Written submission from the RSPCA (UKT0019)

Summary

The RSPCA welcomes the UK’s Trade strategy as it clearly sets out three tests to safeguard animal welfare standards that the UK will use when negotiating any trade agreement: maintain UK’s animal standards, ensure food standards are maintained and if there is a difference between countries’ animal welfare standards, use any mechanism to safeguard those standards.  The previous Government agreed to three trade agreements (UK-Australia, UK-Canada, UK-Mexico) where there was a difference in animal welfare standards but still negotiated a reduction in tariffs to allow in Australian beef, Mexican eggs and Canadian pork products produced to lower standards than in the UK. To date the new Government has negotiated three trade deals (EU-UK Common Understanding, UK-USA, UK-India FTA) which have maintained UK’s animal health, animal welfare standards and not allowed in products produced to lower standards. This is a good start but the key will be in the  negotiations on a Common Veterinary Agreement (CVA) with the EU where the UK has to ensure freer trade can operate to reduce paperworks and border delays whilst maintaining its ability to raise its own animal welfare standards if the EU doesn't reciprocate. It is unclear how British animal welfare standards will be safeguarded where dynamic alignment diverges and the Government needs to ensure present and future improvements in animal standards in both the UK and EU are encouraged.  The EU and Switzerland Food Agreement provides a good basis for the negotiations as this permits a carve out for Swiss animal welfare standards which could continue to be maintained and raised even where Swiss standards are higher than EU standards.

About the RSPCA

The RSPCA is the oldest and largest animal welfare organisation in the world, working to protect and improve the welfare of all animals whether they be pets, farm animals, wild animals or animals used in research. We undertake the vast majority of enforcement work under the Animal Welfare Act 2006 which includes considerable work on animal transit and transport including investigating the illegal trade in puppies and adult dogs. We also worked to end the live exports of farm animals in 2024, which included frontline work by RSPCA inspectors at relevant ports for over one hundred years.  Finally the RSPCA sets the standards for the UK’s only higher welfare farm assurance and food labelling scheme, RSPCA Assured, which has over 3,000 members. These standards operate at higher levels of farm animal welfare than found in the EU acquis particularly for pigs, banning the farrowing crate, and salmon farming setting standards on slaughter and transport.

Do the agreements represent a good deal for the UK?

