Written submission from FOUR PAWS UK (UKT0003)

1. Introduction

1.1 FOUR PAWS is the global animal welfare organisation for animals under direct human influence, which reveals suffering, rescues animals in need and protects them. As experts in animal welfare, we will be responding to this call for evidence with our own knowledge and expertise on the issues raised and what impact this could have on animal welfare.

2. Strategic Assessment

2.1 Do the agreements represent a good deal for the UK?

2.1.1 The agreements have the potential to expand trade opportunities, but concerns remain about their implications for UK animal welfare standards. It is essential to ensure that imported products adhere to the UK's rigorous welfare regulations and that trade liberalisation does not inadvertently undermine existing protections for livestock and wildlife conservation.

2.1.2 Trade liberalisation has a massive impact on animal welfare, particularly because of the requirement, under WTO rules, to liberalise trade in ‘substantially all products’ when negotiating non-multilateral agreements. This means that agricultural products will virtually almost always be included in the discussions. As most of the UK’s higher animal welfare standards impacted by trade concern farmed animals and, to a lesser extent, animals used in laboratories, this means that any FTA concluded by the UK with a third partner can impact these standards.

2.1.3 Most animal-based products imported into the UK, except European ones, will not meet animal welfare standards equivalent to those applicable in this country. As the UK aims to improve several standards above the current EU level, such as chicken and pig standards, this discrepancy between local and imported goods is likely to increase. Currently, the EU and the UK are interlinked on farm standards and farm trade – most of the EU’s 18 farm standards are replicated in the UK, ensuring a level playing field, and most of the UK’s farm exports and imports are to and from the EU. 40% of the pig meat produced in the UK is exported to non-EU countries, making it the UK’s largest agri-food exported product, and 31% of the chicken imported into the UK comes from non-EU countries, making it the first imported agri-food. Further opening the UK market to poorer welfare imports will have consequences for animals, both within and outside the UK, especially in the absence of an effective labelling system based on method of production. Firstly, these imports negatively impact the competitiveness of UK producers who must comply with higher animal welfare standards. Under pressure, farming lobbies will not want further costly regulation of their production. At the most extreme, this may even put the existing UK standards at risk or, at least, their effective enforcement. This pressure on competitiveness contributes to a chilling effect on animal welfare regulations. This has already been witnessed in the EU and the UK, where no new farmed animal welfare regulation has been adopted in the past 10 years. Secondly, providing more market access to poorer welfare products means that more animals will suffer as production under lower animal welfare standards will continue in Third Countries and, most likely, increase to meet the higher demand generated by a lower price in the UK.

2.1.4 On the more positive side, trade agreements could be one effective tool for the UK to cooperate and assist other countries with issues such as animal welfare. Trade policy represents a unique opportunity for the UK to positively influence animal welfare abroad and ensure its place as a world leading force for higher welfare standards. Because the UK has some of the best animal welfare legislated standards in the world, it will be possible for the UK to use its trade agreements as a means to help other countries to raise their animal welfare standards, notably by offering cooperation and technical assistance. This was outlined in the report from the Trade and Agriculture Commission (TAC). The UK can also use conditional access to its market to incentivise states and producers to improve their animal welfare standards. Again, this was a recommendation from the TAC.

2.2 To what extent has the Government achieved its stated negotiating objectives?

2.2.1 If the Government has secured commitments on maintaining high animal welfare standards in imported goods and agricultural trade, this would be a positive outcome. However, any compromises that result in lower welfare standards - particularly in areas such as intensive farming or live animal exports - should be closely scrutinised.

2.2.2 The UK-India agreement does not impose strict animal welfare conditions on imports, raising concerns about products from intensive farming systems entering the UK market. Reports highlight poor welfare conditions in Indian poultry and aquaculture industries, yet the deal does not require imports to meet UK-equivalent welfare standards. Whereas for the UK-US deal, the UK has resisted allowing chlorine-washed chicken and hormone-treated beef into the market, but concerns persist about weaker welfare protections in US livestock farming. However, it is important to note that the deal does not explicitly ban imports from lower-welfare systems, leaving room for future negotiations on food safety and welfare alignment.

