows “that there are gaps” and that funding will be a “challenge.”157 He said that there will be another funding competition going to ports shortly.158
71.Stuart Roberts told us that the Government needs to act now, to ensure that the UK has the capability to process live animal imports at BCPs By March 2022:
Let us remember that the March 2022 deadline is a deadline. The sooner we can get facilities up and running, the sooner we can open trade up and start to trade on our excellent genetics.159
72.Lord Benyon told the Committee that the construction of BCPs is an “is absolutely an urgency” and said that Defra “want to do more and we have secured some funding, which I hope will fill a gap or gaps.”160
73.The current lack of border control posts approved to process live animal exports in European ports is an effective ban on the export of British livestock to mainland Europe. The Government’s strategy of incentivising the construction of border control posts by providing information on the value of the sector has not been successful. The Government must work more closely with the EU and commercial partners to ensure that border control posts capable of processing livestock are built immediately in Northern European ports.
74.The Government must ensure border control posts capable of processing live animals are operational by March 2022. This date is an absolute deadline rather than a target. These posts should be geographically spread around the country and provide appropriate capacity to meet market demand to prevent overly long journey times which endanger animal welfare. Defra should publish information relating to the location and capacity of specific border control posts by December 2021 to allow businesses to prepare for the March 2022 deadline.
75.British breeding stock is an important export. We are concerned that the ban on export for slaughter and fattening has been interpreted as a ban on the export of all live animals, which may have led to EU partners not prioritising suitable border posts. This could damage the export of British breeding stock. Within a month of this report’s publication Defra should provide a clear statement of support for the ongoing export of British breeding stock, emphasizing that these exports will not be affected by the ban on export for slaughter and fattening.
76.The Northern Ireland Protocol requires the animals moved into Northern Ireland from Great Britain to be treated as imports from a third country into the EU. Therefore, if livestock is moved from Great Britain to Northern Ireland it must follow the EU’s full SPS checks including the need for pre-notification and an Export Health Certificate (EHC), an official document that confirms whether an export meets the health requirements of the destination country.161 Animals entering Northern Ireland must also be moved through a Northern Ireland point of entry (NIPOE), which are currently located at Belfast Port and Larne Harbor.
77.Northern Irish farming prides itself on the genetic integrity of its stock, as Victor Chestnutt of the Ulster Farmers Union (UFU) explained, “Northern Ireland is a region with very small family farms, so we do focus on pedigree breeding.”162 Christine Middlemiss, the UK Chief Veterinary Officer, told us that the genetic stock in Northern Ireland is “essential and they are quite unique in the UK as well.”163 The movement of animals between Great Britain and Northern Ireland is important for maintaining this genetic integrity. Therefore, barriers that inhibit the movement of animals between Great Britain and Northern Ireland is a significant threat to the Northern Ireland farming industry.164
78.Beyond the extra burden of SPS checks, the Committee was also told that residency requirements, ear tagging, and scrapie monitoring were preventing the movement of animals between Great Britain and Northern Ireland.165
79.Following our evidence session with Lord Benyon, the European Commission announced that it and the UK Government had found solutions on the residency requirements and ear tagging issues.166 On residency requirements, the Commission said that it is:
[…] working on a regulatory solution to facilitate the swift return of livestock to Northern Ireland from exhibitions or trade fairs in Great Britain, so that the animals concerned will not have to wait for a minimum residency period in Great Britain. The relevant delegated and implementing acts will be adopted in October 2021.”167
On ear tagging the Commission said that it has agreed to remove “the need for re-tagging when animals move multiple times between Great Britain and Northern Ireland during their life.”168 This came into effect on 29 June 2021.
