Moving animals across borders: Government Response to the Committee’s First Report of Session 2021–22

Fifth Special Report of Session 2021–22

Author: Environment, Food and Rural Affairs Committee

Related inquiry: Moving animals across borders

Date Published: 16 December 2021

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Fifth Special Report

The Environment, Food and Rural Affairs Committee published its First Report of Session 2021–22, Moving animals across borders (HC 79), on 30 September 2021. The Government response was received on 10 December 2021 and is appended to this report.

Appendix: Government Response

The Government thanks the Committee for its work on managing the movement of animals between Great Britain, Northern Ireland, and the EU, following the conclusion of the UK-EU Withdrawal Agreement’s transition period on 31 December 2020.

The Committee’s report addresses several important issues concerning the continued facilitation of animal movements across borders whilst maintaining the UK’s high biosecurity standards. The UK has a world-renowned reputation for safety and quality across the agri-food chain. The Government is committed to upholding these standards following the UK’s exit from the EU. This is essential to mitigate the threat to plant, animal and public health from pests and diseases and continuing to provide the same high levels of assurance to consumers and trading partners.

Responsibility for biosecurity is devolved to the government administrations and legislatures in Scotland, Wales, and Northern Ireland. However, as biosecurity threats do not respect administrative or geographic boundaries, there is close cooperation between all the UK administrations who work towards the common aim of safeguarding the health and welfare of our animals. We have well established governance structures to ensure the UK’s approach to biosecurity is well co-ordinated, robust, and effective. In the UK, Central Competent Authorities work closely together to safeguard public, animal and plant health, to promote animal welfare, and protect consumers. This includes the coordination of activities through framework agreements, working groups and official guidance to ensure effective and efficient delivery, as well as coordination at policy and delivery level through liaison groups and online resources.

The Government shares many of the Committee’s key concerns. Pets are central to so many families and we want to ensure their welfare is protected. One of the key reforms set out in our ground-breaking Action Plan for Animal Welfare is to end the abhorrent, cruel practice of puppy smuggling and low-welfare pet imports. Now that the transition period has finished, and we have left the EU, we can go further than ever to crack down on these practices, including the introduction of tougher penalties.

Equines and the equine sector make an important sporting, cultural and economic contribution across the UK. We have been exploring potential changes to equine identification and traceability to improve biosecurity and animal welfare with a range of stakeholders. We plan to consult more widely on proposals early in the new year so that the wider public can have their say and they, welfare organisations and other interested parties, can help us develop our plans.

We recognise the invaluable contribution farmers make to this country. Our priority is to support them and encourage sustainable food production to ensure we have a secure and environmentally sustainable supply of healthy food with improved standards of animal welfare. Promoting high quality biosecurity is fundamental to this and also makes a crucial contribution to trade.

The Government is participating in intensive discussions with the EU with the aim of delivering significant changes to the Northern Ireland Protocol. The Protocol’s purpose was to protect the peace process and the Belfast (Good Friday) Agreement but it is now doing the exact reverse. The Government put forward proposals to fix the problems in our Command Paper in July 2021. These proposals work with the Protocol but they do require significant changes to processes and governance if the Protocol is to work in future.

Working with the EU, the UK Government has agreed a new Scrapie Qualifying Status (SQS) within the existing Scrapie Monitoring Scheme (SMS) for breeding sheep, which will facilitate the movement of breeding sheep from Great Britain to Northern Ireland. Further, we have secured an agreement with the EU Commission on the issue of livestock residency. This will enable cattle, sheep, and goats from Northern Ireland to move to Great Britain to participate in events such as shows and sales and return to Northern Ireland within 15 days without being subject to restrictive residency rules.

We are committed to ending the export of live animals for fattening and slaughter and outside the EU we can now realise this long-standing ambition. In addition, Defra and the devolved administrations in Scotland and Wales have consulted on several other welfare in transport reforms, such as setting maximum journey times, space allowances for animals and temperature controls. We wish to create a system which enforces new measures effectively whilst not adding unnecessary burdens to transporters wishing to export animals for permitted purposes.

The Government has taken a pragmatic approach to the introduction of wider imports checks, recognising the need to balance biosecurity across the UK while ensuring the smooth flow of trade and allowing business to focus on recovering from the pandemic. Live animal checks, based on risk, have continued since 1 January 2021 at the point of destination, will continue until there are designated physical border facilities for live animal checks at the point of entry. The Government has announced that full EU to GB sanitary and phytosanitary import controls will commence on 1 July 2022, and live animal checks will transition from destination to designated border control posts from that date.

