
Written evidence submitted by the NFU (MAAB0057)
Summary
- The direct export of UK live farm animals (cattle, sheep, pigs and goats) is currently not possible to the EU mainland because there are no EU Border Control Posts (BCPs) approved for, or accepting, live farm animals at any UK facing port along the north European coast.
- Potential investors in establishment of EU BCP facilities were alarmed when the UK Government published its recent consultation on live animal welfare in transit, which included proposals to ban the export of live animals for slaughter. The UK Government should make a clear public statement on the future of exports of live farm animals for breeding which would give confidence to European investors and breeding companies alike.
- The Northern Irish Protocol treats GB animals imported into NI as imports from third countries and so full EU SPS rules apply to movements between GB and NI. This places multiple costly and impractical new requirements on traders, including lengthy residency requirements, new counter-intuitive animal ID obligations and costly animal disease surveillance and evidence demands. We believe the government’s Movement Assistance Scheme (MAS) should be expanded to cover the cost of meeting other new requirements now necessary for trading between GB and NI, for example the cost of scrapie genotype testing
- We believe government should monitor whether its Animal & Plant Health Agency (APHA) has sufficient resources for issuing export health certificates given that they have a workload that broaches business as usual exports, avian influenza and now certification for the EU. The NFU echoes the concern about official vet (OV) availability which has been expressed by other industry bodies. Whilst we welcome the efforts made by government to expand the number of OVs and support the introduction of the Certification Support Officer (CSO) role to help OVs in their work, this issue remains an area of concern. It is widely reported that export trade is significantly reduced compared to previous years, meaning that vet capacity may not have been truly tested.
- Diseases do not respect political borders. To protect animal health, animal welfare and public health, reciprocal surveillance data sharing with Europe and internationally is vital. The EU-UK TCA does not provide means by which the UK can continue to access the EU’s system of animal disease notification surveillance, which is to detriment of both the UK and the EU; we encourage both Parties to make every effort to establish sharing protocols.
- The EU/UK Trade and Cooperation Agreement (TCA) foresees the establishment of a Specialist Trade Committee on SPS matters. This should be convened as soon as possible. This would allow for greater cooperation between both parties on border issues. Stakeholder organisations, such as NFU, should have access to this Committee
- The reality is that since the end of the transition period and until such time as the UK Parliament or the EU institutions decide to legislate change, the UK rule book will continue to be aligned to those of the EU. We urge the UK and EU to recognise this unique starting point that exists between both parties and commit to keeping friction as minimal as possible by negotiating advanced equivalence mechanisms that allows for the recognition of each other’s standards to keep trade flowing as freely as possible from administrative burdens.
Introduction
- The NFU welcomes the opportunity to provide written evidence to the EFRA Committee inquiry: Moving animals across borders. The NFU represents 55,000 members across England and Wales. In addition, we have 20,000 NFU Countryside members with an interest in farming and rural life.
- The NFU is pleased that the UK has successfully maintained duty free access to the EU market as part of the EU-UK Trade and Cooperation Agreement (TCA). The (TCA) ensures there are no tariffs and quota free access between UK and EU markets, subject to Rules of Origin requirements. Under the TCA only ‘wholly originating’ goods – in this case animals that are born and reared in the UK – will benefit from tariff free access.
- The UK is now outside of the Single Market and the TCA allows for the UK and EU to develop independent Sanitary and Phytosanitary (SPS) rules protecting human, animal and plant health, while also aiming to limit barriers to trade. There is a phased approach to increasing SPS controls for imported animals at the UK border. To be clear, there is no phased approach on the EU side and full third country rules have applied since 1st January 2021. In practical terms SPS controls on our exports entail Export Health Certificates (EHCs); prenotification at borders; and border checks, the frequency of which is set in EU law as 100% for live animals.
Question 1. Does the UK have sufficient resources and capacity to certify, record and inspect animal movements across its borders?
