Written submission from Chester Zoo (UKT0008)

Barriers to Conservation: Impact of Current SPS Requirements on Conservation Transfers

2.1 International breeding programmes are essential to species conservation, with UK zoos and aquariums playing a pivotal role in over 400 such programmes.

2.2 Chester Zoo, for example, coordinates the programme for the critically endangered eastern black rhinoceros. With 45% of the 87 individuals in this programme cared for in UK zoos, smooth cross-border transfers are vital to maintaining genetic and demographic diversity. Any disruption risks undermining the viability of this population and delaying future reintroductions in East Africa.

2.3 Since 2021, legislative divergence following the UK’s departure from the EU and the introduction of the EU Animal Health Law has delayed or prevented thousands of critical conservation transfers. This misalignment continues to add significant challenges to UK participation in EEPs and threatens to compromise its leadership in global species recovery.

2.4 Despite joint efforts by Defra, BIAZA, and the wider zoo sector, transfers between Great Britain and the EU remain 80% below pre-Brexit levels.

2.5 Before the UK left the EU, an average of 1,400 animals were transferred across the UK-EU27 border each year. In 2021, this fell by 96% to just 56 transfers. While numbers have gradually increased - to 211 in 2022, 265 in 2023, and 282 in 2024 - they remain well below the levels needed to restore the UK’s full contribution to international conservation efforts.

2.6 In addition, transfers that once took 6–8 weeks now take 2–3 years, causing species threatened with extinction to miss several critical breeding seasons.

Key Trade and SPS Challenges Affecting our Conservation Work

Lack of harmonised health certification

3.1 Since leaving the EU, health certification requirements for the movement of zoo animals have diverged significantly. As a Third Country, the UK must now obtain separate import and export health certificates for each species and destination country. For example, transferring the same endangered deer species to zoos in France and Germany, and a monkey to the same German zoo, would require three different health certificates. This creates a complex, expensive, and time-consuming process.

3.2 Further complications arise from the need for transit documentation, requiring permissions from veterinary authorities in each country along the route. These negotiations are often lengthy and unpredictable, involving multiple layers of bureaucracy.

3.3 Rules also vary significantly between EU Member States - and even between regional governments within them. For example, Germany’s 16 federal states each set their own health certificate requirements, making the process even more complex.

3.4 Under the current process, exporting institutions must research entry conditions for each destination country and submit documentation to Defra, which then liaises with EU counterparts to draft an acceptable health certificate. This process is resource-intensive and can take over a year to complete.

3.5 CITES permits are also required for most animal transfers and for the movement of veterinary and research samples. These permits are valid for just six months, and delays in securing health certificates often exceed this timeframe - forcing institutions to restart the process and absorb additional costs. For live reproductive samples such as sperm, eggs, or tissue, timing is critical: they must be transported within 24-48 hours to remain viable. Under the current system, securing the necessary permits can take up to 30 days, and in some cases, transfers have been delayed for up to two years. This has led to missed research opportunities and reduced the effectiveness of breeding programmes that rely on genetic exchange between populations.

3.6 While the development of template health certificates for certain species and destinations has helped streamline some transfers, these remain limited. Given the vast number of species involved and the specific requirements of each destination country, progress under the current system will take many more years.

Lack of Border Control Posts (BCPs) for Road and Ferry Travel

3.7 The lack of accessible border control posts (BCPs) is another major barrier. Post-Brexit, only one UK BCP – Portsmouth - remains open and equipped to carry out the necessary veterinary checks before animals enter the EU. This is largely a commercial decision by port operators due to the increased costs associated with red tape.

3.8 On the European side, only two mainland ports - Caen Ouistreham and Saint Malo - remain open for transfers from Great Britain. Saint Malo has very few ferry connections and cannot process CITES-listed species. Caen’s location adds significant delays for transfers to northern EU countries such as Germany, Poland, and the Czech Republic, where previous routes like Hull–Rotterdam or Harwich–Hook of Holland were faster and more efficient.