The recently established Abattoir Sector Group is working to support and develop a thriving network of local abattoirs across the UK, which is essential to maintain high animal welfare standards, support sustainable farming, and meet the rising demand for local meat. The Group is working with Defra, the Food Standards Agency (FSA), and others to explore what tools might be used to support small abattoirs.

Above all, this Government remains absolutely committed to safeguarding our biosecurity, promoting the UK’s thriving agri-food trade, and continuing to make the UK a trusted partner globally. We will continue to drive forward the work described below and engage constructively with all key parties.

Moving Pets

1. 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. (Paragraph 9)

2. 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. (Paragraph 13)

3. 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. (Paragraph 13)

The Government takes the issue of pet smuggling extremely seriously. Outside the EU, we can manage our own pet travel and commercial importation rules for Great Britain. In relation to Northern Ireland, our proposals set out in the Command Paper recognise that the UK’s high biosecurity standards should form the basis for pet travel, which should operate as it did so successfully before our exit from the EU.

The Animal Welfare (Kept Animals) Bill was introduced in Parliament on 8 June 2021. The Bill sets out how the Government intends to fulfil its manifesto commitment to crack down on the issue of puppy smuggling and address movements of pets (dogs, cats, and ferrets) which are unacceptable on welfare grounds. The Bill aims to reduce the number of pet dogs, cats and ferrets that can travel to Great Britain (GB) in one non-commercial movement This would prevent unscrupulous traders from exploiting our pet travel rules. It would restrict non-commercial movements of pets to a maximum of five animals per vehicle on ferry and rail routes, and three animals per person for foot passengers or air travellers. The Bill includes a power to introduce further restrictions on the commercial import and non-commercial movement of pets on welfare grounds, via secondary legislation; for example, in the light of views and evidence from the public and key stakeholders or the emergence of new practices which cause concern.

In August 2021, the Government launched an 8-week consultation on proposed restrictions to the commercial and non-commercial movement of pets into Great Britain. These include proposals aimed at raising the minimum age of puppies moved commercially and non-commercially into Britain from 15 weeks to 6 months. Our proposals would also prohibit the movement of cropped and docked dogs and heavily pregnant dogs (defined as those over 42 days pregnant) into Great Britain. We are currently analysing responses to the consultation. We will publish a summary of responses in due course. Our approach aims to ensure that members of the public are not unduly impacted, while tightening the existing regime and tackling unscrupulous traders. We agree with the Committee that rapid action is needed to address the issues of pet smuggling and low welfare movements of pets. We are working at pace to deliver the necessary secondary legislation alongside the passage of the Bill through Parliament. Work is in hand to ensure compliance with WTO rules.

The Government’s approach will help to address known issues quickly including emerging practices, and those circumstances where unscrupulous traders seek to circumvent existing restrictions. Such traders were quick to respond to advice to prospective pet owners about seeing a puppy with its mother prior to purchasing, by starting to import heavily pregnant females. This was a relatively new trend identified by the Animal and Plant Health Agency following the introduction of Lucy’s Law in April 2020. Between January 2020 and May 2021, 31 heavily pregnant dams were detained. In our consultation, we set out our proposal to introduce a ban the movement of dogs which are more than 42 days pregnant. The ability to make such changes in future will be key to maintaining a robust system of regulation.

4. Currently pet smuggling is viewed as a low-risk and high reward crime. The UK must improve its deterrents against pet smuggling. (Paragraph 23)

5. 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. 
(Paragraph 23)

The maximum penalty for illegally importing a puppy is 12 months imprisonment or an unlimited fine. In August 2021, the Government launched an 8-week consultation on proposed restrictions to the commercial and non-commercial movement of pets into Great Britain. We sought views on the existing maximum penalty and whether this should be increased. Under the Welfare of Animals (Kept Animals) Bill the Government may set a maximum penalty of 5 years imprisonment for illegally importing a pet, or an unlimited fine. In principle, any new penalties could apply to new criminal offences introduced under the Bill as well as any existing criminal offences which relate to the import of pets. We are analysing the responses to the consultation and will publish a summary in due course.

The Animal and Plant Health Agency (APHA) has appointed two local authority Trading Standards Officers to co-ordinate the targeting and investigation of illegal imports of companion animals. These posts are currently funded until 31 March 2022. In this period the postholders will work in partnership across all local authorities and other agencies to identify and deal with individuals who regularly and intentionally commit offences. The aim is to embed new ways of working and further disrupt the illegal importation of pets.