- Now the UK is outside of the Single Market all exports of live animals to the EU or movement to Northern Ireland require consignments to be accompanied by an EHC signed by an Official Veterinarian (OV). The OV stamp and signature attests that relevant EU rules on public health, animal health and animal welfare requirements have been met. The EHC must accompany the consignment of live animals which must enter the EU via a Border Control Post (BCP) for documentary, identity, and physical checks by EU OVs. Exports of UK live farm animals (cattle, sheep, pigs and goats), whether for breeding or slaughter, are currently not possible to the EU mainland because there are no EU BCPs approved for, or accepting, that category of goods at any port along the north European coast. This means since the 1st January 2021, the UK has effectively been faced with a trade embargo on its live animal exports to the EU mainland. This issue is covered in more depth in our answer to question 3.
- There are facilities in place at the EU border to accept UK exports of breeding chicks. Although small volumes, these exports are significant in value and the UK is one of the leading exporters of poultry genetics and breeding stock. It is possible for these chicks to be flown out by charter flight, but this is cost-prohibitive and would only be considered as a last resort. For example, we understand that due to welfare concerns, day old chicks were flown out to avoid the long queues and disruption at the border before Christmas.
- The UK is taking a phased approach to introducing controls on imports to the UK from the EU. From 1st January live farm animals imported from the EU have been required to travel with an EHC approved by an OV in the exporting EU country. The importer must pre-notify the movement via the UK Import of Products, Animals, Food and Feed System (IPAFFS) at least one working day before the expected time of arrival at the point of entry. Documentary checks will occur remotely, and identity and physical checks on live animals will be undertaken at the point of destination on a risk-led basis. Originally it was proposed that from 1st July 2021 there would be a requirement for live farm animals to enter the UK through a BCP and at this point, physical checks would move to taking place at the border. However, on 11th March the government confirmed in a written ministerial statement that this requirement would be delayed until 1st March 2022.
- This delay in implementing the requirement for imported live animals to enter the UK through a BCP presents a pragmatic solution, given the necessary infrastructure at UK ports will not be ready for the original deadline of 1st July 2021. The NFU understands that in terms of channel facing facilities, there are plans for government to support (both operationally and financially) the build of new BCPs at Sevington for Eurotunnel and Dover White Cliffs for short straights RoRo crossings. However, these facilities are still in construction. There is also interest from the operators of Portsmouth in building BCP facilities and we have been supporting their application for the necessary grant funding of c. £5 million that they require. We believe there is merit in having a further facility beyond the two facilities proposed in Kent by government and Portsmouth is well placed geographically to offer an alternative.
- It is vital these UK BCP facilities for live animals are built and operational by the new deadline of 1st March 2022. There is a risk that animals imported into the country bring disease or pests with them. Checking this at, or very close to, the border rather than at place of destination removes the risk of inadvertently bringing those threats far in-country.
- Genetics make an important contribution to the UK livestock sector in driving productivity and sustainability gains. All of which plays an important role in ensuring UK livestock farmers not only continue their role as food producers, but also meet the NFU’s ambition to reach net zero carbon emissions by 2040. Genetics is a global business and without the infrastructure and resources in place at the border to allow the importation of high-quality breeding animals there will be a net loss for both farmers and society alike.
- It is essential that there are adequate resources in-country and at the border to ensure the necessary formalities and checks are carried out in a timely manner. This includes veterinary staff but also adequate customs officials and intermediary customs agents to help navigate complex customs rules. APHA resourcing must be considered as part of this. We believe government should monitor whether APHA has sufficient resources for issuing of export certificates given that they have a workload that broaches business as usual exports, avian influenza and now certification for the EU.
- The NFU echoes the concern about vet availability which has been expressed by other industry bodies. Whilst we welcome the efforts made by government to expand the number of OVs and support the introduction of the Certification Support Officer (CSO) role to help OVs in their work, this issue remains an area of concern. It is widely reported that export trade is reduced compared to previous years, meaning that vet capacity may not have been truly tested. On 21st April there will be changes to the EHCs required for EU trade and new EHCs introduced for a wider range of products (e.g. EHCs will now be required for a wider range of composite products) as a result of the implementation of the new EU Animal Health Law. We do not yet know what the new EHCs will look like nor do we know the time it will take to complete. However, we do know that EHCs for composite products take longer to complete due to the complexity of the supply chains involved, putting further pressure on availability of resource and increasing the cost of certification.