3.9 We believe restoring access via Calais, which previously handled 98% of UK-EU conservation transfers, would be a major step forward. We ask the Committee to urge the UK Government to engage with EU counterparts and French port authorities to explore options for re-establishing Calais as a designated route. This would help remove a major logistical barrier and support the UK’s contribution to international conservation programmes.

3.10 Following concerns raised by BIAZA, the UK now allows post-import checks at the point of destination rather than at BCPs. This agreement will continue until there are more BCPs with the necessary facilities in place. This pragmatic solution has significantly reduced delays and reflects constructive engagement between Government and the sector. However, EU Member States have yet to adopt a similar approach.

The Escalating Costs of red tape

3.11 The cumulative impact of these new bureaucratic requirements is becoming prohibitively expensive for conservation institutions across the UK and Europe. Transportation costs are traditionally covered by the importing institution, but the additional staff time needed from registrars, veterinarians, and curators to navigate increasingly complex legislation has driven these sharply upward. Added requirements - including pre-export testing, expanded on-site facilities, and the time needed to complete paperwork and ensure compliance - are making participation in EEPs increasingly unaffordable for many. In our experience, costs have risen by up to £1,000 per animal.

3.12 As a result, some EU zoos are now reluctant to transfer animals to the UK, citing this administrative burden, financial strain, and regulatory uncertainty.

Urgent call for a UK-EU veterinary/SPS agreement

4.1 We welcome Defra’s efforts to-date to address these challenges faced by conservation zoos, particularly the introduction of post-import live animal checks at the point of destination. However, under current permanent restrictions, a return to pre-Brexit levels of conservation transfers is increasingly unlikely. There is now a pressing need for greater legislative compatibility between UK and EU veterinary and animal health laws to facilitate efficient cross-border animal movement for conservation.

4.2 We recognise the importance of robust SPS measures to protect biosecurity across both the UK and the EU. However, the current regulatory misalignment is creating unsustainable barriers and is directly threatening the UK’s ability to continue contributing to international conservation breeding efforts for species on the brink of extinction.

4.3 A UK–EU veterinary/SPS agreement would provide a long-term solution. It would improve legislative compatibility, streamline animal movements, and enable the use of harmonised health certificates - reducing costs and delays for zoos and aquariums on both sides of the Channel.

4.4 We therefore welcome the Prime Minister’s confirmation at the first UK-EU Summit that the Government will seek to negotiate an such an agreement. While the public focus has largely been on food and agriculture, we have since received welcome confirmation through discussions with Ministers and responses to parliamentary questions that the agreement will also aim to support the safe and efficient movement of zoo animals[5][6][7]. This recognition is encouraging and reflects growing awareness of the wider benefits such an agreement could bring - not just to trade, but to conservation.

4.5 We urge the Business and Trade Committee to continue championing the need for a UK–EU veterinary/SPS agreement that reflects the specific needs of zoos and aquariums.

4.6 Finally, we commend the Government for its commitment to continuing discussions with zoos as negotiations progress[8]. It is essential that conservation zoos remain actively involved in shaping these discussions as decisions around the agreement are made. For example, clearer communication around the scope and timeline of negotiations would provide much-needed reassurance and allow organisations to plan the future of breeding programmes more effectively. Ongoing engagement will be key to ensuring that the final agreement supports the efficient movement of animals and biological samples - enabling UK conservationists to continue playing a leading role in international species recovery efforts.

Case Study - Bernie the Bear: 1,000 Days of Red Tape Blocking Conservation

5.1 Fewer than 10,000 Andean bears remain, with threats like deforestation, climate change, and human-wildlife conflict putting this species at risk of extinction. Chester Zoo is working with local communities in places like Bolivia to protect this iconic species, but a strong, genetically healthy population in zoos is also essential for its survival.

5.2 Bernie, a male Andean bear at Chester Zoo, has already fathered three cubs, contributing to a genetically viable population in Europe. In March 2022, Bernie was scheduled to move to a zoo in Germany, where he was identified as a perfect genetic match for their female. However, the transfer faced repeated delays due to bureaucratic hurdles.