2.2.3 While the EU generally aligns with UK welfare standards, the agreement reduces trade barriers, potentially increasing imports of lower-welfare agricultural products. The UK has maintained some biosecurity checks, but concerns remain about disease risks from livestock imports. A Common Veterinary Area (CVA) between the UK and the EU would help address animal welfare risks by ensuring harmonized veterinary standards, reducing biosecurity threats, and improving trade efficiency.[1],[2] Currently, UK exports of animal products to the EU face sanitary and phytosanitary (SPS) checks, which can lead to delays, increased costs, and welfare concerns, particularly for live animal transport. By establishing a CVA, the UK could align with EU veterinary regulations, ensuring that imports and exports meet high welfare standards. This would reduce border delays, preventing transport stress for animals and ensuring faster veterinary inspections. Additionally, a CVA could strengthen disease prevention measures, reducing the risk of zoonotic outbreaks linked to intensive farming and poorly regulated imports. Such an agreement would also protect British farmers from being undercut by lower-welfare imports, ensuring that high welfare standards remain a priority in trade negotiations.

2.3 How should Parliament judge the success of these agreements over the coming years?

2.3.1 Parliament should assess whether the agreements uphold UK animal welfare standards, prevent the import of products from systems with lower welfare regulations, and promote ethical sourcing. Ongoing monitoring of compliance and trade practices will be key to ensuring long-term benefits without compromising welfare protections.

2.3.2 Whilst the UK has so far maintained and safeguarded its animal health standards which are import conditions set in law, such as stopping the import of beef treated with hormones, it has negotiated away its animal welfare standards, which have no import conditions aside from slaughter.[3] It is difficult to currently assess the impact of Free Trade Agreements (FTAs) on UK farming and production due to the long lead time on the implementation of the Tariff Rate Quotas (TRQs) (15 years with Australia, 10 years with the Comprehensive and Progressive Agreement for Trans-Pacific Partnership (CPTPP)). There is potential with the CPTPP FTA for pigmeat and egg products to enter the UK and undercut British producers as these products have been produced at lower welfare standards than permitted under UK law and are therefore produced at a cheaper price. All 26 of the countries the UK has agreed to, or is negotiating FTAs with, aside from New Zealand and Switzerland, produce animal products to lower animal welfare standards than the UK, particularly in the pigmeat, eggs, chicken and beef.[4]

3. Economic Impact

3.1 How are the terms of these agreements likely to affect you, your business or organisation, or those that you represent?

3.1.1 For businesses involved in agriculture, food production, and animal welfare advocacy, the agreements may present challenges and opportunities. Ensuring fair competition while maintaining the UK’s high welfare standards is critical, particularly in sectors where cheaper imports from countries with lower regulations could disadvantage ethical producers.

3.1.2 The 18 farmed animal welfare standards in the UK, such as the ban on the conventional battery cage, the ban on sow stalls in pig farming and the ban on veal crates in calf rearing, only applies to British farmers and not to products that are imported from other countries. All these prohibitions are either derived from or are equivalent to EU legislation and standards, but the EU ensures that when it agrees FTAs, such standards are not undermined by cheaper imported products produced to lower standards. This is achieved by retaining the Most Favoured Nation (MFN) tariff or by only lowering tariffs for equivalent products such as free-range eggs (EU-Mercosur) or pasture raised beef (EU-New Zealand). The UK has not negotiated on this basis and has given away TRQs which are not based on method of production and has therefore allowed in products produced to lower standards which could, and will, undermine British producers. 

3.1.3 The current process of consulting and scrutinising FTAs is weak. Parliament should have oversight of future FTAs to ensure the Government is not trading away Great Britain’s (GB) animal health and animal welfare standards.  The Trade and Animal Welfare Coalition (TAWC) recommends the following to improve the process:

• A Parliamentary debate should be held for each FTA, with a guarantee of a vote for MPs on the content of the agreement.
• The negotiation objectives should be published, alongside an assessment and consultation.
• Parliament and devolved administrations should be engaged ahead of time, with access to regular, meaningful updates on the progress of negotiations.
• Stakeholders, including civil society, should be regularly and meaningfully consulted.
• Parliament should have the right to consent to, amend or reject a trade agreement. This was the position pre-2020 when the UK was a member of the EU.[5]

3.1.4 It is important that there is an agreed trade strategy to ensure clear red lines on animal health and animal welfare to other countries, ensuring that animal welfare standards and biosecurity risk mitigation will not be lowered in pursuit of trade deals.  