- Since the end of the transition period, the EU no longer accepts Transporter Authorisation, Certificates of Competence or Vehicle Approval Certificates issued by a UK authority and viceversa. GB issued Transporter Authorisations, Certificates of Competence, and Vehicle Approval Certificates continue to be valid for use in Northern Ireland. In January we did see confusion from hauliers about the certification required and some certification bodies were unprepared for the new requirements. These “teething problems” have now been resolved and after a short term hiatus, import trade has started to happen again.
- For any animals completing a journey of over 8 hours between the EU and GB in connection with an economic activity, a Journey Log is also required. Since 1st January 2021 Journey Logs approved by the EU authorities are not accepted in GB and vice versa. Hence, a separate Journey Log approved by GB authorities is needed for travel in GB. This therefore means that two Journey Logs are required to cover the entire journey, one issued by the competent authority in the EU member state of origin / destination and another from APHA to cover the GB leg of the journey. This duplication creates an extra administrative burden and adds extra cost to the movement of live animals between GB and the EU, for both traders and government alike.
Question 2. How effectively will the UK be able to conduct animal disease surveillance and respond to outbreaks?
- Diseases do not respect national borders. To protect animal health, animal welfare, public health and to ensure trade, mutual sharing of surveillance data with Europe and internationally must be maintained, and the UK must maintain effective and adequately resourced systems for detecting new and emerging diseases. Structures should be put in place to ensure ongoing cooperation and collaboration with the EU in this context. This will be particularly important with respect to Northern Ireland which will continue to share a land border with the EU. It is worth noting that it is thanks to North-South cooperation the island of Ireland can be treated in policy and operational terms as a single epidemiological unit for the purposes of animal health and welfare.
- The UK continues to have access to the OIE International surveillance system and alerts through the World Animal Health Information System, better known as WAHIS, an internet-based computer system that processes data on animal diseases in real-time and then informs the international community. The Animal Disease Notification System (ADNS) is an EU notification system designed to register and document the evolution of the situation of important infectious animal diseases. The system permits immediate access to information about contagious animal disease outbreaks and ensures implementation of early warning which enables for a prompt response for controlling the epidemiological situation. This has a direct impact on trade of live animals and their products both for the internal market as well as for international trade with third countries. ADNS is quicker and more detailed than WAHIS, but only reports incursions and outbreaks in member countries. In this respect, despite ADNS being an EU system, it is possible for it to be accessed by those outside of EU membership as is the case for Turkey, Switzerland and Norway at present. The EU-UK TCA does not provide means by which the UK can continue to access ADNS but this is something we encourage both Parties to explore as a matter of priority.
- The loss of access to ADNS has already been acutely felt in the UK poultry sector, as its loss occurred part way through the most serious winter outbreak of Avian Influenza (AI) since 2016/17. To date, this season the UK has recorded 19 outbreaks of AI in commercial farms and over 300 outbreaks in wild birds. Since 1st January, the UK has only received information on outbreaks across the EU and the rest of the world because of good bilateral links within APHA to other countries. The OIE website we mention above has been down for several days during the outbreak leaving a gap in the information available. The UK needs access to this data to monitor the spread of the disease, this is especially important for AI where the migration of wild birds from the continent to the UK is seen as a key factor influencing the spread of disease. This information all feeds into the assessment of risk levels in the UK which influences national control measures such as the housing order (a requirement to keep all free-range birds indoors) which is currently in place. It is vital that this risk assessment makes use of the best available data and is kept under regular review as its implications can have severe consequences for the UK poultry industry. For example, if the current housing order extends past the 4th April, UK eggs could no longer be marketed as free range.
