Written evidence submitted by Battersea Dogs and Cats Home (MAAB0045)

About Battersea Dogs & Cats Home

Established in 1860 to care for abandoned animals, Battersea Dogs & Cats Home aims to never turn away a dog or cat in need of help. We reunite lost dogs and cats with their owners; when we cannot do this, we tend to their medical needs and care for them until new owners can be found. We accept any breed of dog or cat, at any age, including those with serious medical and behavioural problems. Our expert team of dog and cat care professionals and veterinary staff give the animals in our care the best possible chance of a fresh start in a happy new home in the UK, or even further afield. There is no time limit on how long an animal can stay with us until the perfect new owners are found.

Battersea shares our knowledge and experience of animal welfare expertise through our Academy. This is open to any dog and cat rehoming or rescue organisation in any location around the world, from small volunteer-run shelters to established animal rescues. Our programmes are a mix of classroom-based learning and hands-on practical work in our kennels and cattery. 

Battersea’s non-selective intake policy means that we often see dogs and cats come to us that have been through the worst kind of cruelty and mistreatment. We see animals that have been abandoned, brought into this country illegally, denied essential medical treatment, physically abused, starved, overused for breeding, and even used in dog fighting.

Key statistics

•                      In 2020, we helped over 3,000 dogs and cats across three centres: 1,796 dogs and 1,653 cats. Intake was lower in 2020 due to the COVID-19 pandemic. By comparison, in 2019, we helped over 5,000 dogs and cats at our centres including 3,213 dogs and 2,476 cats.

•                      Battersea received 212 dogs and 130 cats from other animal rescues across the UK, equivalent to 11% of total intake.

•                      Prior to the coronavirus pandemic, we had an average of 247 dogs and 120 cats at any one time on site or foster.

•                      Battersea's Lost Dogs & Cats Line received 1,902 calls about lost dogs and cats, and 1,821 calls about stray animals that had been found last year. We helped reunite 345 dogs and cats with their owners.

•                      Our average stay in 2020 was 34 days for dogs and 25 days for cats.

•                      Last year Battersea’s Academy delivered 27 programmes and webinars, which were attended by 467 delegates from 146 UK and international organisations

•                      The Battersea Grants programme which began in November 2018 has to date indirectly helped 43,100 animals worldwide.

Executive Summary

• Brexit provides an opportunity to reduce the movement of dogs under six months old through mechanisms such as increasing the post-vaccination wait period.
• The UK Government has the opportunity to reduce the number of illegally landed animals by changing the non-commercial importation requirements, closing current loopholes in the Pet Travel Scheme (PETS). There are
• credible concerns over the certification and recording of data by statutory bodies, with a range of different data being reported. This leads to uncertainty over the number of animals legally entering the UK.

1. Does the UK have sufficient resources and capacity to certify, record and inspect animal movements across its borders?

Battersea is of course an animal welfare charity, rather than a border protection agency, and so it would be inappropriate to make an assessment of how much extra capacity exists within the system. However, protecting the UK from criminality and disease risk at the border is a key function of Government, and therefore one that must be adequately resourced. If there is a difficulty with resources, then it is incumbent on policymakers to make enforcement as easy and manageable as possible.

Two key changes could be to alter the rules of pet travel around the number of animals travelling: firstly limiting the number per vehicle, and also increasing the wait time post-rabies vaccinations to 12 weeks, while restricting the age of vaccination to 12 weeks. Not only would this make illegally underage puppies easier for enforcers to spot, but it would make dogs farmed overseas unable to enter the UK till 24 weeks, making it less economically viable for unscrupulous puppy farmers to breed overseas and import.

We can identify from available data that before the end of the Brexit transition period on 31 December 2020 there was an increasing number of puppy and kittens that entered the UK through legal means (excepting the drop in non-commercial movements in 2020, which would be expected as international travel was heavily discouraged or impossible during the COVID-19 pandemic). Therefore, there was an increasing pressure on the resources needed to manage the control of pet animals moving across UK borders, and there has been for a number of years.

Data from APHA for the Pet Travel Scheme (PETS).

Data for dogs entering the UK under the Balai Directive.

Dogs and cats can legally be brought to the UK via either PETS for non-commercial movement or the Balai Directive for commercial movement. All data on the number of legally imported dogs is held by the Animal and Plant Health Agency (APHA). This includes PETS and commercial imports, which as of January 1st, 2021 is held via the Import of products, animals, food and feed system (IPAFFS)[5] (which replaced the EU wide database TRACES for UK movements). It is only through freedom of information requests and Parliamentary Questions that this data can be accessed publicly, which is a situation on which Battersea and others would welcome greater transparency.