6. 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. (Paragraph 24)

7. 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. (Paragraph 25)

8. 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. (Paragraph 25)

We continue to operate one of the most rigorous and robust pet travel checking regimes in Europe. Under existing Pet Travel rules all non-commercial dogs, cats, and ferrets entering Great Britain on approved routes (excluding those travelling from the Republic of Ireland, the Isle of Man, and the Channel Islands) must undergo 100% documentary and identity checks by authorised pet checkers.

Authorised pet checkers must be trained by APHA staff before they are granted approval. A system of audits carried out at least once a year, or more frequent depending on the throughput, plays an important part in ensuring rules and requirements are properly implemented and standards met. Pet checkers receive refresher training and are encouraged to work with APHA to identify trends in non-compliance and additional training requirements.

Engagement with pet carriers demonstrates that they are committed to preventing illegal imports of pet animals. Carriers have already instituted unilateral measures to reduce the carriage of pet animals for commercial reasons. For example, both P&O Ferries and Brittany Ferries have refused accounts to commercial dog importers. Eurotunnel now limits the number of pets that can be transported in one vehicle. These carriers work closely with operational colleagues at APHA and Border Force. Evidence gathered by APHA during mandatory quality assurance checks on pet travel movements demonstrates good awareness of the pet travel rules.

Although the Government have no plans to change the current compliance checking arrangements, we will continue to keep the compliance and enforcement of any new and existing requirements under review.

9. 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. (Paragraph 26)

10. 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. (Paragraph 26)

APHA is the primary operational delivery agency for pet movements. Defra, Border Force and APHA work collaboratively to share intelligence to support the prevention of illegal imports. Responsibility for conducting pet checks on non-commercial movements is delegated to authorised carriers and pet checkers who can refuse travel to non-compliant animals or share intelligence with APHA who can intercept at the port/border if non-compliance is suspected. Local Authorities are the enforcement and prosecuting bodies for any offences discovered during the process of smuggling puppies. These roles are not anticipated to change following the introduction of measures under the Animal Welfare (Kept Animals) Bill.

APHA is working closely with Defra to determine Border Control Post (BCP) resource requirements and provide capacity in readiness for the new 2022 Live Animal Imports regime. There are no plans to provide Local Authorities with additional funding for risk-based checks at this stage.

11. 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. (Paragraph 30)

12. 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. (Paragraph 30)

The EU Commission informed us of their decision to grant the UK ‘part 2 listed’ status late last year. The Government immediately issued comprehensive guidance through GOV.UK in December 2020 to support pet owners who wish to take their pet or assistance dog to the EU or Northern Ireland. This was supported by a social media campaign. We continue to work closely with private veterinarians, carriers (including ferry companies), and assistance dog charities to communicate the new rules for pet travel as widely and effectively as possible.

Surveys carried out on behalf of the Government suggest that there are good levels of public engagement with our guidance. The latest survey (May 2021) suggests that a very high proportion of those who plan to take their pets to the EU are aware that they need to prepare at least one month before travelling. We created and published additional communications products in mid-July 2021 to ensure that potential travellers continue to be aware of the new pet travel rules before they travel. We continue to communicate the new requirements.

This Government will continue to work with carriers, vets and officials in individual EU Member States, to minimise the number of pets that are non-compliant with the pet travel rules. We will work with key stakeholders to amplify our pet travel guidance on an ongoing basis. To prevent travellers with pets being turned away upon landing in the EU, some carriers carry out pre-boarding checks. Additionally, we have put in place measures that enable pets which are refused entry into EU Member States to return to Great Britain without the need for quarantine, under specific circumstances for a limited time.

13. 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. (Paragraph 33)

14. 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. (Paragraph 33)

The Department has applied to the European Commission to become a ‘Part 1 listed’ third country in relation to non-commercial movements of pet dogs, cats, and ferrets. On 3 December 2020 the EU’s Standing Committee on Plants, Animals, Food and Feed voted in favour of, and has now adopted, the UK as a ‘Part 2 listed’ country. The UK meets all the animal health requirements for becoming a ‘Part 1 listed’ third country. Indeed, as already noted, we have one of the most rigorous pet checking regimes in Europe to protect our biosecurity. Our animal health disease risk has not changed since leaving the EU. We recognise the challenges that ‘Part 2 listed’ status poses for those travelling with pets and assistance dogs. We will continue to press the EU Commission to secure both ‘Part 1 listed’ and recognised tapeworm free status.