- Since the end of the transition period the UK must apply to the EU for recognition of regionalisation. This means only areas immediately around premises infected with AI are unable to export poultry products such as meat and breeding chicks to the EU. Without regionalisation the ban would apply to the whole of the UK. Each time a new case is declared, the UK must apply to the European Commission and member states must vote in the relevant standing committee on the declared regionalisation. Delays to this process has caused several days of significant disruption to the export of breeding chicks to the EU.
- The NFU also raises concern about the speed at which the UK is able to respond to outbreaks of disease in Northern Ireland. We understand that when two outbreaks of AI were suspected in Northern Ireland the samples had to be sent to Italy to be tested, because APHA facilities in England (Weybridge) were no longer approved as an EU testing lab. In this example, samples were sent to both Italian facilities and Weybridge and we understand that Weybridge was able to confirm the presence of the disease 48 hours earlier, partly because of the logistics involved with getting a sample from Northern Ireland to Italy. Whilst temporary restrictions were imposed on the two sites as soon as disease was suspected, we question why the UK would not want to work with the EU to ensure outbreaks of disease can be identified and confirmed as quickly as possible.
- Movement of animals, semen and embryos within the EU is facilitated by the Trade Control and Expert System (TRACES) system. The possibility to trace back and forth all the movements of animals, semen and embryo, food, feed and plants contributes to the reduction of the impact of disease outbreaks and brings a quick response to any sanitary alert, for the better protection of consumers, livestock and plants. Since the end of the transition period the UK has lost access to TRACES and instead, created its own system IPAFFS, to deal with the importation of live animals alongside other regulated products. The NFU recognises that there are concerns within the veterinary profession about losing access to these EU surveillance systems and the harm that could arise without vital surveillance data, analysis and notifications.
Question 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 implementation of the Northern Ireland Protocol and specifically the measures related to the agri-food sector has generated significant interest and concern at the political level. In addition to the well documented concerns that relate to the supply of food to retail outlets in Northern Ireland from GB, there have been issues identified which effect the trade in live animals between GB and NI. We believe that every step should be taken to protect a well-functioning single market for animals and breeding material throughout the UK, whilst also acknowledging the need to avoid a hard border on the island of Ireland.
- The Northern Irish Protocol treats GB animals imported into NI as imports from third countries, hence EU SPS rules apply. This places new requirements on traders as follows:
- Residency requirements - animals required to be resident in the territory of the third country (i.e. GB) 6 months prior to export to the EU and they must be resident on a GB holding for 40 days immediately prior to export. Movement through a livestock markets restarts the 40-day residency period, which is an issue as the majority of UK breeding stock destined for NI will move through a GB auction mart.
- Animal ID - animals have to be tagged with a GB export tag (UK domestic tags use UK as an identifier and EU requires third country animals to be identified by their ISO code which is GB) and on arrival in NI animals must be retagged with an NI tag
- New animal health requirements for specific species e.g. scrapie requirement as detailed below.
- In addition to the current requirement for a maeda visna (MV) test at 12 months, a scrapie attestation is required for the EHC which must accompany sheep moving from GB to NI. This is an EU requirement for importation of sheep from third countries. There are two options the UK can take to comply with this:
- One option would require sheep to be Scrapie monitored or genotyped but because of the cost of testing (c.£30 head) it would be uneconomical and would stop the commercial breeding stock trade between GB and NI, bar a small number of high value animals. Many of the hill breeds (which make up a substantial proportion of the current trade) would also fail this genotyping test.
- The other option is for sheep to be part of the Scrapie Monitoring Scheme – this takes 3 years to get below the critical risk level and 7 years to get to negligible risk, so not a short-term solution.
- On average around 9,000 breeding sheep are imported into NI from GB per annum and information supplied from the Ulster Farmers Union, suggests that there have been higher numbers bought in the autumn of 2020 which means 2021 trade could be up. The sheep could not be brought into NI ahead of the end of the transition period, as the sheep need to be at least one year old to be able to travel and have their MV test. Normally, NI farmers buy ewe lambs in the autumn and pay the GB farmer to keep them until they are old enough to travel, usually the following year. The NFU understands that the UK sought a 7-year derogation for breeding stock for the scrapie testing requirements, but this was turned down by the EU. Ideally the derogation would be for any breeding sheep moving to the EU from GB, but in the absence of this GB–NI movements would suffice.