These figures clearly show a sharp rise in the number of dogs legally entering the Great Britain through both commercial and non-commercial sources between 2015 and 2019. 2020 differs due to the impact of the COVID-19 pandemic, however this figure is still higher than it was in 2015 when there were no travel restrictions imposed. This, coupled with eyewitness reports, means it is logical to assume that illegal movements have also increased to a significant degree, even if it is difficult to put an exact number on covert movements

There are concerns about the validity and quality of the current and historic data recorded through APHA and TRACES. In late 2020, Battersea submitted a Freedom of Information request to APHA for the number of dogs entering the UK via the Balai Directive for the years 2015 to 2019. For the year 2018, the number provided was 41,313. However, in an answer to a Parliamentary Question, the number provided was 37,144[6], a difference of 11%. The latter number was provided along with a breakdown by country of origin. The USA was not included in this data despite being the country of origin of 1,848 dogs in 2016, 1,916 dogs in 2017,[7] and 2,604 dogs in 2019.[8] This could explain part of the discrepancy, but not all of it and it is concerning that the USA data appears to have been absent in the answer provided to the Parliamentary Question.

In another example of a discrepancy, in 2020, the answers to two written Parliamentary Questions on the number of dogs entering Great Britain in 2019 via PETS were inconsistent. One gave the total for the year as a whole as 307,263[9], while another reporting the numbers by month totalled 308,404, a difference of 1,141.[10] Although the length of time it takes to report some of the data could mean that the data available when one question is asked is different to the next, this is not mentioned in the answer to either.

Furthermore, in response to a Parliamentary Question from Kenny MacAskill MP on the validity of pet imports data Parliamentary Under-Secretary for DEFRA Victoria Prentis MP responded stating:

“The number of dogs imported under the Pet Travel Scheme in July 2020 was 17,984.

In answer to question 85115, the figure of 5,423 was based on information provided by checkers employed by approved carriers of pet animals. The Animal and Plant Health Agency (APHA) advised at the time that the information supplied was a true reflection of the data that had been provided.

APHA is unable to guarantee the accuracy of this data, as it can only rely on the information provided by third parties. Subsequently, figures may be amended as third parties submit new data, as occurred in this instance.”[11]

There are certification and reporting concerns over the current data, which directly contributes to the level of uncertainty over the number of animals entering the UK legally. Clearly the certification, reporting and inspection of animal importing should be improved.

APHA does not record certain data that would enable trends to be observed and would help combat illegal imports, such as the country of origin for PETS,[12] which has not been stored since 2016. This would help identify when puppies are coming from countries where documentation is known to be less reliable and would help identify trends in country of origin of puppies.[13] Furthermore, APHA only has a data retention period of three years,[14] abnormally short for public records, and making it hard to show long-term changes in demand for puppies from outside the UK. Similarly, TRACES did not collect data on all reasons for the commercial import, such as for international rehoming.[15] The facility to collect this data has been added to the IPAFFS system, which is welcomed.

2. How effectively will the UK be able to conduct animal disease surveillance and respond to outbreaks?

This issue is of concern to Battersea as we are increasingly seeing dogs with foreign microchips. Whilst this may in part be a result of foreign microchips being implanted into UK animals as they are cheaper, it still raises concerns. Foreign microchips are routinely not scannable by UK scanners so (a) do not help reunite animals with owners and require Battersea to quarantine dogs while they are checked for disease, and (b) are unlikely to comply with the Microchipping of Dogs Regulations as they are not recorded on a compliant database. In both cases it means that we do not have a history for the animal and must assume that it is an imported animal. Therefore, we must quarantine it as a matter of precaution and carry out blood tests. Until these are complete, and results returned, the animal must stay quarantined in a kennel, which is detrimental to their welfare and has considerable cost implications.

If the entry requirements are maintained, then there is likely to be no change in the risk of new diseases entering the UK. However, if pets are only allowed to legally enter the UK via certain Border Control Posts (BCPs) as will be required for commercial imports from March 2022,[16] it is unclear what steps will be taken to ensure illegal importers cannot subvert the system and land their animals at a non-designated port which may have less stringent checks. From an animal welfare perspective, it is also unclear what will happen to animals that are moved (intentionally or otherwise) to a port other than the BCP, as they may have already undergone a significant ordeal to reach the UK.

There are also ways in which disease surveillance can be improved to reduce the risk of non-endemic diseases entering the UK, such as rabies, distemper and leishmaniosis. As stated in our previous submission to the Committee[17] and further explored in the response to question 8 below, the post-vaccination wait period should be increased from 3 to 12 weeks to ensure rabies does not enter the UK from countries where it is present. Similarly, a requirement should be added so that all dog and cats entering the UK are treated against tick borne diseases.