3.2. What is likely to be the impact of the agreements on:

3.2.1 a) the UK’s economy as a whole?

3.2.1.1 The agreements could contribute to economic growth, but risks remain if they allow lower-standard products to enter the UK market, potentially undercutting domestic producers committed to high welfare standards.

3.2.1.2 The UK’s trade agreements must uphold stringent biosecurity and animal welfare standards to prevent the spread of zoonotic diseases. The global fur trade has been directly linked to SARS-CoV-2 outbreaks, with mink fur farms across Europe and North America experiencing repeated infections since 2020. Similarly, the production of foie gras has been impacted by highly pathogenic avian flu, which resulted in millions of bird deaths. Permitting imports from industries with documented disease risks undermines national biosecurity measures and exposes UK consumers and producers to potential outbreaks. It is essential that trade agreements prohibit imports from high-risk sectors and prioritise ethical sourcing.

3.2.1.3 The exotic pet trade also presents significant challenges, with imported animals capable of carrying zoonotic pathogens that threaten public health. Studies show that a concerning percentage of rescued exotic pets harbour bacterial, viral, and parasitic diseases, yet current UK trade policies lack comprehensive restrictions on species linked to disease transmission. Furthermore, inadequate import regulations for reptiles, amphibians, and other wildlife increase the likelihood of zoonotic spillover. To ensure trade agreements do not exacerbate these risks, Parliament must establish strict health screening requirements for animal imports and maintain prohibitions on wildlife trades that pose public health hazards.

3.2.1.4 A successful trade policy must align with the One Health framework, ensuring that economic growth does not come at the expense of disease prevention and animal welfare. The UK should use its leadership within international forums such as the G7 and G20 to advocate for biosecurity-first trade policies. By integrating robust animal health safeguards into trade agreements, particularly the UK-India FTA, the Government can reinforce its commitment to ethical trade and protect both domestic industries and public health from preventable zoonotic threats.

3.2.2 b) UK producers, including SMEs and key sectors

3.2.2.1 UK farmers and producers following high welfare practices may face increased competition from imported goods that do not meet the same standards. Allowing imports from countries with lower animal welfare standards poses a significant threat to British farmers who adhere to some of the highest welfare regulations in the world. These imports often come from systems where intensive farming practices, such as overcrowding, excessive antibiotic use, and poor living conditions enable lower production costs. As a result, British farmers, who invest in humane treatment, disease prevention, and ethical farming methods, face unfair competition from cheaper, lower-quality imports. This price disparity could undermine domestic producers, forcing them to either cut costs at the expense of welfare standards or struggle to remain competitive in the market. Without robust trade protections, high-welfare British farms risk losing viability, which would have long-term repercussions for rural economies and employment. Therefore, it is crucial that the Government ensures regulatory safeguards to protect domestic producers and prevent a race to the bottom in welfare standards.

3.2.2.2 The UK-US trade negotiations have raised concerns about imports of US agricultural products that do not meet UK welfare standards. The US allows practices such as hormone-treated beef and chlorine-washed chicken, which are banned in the UK. If these products are permitted under the trade deal, British farmers could face unfair competition from cheaper imports produced under lower welfare conditions. This could pressure UK producers to lower their standards or risk losing market share, ultimately harming the UK’s reputation for high-quality, ethically produced food.[6]

3.2.2.3 India’s animal welfare standards are generally lower than those in the UK, particularly in sectors such as egg production, leather exports, and slaughter practices. If tariffs on Indian agricultural imports are reduced without conditionality, British farmers, especially those in the free-range egg sector, could be undercut by cheaper imports from India, where production costs are lower due to less stringent welfare regulations. The UK must ensure that trade agreements include safeguards to prevent the import of products that do not meet its welfare standards, protecting both farmers and consumers.

3.2.2.4 The new UK-EU agreement removes much of the post-Brexit red tape on agrifood exports, which can be beneficial for British farmers. However, concerns remain about the potential influx of lower-standard EU meat imports. The UK’s Border Target Operating Model still applies, but reduced checks could increase the risk of diseases such as African swine fever and foot-and-mouth disease.