- These new requirements make the export of live farm animals (cattle and sheep) from GB to NI a very difficult and costly exercise, which will largely curtail trade. It is important to note that these rules also apply to animals being moved for show and sale. Effectively the shop window for NI pedigree breeders has been blocked, as animals cannot be taken to mainland GB to be shown and then return home to NI. If an animal is taken to mainland GB to be sold and is not, that animal has to complete a 6-month residency in GB and has to be re tagged to be brought back into NI. This is not a workable situation and the long-term damage will not only affect the pedigree sector but eventually will affect the availability and quality of the genetics of NI livestock. The NFU believes the UK Government should re-double its efforts and continue discussions with the EU, to ensure farmers in both GB and NI are able to continue this centuries old trade in live animals.
- NFU poultry members also report issues sending pullets (young birds of between 16 - 20 weeks of age) to NI from GB. Live birds imported into NI from GB must meet EU third country rules and whilst solutions have been found to allow the trade in day old chicks to continue, this is not the case for pullets which are classified as adult birds. According to EU rules, the birds from GB must have been reared on farms which are members of the UK poultry health scheme. However, the requirements of the poultry health scheme mean it is not set up to cover commercial rearing farms. For example, these adult birds will have been vaccinated for salmonella meaning the salmonella blood tests which are required will come back positive as antibodies are found. The UK Government should work with the EU to find a solution because as it stands, this trade will become unviable.
- The Trader Support Scheme (TSS) and Movement Assistance Scheme (MAS) have been helpful additions to the support provided to the industry for movements of goods to NI. MAS is in place to assist with the paperwork and cost of exporting agri-food goods, including live animals, to Northern Ireland. However, we understand from colleagues in the veterinary industry that the scheme does not cover the true cost of certification. We are concerned that if this financial shortfall continues, OVs will look to undertake other operations or will move from certifying exports for the NI market to certifying exports for the EU market, where they can recover the true cost. We also believe MAS should be expanded to cover the cost of meeting other new requirements now necessary for trading between GB and NI. For example it could cover the cost of scrapie genotype testing as discussed in paragraph 26. Northern Ireland remains an integral part of the UK market and the NFU believes the government should ensure GB businesses are not disadvantaged when undertaking what is an intra-UK movement.
- Since 1st January 2021 there has been significant changes to the way live animals are traded between the EU and the UK. Live animals moving from GB to the EU will need to enter the EU via an appropriately designated BCP for the animals to be checked. There are currently no BCPs authorised to accept live farm animals (cattle, sheep, goats and pigs) whether for breeding or fattening in channel facing ports in France, Belgium or the Netherlands. The trade in live animals for breeding is an important and valuable one, with UK genetics in high demand. This means that since 1st January this trade has ceased. The NFU has been working to make the commercial case to ports operators to encourage them to invest in facilities with some success. Any potential investors in the EU were alarmed when the UK Government published its recent consultation on live animal welfare in transit, which included proposals to ban the export of live animals for slaughter. The UK Government should make a clear public statement on the future of exports of live farm animals for breeding which would give confidence to European investors and breeding companies alike.
- We understand through contact with livestock companies in France that a suitable potential facility for a BCP near Calais has been identified. It is possible under EU regulations for a BCP to be located outside of the curtilage of the port provided it is within a reasonable distance. New facilities must also be inspected and approved by national authorities and the Commission. In this context, the NFU requests the UK government to undertake significant government-to-government contact to help expedite the necessary processes and to bring all interested parties round one table.
- Export data in the appendix of this submission provides numbers of consignments and animals exported from the UK to EU seaports. The value of this livestock is hard to determine but reports from the National Beef Association, National Sheep Association and UK dairy breed societies put a value on the import and export trade to be in excess on £20m per annum with breeding rams typically valued at £1,000 head and beef and dairy breeding females typically valued at £2,000 to £4,000 per head.
