Written evidence submitted by Countryside Alliance (MAAB0050)
March 2021
Summary
The Countryside Alliance is a membership-based organisation that works for everyone who loves the countryside and the rural way of life. We reflect the views and interests of 100,000 members and supporters who come from all walks of life and every part the United Kingdom.
The Countryside Alliance welcomes the EFRA Committee’s Inquiry into the movement of animals across borders, as Brexit has had a very significant impact on those movements from pets and equines to live exports for breeding. All these issues were raised with the UK Government during the Brexit negotiations, and the current problems should have been avoidable.
We have the unacceptable situation that in many of these areas those travelling to the UK face few, if any, additional hurdles, while UK citizens are faced with additional bureaucracy and costs. The pet passport scheme is a case in point. There is also the unacceptable situation for the movement of pets between Great Britain and Northern Ireland which are now subject to the same rules as pets travelling to the EU.
The question must be asked why the UK Government has failed to protect the interests of UK citizens where the movement of animals is concerned, while accepting the existing EU arrangements for those entering the UK. The pre-Brexit arrangements were understood, relatively light touch and inexpensive. Those arrangements should have been secured by mutual recognition between the UK and EU. A similar situation arises with the movement of firearms. People coming from the EU face no additional hurdles or costs from Brexit, while UK citizens are now forced to arrange import and export licences for each EU country they enter even if only transiting through that country.
The briefest look at the internet for guidance about movements shows how complex matters have become. The public are directed to Government websites which contain links to documents and guidance which are unclear, incomplete and often cross reference documents that are no longer current. We appreciate the vast scale of the adjustment being made across all sectors, but there are serious concerns about the movement of animals on the part of owners, fearing that movement will be refused at some point on a journey, including pets. There are also serious welfare implications for animal welfare in terms of longer journey times and journeys having to be aborted.
The Government must simplify all processes, remove the additional burdens on UK citizens through renewed negotiations with the EU. The situation in Northern Ireland as an integral part of the UK should also be a priority.
Response to Consultation Questions
1. Does the UK have sufficient resources and capacity to certify, record and inspect animal movements across its borders?
We believe that the UK does have resources and capacity as far as the movement of pets are concerned, although there is concern around the movement of equines.
For equines, we would like to draw the Committee’s attention to the submission from the British Horse Council (BHC) and note the issues around equine movements in the face of Brexit. There is widespread agreement that current paper-based systems are inefficient, slow and resource heavy. The Export Health Certificates are unduly lengthy (up to 40 pages per horse) and contain unnecessary content. BHC notes that there is no clear guidance for Official Veterinarians (OVs) completing an often confusing document. The documentation is taking OVs 1-3 hours to complete and even where clarification has been sought on areas of the forms where there has been uncertainty, some equines have still been turned away from Border Control Posts (BCPs) on the grounds that the documentation has not been correctly completed. There is concern that the substantial additional burdens could see some OVs unwilling to continue.
As the BHC notes, traceability is key and the Equine ID Regulations need updating including: identification of horses on digital smartphone apps to take precedence over paper documentation to ensure accuracy of data in the Central Equine Database (CED); and Application Programming Interfaces (APIs) between Export Health Certificates Online (EHCO) and Import of Products, Animals, Food and Feed System (IPAFFS) to the CED ( and other approved databases) to enable export health certificates to be created and submitted digitally with minimal effort and error.
It is also vital that GB BCPs receive sufficient funding to ensure the Animal Plant and Health Agency (APHA) is adequately staffed and trained and an appropriate number of BCPs, capable of inspecting and housing equines, are built and approved. There also need to be more BCPs approved.
2. How effectively will the UK be able to conduct animal disease surveillance and respond to outbreaks?
As the BHC notes, traceability is of vital importance and key will be ensuring traceability systems are put in place for High Health Horses which are accessible to competent authorities if necessary, or at least an agreement that information is shared by industry if equines pose a disease risk and are being transported back to Great Britain. It is regrettable that the UK no longer has access to the EU’s animal disease notification system (ADNS), which would allow for relevant information to be shared between the UK and EU Member States in the event of a disease outbreak, or suspicion of an outbreak. The Government should look to rectify this situation.
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 issues around the movement of animals that are not classified as pets, especially those used for breeding, even when not commercial, is a significant issue. We would note that working dogs, such as hounds, are frequently drafted to Ireland, to improve blood lines. Several Alliance members have contacted us having experience problems with moving animals both working dogs and breeding livestock.
The Government needs to look at the current arrangements for the movement of dogs, especially between the UK and Ireland, including Northern Ireland, and in particular the requirements regarding rabis and tapeworm. The UK and Ireland are both rabis free and this needs to be recognised both for movements between Great Britain and the island of Ireland, and by the EU. The current arrangements are unsatisfactory, unnecessarily burdensome and expensive.
