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Written Evidence Submitted by FOUR PAWS UK (Maab0032)

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Written Evidence Submitted by FOUR PAWS UK (Maab0032) Written Evidence submitted by FOUR PAWS UK (maab0032) Our responses: 1. Does the UK have sufficient resources and capacity to certify, record and inspect animal movements across its borders? We know the UK has a huge dependence on EU vets, so with Brexit may have a shortage of personnel within this profession, in general. Companion Animals: The enforcement of the legislation on commercial pet movement is largely the responsibility of Defra/APHA - with vets doing checks in border inspections. There seems to be not enough resources available to carry out the checks required. Additionally, there might be misuse happening through the PETS Scheme. It is questionable whether enough resources are available post Brexit, or if there are any plans to increase controls of companion animal movements. It has been demonstrated that puppy smugglers are able to easily circumvent UK border controls. Equines: Regarding equines, the current system is paper based, inefficient, slow and resource heavy. In addition, the Export Health Certificates contain unnecessary content. o No clear guidance for OVs for a confusing document containing unnecessary content. Taking OVs 1-3 hours to complete and even after sought clarification, some equines are still being turned away from BCPs as not been correctly filled in. o Concern this will encourage some to relinquish OV status. o However, pleased that steps are being taken to remedy this – documents are now in English and language of country entering EU via (not in multiple unnecessary languages). Traceability is key and update of Equine ID Regs. Including: o Identification of horses on digital smartphone apps (distinct from smartcards) to take precedence over paper documentation to ensure accuracy of data in the Central Equine Database (CED). o APIs (Application Programming Interfaces) between EHCO and IPAFFS to CED and other approved databases so that export health certificates can be created and submitted digitally with minimal effort and minimal error. This will improve the economic viability of producing transit documentation, enabling the equine transportation industry to remedy the unsustainable loss-making situation it is currently operating under. o Government funding to create these interfaces and pilot the process of Digital by Design and Digital First, supported by paper only where essential and during any transition. The principles of global trade indicate digital needs to be at the forefront in order to forge new Free Trade Agreements. o High Health Status for appropriate groups of horses, with a view to extending further in the future when individual equines become fully traceable and ‘high health status’ requirements can also be proven for ‘unregistered’ equines. We believe a High Health Status would better reflect the disease status of an equine, than the current categorisation of ‘unregistered’ and ‘registered’. The latter refers to equines which are registered with a recognised studbook but does not automatically mean that the equine is of a higher health status. o Ideally, the UK Government should work together with their Welsh and Scottish counterparts to ensure any changes are reflected in legislation across Great Britain and systems are integrated. Sufficient funding must be released to ensure APHA is adequately staffed and trained and an appropriate number of GB Border Control Posts, capable of inspecting and housing equines, are built and approved. 2. How effectively will the UK be able to conduct animal disease surveillance and respond to outbreaks? Companion Animals: Responding to disease outbreaks is closely linked to the traceability of diseased animals, both for commercially imported animals as well as for privately imported animals. The third-party sale of puppies for commercial breeders is banned in England (and Scotland and Wales are intending to bring forward the same legislation). The way the law is being interpreted is that someone in the UK can have a pet selling licence in place and import for commercial sale. As there is a considerable demand for puppies that likely cannot be met by domestic breeders, imports might increase. In general on inconsistencies between privately and commercially imported animals: “Inconsistencies documented in TRACES suggest discrepancies in the database recording procedures and highlights the system’s inability to trace dogs or explain the large discrepancy in the number of dogs estimated to be coming into the UK commercially and the number of dogs recorded”1. With Brexit animal imports will discontinue being notified through TRACES, but via IPAFFS2 (Import of products, animals, food and feed system). It is not clear to us whether IPAFFS is more secure and better than TRACES in tracing companion animals, after the animal was imported and sold, in case it turns out the pet is sick, and authorities would need to find out by the transponder or passport number who imported the animal, in which transport this animal was, and where other sick animals from the same transport or origin went to in the country. There is a clear need that all used transponder numbers, importer and breeder/exporter establishment registration numbers are reliable, and fake entries are not possible. To effectively trace diseased companion animals such as dogs and cats, FOUR PAWS recommends the pet be registered in the pet (microchip) registry along with involved stakeholders, starting with the breeder and the importer. Furthermore, the UK should demand a registration abroad for all imported animals. No animal should be imported without first being registered to an identifiable person abroad. This would help authorities to trace diseases, and to report potential sources of outbreaks also abroad. With the introduction of the EU Animal Health Law coming into effect in April 2021, tracing disease outbreaks will be further served, as each breeder/seller must be registered with their national competent authorities. A system whereby breeder/seller and pet microchipping databases are interconnected and accessible to authorities would quickly allow the tracing of disease origins for companion animals. The misuse of the pet passports (Pet Travel Scheme -PETS -intended for private pet movements) for the sake of importing animals for sale might remain, and so does the risk of importing diseases. Weak spots in EU law, namely the lack of a registration obligation of the animals’ origin, health status and ownership details in a national database, as well as the disproportionate reliance on the Pet Passport, facilitates the illegal trafficking of underaged, unvaccinated and often sick animals bred in poor conditions. If a pet passport is thrown away after a pet entered the country, it becomes very difficult or impossible to trace the animal back to its origins (and prevent further imports from that source) if there is no registration obligation across all of Europe, enforcing a 1 Maher, J. and Wyatt, T. 2019. Rural-urban dynamics in the UK illegal puppy trade: Trafficking and trade in ‘man’s best friend’ (2019) 2 (special issues on Rural Crime). International Journal of Rural Law and Policy, Article ID 6266, https://doi.org/10.5130/ijrlp.2.2019.6266 2 http://apha.defra.gov.uk/documents/bip/iin/bllv-5b.pdf registration on the breeder as the first owner, and listing all involved stakeholders such as chipping and registering vet, and consecutive owners. It is crucial, that all pet registries in the UK are EUROPETNET members, to ensure international traceability of the animals brought into the UK, through their publicly accessible search function. If no registration data is available, a complicated search would need to be started through the manufacturers of the transponders, to whom the transponders were sold to, which might not result in needed information. To our knowledge about TRACES needs to overcome several flaws. Ideally IPAFFS is safer and allows for a posteriori tracing of the imported companion animals. Regarding TRACES, there were cases reported where unregistered breeders used TRACES by entering fake registration numbers, and also the transponder numbers of the animals seem not to be verified, e.g. if they are ISO conforming. The original source of an animal could also be hidden, if the travel was split into various parts. Destinations could be filled out, and the system did not check whether this consignee is registered or approved by the competent Member State to receive live animals. To our knowledge, at this moment, to trace dog and cat movements, you can only search on TRACES number. This means that a posteriori tracing is not possible, if you cannot search for a transponder code or a passport number. Equines: Regarding equines, traceability is very important. First step should be ensuring traceability systems that are put in place for High Health Horses 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. We are concerned 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. 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? Companion animals: The UK was granted Part 2 listed status by the European Commission under the bloc's pet travel scheme, which means that the EU pet passport is not valid anymore, when travelling with a pet from Great Britain to Northern Ireland or to the EU. The dog needs to have a rabies vaccination followed by a 21-day waiting period, a recent tapeworm treatment and a veterinarian needs to issue an animal health certificate (AHC), no more than 10 days before travel to the EU. It is understood that pets entering Great Britain from the EU from 1 January 2021 need to either have an EU Pet passport, or the animal health certificate (AHC) issued in GB used to travel to the EU – which you can use to re- enter GB for up to 4 months after it was issued, or a GB pet health certificate (for travel into GB only).
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