15. 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. (Paragraph 40)

The Government agrees with the Committee’s findings. Since the beginning of the Covid-19 pandemic, there has been a marked increase in pet ownership. These animals include a proportion of rescued street dogs from Eastern Europe. Linked to this, we have seen a rise in the cases of canine brucellosis caused by the Brucella canis bacterium. This is a serious zoonotic infection which causes abortions in pregnant dogs and serious clinical disease. This rise in cases, has caused concern in Defra, the devolved nations and in the UK Health Security Agency. Incidents are investigated on a cross-departmental basis. No cases have been detected in humans in the UK. In February 2021 we took action to make sure that infection with B.canis is reportable. This will help improve our evidence base on this disease. We are now considering what additional steps might be needed for commercial pet imports. Proposed changes to existing regulations to clamp down on low-welfare pet imports might also be needed. Our work to pursue the licensing of dog breeders and initiatives to educate the public on how to source dogs responsibly should have a further positive impact.

16. 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. (Paragraph 40)

The Government broadly agrees with the Committee’s findings. On tick treatment, there is a greater risk that the brown dog tick, Rhipicephalus sanguineus, might become established because of increasingly mild winters. However, the prevalence and incidences of other ticks and tick-mediated infections is also rising, in livestock as well as pets, such that tick treatment of pets alone is not the complete answer.

Surveillance demonstrates that tick distribution and abundance is changing throughout the UK for many reasons, including habitat and climate change. Small numbers of localised infestations with non-native tick species have been reported in recent years. For these reasons, Defra strongly encourages pet owners to treat their pets to help protect their animals against ticks and tick transmitted diseases when travelling abroad.

The rabies titre test is a good indication of the level of protection of an individual animal. However, it is not the only indication and we also need to see evidence of the place of origin of the animal, the vaccination programme, identification and pet passport or health certificates. Extra burdens on pet owners would be significant if rabies serology were to be re-introduced. Because the requirement is for only one titre to be taken during the lifetime of the animal, provided the rabies booster vaccination is up to date, we consider the serology test alone can be misleading. Recent quantitative risk assessments have concluded that the risk of a pet animal with rabies entering the UK under the pet travel rules is very low.

This Government remains vigilant to the risks posed by non-endemic diseases and we continue to monitor the disease situation carefully. Defra has no immediate plans to change the import health requirements for dogs, cats and ferrets entering Great Britain. Our future policy will be guided by risk assessment.

Moving horses

17. Britain is a leading player in the global equestrian market, which provides significant economic benefits to the UK. The Government must enable the expedited movement of ‘high health status’ horses across Europe to protect this industry. An agreement on high health status horses would benefit all parties involved and has been advocated by the British, Irish and French racing and breeding industries to the highest levels of the European Commission. (Paragraph 50)

18. The Government should work with the EU to formulate an agreement on ‘high health status’ horses as quickly as possible. This agreement should be based on a system which is digital by design and easy to use. The Government should adopt a pragmatic and practical stance in pursuit of this goal. (Paragraph 50)

The Government acknowledges the benefits to industry of streamlining equine movements between the UK and the EU, and notes that our robust animal health controls have not changed since we left the EU. We will explore any potential flexibility that will facilitate the movement of horses, including ‘high health status’ horses, and have supported industry lobbying on these issues. The European Commission has, to date, been clear that third country rules will apply to the UK in this area. However, we will continue to work towards a satisfactory solution.

19. We have been told that there are horses being illicitly moved across Britain’s borders and being sent to slaughter under the guise of being sold for other purposes.
(Paragraph 55)

20. Defra should investigate non-compliant horse movements and quantify the scale and causes of the practice. This work should take place in collaboration with industry groups like World Horse Welfare who have developed intelligence and expertise on horse smuggling. Once the scale of the issue has been identified, Defra should set out a plan to address it within a year, and no later. (Paragraph 55)

The Government is fully committed to delivering its manifesto commitment to end the live export of animals, including equines, for slaughter and fattening. As part of this approach, we are working closely with devolved nations and the key industry organisations on the issue of misdeclaration of movements of equines for slaughter.

Through our engagement with Weatherbys, the Fédération Equestre Internationale and other Passport Issuing Organisations we are working to identify what evidence is available to prove the purpose of an individual export at the application stage. These discussions are focused on facilitating the legitimate trade of equines moving for the purpose of competition, racing or breeding. We are also working closely with World Horse Welfare to identify trade of concern, for example, horses that are allegedly being sent abroad for slaughter. These discussions will enable us to focus our controls on higher-risk consignments.