80.The scrapie monitoring system, however, is still preventing the movement of sheep between Great Britain and Northern Ireland. Scrapie is a fatal, degenerative disease affecting the nervous systems of sheep and goats. To prevent the spread of scrapie, the EU requires sheep entering the EU from a third country to have been part of the ‘scrapie monitoring system’ or have had a scrapie genotype test.169
81.To be part of the scrapie monitoring system flocks must undergo an annual flock inspection by a vet, with a proportion of adult animals are screened for scrapie.170 It takes three years to become partially certified and seven years to become fully certified. This long lead in time means that access to scrapie monitoring systems is not an immediate solution for Farmers in Northern Ireland.171 Individual genotype testing costs £30 per animal, a cost that some stakeholders say makes the trade uneconomical.172 Furthermore, many of the hill breeds that make up a substantial proportion of the trade would fail a genotyping test.173
82.The National Sheep Association (NSA) said that “each year between 9000 and 18,000 sheep of high value are moved between NI and mainland Great Britain” and that scrapie rules have “ completely disrupted” the breeding stock trade “with no effective warning or understanding.”174 They warn that “On an industry scale this may be considered small but for individuals affected the restrictions on movements to be imposed are creating catastrophic consequences for many of our pedigree breeders and those trading in commercial breeding animals on both sides of the water.”175
83.Victor Chestnutt brought this issue to life when he informed us about a Northern Irish farmer who has “bought roughly around 400 blackface ewe rams every year in September in Scotland. This year, they were not told that there would be any difference, so they went ahead and bought their ewe lambs.”176 These sheep were trapped in Scotland because they could not pass the Scrapie genome test. He told us that farmers had no way to prepare for these changes because “there was no grace period, because the deal was not done until the very last days and we were straight into implementation.”177
84.Mr Chestnutt told us that joining the Scrapie monitoring system should be the “long-term objective” but in the short term the Government should seek a derogation for Northern Ireland.178 He also emphasised that there must be a reasonable lead-in period to allow the industry to prepare; “We need a lead-in period to allow this trade to continue rather than just bouncing these things on people straightaway.”179 The NFU stated “that the UK sought a 7-year derogation for breeding stock for the scrapie testing requirements, but this was turned down by the EU.”180 The NFU and the NSA would like to see use of the Movement Assistance Scheme, a scheme set up by the Government to reimburse certain certification costs for moving agri-food goods, to cover the costs of scrapie testing.181
85.Lord Benyon said that he understood that the scrapie monitoring system was causing farmers “difficulties” and that “The Commission is quite sympathetic here, so we want to work with it.”182 Gareth Baynham-Hughes mirrored the advice of industry and said that the solution “would be a derogation of some form.”183
86.The movement of agricultural animals between Great Britain and Northern Ireland, a practice that has existed for generations, has been disrupted by the Northern Ireland Protocol. The residency, scrapie and ear tagging requirements risk jeopardising the genetic integrity of Northern Irish breeding stock. Although it is a small number of farm businesses that are affected, these are often small, independent, family run business and the impact of the restrictions could be catastrophic.
87.The Committee welcomes the agreement between the Government and the Commission on residency requirements and ear tagging. However, the Government should monitor the implementation of the new systems to make sure they are fit for purpose and fully enable the movement of livestock from Great Britain into Northern Ireland. It should review these arrangements within 12 months of their implementation and report back to this committee.
88.Furthermore, we welcome that the Government is working on a solution to the scrapie requirements, but a solution must be found immediately. The Government should work with the EU to agree a derogation from the scrapie monitoring system, as quickly as possible. This derogation should provide adequate time for farmers to join the system. The Government should adopt a pragmatic and practical stance in pursuit of this goal.
89.In the short-term Defra should extend the Movement Assistance Scheme to pay for scrapie testing. The new breeding season for sheep is about to start meaning the Government needs to find an immediate solution to allow breeding stock from Great Britain to enter into Northern Ireland. As such, the Movement Assistance Scheme should be extended for this purpose by October 2021.