3.2.2.5 To maintain fair competition and uphold the UK’s high welfare standards, Parliament must ensure that these trade agreements include strong protections against low-welfare imports. Without such measures, British farmers risk being disadvantaged by cheaper, lower-quality imports that do not align with the UK’s commitment to ethical and sustainable farming.

3.2.2.6 Lower-welfare imports are less likely to be prominently featured in UK supermarkets, as major retailers often uphold stringent sourcing policies aligned with consumer demand for high welfare standards. Supermarkets frequently commit to ethical supply chains, ensuring that meat, dairy, and other animal products meet UK welfare expectations. However, public sector food procurement, such as meals provided in schools, hospitals, and care homes, often prioritises cost efficiency over welfare considerations, making these settings more vulnerable to lower-quality imports.

3.2.2.7 Government contracts for bulk food purchasing often favour lower-cost suppliers, meaning food served in public institutions may include imported products produced under weaker welfare and hygiene regulations. This raises concerns about both food quality and ethical standards, as institutions catering to vulnerable groups, such as children, hospital patients, and the elderly could be inadvertently serving products that do not align with UK farming regulations. To prevent this, public procurement policies should prioritise domestic sourcing from high-welfare producers and establish stricter welfare criteria for imported goods, ensuring that cost-cutting measures do not come at the expense of food safety, ethics, and long-term public trust.

3.2.3 c) UK workers and consumers?

3.2.3.1 Consumers may benefit from increased product variety, but clear labelling and transparency regarding welfare standards must be maintained. Workers in agriculture and related industries may experience shifts in market dynamics depending on how these agreements shape competition and ethical sourcing practices.

3.2.3.2 A standardised, compulsory labelling system - clearly distinguishing between intensive, free-range, organic, and high-welfare production methods - would not only safeguard consumer rights but also support British farmers who adhere to higher welfare regulations. It would encourage market differentiation, reward responsible producers, and drive demand toward more ethical and sustainable farming practices. By making welfare standards explicit at the point of sale, the UK can uphold its commitment to consumer trust, strengthen domestic farming, and ensure that higher-welfare products remain competitive in the marketplace.

3.2.3.3 Workers in the livestock industry face a range of challenges, including exposure to hazardous conditions, low wages, and job insecurity. Many roles involve physically demanding labour, such as handling large animals, operating heavy machinery, and working in extreme temperatures. Additionally, workers are frequently exposed to zoonotic diseases, antibiotic-resistant bacteria, and airborne contaminants, increasing health risks. In meat processing plants, repetitive tasks and high-speed production lines contribute to musculoskeletal injuries, while inadequate protective measures can lead to respiratory issues from prolonged exposure to dust and chemicals.

3.2.3.4 Labour shortages in the UK food and farming sector have exacerbated these issues, with many positions relying on migrant workers who often face precarious employment conditions. Brexit and the COVID-19 pandemic have further strained the workforce, leading to increased workloads and reduced job stability. Addressing these concerns requires stronger labour protections, improved workplace safety regulations, and fair wages to ensure that workers in the livestock industry are not disproportionately affected by economic and policy shifts.

4. Standards and Safeguards

4.1 Do you believe the three agreements adequately safeguard UK standards in labour rights, environmental protection, consumer protection and food standards?

4.1.1 The UK-US agreement has raised concerns about food safety and consumer protection, particularly regarding imports of chlorine-washed chicken and hormone-treated beef, which do not meet UK standards. Additionally, labour rights protections in US agriculture and manufacturing differ from UK regulations, potentially leading to unfair competition for British workers.

4.1.2 India’s environmental and labour standards are generally lower than those in the UK, particularly in sectors such as agriculture, textiles, and manufacturing. The agreement could allow imports from industries with weaker worker protections and lower environmental safeguards, potentially undercutting UK businesses that adhere to stricter regulations.

4.1.3 While the EU generally aligns with UK standards, the new agreement reduces trade barriers, which could lead to increased imports of lower-welfare agricultural products. Concerns remain about biosecurity risks, particularly regarding disease outbreaks in livestock, such as African swine fever and avian flu. To ensure these agreements do not compromise UK standards, strong enforcement mechanisms and clear regulatory safeguards must be in place. Without these protections, British farmers, workers, and consumers could face unfair competition, lower-quality imports, and weakened environmental commitments.