21. The current system of equine ID is not fit for purpose. Its outdated and fragmented paper systems enable fraud. A digital identification system would help to prevent horse smuggling and enable the expedited movement of ‘high health status’ horses. The mandatory microchipping of equines facilitates a digital identification system, which we believe is available at the moment. Defra should move to this system as a matter of urgency. (Paragraph 63)

22. The proposals put forward in Defra’s upcoming equine identification consultation should be digital by design and easy to use, except in exceptional circumstances, such as the studbook network which is vital for the support of native, rare and indigenous breeds. It is our understanding that these systems already exist within the industry. The Government should embrace these systems or guarantee interoperability with them. Alongside this new identification system Defra should develop a funded action plan to enforce the identification rules. The consultation should be published within the next three months and the action plan should be published within three months of the consultation’s conclusion. (Paragraph 63)

The Government is clear that our departure from the EU has provided us with an opportunity to improve the existing equine ID and traceability regime in England. We can act on our own national priorities for robust equine health and welfare and continue to protect public health. As set out in our Action Plan for Animal Welfare, proposed changes, including further digitisation, will be considered as part of a new public consultation we now plan to launch early in the new year.

As part of our approach, we will focus on making it easier for owners and others who are responsible for equines to update their records. This will make the Central Equine Database a more accurate record of those animals registered here and better support our animal welfare and disease controls. We recognise the critical importance of studbooks and the work of breed societies in supporting native breeds and we do not propose to materially alter these arrangements.

Moving Livestock

23. 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. (Paragraph 74)

24. 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. (Paragraph 74)

25. 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. (Paragraph 75)

The UK has a well-established and effective assurance system to ensure that relevant agri-food legislation remains fit for purpose. The UK food and farming sector is one of the most highly regulated in the world, meeting the strict requirements of domestic legislation. The Government is committed to maintaining the UK’s high standards following EU Exit and to providing the same high levels of assurance to consumers and trading partners.

Against this background, the Government has taken a pragmatic approach to the introduction of wider imports checks, recognising the need to balance biosecurity across the UK while ensuring the smooth flow of trade and allowing business to focus on recovering from the pandemic. Risk-based live animal checks at the point of destination will continue until there are designated physical border facilities for live animal checks at the point of entry. The Government has announced that full EU to GB sanitary and phytosanitary import controls will commence on 1 July 2022. Live animal checks will transition from destination to designated border control posts from that date.

The UK will have a Border Control Post (BCP) for livestock, equines, and camelidae at the Sevington inland Border Control Post located in Ashford, Kent. This BCP will carry out necessary sanitary checks on these species when entering the UK via Eurotunnel and the Port of Dover. It is expected to be operational from 1 July 2022. A second facility in Kent to accommodate all other animal species arriving via the Short Straits is currently being identified. Live animal checks on all other species will continue at destination until BCPs become operational.

Defra is continuing to assess the national picture of planned live animal BCP capability and to explore how this might be increased. Further BCPs, funded by the live animal infrastructure fund grant competition, will be designated once complete. In addition to these sites, the Port of Tyne, several airports, and sites within the devolved nations will also have BCPs to facilitate live animal checks.

26. 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. (Paragraph 76)

27. 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.
(Paragraph 76)

Prior to the introduction of the Animal Welfare (Kept Animals) Bill, the Secretary of State wrote to industry stakeholders on 7 June 2021 clarifying the scope of the live exports ban. The Secretary of State’s letter confirmed that the Animal Welfare (Kept Animals) Bill would not introduce a prohibition on the export of live animals from Great Britain to third countries for breeding purposes. Nor would it introduce a prohibition on the export of poultry from Great Britain to third countries. The provisions of the Animal Welfare (Kept Animals) Bill make clear that this is not a ban on the export of all live animals, rather a ban on the export of animals for slaughter and fattening purposes alone.

The Government recognises the economic value of the global trade in breeding stock from Great Britain, in addition to its role in the development of resilience of local breeds within third countries. British breeds can offer advantages such as genetic disease resistance, higher quality meat, and increased carcass size. Animals that are exported for breeding purposes are generally transported in very good conditions above the regulatory baseline, with procedures put in place to ensure that the welfare of the animal is prioritised throughout the journey. Animals exported for breeding are typically able to live a full and healthy life once they arrive at the destination country.