90.In May, Defra announced it will ban the export of animals for slaughter and fattening from England and Wales, including where the journey originates in another nation but passes through England or Wales.184 The number of animals exported for slaughter and fattening is very small compared to overall UK herd size.185 The current UK rules on the welfare of animals being transported for commercial purposes constitute EU retained law (derived from Council Regulation No 1/2005). While part of the EU, the UK could not ban live animal exports. However, it has been the UK Government’s longstanding position that it would prefer animals to be slaughtered as close as practicable to their point of production.186
91.Defra said that, “In 2020, around 2.8 million cattle, 14.5 million sheep, 11.2 million pigs and around one billion poultry were slaughtered in the UK.”187 In comparison, 16,000 animals were exported to Europe for slaughter in 2018.188 On this basis Defra said that it “expect[s] a ban on exports for slaughter and fattening to have a relatively low impact on our farmers, processors and other businesses.”189 The ban has received strong support from animal welfare groups. The RSPCA said a live export ban would be a “landmark achievement for animal welfare”,190 while the campaign group Compassion in World Farming said they are “delighted” by this “unambiguous proposal.”191
92.During our inquiry, witnesses from the NFU and the UFU said they did not support a ban on export for slaughter. Instead, Stuart Roberts told us that the NFU wanted tighter regulatory control on exports.192 Similarly, Victor Chestnutt, President of the UFU said “We do not see any reason to introduce additional controls or suddenly ban the live export of farmed animals.”193
93.There was a concern amongst some witnesses from the farming industry that the ban could unintentionally reduce animal welfare by leading to longer journey times. Over the past 20 years, the UK abattoirs network has become dominated by a few large abattoirs, spread across the UK.194 Stuart Roberts told us that for some farmers, particularly in the east of England “your closest abattoirs may well be on the other side of a piece of water.”195 This argument is particularly significant in the context of the Government has a manifesto commitment to end excessively long journeys for slaughter and fattening.196 Minister Benyon highlighted the link between the ban and the need for robust slaughterhouse capacity; “We have to make sure that we have capacity in our existing slaughterhouses to feed this market.”197
94.The Government’s ban on export for slaughter and fattening puts a focus on the domestic abattoir network and the role abattoirs play in supporting the British food supply chain. According to the Sustainable Food Trust, which runs a campaign to support small and medium abattoirs, “the national network of small local abattoirs is rapidly declining. There are now only around 100 small red meat abattoirs (those slaughtering no more than 1,000 livestock units annually) left in the UK.”198
95.Despite the closure of many small and medium abattoirs, there is little evidence that the overall capacity of the network has declined or that the supply chain is ‘running out of capacity.’199 Instead there has been a consolidation of the supply chain, with larger abattoirs and processors increasing capacity to meet retailer demand. A 2020 report from the All Party Parliamentary Group on Animal Welfare illustrated this trend:
In 2018 a total of 19,718,680 animals were slaughtered across 248 operating plants but 32 abattoirs in England slaughtered 88% all of the sheep, while just 19 abattoirs slaughtered 73% of all cattle.200
96.However, considering the overall capacity of abattoirs does not provide a full picture of the supply chain. The consolidation of abattoir services mean that the spread of services is not uniform across the UK, so many animals have to travel long journeys prior to slaughter. This undermines the ambition of the Government’s consultation on ‘Improvements to animal welfare in transport’ to reduce unnecessarily long journey times (discussed in more detail the next section).