There would also appear to be an issue with livestock exported for breeding. One Alliance member was refused the necessary Intra-Trade Animal Health Certificate (ITAHC)for live transport of high value breeding stock through the EU because the “steer from the Secretary of State & the CVO is to not actively encourage live animals exports specially where there are alternative invitro breeding methods available. We cannot therefore facilitate the export & strongly advise that it should not take place…” In this case invitro breeding was not a viable alternative. The impact of these sorts of decisions on trade and their economic consequences should not be underestimated. Live exports for breeding is, according the Defra’s recent consultation, to be an exemption to any ban on live exports. The lack of clarity, transparency, and certainty here is not acceptable and harmful to UK business.
The Alliance also understands from its members, and the BHC, that there has been an increase in delays and increased journey times for equines being exported from Great Britain to the EU, on occasion adding 12 hours to the journey. Given the Government’s laudable intention to keep live animal journeys to a minimum it is ironic that we are seeing increased journey times. We understand this results from the excessive length of the Export Health Certificates and the fact these are being checked by border officials page by page. The BHC has noted that the situation in Calais has been particularly problematic and there are also reports of horses being turned back from other BCPs such as Dublin. As the BHC point out the charges necessitated by the new ‘non-tariff barriers’ requirements mean that cost of moving a horse to the EU has increased, in some cases by more than 300%.
The duty to be paid on horses is particularly damaging to the equine trade. Those paying duty plus VAT can claim VAT back but only if they are VAT registered, which most private sellers and buyers are not. As an example, an Alliance member was planning a sale of a horse which involved the horse going from Devon to Ireland. Before Brexit this would have cost about £450 but would now cost around £3000 with duty and VAT. As a result, the purchaser decided not to proceed due to the prohibitive additional costs. The new situation risks destroying a vital part of equine trade between Ireland and the UK.
In addition, as with pet movements, there seems a willingness on the part of the UK Government to accept EU standards, without requiring an equivalent recognition from EU. For example, one transporter noted that the UK does not require additional blood tests for the import of horses to the UK, while the EU does insist on bloods for exports from the UK. Once again, the UK is placed at a disadvantage.
To assist equine movements and reduce negative animal welfare consequences associated with current problems the BHC has rightly suggested that there should be a clear timeboxed sequence for inspection of documentation and identification of horses, and central recording, on arrival at BCPs. Current Calais processing volumes are now proposed to be 10 horses per half an hour however this is not proving to be the case and capacity to process animals needs to improve. There should be longer opening times at Calais and new BCPs, which must have appropriate facilities and adequately trained staff not just in UK and France but across Europe. Live animals must also be prioritised at BCPs. Currently horseboxes line up in the same queues as all other vehicles carrying products of animal or plant origin. This is clearly not acceptable.
4. How should the Government balance animal health and welfare alongside economic interests?
The Alliance believes there should be no conflict between animal health and welfare and economic interests. Those transporting animals, whether equines, working dogs or livestock have no interest in those animals arriving in poor condition.
The current situation which is slowing and impeding the efficient movement of animals across borders, especially between Great Britain and Ireland (including Northern Ireland), is damaging economically, harming existing trade and markets and has a directly negative impact on welfare, with animals being in transit for longer. Get the processes right in welfare terms and there will be benefits in economic terms. Brexit should be an opportunity to advance animal welfare, not result in increased problems. The UK Government needs to work with the EU authorities to ensure that movement is as frictionless as possible and that the rules are applied evenly at all BCPs and understood by those on the ground. Unnecessary checks should be removed, and UK citizens not burdened with additional bureaucracy and costs that are not required of EU citizens.
We would support the view of the BHC that consideration should be given to a common veterinary area agreed between the EU and the UK, as this would overcome many of the barriers facing equine movement and the associated welfare implications. Such an agreement could cover the control of certain animal diseases and their notification; trade between Great Britain and the EU/NI in living animals for competition and breeding purposes; the import of these animals and products from other territories into the veterinary area and arrangements to keep standards aligned within the common veterinary area.
5. What impact will ending live animal exports for slaughter and fattening have on UK farmers, processors and other businesses?
As set out below, the Alliance would like to see any ban accompanied by a concerted effort to expand the number of small and medium sized abattoirs to reduce the distances animals travel for slaughter and reduce costs for farmers, while encouraging the growth of locally sourced food, including meat.
6. Does the UK have sufficient capacity to slaughter and process animals that are currently exported? If not, what could be improved?
We support the Government’s objective of slaughtering animals as close as possible to the point of production. One of the main obstacles to this has been the lack of abattoirs in the UK, particularly small and medium size facilities which play a pivotal role in the local food economy. They provide small scale slaughtering services to livestock farmers allowing them to participate in farmers’ markets, sell in local shops as well as their own farm shops, which all helps to reduce food miles.