The Government is working closely with the National Farmers’ Union in its efforts to encourage ports and commercial operators to set up Border Control Posts (BCPs) to enable the export of livestock for breeding to the EU. The Government is also in discussion with officials of EU Member States about the development of BCPs for livestock. We will continue conversations with Member States and keep the issue on the agenda.

28. 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. (Paragraph 87)

29. The Committee welcomes the agreement between the Government and the Commission on residency requirements and ear tagging. (Paragraph 88)

30. 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. (Paragraph 88)

The Government and the European Commission have come to an agreement on the issue of livestock residency. This will enable cattle, sheep, and goats from Northern Ireland to move to Great Britain to participate in events such as shows and sales and return to Northern Ireland within 15 days without being subject to restrictive residency rules.

Livestock identification remains an outstanding issue, however. Livestock are currently identified with tags containing either a two-letter country identification code, or a numeric equivalent, followed by a unique identification number for each animal. Livestock from Northern Ireland are currently identified with ‘UK’ or 826 tags. Livestock from Great Britain have the same identification number and code.

On 28 June 2021, the EU adopted Regulation (EU) 2021/1064 which requires livestock from Northern Ireland to be identified with a new two letter code ‘XI’ or its numeric equivalent 899. This means that livestock from Great Britain and Northern Ireland are now identified using different country codes. Livestock which do not already have EU-compliant ID which are moved into Northern Ireland from third countries, including Great Britain, need to be re-identified in accordance with EU rules. This requirement also applies to British livestock moved into Northern Ireland.

We would prefer to continue using ‘UK’ identification codes for livestock from Great Britain and Northern Ireland. The unique identification number for each animal already contains a regional identifier. We believe this is sufficient to enable the identification of livestock from Northern Ireland and to resolve traceability concerns.

These issues were discussed with the European Commission at official level on 20 July 2021. The UK is continuing to work with the EU to find a solution that can fully respect Northern Ireland’s place in the UK and facilitate intra-UK movements.

The Government will continue to monitor the implementation of residency and identification requirements and will report back to the Committee within 12 months of implementation as its report recommends.

31. Furthermore, we welcome that the Government is working on a solution to the scrapie requirements, but a solution must be found immediately. (Paragraph 89)

32. 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. (Paragraph 89)

33. 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. (Paragraph 90)

Working with the EU, the UK Government has agreed a new Scrapie Qualifying Status (SQS) within the existing Scrapie Monitoring Scheme (SMS) for breeding sheep, which will facilitate the movement of breeding sheep from Great Britain to Northern Ireland.

Once SQS status is achieved, operators will be able to move breeding sheep and goats from Great Britain to Northern Ireland, provided they comply with other conditions of the relevant Export Health Certificate. Following three years of compliance with SQS rules, operators will progress to Controlled Risk status on the Scrapie Monitoring Scheme. Applications for Scrapie Qualifying Status need to be made by 31 December 2021 and details are available through SRUC. Defra will continue to work closely with trade bodies, SRUC and DAERA over the coming months to make operators aware of the SQS solution.

From 1 July 2021 we have included the cost of scrapie testing for GB-NI movements in the Movement Assistance Scheme.

We put forward proposals to address these problems in the Command Paper Northern Ireland Protocol: the way forward in July 2021. In the longer term our proposals recognise that the UK’s high biosecurity standards should form the basis for livestock travel within the UK, which should operate as it did so successfully before our EU exit.

34. 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. (Paragraph 108)

The number of animals exported for slaughter represents only a very small proportion of the total number of animals processed in the UK every year. In 2020 slaughter exports from Great Britain to the EU corresponded to around 0.02% of livestock slaughtered in the UK and less than 0.2% of sheep produced in the UK.

The Government does not accept that the ban on exports for slaughter will create longer journeys. The shortest direct to slaughter export journey from the UK to continental Europe in 2018 involved a journey time of 18 hours. Most journeys to slaughter in the UK are significantly shorter.

The Government’s view is that animals should be slaughtered as close as possible to the point of origin. Trends in data indicate that the number of animals being slaughtered in the UK has increased year on year as some slaughterhouses have expanded their production. This indicates that, overall, current slaughterhouse capacity should be able to absorb the additional supply of animals that are currently exported.