97.The RSPCA also said there is a specific concern over slaughterhouse capacity for equines and cull animals (an animal at the end of its productive life). There are “four abattoirs licensed to take equines” and “only one in England is now regularly taking horses.”201 As discussed in chapter 2 there is evidence that horses are being illicitly exported for slaughter. The RSPCA suggested that “The reduction in equine licensed abattoirs over the past decade may have led to a rise in illegal exports … further capacity may be needed if the ban [on exports for slaughter] is implemented to ensure this does not continue in the future.”202
98.Similarly, there is a lack of facilities for cull animals. The RSPCA explained that these animals are “particularly vulnerable to the stressors associated with transport” because of their poor body condition which means “they are at increased risk of suffering injuries during the journey.”203 For example, cull sows must travel from Northern Ireland to Great Britain because there are no suitable abattoirs in Northern Ireland.204 The RSPCA explained that, “The fragility of this system was exposed last year when abattoir capacities were reduced during the Covid-19 pandemic. This resulted in a backlog of sows, which caused difficulties for the supply chain with a consequential negative impact on welfare.”205
99.The UK Abattoir Network, an industry group representing abattoirs, told us that Defra “should recognise abattoirs, specifically including the smaller-scale abattoirs vital to an adequate local network, as a strategic national asset and integral to their future visions for sustainable farming and food resilience.”206 This view was supported by Professor Tim Morris, Special Professor of Laboratory Animal Welfare and Science at the University of Nottingham, who argued that the core issue with abattoirs is that “in the past nobody has treated the abattoirs—and the abattoirs are basically a network—as a strategic national issue.”207
100.The Abattoirs Sector Group, group established to represent small and medium abattoirs, told the Committee that the Future Farming Resilience Fund could be used to support small slaughterhouse businesses.208 The Future Farming Resilience Fund has been developed by Defra to help farming business adapt as the Common Agricultural Policy comes to an end in the UK. It offers support to help businesses understand the changes that are happening because of the Agricultural Transition; identify how, what and when they may need to adapt their business model; and how to access financial support to address these changes.209 The Abattoirs Sector Group view it is an appropriate mechanism to help build a resilient and financially viable network of small and medium abattoirs.210
101.Lord Benyon agreed with witnesses that abattoirs are “strategic assets.” He said that “We have to recognise that there is a strategic-asset argument to make to sustain the existing abattoirs and encourage new ones, where possible.”211 He said that the Government can be economically interventionalist, if it chooses to be, and that the abattoirs network may be an area that needs to be addressed.212
102.Witnesses also told the Committee that the viability of small and medium abattoirs is often disadvantaged by complex regulations. Professor Tim Morris said that no new small and medium slaughterhouses are built because they are “required to have the same building regulations as an office building, which is patently ridiculous.”213 The Abattoirs Sector Group said that there “are a number of examples of varying interpretations of the regulations, inconsistent approaches to implementation and unnecessary constraints.”214 A key example of this is the failure to implement the ‘5% rule’, whereby if an abattoir exceeds 1000 animals, they are required to have full veterinary attendance instead of delayed post-mortem inspection, which increases the cost of production. However, the 5% rule allows a 5% margin of flexibility before veterinary attendance is required. The Abattoirs Sector Group and The UK Abattoirs Network suggested that the Defra should establish a streamlined working group focused on ensuring that regulations in small and medium sized abattoirs are applied in a proportionate and coordinated way.215
103.The consultation on the ban of export for slaughter and fattening was published in December 2020 as part of a call for evidence on Improvements to Animal Welfare in Transport.216 Alongside the ban on export for slaughter, it also proposed further measures such as new species dependent maximum journey times and a prohibition on journeys if the forecast external temperature for the journey is outside of a temperature range of 5–30°C, unless the vehicle is temperature regulated.
104.The proposals were heavily criticised by the farming industry. NFU Scotland said the consultation was “deeply flawed […] Regrettably, the driver behind much of this was a [Animal Welfare Committee] report that was, in our opinion, poorly written and simplistic in approach and shows no appreciation or understanding of livestock production across all parts of the UK.”217 The National Sheep Association (NSA) said that it “exposes a serious lack of knowledge” about how the industry works.218 The Ulster Farmers Union said, “this is not the first time the government has failed to recognise the importance of live exports, suggesting it highlights a lack of knowledge of agriculture.”219
105.Concerns were raised about the temperature limits. Professor Tim Morris told the Committee that “from an equine point of view, of the 80 race meetings held in January, … 43 would have been cancelled” because the outside temperature was lower than five degrees220 Professor Malcolm Mitchell, Professor of Physiology and Animal Welfare, Scotland’s Rural College, said that “very often scientific fact does not support some of the proposals that have been put forward.”221Professor Morris told us that the proposals would have benefited from “Some pre-discussions and preliminary co-design.”222 When we asked the Chief Veterinary Officer about the proposals, she said “I get copied into lots of emails” and she could have “read the actual detail of it more thoroughly.”223
106.Gareth Baynham-Hughes, Director of Director, Animal and Plant Health and Welfare at Defra, said he regretted that the proposals “did not land in the right way and undermined a wider sense that we have been building over the last few years for really good and effective stakeholder engagement with the sector.”224 Defra have said they are “now considering this policy area in further detail to determine what will be taken forward in future legislation to improve transport conditions for animals.”225 Lord Benyon said that he will keep the proposals within “the realms of practicality.”226
107.We welcome the ban on export for slaughter and fattening as an important step in protecting animal welfare. We understand that the number of animal movements this ban will affect is small, however, we are concerned that there may be unintended consequences. Particularly, that it may create longer journeys, which may increase costs for some UK farms and could have the unintended effect of worsening animal welfare. We are also concerned that this will prohibit the movement of livestock for breeding purposes. Defra should work with the organisations and businesses that will be affected by the ban on export for slaughter to ensure that the ban is introduced in a pragmatic way that will not adversely affect rural businesses or animal welfare.