4.1.4 Livestock production, particularly intensive farming systems, poses significant risks to not only animal welfare but also the environment and biodiversity worldwide. One of the most pressing concerns is deforestation, as vast areas of forests - especially in regions like the Amazon rainforest - are cleared to create pastureland or grow feed crops such as soy to feed farmed animals worldwide. This habitat destruction leads to the loss of countless species, disrupting ecosystems and accelerating biodiversity decline. Additionally, overgrazing in intensive livestock systems depletes soil nutrients, causing erosion and reducing the land’s ability to support diverse plant and animal life.

4.1.5 Another major issue is greenhouse gas emissions, with livestock farming contributing significantly to global methane output, particularly from cattle. Methane is a potent greenhouse gas that accelerates climate change, exacerbating extreme weather patterns and environmental instability. Furthermore, water pollution from manure runoff and excessive fertilizer use contaminates rivers and lakes, harming aquatic ecosystems and reducing freshwater availability. Intensive farming also relies heavily on antibiotics, increasing the risk of antimicrobial resistance, which can have devastating consequences for both human and animal health. To mitigate these risks, sustainable farming practices, such as regenerative agriculture, improved waste management, and reduced reliance on intensive systems, must be prioritised to protect biodiversity and ensure long-term environmental stability.

4.1.6 The UK has long been a global leader in high animal welfare standards, setting benchmarks for ethical farming and responsible food production. Some British farmers invest heavily in humane practices, ensuring animals are raised in conditions that prioritise their well-being, from free-range systems to strict regulations on transport and slaughter. This commitment not only improves animal welfare but also enhances food safety, environmental sustainability, and consumer trust. As a nation, we should take pride in these high standards and ensure that farmers who adhere to them are rewarded - through subsidies, trade protections, and strong market positioning.

4.1.7 Consumers deserve an honest choice when purchasing food, and mandatory method of production labelling is essential to achieving transparency. Clear, standardised labelling would allow shoppers to distinguish between intensively farmed, free-range, organic, and high-welfare products. Without this clarity, lower-welfare imports could enter the market unnoticed, potentially undercutting ethical British producers. By implementing compulsory welfare labelling, the UK can protect consumer rights, reinforce its commitment to high welfare farming, and ensure that responsible farmers are recognised and supported.

5. Engagement and Transparency

5.1 How well has the Government communicated its progress in negotiations – and how much has it listened to stakeholders during those negotiations?

5.1.1 Experience with the UK-Australia and UK-New Zealand negotiations demonstrated that updates provided to Parliament and stakeholders were often delayed, lacked detail, and offered little insight into the progression of talks. Going forward, both Parliament and the Devolved Administrations should receive regular, substantive updates on the status of negotiations. These updates should allow adequate time for scrutiny and feedback, which should, in turn, inform subsequent negotiating rounds. Stakeholder consultation, including with business groups, civil society organisations, and devolved governments, should be structured, ongoing, and meaningful.

5.1.2 The Government’s ongoing review of the Internal Market Act and Common Frameworks provides an opportunity to formalise and improve consultation mechanisms with the Devolved Administrations. We recommend that FTA proposals be integrated into the Common Frameworks process to enhance transparency and structured engagement. Notably, both the Scottish Parliament and the Senedd withheld Legislative Consent Motions (LCMs) for the UK-Australia and UK-New Zealand trade legislation, reflecting the limited avenues available for expressing concerns about these agreements. A more collaborative and transparent process would help prevent such breakdowns in intergovernmental relations.

5.1.3 Since the United Kingdom’s departure from the EU, it has not undertaken substantive reforms to its treaty scrutiny processes. As a result, the UK now lags behind comparable jurisdictions in terms of transparency, accountability, and parliamentary oversight of FTAs. Under the EU system - where trade policy is a shared competence - the process for negotiating and ratifying FTAs includes a number of safeguards that ensure meaningful scrutiny and public accountability. For example, the European Comission (EC) routinely publishes its negotiating mandate in advance of commencing FTA negotiations, enabling both the European Parliament and Member States to assess and influence the scope and objectives of proposed agreements.

5.1.4 Furthermore, the EC provides regular and substantive updates to stakeholders, including civil society and business groups, throughout the negotiation process. In the UK, while stakeholder meetings are held, the information shared is typically limited to material already in the public domain, and discussions tend to be high-level and lacking in detail. This inhibits effective engagement and undermines confidence in the consultation process.