The Government engages regularly with stakeholders from the livestock production and meat processing sectors, including any concerns about capacity and cost. We will continue to work closely with the Abattoir Sector Group. The Government welcomes the Farm Animal Welfare Committee’s recommendation on the introduction of mobile abattoirs, and we support work on innovative solutions to address the challenges faced because of the decline in small abattoirs. The Rural Development Programme for England Growth Programme, delivered by the Rural Payments Agency, is currently supporting a farmer-led mobile abattoir project which is trialling the use of a compact system for the on-farm slaughter of livestock. The project is due to be operational later this year and, if successful, could be replicated elsewhere.

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. (Paragraph 108)

Our impact assessment indicates that the current volumes of live animals exported for slaughter and fattening from Great Britain are minimal in comparison to total volumes of live animal trade for all purposes between Great Britain and the EU. The cost of this reduced trade is estimated to be around £8.4m across the 10-year appraisal period, around £0.7m per annum.

The Animal and Plant Health Agency will be responsible for implementing the ban through the journey log system. We plan to adapt the existing system to require those who wish to export livestock and unregistered horses for permitted purposes, such as breeding or attending shows, to provide evidence of the purpose of their journey. We are working with the industry on the type of evidence that will be required. We wish to create a system which enforces the ban effectively whilst not adding unnecessary burdens to transporters wishing to export animals for permitted purposes.

35. 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. (Paragraph 109)

36. 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. (Paragraph 109)

37. Heavy handed regulations can overburden small and medium abattoirs, preventing them from being successful commercial enterprises. (Paragraph 110)

38. 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. (Paragraph 110)

The Government acknowledges the important role that small abattoirs play in rural economies and the benefits to animal welfare that reduced journey times to slaughter can have. We are fully committed to working with industry to ensure that the UK maintains its high-quality slaughtering facilities within a robust and competitive market. We will continue to work closely with small abattoirs on the range of complex issues that they are facing.

Defra chairs the Small Abattoirs Working Group, which brings together Defra policy teams, the Food Standards Agency, the Rural Payments Agency, and industry representatives. The department has initiated a series of smaller sub-groups to enable detailed discussions to take place with the recently established Abattoir Sector Group. Issues discussed to date include: the new Livestock Information Programme; the potential for streamlining administrative and regulatory burdens on small abattoirs; and ways to ensure greater co-ordination across government agencies and abattoirs to maintain and strengthen the UK’s high standards in food hygiene, biosecurity, and animal welfare.

The Food Standards Agency’s Operational Transformation Programme and implementation of a Future Delivery Model was endorsed by its Board at a public meeting in September 2021. The Programme is progressing with several activities underway to transform current practices and systems. The Food Standards Agency continues to work with stakeholders to identify opportunities to modernise the delivery of official controls and to take a more proportionate approach, including exploring the use of flexibilities within existing legislation and reducing administrative burdens on abattoirs. One of the most beneficial flexibilities for small abattoirs is an increase in the threshold for “low-capacity establishments” (to 5% of national throughput) that can then benefit from reduced levels of FSA presence and cost. This is a “Member State” flexibility in retained OCR legislation but requires agreement with the European Commission before it can be implemented due to the potential impact in exports.

The FSA is working with the Abattoir Sector Group on a pilot project which is designed to reduce some of the administrative burdens on small abattoirs by streamlining administrative processes.

The Government supports innovative solutions to funding issues for small abattoirs. We are exploring what future support might be made available to the sector, for example, through the ‘Adding Value’ theme of the new Farming Investment Fund. This theme is intended to support producers wanting to process and add value to their products. Further details will be made available in due course.

39. 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. (Paragraph 111)

40. 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. (Paragraph 111)

The Government notes the Committee’s concerns. The public consultation, issued jointly by the UK and Welsh Governments, evoked a range of responses including important considerations about the practical and welfare implications of these proposals. We have listened carefully to people’s views and will continue to work with the industry, NGOs, and others to explore some of the issues and evidence in more detail. This work will be taken forward through a series of stakeholder workshops starting in Autumn 2021 and continuing into 2022. Once agreed, a package of reforms will be implemented through secondary legislation or guidance, as appropriate.

The reforms proposed in the Government response follow careful consideration of consultation responses, scientific evidence, and veterinary advice. We want to take a proportionate approach to regulation and, where the evidence is clear, we will act to make improvements that are practical and sensible.

We want to work together with all interested parties to develop workable solutions that generate good welfare outcomes. We are also working closely with the Scottish and Welsh Governments to ensure that, as far as possible, a consistent legislative approach is applied across Great Britain.