108.Supporting and bolstering the UK abattoirs network will benefit our food security and protect animal welfare. There is a direct link between the Government’s current policy of limiting journey times between the farm and abattoirs, and the need for a network of small and medium abattoirs spread geographically around the UK. Equally, small abattoirs must be commercially viable businesses, capable of supporting themselves. Defra should take action to protect small and medium abattoirs as a national strategic asset. These businesses should be supported and bolstered through the Future Farming Resilience Fund. Defra should set out and enact its approach to funding the UK abattoirs network as a strategic national asset within six months.
109.Heavy handed regulations can overburden small and medium abattoirs, preventing them from being successful commercial enterprises. Defra should establish a small working group to assess how effectively and fairly regulations are being applied in small and medium abattoirs. This group should ensure regulations are sensible and maintain food hygiene standards without overloading businesses. This group should be established by December 2021.
110.The Government’s proposals on ‘Improvements to animal welfare in Transport’ are well-meaning but flawed. They show a lack of understanding in how parts of the agricultural economy work and would have benefited from better co-design and consultation. We welcome that Defra is rethinking its proposals. Defra should ensure they work with the industry to develop its new proposals, making sure they protect animal welfare while being practical and realistic. It should publish the updated proposals by December 2021.
140 HM Government, Export or move livestock and poultry, March 2021
144 Michael Gove, 11 March 2021, [Statement UIN HCWS841]
152 The ban on the export for slaughter and fattening is discussed in more detail in paragraphs 87 to 92.
156 Building of Brexit border posts faces delays, Financial Times, January 2021
161 Department for Environment, Food and Rural Affairs, Get an export health certificate, June 2021
166 The European Commission, EU-UK relations: solutions found to help implementation of the Protocol on Ireland and Northern Ireland, 20 June 2021
167 The European Commission, EU-UK relations: solutions found to help implementation of the Protocol on Ireland and Northern Ireland, 20 June 2021
168 The European Commission, EU-UK relations: solutions found to help implementation of the Protocol on Ireland and Northern Ireland, 20 June 2021
184 Department for Environment Food and Rural Affairs, Action Plan for Animal Welfare, May 2021
186 HC Deb, 6 Dec 2012 C893w
188 Europa.eu, TRACES data - Animals traded between Member States in 2018, (Accessed 2021)
190 BBC news, Live animal exports to be banned in England and Wales, December 2020
191 Compassion in world farming, VICTORY IN FIGHT TO BAN LIVE EXPORTS, December 2020
194 The British abattoirs network is explored in more detail in paragraph 94 - 102.
196 Department for Environment, Food and Rural Affairs, Improvements to animal welfare in transport, December 2020
198 Sustainable Food Trust, Local abattoirs: Why they are closing and how we can save them, (accessed 2021)
200 The Future For Small Abattoirs In The UK, The All-Party Parliamentary Group for Animal Welfare, June 2020
209 Department for Environment, Food and Rural Affairs, Future Farming Resilience Fund to open in August, July 2021
216 Department for Environment, Food and Rural Affairs, Improvements to animal welfare in transport, December 2020
217 The Scotsman, Farming: Union hits out at new proposals for transport of livestock, February 2021
219 Ulster Farmers Union, UFU disappointed by government announcement on live exports, December 2020
Published: 30 September 2021 Site information Accessibility statement