1. UK’s Trade Strategy sets out three key red lines for the UK in any trade negotiations to safeguard the UK’s animal welfare standards:  the UK will not lower food standards and will uphold high animal welfare standards, in particular recognising concerns about methods of production, such as sow stalls and battery cages, which are not permitted in the UK. Secondly the UK will assess whether overseas produce has an unfair advantage and any impact that may have and will use, where necessary, powers to protect sensitive sectors including permanent quotas, exclusions and safeguards. Finally, the UK will always maintain present levels of statutory protection in relation to human, animal or plant life or health, animal welfare, and the environment.  Each of the three FTAs will be examined against the red lines. 
2. The EU-UK Common Understanding (CU) sets the framework for negotiations on a Common Veterinary Agreement (CVA) with the EU.  It represents a reasonably good deal for the UK though the negotiations in the CVA will be crucial. There are a number of advantages to this agreement. The Trade and Cooperation Agreement (TCA), in force since January 2021, fully liberalises trade in animal and animal products between the EU and the UK. Yet it does not take into account animal welfare standards as live animals and animal products have to go through strict import controls when entering the EU market. Great Britain has been a third country to the EU since January 2021 so GB to EU trade is subject to sanitary and phytosanitary (SPS) controls such as additional paperwork and inspections at border control posts (BCPs), which a CVA would reduce. 
3. Secondly the CU sets an ambition of dynamic alignment of standards with the EU which would incentivise the UK to raise its animal welfare standards. The EU is in the process of revising its animal welfare legislation, and will be looking at possible bans on the use of cages. The UK’s governments are  also likely to consult on a ban on certain cages and dynamic alignment of standards encourages improvements to animal welfare standards in the future whilst lowering trade barriers.  The RSPCA also believes dynamic alignment could permit the UK to rejoin the European Chemicals Agency (ECHA) or allow for increased data sharing, and ensure parity in testing approaches under REACH. This would negate a potential need to double test products being exported to the EU and will reduce the testing of products on animals in the UK. This should be explicitly negotiated under the CVA.
4. Thirdly the CU explicitly states that equivalent animal health standards will be maintained with import restrictions (so as not to allow products with lower animal health standards to enter the EU market). The RSPCA welcomes this agreement as it ensures the UK must maintain all of its import restrictions inherited from being a Member State such as the ban on the use and import of hormones used in beef production, the use and import of ractopamine in pig production and the import of chicken washed in chlorine. Although the UK has maintained such bans in all the FTAs it has negotiated including those with USA, Canada and Australia, this cements a clear direction on red lines for the UK when negotiating FTAs with other countries.
5. The RSPCA sees one threat from the Common Understanding Agreement:  the lack of clarity as to whether animal welfare standards will be included within the scope of the Agreement. The CU details the measures that are caught which are wide ranging (agrifood measures, live animals, consumer protection measures and pesticides) and details the thresholds the UK would need to meet if it wants to opt out of regulatory alignment.  However, without a specific “carve-out” for animal welfare standards when they are higher than the EU’s, the Agreement could prevent the UK from restricting EU imports that don't meet British animal welfare standards and may also inhibit the UK's ability to apply welfare standards to third-country imports.
6. Although the UK was a member of the EU for 48 years and so had regulatory alignment in those 44 areas of animal welfare law that are part of the acquis, there are a number of areas where divergence was already occurring given the ability of Member States to set their own higher standards such as those covering standards on pigs, calves and laying hens. For instance, England, Wales and Scotland have higher standards on pig farming than the EU such as not permitting the use of sow stalls at all rather than the 28 days permitted in many EU countries.  Over half of the pork consumed in the UK is imported with the majority coming from systems where sow stalls are allowed up to 28 days.
7. The EU and Switzerland have signed, albeit not yet ratified, an enhanced food veterinary agreement which permitted a carve out for Swiss animal welfare standards which could continue to be maintained and raised even where they do not have parity with EU standards. The RSPCA would want to see a similar carve out agreed as part of the UK-EU CVA negotiations.
8. Turning to the UK-USA Economic Prosperity Deal (EPD), agreed in May 2025 and effective from 30 June, this is is a non-binding agreement focused on sector-specific tariff reductions and regulatory cooperation; it is not a comprehensive Free Trade Agreement (FTA).  It is unclear, as the text of the EPD has yet to be released, if there is a SPS Chapter and if SPS measures are subject to dispute resolution. However, it is clear from the information that has been released that the EPD does represent a good deal for the UK’s animal welfare standards as the UK’s red lines on food safety have been met and no large scale trade will be permitted on products produced to lower animal welfare standards. The deal does not change any SPS measures so the UK legislation and import bans on beef hormone, chlorine chicken remain in place. The RSPCA welcomes this.