5.3 A lack of harmonised health certification, combined with difficulties in obtaining the necessary specifications from the German Authority, created significant obstacles. The prolonged process required multiple re-applications for CITES export and import permits, as permits expired before the necessary paperwork could be finalised.

5.4 Additionally, restrictions limiting animal transport to a single port, along with bureaucratic hurdles, resulted in increased costs, logistical challenges, and significant delays. As a result, Bernie remained at Chester Zoo for nearly three additional years, delaying his opportunity to contribute to the breeding programme.

5.5 In December 2024, 1,000 days after he was scheduled to be transferred, Bernie was finally authorised to make his way to Germany. Prior to the UK’s departure from the EU, a transfer like this would have taken 6-8 weeks. His case highlights the urgent need for greater legislative compatibility between the UK and the EU to ensure conservation efforts are not hindered by unnecessary bureaucracy.

Case Study – Stuck at the Border: How Paperwork Delayed a Vital Bird Transfer

6.1 In July 2023, Chester Zoo attempted to move six Red-billed Curassows and one Sumatran Laughing-thrush to a zoo in Belgium as part of the European Endangered Species Programme (EEP). This move was critical for ensuring their survival and genetic diversity. The receiving zoo was to set to provide quarantine before the Curassows continued to another Belgian collection. However, post-Brexit regulations created multiple logistical hurdles, causing major delays.

6.2 The first challenge was securing the necessary case-by-case derogation from the Belgian Government Veterinary Authority. This was required for the UK’s State Vet to sign the Export Health Certificate (EHC). Once the derogation was obtained, Chester Zoo had to arrange and pay for an official translation of the documents before submitting them for approval by SIVEP, the French Veterinary and Phytosanitary Border Inspection Office.

6.3 Despite these preparations, a new issue emerged when the birds arrived at Portsmouth. The French Authorities insisted that an additional derogation was needed for the birds to transit through France enroute to Belgium, even though France was not the final destination. This requirement had not been anticipated, and previous attempts to obtain similar derogations from the French Authorities had been unsuccessful.

6.4 With no clear resolution, the transporter was advised to travel to Dover and attempt the Channel Tunnel route – only to be turned away again. After returning to Portsmouth and engaging in further discussions, SIVEP stated that the final decision rested with the Brittany Ferries captain at Dover. Fortunately, the captain agreed to proceed, allowing the birds to board the ferry.

6.5 While the animals arrived safely, what should have been a 24-hour journey stretched to 52-hours. Despite meticulous planning, inconsistencies in post-Brexit regulations led to unnecessary delays, highlighting the urgent need for clearer, more coordinated procedures to facilitate the movement of endangered species for conservation.

Case study – Okapi Transfers: The Cost of Bureaucratic Delays

7.1 In 2023, Chester Zoo was in the process of transferring an Okapi to a zoo in Poland. The move had been in development for nearly two years, yet regulatory hurdles repeatedly stalled progress. The transfer, also recommended by the EEP, had been in the works for nearly two years.

7.2 One of the major challenges was securing transit permits for the animal to pass through multiple EU countries. The receiving zoo was instructed to obtain transit permits for the Netherlands, Belgium, France, and Germany. While the Netherlands, Belgium, and France granted the necessary transit permits, Germany failed to respond for several weeks - far exceeding the expected 48-hour timeframe.

7.3 Despite repeated efforts by both Chester Zoo and the transporter to push for the necessary German approval, the prolonged delay made it impossible for the move to proceed. As a result, the transfer was cancelled, leading to a significant financial loss of approximately £9,000 for the receiving institution.

7.4 Frustrated by the overwhelming bureaucracy and excessive costs, the zoo in Poland decided not to proceed with any future okapi transfers. Meanwhile, another planned okapi transfer from Chester Zoo to a zoo in the Czech Republic has been delayed by over 18 months. The challenges faced in these cases have made the receiving institution hesitant to proceed with the transfer due to the known challenges and potential costs involved.

August 2025

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