- Although there is currently a hiatus in the export of live farm animals to mainland EU, it is worth noting that currently EHCs need to be manually filled in by an OV. This can require versions in two or more languages with the same boxes filled/ translated (English, the language of 1st point of arrival and the language of final destination). We understand that this means a single EHC can take at the minimum 30 minutes to fill out. Although related to a movement of meat as opposed to live animals, we know of one example of a vet needing to stamp paperwork 72 times for one consignment. This is very onerous for the limited number of Official Vets (OVs) and adds costs to the export process. A fully digital system should be developed in conjunction with the EU to future proof the system of exporting and importing and to reduce the administrative burden placed on businesses.
- The TCA allows for the UK and EU to develop independent SPS rules protecting human, animal and plant health, while also aiming to limit barriers to trade. This includes regular, joint reviews of the SPS border controls on each side to seek further steps to facilitate trade without compromising on biosecurity. The committee structure under the TCA on SPS matters should be established as a matter of urgency. This would allow for greater cooperation between both parties on border issues. The reality is that since the end of the transition period and until such time as the UK Parliament or the EU institutions decide to legislate change, the UK rule book will continue to be aligned to those of the EU. We urge the UK and EU to recognise this unique starting point that exists between both parties by negotiating advanced equivalence mechanisms that allows for the recognition of each other’s standards to keep trade flowing as freely as possible from administrative burdens.
- Other countries have negotiated ‘mutual recognition’ and ‘equivalence agreements’ with the EU, for example the New Zealand veterinary agreement, the Swiss Veterinary Agreement and equivalence mechanisms under the Canada – EU deal (CETA). These countries have negotiated outcomes to assist with trade flows. Although it should be noted that for some of these, such as the EFTA countries, this lack of friction at the border comes at the cost of alignment with EU regulation. The UK is unique compared to most other countries trading with the EU market, in the sense that we are trading with our closest neighbours and at least for the time being remain aligned in practice with EU rules. The UK should seek to continue negotiations with the EU to simplify and streamline border procedures, and ensure that the unique nature and special starting point (i.e. regulatory alignment) is taken into consideration when developing mutually beneficial systems for both EU and UK exporters.
Question 4. How should the Government balance animal health and welfare alongside economic interests?
- Animal health and welfare is a top priority for British farmers, and it is recognised that we have some of the highest standards globally. We do not place economic impacts above animal welfare but would urge the government to be mindful of the animal welfare challenges that can occur when farming business and supply chains are impacted by external factors such as exotic disease restrictions and extreme weather incidents.
- There is a real opportunity for the UK to become a global leader in agri-food standards through its trade policy. It will require effective mechanisms to appropriately price in externalities such as environmental impact, worker rights and animal welfare – and there should be an ongoing debate about what other policy aspirations need also to be accommodated. One of the challenges for post-coronavirus economies will be to build back better, to ensure our models of production and consumption are environmentally, socially and economically sustainable. This must be driven by quality data which supports domestic ambitions and global comparisons, thus helping the advancement of global standards.
- The UK is in a unique position in developing a new, independent trade policy and is therefore well placed to ensure that this policy is innovative and fits contemporary needs, rather than being rooted in outdated principles of free trade. The UK Government should be proud of what UK agriculture has delivered in terms of efficient production which balances affordability with high production and safety standards, and should therefore take every step to protect these standards. In doing so the UK will not only secure the future of our domestic agricultural sector, but also help level up global agri-food standards and develop new markets for our producers.
Question 5. What impact will ending live animal exports for slaughter and fattening have on UK farmers, processors and other businesses?
- We are aware of the Conservative Party’s manifesto commitment and recent Ministerial statements to ban live exports for slaughter and further fattening. The trade in live animals is an established practice, albeit at much lower volumes in recent years as we export more product as whole and part carcasses and cuts of meat. This approach retains value in the UK processing sector and is an efficient way of exporting our product to international customers. The NFU wishes to ensure that balance and freedom in the marketplace is maintained, and live exports could continue to provide an additional marketing option for producers, especially at times of peak supply. With processor and wider supply chain consolidation seen in recent years due to a greater reliance on the UK retail sector, we must ensure we maintain as many marketing options as possible.