9. The USA will have pushed to relax the UK’s animal health standards.  Around 9% of the US dairy cattle herd and 22% of herds between 500 animals and 1,000 animals use BST to improve milk yield[1].  An estimated 80% of beef cattle in feedlots are given growth promoting hormones in its beef industry[2]. The USA has challenged the EU’s beef-hormone ban at the WTO in 1998 but after ten years of negotiation agreed a compromise to allow increased exports in non hormone beef in exchange for dropping the WTO challenge. The UK inherited the EU’s beef-hormone ban when it left the EU and the USA stated that it will look to overturn that ban when it starts negotiating a FTA with the UK under the previous Trump administration[3]. The RSPCA welcomes that the UK apparently turned down US proposals particularly as the UK did agree to a new 13,000 tonne import TRQ on beef.
10. The UK’s red lines on upholding animal welfare standards also seem to have been met. The RSPCA was deeply concerned about an agreement with the USA due to the lack of equivalency on farm animal welfare standards between the two countries.  The USA has few national laws on farm animals and the farm standards in most of the agricultural States that export overseas, are much lower than the UK’s. The World Organisation on Animal Health (WOAH) sets 11 non-binding standards on farm animals. The USA may also not meet all the standards in the WOAH Codes.
11. Sectors such as beef, eggs, pig products and chicken were all highly sensitive to tariff reductions unless strict animal welfare conditional liberalisation was agreed such as using TRQs conditional on certain animal welfare standards. Unqualified further reductions in tariffs, together with improved market access, posed a real threat to farm animal welfare policies within the UK which could result in a slow down in the pace of new legislation for farm animal welfare (eg dairy, beef, other poultry) and leave British producers at a disadvantage and expose consumers to products they do not want to consume. The USA has yet to phase out extreme confinement systems such as the conventional battery cage, the veal crate system and sow stalls, all of which are prohibited in the UK. The RSPCA would be very concerned if such imports were permitted as they would leave UK farmers exposed to products produced under standards illegal in the UK. The EPD does not permit any changes in agrifood tariffs other than an increase in the zero tariff on beef from 1,000 tonnes annually (shared with Canada) to 13,000 (plus the original 1,000 tonnes). This quota does not include any beef treated with hormones but it is unclear if there are any other conditions such as no beef produced in feedlots. As the USA did not fill its beef quota in 2024, it is unclear if this large increase in tariff free beef will see a diversion of beef to the UK particularly as it will have to compete with Australian beef imports.
12. There does not appear to be any other changes in agri food tariffs or TRQs e.g. on egg products, pig exports and chicken exports. Again this should be seen as a win for the UK as the pig industry was particularly concerned at any new increase in tariff free trade on pigmeat and the impact of this on the UK’s pig farmers, as US pig farmers use systems such as the sow stall, illegal in the UK, in the large pig producing States which would be exporting porkmeat to the UK.
13. This is important not only on agrifood trade from the USA to the UK but there does not appear to be anything in the UK-US deal that would interfere with the EU CVA negotiations due to start in September. The EU-UK Common Understanding explicitly states that the UK will have to ask for an opt out from the EU if any animals and goods which are non compliant with European Union rules are able to be moved into the European Union.  Ensuring that products such as hormone-treated beef, battery eggs or pigs permanently raised in sow stalls are not able to enter the UK market in the EPD ensures that meeting this threshold is made easier.
14. Lastly the UK-India Comprehensive, Economic and Trade Agreement (CETA); this represents a good deal for the UK.  The RSPCA set four goals: no change to tariff liberalisation without equivalency language to stop imports of products not produced to UK standards; animal welfare cooperation provisions in a model animal welfare chapter; recognition of the precautionary principle or of the right of the UK to uphold existing import bans based on animal health in the SPS Chapter; export opportunities via reduced Indian import tariffs such as on meat and fish.
15. These were by and large all achieved. There are no tariff reductions for the sensitive products (pigs, chicken, eggs, dried eggs, liquid eggs) so maintaining the UK red line on safeguarding UK standards. Whilst there are immediate tariff reductions on a range of other sectors such as beef, sheep, fish, turkey leather, wool and fur, these are not expected to change trade levels as tariff levels were low for leather, wool and fish and there is little trade in the other products.
16. India has agreed to a new zero rate import tariff for salmon from the date of entry into force which will open up the Indian market to Scottish salmon exports and be favourable to Scottish salmon production and animal welfare as around 90% of Scottish salmon is produced to RSPCA standards and falls under the RSPCA Assured scheme.
17. The SPS Chapter recognises the principle of equivalence on SPS standards so it is the outputs that are critical not the standards which don't have to be the same. Although India does not diverge from the UK on food animal health standards such as beef-hormone or chlorine-chicken this provision maintains the UK’s animal health standards. A new Indian law came into effect in April 2025 on antibiotic use and this will need to be monitored to assess if it brings equivalent standards to the UK.
18. CETA has a stand alone section on animal welfare under the SPS Chapter but this section is weaker than previous Chapters agreed under FTAS with Australia and New Zealand as it only has vague top line commitments and no Working Group on animal welfare has been set up.