3. What impact will the new UK-EU agreement have on moving animals across the Irish border and between GB and the EU/Northern Ireland?

The requirements for bringing non-commercially imported animals into Great Britain under the Northern Ireland protocol across the Northern Ireland/Ireland border remains unchanged as of 1st January 2021.[18] The UK Government still recognises EU and Northern Ireland Pet Passports and the requirements for vaccinations, microchipping, and numbers of animals remain the same. This may change if the UK Government revises the pet travel requirements.[19]

This is different for those taking pet animals from Great Britain into Northern Ireland or the rest of the EU. The UK is now classed as having Part 2 third country status under Annex II of the EU Pet Travel Regulations, which means that all UK issued EU Pet Passports are no longer valid. Great Britain residents are advised that they now need to take extra steps if they wish to travel with their pet. This includes obtaining the correct vaccinations, boosters, blood tests, microchip, and tapeworm treatment; this can all take up to a month.[20] Pet owners will then have to obtain an Animal Health Certificate (AHC) for their dog or cat no more than 10 days before travel, as an AHC is only valid for 10 days from issue for the outbound journey. EU pet passports can continue to be used for return into the UK, provided it is still valid, or the AHC within four months of its issue.

The Commercial Movement of Animals is somewhat more complicated, as Great Britain no longer uses TRACES and instead uses IPAFFS.[21] Therefore, commercial importers will likely have to register their importation on both TRACES and IPAFFS, which have different data recording requirements, which mean increased paperwork.[22] Similarly, there are new requirements for importers to have new certification specific to Great Britain they did not previously require and this has to be obtained within the UK, in addition to their own country. These include transporter authorisation, certificates of competence and vehicle approval certificates. This will therefore add both cost and delay to doing business in 2021, although this is something that should be ironed out longer term. However, if the journey originates in Northern Ireland coming into Great Britain, these new certificates can be issued there.[23] The full impact of this increased data collection and certification is not yet clear and will need to be monitored.

4. How should the Government balance animal health and welfare alongside economic interests? 

In our view, it is a false dichotomy to suggest that the two are not intertwined. The figures stated in our response question 1 show an 86% increase in the non-commercial import of dogs between 2015 and 2019, with commercial imports increasing by 57% in the same period. Whether or not people wish it to be, the trade in pets is clearly a large, global one which requires good management at the border in order to protect animal and human health within the UK, thereby protecting the country from the health and economic consequences of a non-endemic disease outbreak.

Whilst 2020 was an anomalous year due to the impact at the borders of the COVID-19 pandemic, this data clearly shows a large number of animals entering the country. This is coupled with uncertainty over the number of dogs being brought into the country illegally to be sold on. Battersea believes that animal welfare should be prioritised in the import and export of dogs and cats. This would not only benefit animal welfare, but human health and thereby the national economic interest.

Live animal exports:

5. What impact will ending live animal exports for slaughter and fattening have on UK farmers, processors and other businesses?

Battersea as a dog and cat welfare organisation does not take a view on this question.

6. Does the UK have sufficient capacity to slaughter and process animals that are currently exported? If not, what could be improved?

Battersea as a dog and cat welfare organisation does not take a view on this question.

Domestic animals:

7. How will Great Britain leaving the EU Pet Travel Scheme affect both legal and illegal movements of animals between GB and the EU/NI

There is still no specific law relating to the movement and safety of dogs and cats cross-border, and the recent DEFRA consultation on animal movements related almost exclusively to livestock. Outside the EU, there is an opportunity for the UK to set its own standards for companion animal transport, recognising the significant welfare risks around temperature, excessive stocking density, access to food and water and opportunities for rest and exercise in journey.

The UK is still aligned to the EU Pet Travel Scheme for the importation of dogs and cats from EU countries, as stated in question 3. However, it is not known if or when the Government intends to make changes to the importation requirements, as it is now entitled to do. The requirements for people from the UK taking pets to EU countries, however, have become more complex, with all Great British issued Pet Passports now being invalid for travel, extra checks required for vaccinations and blood tests, and needing an Animal Health Certificate (AHC) which is only valid for outward travel for 10 days.[24] This will naturally make it less attractive to travel with pets outside the UK, and the significant (and potentially intimidating) extra administrative burden will likely reduce the number of pet movements undertaken. The UK is similarly still aligned to the current commercial importation requirements under the Balai Directive. However as discussed in question 1, the UK can no longer utilise the EU TRACES database of recording imports and it has instead been replaced with the new IPAFFS database. Battersea welcomes the increased traceability afforded with this new database, however there are ways in which it could be improved, an example being the automated creation of health certificates, which currently are required to be filled out by hand. 