41. Diseases do not recognise borders. Enhancing biosecurity protects animal, plant and human health. Although we have full faith in the Chief Veterinary Officer, it would be easier to monitor animal diseases in our closest neighbours if the UK regained access to the Animal Disease Notification System. ADNS is a quick and reliable system, and it would help to remove the opportunity for human error. Regaining access to the ADNS would also benefit our European neighbours as it would allow them to better monitor disease in the UK. This is a win, win situation. Failing to regain access could have catastrophic consequences for UK biosecurity. (Paragraph 117)

We agree with the Committee’s recommendations on biosecurity. ADNS has now been replaced by the ADIS system for EU Member States and we continue to engage with the Commission to facilitate access. This is part of a wider negotiation which means that progress is unlikely to be straightforward. Currently, the UK has in place alternative systems for horizon scanning and risk assessment including the World Organisation for Animal Health Information System (OIE-WAHIS). Our relationship with the European Commission also means that the UK authorities are notified of any new outbreaks of significance in the EU. This has allowed us to ensure the UK CVO has information about any potential changes in the disease situation in Europe.

42. The Government should work with the EU to regain Britain’s access to the ADNS as a matter of urgency. Defra should update this committee on its efforts. 
(Paragraph 117)

We agree with the Committee’s recommendations. We retain reporting access with the European Food Safety Agency and continue to share surveillance data for several significant animal diseases. On these issues we will continue to work closely with our colleagues in Europe. We will continue to engage with the European Commission.

43. There is disagreement between Defra, the veterinary sector, and the Chief Veterinary Officer about whether there are enough veterinarians to carry out the increase in certification work which is required following the transition period. (Paragraph 123)

44. Government should closely monitor veterinary capacity alongside projections of six-month demand and publish statistics on a quarterly basis. (Paragraph 123)

The number of veterinarians registered to practise in the UK is increasing year on year and currently stands at 27,000. The opening of new veterinary schools in the UK means that the numbers of veterinarians being trained here continues to grow. However, there has been a drop in the number of veterinarians registering in the UK having done their training abroad.

This has a disproportionate impact on a small but vital part of the veterinary sector—official veterinarians working in abattoirs. This part of the profession has historically been dominated by veterinarians trained overseas. There are currently around 210 veterinarians carrying out these vital jobs in England and Wales with a further 27 veterinarians working in Scotland. This is around 20 per cent below the optimum level of personnel. The impact of Covid and travel restrictions are likely to have contributed to this drop in numbers.

To practice in the UK, vets are required by the RCVS to have Level 7 English language. This has proved a barrier for most EU-based vets looking to move to the UK to work as Official Veterinarians since EU Exit (Prior to the end of EU Exit Transition Period, vets from the EU benefitted from mutual recognition of professional qualifications which meant that they did not formally have to meet the level 7 requirement). To make recruitment for these roles easier, the RCVS has temporarily allowed veterinarians trained overseas to improve their English while working in the UK with support and supervision, as temporarily registered veterinarians in England and Wales only. The RCVS will be reviewing this arrangement. Defra and the FSA will be in dialogue with RCVS.

The Food Standards Agency is closely monitoring the situation and is satisfied that there has been no service interruption to date. This will be closely monitored during the busy period leading up to Christmas.

Although there have been concerns about the capacity of official veterinarians working on export certification, these have now been addressed. The Government has taken following steps to mitigate this risk:

  • The Scheme for Temporary Agri-food Movements to Northern Ireland (STAMNI) Compliance Declaration was introduced for Authorised Traders.
  • Funding has been provided to make training for product export qualifications free.
  • From January to May 2021 Defra operated a GB-wide surge capacity to help fill certification gaps as needed. Demand for this was low with c.10 OVs deployed. We continue to gauge capacity and any emerging issues through our regular calls with industry.
  • Since 2019, more than £1.8m in grant funding has been provided to key local authorities in England to help them build certifier capacity for exports.
  • A centralised training package is being developed for LA. Food Competent Certifying Officers (FCCOs). This will enable current FCCOs to build on their existing skills and enable other LA officers to qualify as FCCOs.
  • The role of Certification Support Officer has been created to reduce the burden of administrative workload on the OV. Working under the direction of a certifying offer, a CSO can undertake administrative and preparatory work to get a consignment ready for export making the work of OVs more effective.

The number of official veterinarians (working in private practice) able to certify products of animal origin has increased from 643 in January 2019 to 1592 in January 2021 and has continued to grow to 1894 in October 2021. The number of CSOs has increased from around 100 in November 2020 to over 500 in March 2021 and continues to grow.