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

19. The RSPCA welcomes the UK’s Trade Strategy as it clearly sets out red lines for the UK in any trade negotiations. In particular, to safeguard the UK’s animal welfare standards, the trade strategy sets out three key tests:  the UK will not lower food standards and will uphold high animal welfare standards, in particular recognising concerns about methods of production, such as sow stalls and battery cages, which are not permitted in the UK. Secondly the UK will assess whether overseas produce has an unfair advantage and any impact that may have and will use, where necessary, powers to protect sensitive sectors including permanent quotas, exclusions and safeguards. Finally, the UK will always maintain present levels of statutory protection in relation to human, animal or plant life or health, animal welfare, and the environment. 
20. These safeguards are crucial to the UK’s animal welfare standards. The UK has over 40 specific animal welfare and health standards set out in legislation, 18 on farm welfare.  None of these standards, apart from those related to welfare at the time of  slaughter[4], legally apply to imports. Whilst FTAs do not change internal animal welfare legislative standards, they can and do have a direct impact on those standards being used by UK farmers as they allow imports of products produced to lower standards which can undercut British producers. A surge of lower welfare imports could lead to a general race to the bottom amongst UK producers, understandably keen to avoid being undermined by sub-standard foreign imports, which would result in an overall deterioration of animal welfare standards in UK food and farming. As the UK has higher legal animal welfare standards than all the countries that it has or is negotiating FTAs with, except Switzerland and New Zealand, the safeguard clause that the UK will uphold high animal welfare standards is crucial.
21. The UK’s animal health standards are backed up by legislative import conditions, and so need a change of law before any new FTA measures can be implemented. Under the previous Government, the UK delivered compliance for animal health import standards in FTAs such as on hormone-beef, chlorine chicken, ractopamine but not for animal welfare standards, which were negotiated away eg UK-Australia permitting exports in lower welfare beef and sheep and UK-Canada permitting exports in lower welfare pigmeat and eggs.  Each of the three FTAs will be examined against the red lines. 
22. Although the UK did not explicitly produce any negotiating objectives before the three trade deals being examined, the UK did achieve the objectives as set out in the trade strategy in all three deals. The UK did not lower food standards in any of the deals and resisted pressure in the UK-USA EPD to allow in products such as hormone treated beef .
23. The UK did uphold high animal welfare standards, by not agreeing to reduce tariffs in UK-India CETA or UK-USA EPD for sensitive products such as eggs, pigs so recognised concerns about methods of production, such as sow stalls and battery cages, which are not permitted in the UK. Whilst they did not agree to any tariff reductions based on conditionality to animal welfare standards, the only sector where tariffs were reduced, beef under EPD, maintained the animal health standards.
24. Finally, the UK did maintain present levels of statutory protection in relation to animal welfare under CETA and EPD.  Whilst it is welcome that dynamic alignment with the EU’s animal welfare standards is set under the CU, it is unclear if animal welfare standards will be included within the scope of the Agreement. The CU states that the UK will need to meet certain thresholds if it wishes to opt out of regulatory alignment with the EU on agrifood measures and the RSPCA fears that unless there is a specific “carve-out”, the Agreement could prevent the UK from restricting EU imports that don't meet British animal welfare standards and may also inhibit the UK's ability to apply welfare standards to third-country imports. For instance should the UK decide to raise its animal welfare standards by banning all cages for laying hens, will it be permitted to ensure that only European eggs from equivalent standards are permitted to be imported. If a carve out is not agreed in the forthcoming CVA negotiations, this has the potential to act as a brake on the UK and Devolved Administrations raising their animal welfare standards in the future.

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

25. Parliament should assess the success of these agreements against the following tests: have the agreements led to an increase in agrifood products entering the UK which have lower standards than those allowed to be produced in the UK (this is the test that the Trade and Agricultural Committee reports on for Parliament). It is likely that this test will be met for CETA and EPD as there was little tariff reduction on sensitive products, but the CVA negotiations will be crucial to ensure that the UK is able to raise animal welfare standards in the future if those same standards are not raised in the EU. Secondly Parliament should assess the agreements on the rise in exported products, such as salmon where tariffs in the importing country have been reduced. Finally and specific to the UK-EU negotiations, has the agreement resulted in reduced paperwork and freer trade between the two partners. This should result in increased trade particularly in those sensitive issues such as shellfish exports from the UK, shorter waiting times at border posts, particularly important for exports of live high value horses and people going on holiday with their dogs.

Economic Impact

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

26. The agreements should result in increased exports of salmon particularly to India, of which 90% are RSPCA Assured and so produced under higher animal welfare standards. The agreements should also incentivise UK production of products produced to RSPCA animal welfare standards such as free range eggs and pigmeat produced under free farrowing systems as these are not threatened with imported products entering the UK market produced to lower standards and so undercutting members of RSPCA Assured scheme.