- It should not matter whether the movement is for domestic or export purposes; standards of transportation should be the same for all animals and should also apply equally to breeding, fattening or slaughter animals, in line with current legislation. Animal health and welfare standards must be met for the entirety of the journey whether in this country or abroad, which are still linked by shared application of EU Regulation 1/2005 for transport welfare.
- We believe that the current transport regulations are robust and based on sound and relevant science. Government must address any non-compliance issues with the appropriate authorities to ensure robust enforcement is applied. The NFU believes that the welfare of animals during transport can be maintained through measures such as a code of practice or an assurance scheme which all exporters would have to comply with, setting minimum standards for the transport of animals to be exported for slaughter or fattening. The NFU has urged government to reconsider its proposal and to work with the industry to develop a suitable assurance scheme to ensure the welfare of animals throughout their journey to enable this trade to continue, whilst at the same time ensuring that high standards of welfare are maintained.
- The government’s transport proposals discriminate against English and Welsh producers and presents unintended consequences, since the consultation does not directly include Scotland and Northern Ireland. An impact assessment is required to quantify the scale of this and the potential for unintended welfare consequences for animals.
- The UK is a net exporter of lamb and in 2019, circa 30% of UK lamb produced was exported to the EU. We are concerned about the financial impact of retaining lambs on the UK market that would previously have been exported. The recent Defra consultation on animal transport did try to model this impact and suggested a cost to industry of £55.3m over 10 years. However, it is worth noting that in the NFU’s response to the consultation we did raise significant questions about the modelling and believe that the true cost could be much higher.
- As noted throughout this evidence, currently there are no EU mainland BCPs or UK BCPs in place to facilitate trade in live animals between the EU mainland and the UK. This means the UK is currently unable to export live animals to the EU until such facilities are in place at UK facing ports. Whilst steps are being taken to try and put the necessary facilities in place it should be noted, they are unlikely to be on routes which will accommodate chartered vessels such as the MV Joline (which is the vessel often used for export of live animals currently). Ultimately, regardless of decisions made by UK Government this will effectively remove all feasible options for live animals to be exported to the EU for slaughter and further fattening / rearing.
Question 6. Does the UK have sufficient capacity to slaughter and process animals that are currently exported? If not, what could be improved?
- The Farm Animal Welfare Committee (FAWC) recommended an assessment of UK abattoir provision and capacity, which has already been scrutinised by the All-Parliamentary Animal Welfare Group report (APAGW) of 2020. Any review would, we assume, look again at the abattoirs’ location, capacity and proximity to areas of production. The UK supply chain is now dependent on aligned supply contracts with UK supermarkets. This lower cost integrated model has become the norm for domestic retail which has resulted in an increase in the average journey time and a much greater reliance on collection centres and multiple pickups for cattle and sheep destined for slaughter.
- The number of abattoirs in the UK has reduced overall because of the economies of scale and the challenges posed by the necessary regulation and cost of compliance. It is recognised that larger abattoirs can, and do, provide many additional requirements that support health and welfare along the supply chain from farm through to slaughter. Many smaller abattoirs have found it difficult to invest in the structural requirements needed to maintain and meet the baseline legislative standards. It is incorrect to say that animals sent for export have passed suitable abattoirs on route. Simply slaughtering the right species does not confer ability or commercial viability, but also could limit competition. Many small, low throughput abattoirs are struggling to survive, partly because of the centralised nature of food production, lessening demand from the butchery businesses and small-scale producers they supply (as supported by APAWG report findings).
- The Government should review the findings of the APAGW 2020 report and conduct a UK-wide assessment of abattoir provision and capacity to ensure there are no adverse impacts on the welfare of animals during transport, at slaughter, or on-farm if accessing slaughter facilities in a timely fashion becomes a challenge.
Appendix
Table 1: Export data from APHA (2017 – 2019)