5.1.5 Upon completion, EU FTAs are subject to a formal ratification process involving both the European Parliament and the parliaments of individual Member States. This is not a perfunctory exercise; for example, the regional Parliament of Wallonia delayed the ratification of the Canada-EU Comprehensive Economic and Trade Agreement (CETA), while the Transatlantic Trade and Investment Partnership (TTIP) negotiations were ultimately halted due in part to parliamentary opposition. Similar scrutiny is now being applied to the proposed EU-Mercosur Agreement. By contrast, no completed FTAs have been the subject of formal debate in the UK Parliament prior to ratification.

5.1.6 Although the texts of the CPTPP were shared with relevant parliamentary committees after negotiations concluded, this falls short of international best practice. In both the EU and the United States, members of the European Parliament, national parliaments, and the U.S. Congress are granted access to negotiating texts during the negotiation process under controlled conditions. This allows for informed oversight before final agreements are reached or presented for ratification.

5.1.7 The UK Government should adopt a similar approach by granting access to negotiating texts to appointed representatives of both Houses of Parliament and the Devolved Legislatures during the negotiation process. This could be facilitated through the use of non-disclosure agreements (NDAs), as has already been the case with members of the Board of Trade. Extending this practice to parliamentary representatives would support democratic scrutiny while maintaining the necessary confidentiality in trade negotiations.

5.2 How should the Government best engage with stakeholders to implement the UK-India FTA to maximise its potential?

5.2.1 To maximise the potential of the UK-India FTA, the Government must adopt a more transparent, inclusive, and structured approach to stakeholder engagement. Previous experiences with the UK-Australia and UK-New Zealand negotiations highlighted the limitations of delayed and insufficiently detailed updates. Going forward, regular, substantive updates should be provided to Parliament and Devolved Administrations, ensuring that policymakers and industry leaders have adequate time to scrutinise and provide feedback during negotiations. A structured consultation process - including business groups, civil society organisations, and devolved governments - would allow for ongoing input, preventing key concerns from being overlooked in final agreements.

5.2.2 Additionally, the Government’s review of the Internal Market Act and Common Frameworks offers a crucial opportunity to formalise engagement mechanisms with Devolved Administrations. The integration of trade proposals into these frameworks would improve transparency and ensure regional interests are adequately represented. As seen in the EU’s trade policy model, greater parliamentary oversight, through access to negotiation texts, structured stakeholder updates, and formal ratification debates, strengthens accountability and fosters confidence in the process. The UK should consider adopting similar safeguards, granting parliamentary representatives controlled access to negotiating documents under confidentiality agreements. This would enhance democratic scrutiny, promote stakeholder trust, and ensure the UK-India FTA reflects the diverse interests of businesses, consumers, and policymakers alike.

6. Conclusion

6.1 FOUR PAWS UK’s submission as set out above reflects the Government’s concern about the risks of lower welfare import and highlights the need for greater trade negotiation transparency, increased animal welfare protections and support for higher welfare farmers. There is an urgent need for transformational change in our food and farming systems to promote animal welfare, climate mitigation and environmental protection. The measures proposed here will, if adopted, help protect the welfare of animals, the environment and the health and wellbeing of the public, both at home and abroad.

The UK has an opportunity to lead in global animal welfare by ensuring that trade policies support high-welfare farming rather than incentivising intensive, low-welfare production abroad. One of the most effective ways to achieve this is through tariffs and trade protections that safeguard British farmers while setting international expectations for ethical food production. By imposing higher tariffs on imported animal products from countries with weaker welfare regulations, the UK can discourage trade in products from systems that rely on intensive confinement, excessive antibiotic use, or inhumane slaughter methods.

Additionally, maintaining strong domestic safeguards, such as mandatory animal welfare labelling and public procurement policies that favour plant-based foods and high-welfare sourcing, ensures that British farmers are not undercut by cheaper, lower-standard imports. These measures would reward British producers for their commitment to humane farming while pressuring international suppliers to raise their own welfare standards to access the UK market. By embedding ethical sourcing requirements into trade agreements, the UK can drive global improvements in animal welfare while strengthening its position as a world leader in sustainable and humane agriculture.

August 2025