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

a) the UK’s economy as a whole?

b) UK producers, including SMEs and key sectors

c) UK workers and consumers?

27. The DBT’s Impact Assessment on the agreement with India projects a permanent increase in UK GDP by 0.13% (£4.8 billion) and a real wage increase of 0.19% (£2.2 billion) per year in the long term and bilateral trade to grow by 39%[5]. It is expected to result in an increase in the salmon industry in Scotland due to the reduction of Indian import tariffs.
28. One study by Aston and Bristol Universities projects that the UK-EU CVA has the potential to increase agrifood exports from the UK to the EU by over 22%, adding 0.22% to the agricultural sector’s value[6]. This is mainly due to reduced border checks and paperwork for businesses. However unless the UK negotiates a carve out for animal welfare as part of the CVA negotiations it could see imports rise in products that are illegal to produce in the UK (eg pigmeat from systems that permit sow stalls). This could have two important impacts - a freezing effect on farm animal standards being raised in the UK and a slow down in increases in higher animal products being produced particularly in the free range egg and free farrowing pig sectors.

Standards and Safeguards

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

29. The UK did not lower food standards in any of the deals and resisted pressure in the UK-USA EPD to allow in products such as hormone treated beef.
30. The UK did uphold high animal welfare standards, by not agreeing to reduce tariffs in UK-India CETA or UK-USA EPD for sensitive products such as eggs or pigs, so recognised concerns about methods of production, such as sow stalls and battery cages, which are not permitted in the UK. Whilst they did not agree to any tariff reductions based on conditionality to animal welfare standards, the only sector where tariffs were reduced, beef under EPD, maintained the animal health standards.
31. The UK did maintain present levels of statutory protection in relation to animal welfare under CETA and EPD.  Whilst it is welcome that dynamic alignment with the EU’s animal welfare standards is set under the CU, it is unclear if animal welfare standards will be included within the scope of the Agreement. The CU states that the UK will need to meet certain thresholds if it wishes to opt out of regulatory alignment with the EU on agrifood measures and the RSPCA fears that unless there is a specific “carve-out”, the Agreement could prevent the UK from restricting EU imports that don't meet British animal welfare standards and may also inhibit the UK's ability to apply welfare standards to third-country imports. For instance should the UK decide to raise its animal welfare standards by banning all cages for laying hens, will it be permitted to ensure that only European eggs from equivalent standards are permitted to be imported.
32. If a carve out is not agreed in the forthcoming CVA negotiations, this has the potential to act as a brake on the UK and Devolved Administrations raising their animal welfare standards in the future. The UK has already failed to support a Bill proposing a fur import ban as it is concerned on the impacts of this ban on the CU as it would impact European fur being placed on the British market albeit not an agrifood product.

Engagement and Transparency

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

33. Although the Government gave periodic updates on UK-India these were very top level, often late and gave no indication to either business, civil society or Parliament of progress.  The RSPCA believe that Parliament and devolved Governments should have access to regular, meaningful updates and information about the progress of negotiations.  This would enable legislators and DAs to raise issues important to business and members of the public on the impact of any negotiations on animal welfare standards, particularly on farm welfare.  This is particularly important for DAs who have devolved authority to establish legislative standards on animal welfare but not at present the ability to influence trade negotiations which could negatively impact on those same standards and may even render those standards obsolete.  This information should be provided with sufficient time for Parliament to analyse and respond to the update and for Parliament’s response to be taken into account in the next stage of negotiations. The Government should regularly and meaningfully consult stakeholders, including civil society organisations. It is entirely possible to increase transparency and stakeholder input while maintaining confidentiality.
34. The Government did seem to listen to concerns of sectors such as the pig and egg industries who were particularly concerned at any new increase in tariff free trade on pigmeat eggs in the UK-US EPD and the UK-India CETA. Any reduction in tariffs without any conditionality on animal welfare standards would have greatly impacted the UK’s pig and egg producers, as US and Indian egg and pig farmers use systems such as the sow stall and conventional battery cage, both now illegal in the UK and would have been able to undercut those producers.

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

35. The Government should engage with those sectors, such as the salmon industry, where the UK-India CETA has opened up increased export potential. This engagement could include liaising with the trade missions that DBT has in India to increase UK-India contacts and trade potential. 

August 2025