There are a number of factors behind the decline in the number of small abattoirs but one of the main reasons has been the regulatory demands of the EU. Abattoirs have been subject to increasing regulation since the UK joined the Common/Single Market in 1973, particularly with the introduction of EU Directive 91/497/EC which imposed prohibitively expensive structural and procedural changes. Many smaller and medium sized facilities were unable to meet the costs involved and closed. Although the law has subsequently changed, abattoirs still face very high operating costs associated with regulation and this now also includes the cost of installing mandatory CCTV. Regulations are important but these must be streamlined to reduce the burden on businesses and leaving the EU provides the opportunity to do this.
Fewer, larger abattoirs mean that many animals have to be transported over greater distances for slaughter. Large parts of South East England are now devoid of abattoirs and, in some cases, travel to Europe may well be the best option for slaughter. If the Government does ban the export of live animals for slaughter, the Government should also explore options for how to use the opportunity of leaving the EU to support small abattoirs. The establishment of more small and medium sized facilities would be a more effective way of helping to reduce journey times from production to slaughter, rather than simply focusing on international transportation. As we noted in our response to the recent consultation on live exports the journey abroad can be significantly shorter than that within the UK.
We would also note that while there are few, if any equines, bred for slaughter in the UK, there is only one abattoir in Great Britain currently slaughtering equines (in any significant number). As the BHC has warned: “There will be an unintended consequence for equine welfare if, in the future, there are no slaughterhouses in Great Britain that take horses and we strongly suggest this is taken into consideration and that support is considered for small high-welfare slaughterhouse provision as a public good.”
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?
It is extraordinary that with the UK departure from the EU we now have a system that creates an inequality between the process by which EU citizens may bring pets into the UK and the situation facing UK citizens taking pets into the EU, including Northern Ireland. The UK has imposed no further conditions on those with a pet passport issued in the EU, while pet passports issued in UK are no longer valid for entry into EU, necessitating additional paperwork and costs, with each pet requiring an Animal Health Certificate (AHC) obtained from a vet.
This situation must be resolved with the EU authorities so that there is mutual recognition of a UK pet passport equivalent. Requiring an AHC for each animal for every journey should not be necessary.
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?
One issue of concern is the abuse of the EU pet passport scheme by EU puppy farmers. Anyone who has regularly used the pet passport scheme prior to Brexit cannot have failed to observe at BCPs, Calais in particular, large numbers of dogs of the same age (puppies), that are clearly not pets, being transported with pet passports. These are puppy farm operators who travel in groups whereby each person travelling has ‘ownership’ of the maximum number of dogs allowed per person under the pet passport scheme. The result is that large numbers of puppies are brought into the country as pets, but where they are in fact destined for sale as part of a commercial operation. This undermines the Government’s attempts to regulate dog breeding in the UK and ensure proper standards of breeding.
To give but one example, on one occasion puppies all the same age were seen being approved for travel who were, not only clearly too young, but imaginatively named by their ‘owner’ by letters of the alphabet. This individual was followed by another individual transporting further puppies in the same van, with each pup ‘named’ after a number. When concern was raised with officials, they said they knew what was going on but could do nothing to stop it as the paperwork was all duly stamped and in order.
The exploitation of the current rules by puppy farmers in the EU is widely recognised and the UK should review its procedures to try and eradicate this trade under the current pet transport arrangements, without making life yet more difficult for genuine pet owners. It is ironic that while the process for pet animal movements is more burdensome and costly to UK citizens, EU citizens, even those brazenly exploiting the system, face no additional checks. The Government should take the opportunity of Brexit to ensure the rules are not being exploited as is currently the case.
9. What impact will the EU Animal Health Law have on the movement of equines between GB and the EU/NI from April 2021
While generally supportive of the objectives of the new EU Animal Health Law, improving the protection of equines located in the EU from disease, we share the concerns of the BHC that before further requirements are imposed, the flaws in the existing system should be addressed, otherwise there is a real risk that the existing problems surrounding the movement of equines could be made worse. The BHC have also noted that the pandemic “has meant that the equine industry and competent authorities have been unable to prepare adequately for the full implementation of this legislation”. There would therefore seem to be good reason to delay the full implementation of the law.
10. Will the rules and checks on the movement of equines be strong enough to prevent illegal activity? If not, what could be improved?
Unless the rules and checks are applied consistently, there is scope for illegal activity, especially while BCPs are still getting procedures and infrastructure in place. All BCPs must apply the rules equally but also efficiently so as not to place unnecessary burdens on transporters or increase journey times unnecessarily. We would note that the BHC has pointed out the risk of certain BCPs being identified as ‘easy routes’ and that without consistency across all BCPs there is a risk of so-called ‘backdoors’ at those ports seen to be applying less rigorous checks.
March 2021
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