There is currently a major issue with illegal imports of dogs into the UK. However, there is no way to accurately estimate the number of animals entering the UK as not all illegally imported animals will be caught by border agencies. It is therefore difficult to estimate the impact of leaving PETS. Illegal importers use many different methods of bringing animals into the UK; taking advantage of known weaknesses in border protection activity (such as only carrying out checks during working hours, and targeting entry points with less stringent checks), and utilising loopholes in the current legal importation system (such as the current allowance of five animals per person via PETS). Many animals are therefore not properly identified and quarantined at ports.

There is only a small amount of information on illegal imports from two main sources - the Dogs Trust Puppy Pilot Scheme,[25] and APHA. The Dogs Trust Puppy Pilot Scheme ran from December 2015 to July 2018, but not during the COVID-19 pandemic. During this time, they intercepted 1,433 puppies suspected to be entering the country illegally under PETS; 60% were deemed illegal and quarantined.[26] 

APHA holds data on ‘illegally landed’ dogs, which are landings that do not comply to the current PETS standards rather than specifically ‘smuggled’ dogs, meaning it is a confused picture. Although there is a clear decrease over time, we cannot be certain if this is because of a reduction of illegally landed dogs or simply fewer coming to APHA’s notice. As recorded elsewhere in this document, there are significant questions over APHA’s statistical reporting.

The unknown scale of illegal imports is key when considering resource implications for UK border agencies. Whilst there is a clear level of uncertainty, now that the UK has left the EU there are ways in which the importation system could be improved to make the most of resources and substantially reduce the ability for illegal importers to operate.

8. Are the current rules and checks on the movement of domestic animals strong enough to prevent illegal activity? If not, what could be improved?

Battersea welcomed the statement by Lord Goldsmith during the oral evidence session the Committee held on 24th November 2020:

‘There are many ways we are going to be able to take forward our commitment on animal welfare, after Brexit and after the transition period, that we were not able to before. Those include the things we have discussed today, for example, about reducing the age at which puppies can be imported, reducing the numbers of pets that can accompany an individual and the live export of animals.’[29]

Battersea believes there are ways in which the current administrative arrangements for pet travel could be improved to substantially reduce the number of illegal dogs entering the UK. Battersea proposes the following policy changes, which need not impact on the ability of UK citizens to travel with their pets:

• The vaccination of puppies for rabies should only be undertaken when they are 12 weeks of age, and the wait time post-vaccination also increased to 12 weeks, meaning that importing or transporting puppies to the UK would be prohibited until they are at least six months’ old. This would have two significant benefits – firstly, it would make puppy smuggling uneconomic as there is nowhere near the market for six-month old dogs that there is for puppies; and it would also make enforcement easier as spotting the difference between a young puppy and a six-month old dog is much easier than enforcing an import age of eight weeks.
• Better enforcement of border control checks, including spot checks out of office hours, is vital to root out illegally sourced animals entering the UK. If an enforcement presence is predictable in its timing and nature, it is naturally easier to avoid. There must be more vigorous checking at ports and stricter penalties for those found smuggling puppies, leading to prosecution.
• A requirement should be added for dogs to be treated against ticks before entering from the certain countries where specific tick-borne diseases such as babesiosis and ehrlichiosis are present, to help prevent the spread of these diseases.
• The number of dogs permitted to travel across international borders by non-commercial means should be reduced to three dogs per non-commercial vehicle rather than the current PETS standard of five dogs per person. This will allow for families to still travel with their pet whilst guarding against the smuggling of puppies and kittens under the guise of owned pets.
• Verification of the age of the animal being transported should be added to the border-checking process. For example, the age of a puppy can be indicated by the growth and size of their teeth. To facilitate this, a mandatory training programme for border control officials should be implemented. Animal welfare organisations would be happy to help with the provision of this training.
• More visual checks should be made of the conditions that animals travel in to help ensure that their health and welfare needs are being met.
• Increased transparency of both commercial and non-commercial pet importation data, to allow for increased traceability and identification of importation trends.

Equines:

9. What impact will the EU Animal Health Law have on the movement of equines between GB and the EU/NI from April 2021

Battersea as a dog and cat welfare organisation does not take a view on this question.

10. Will the rules and checks on the movement of equines be strong enough to prevent illegal activity? If not, what could be improved?

Battersea as a dog and cat welfare organisation does not take a view on this question.

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