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Written Evidence Submitted by British Horse Council (MAAB0044)

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Written Evidence Submitted by British Horse Council (MAAB0044) Written evidence submitted by British Horse Council (MAAB0044) The British Horse Council is the channel through which all parts of the UK’s equine industry can join forces. Where consensus exists, the organisation engages with government and others for the benefit of the sector. Summary: Traceability of equines is key, including identification of horses on digital smartphone apps (distinct from smartcards) to take precedence over paper documentation. Digitalisation of systems and processes: APIs (Application Programming Interfaces) between Export Health Certificates Online and Import of products, animals, food and feed system (IPAFFS) to CED and other approved databases so that export health certificates can be created and submitted digitally with minimal effort and minimal error. A High Health Status should be introduced for appropriate groups of equines. Sufficient funding must be released to ensure an appropriate number of Border Control Posts, capable of inspecting and housing equines, are built and approved. This should include: Dover (ferry and tunnel), Holyhead, Portsmouth, Harwich, Fishguard, Hull and Harwich, as well as Cairnryan and Pembroke. To be effective rules and checks need to be applied consistently. Enforcement agencies also need to be given adequate resources and training, and collaboration between them needs to be improved. There are reports of journeys being increased by up to 12 hours due to delays at European BCPs. We propose: o Longer opening times at Calais port and new BCPs. o Animal welfare being given top priority at BCPs. Prioritisation for live animals over POAO and products containing plants. o BCP processing to be streamlined. o Clear timeboxed sequence for inspection of documentation and identification and central recording of horses on arrival at Border Control Posts (BCPs). o Improved capacity at Calais to process equines to enable the normal short straits transit volumes to be handled easily. 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%. This is an incentive for British competitors to relocate to the EU. The UK Parliament and Government should seriously consider a common veterinary area (CVA) between the EU and the UK, as this would overcome many of the barriers facing equine movement and the associated welfare implications. Ending live animal exports for slaughter and fattening should have no impact on UK businesses. We support equines being slaughtered as close to their point of origin as possible. It should be recognised that, of those licenced, there is only one equine slaughterhouse in Great Britain that is currently slaughtering equines (in any significant number). Support should be considered for small high-welfare slaughterhouse provision as a public good. 1. Does the UK have sufficient resources and capacity to certify, record and inspect animal movements across its borders? Current systems are paper-driven, inefficient, slow, resource heavy, expensive and environmentally unfriendly. British Horse Council welcomes the changes to the Export Health Certificates (EHCs), which are now in English and the language of the Border Control Post (BCP) at which consignments arrive in the EU (except The Netherlands, which will just be in English) – as opposed to multiple languages. However, they remain unduly onerous to complete as they contain unnecessary content. The time required to complete the current certificates, around 1-3 hours, is off-putting for Official Veterinarians (OVs) and we believe is leading to errors and rejections from French Border Control Posts upon pre-submission (72 hours before departure). The certificates also often require additional amendments upon signoff 12-24 hours before departure. This has led to increased costs and delays, sometimes of up to 3 days. This is immensely stressful for OVs as they are often caught between clients and the unclear and inconsistent requirements of EU BCPs. Furthermore, they often feel responsible for the welfare of the equines in question in a situation over which they have no control and are expected to certify documents in languages in which they are not fluent, where the meaning of the English text is open to interpretation or, where a typical English interpretation of the text does not align with the appropriate certification. It also has the additional consequence of OVs having less time to carry out their normal day to day work of treating horses and they cannot realistically charge for the time it takes for them to compete the paperwork. As such some are looking to relinquish OV status, which is likely to lead to an undersupply. We would therefore like to see current Export Health Certificates cropped immediately, leaving only the relevant pages. In addition, we have heard that the support that the OVs are receiving from the competent authorities and government agencies, including Defra and APHA – is often lacking due to shortage of resource, although we are hopeful that this appears to be improving. The situation is further complicated as BCPs also vary in the advice they are giving – meaning that what is acceptable to one, is not to another – and we have been told that this can even differ between officials at the same BCP. This results in paperwork not always being filled in ‘correctly’, as there is no consistency with regard to what BCPs accept. As outlined above this has led to delays, with the worst-case scenario that animals are being turned back from BCPS as the paperwork is not accepted, despite the OV having sought advice. Furthermore, there are currently no phytosanitary EHCs for hay and feed or feed components or supplements (chondroitin and glucosamine) meaning only small amounts can be carried for the journey, leading to increased risk of gut motility issues such as colic. Looking ahead, we would like England’s review of the equine identification Statutory Instrument 761 to include the following, many elements of which should urgently be brought to bear in negotiations prior to any new SI becoming law: 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. 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). APIs (Application Programming Interfaces) between Export Health Certificates Online and Import of products, animals, food and feed system (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. 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 that digital processes and systems need to be at the forefront in order to forge new Free Trade Agreements. 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. From a Border Control Post perspective, we appreciate that Larne does have facilities to unload animals, if necessary. However, this is not true for Belfast and we would prefer to see species- specific accommodation – meaning stabling for equines – built at both ports. Looking forward, we do have concerns that facilities have not started being built yet at ports in Great Britain and that APHA is not sufficiently staffed with trained personnel. We do not want to see the same situation that is occurring at Calais – with only small numbers of equines being processed daily1 and delays at the port due to lack of resources – occurring once animals have to be physically checked upon entry into Great Britain from March 2022 in line with the phased implementation of the Border Operating Model. Sufficient funding must be released to ensure APHA is adequately staffed and trained, and an appropriate number of Border Control Posts, capable of inspecting and housing equines, are built and approved. In consultation with shippers, we have collated a list of ports where BCPs could most beneficially be deployed, and this has been provided to the Defra policy team. The current list of BCPs proposed by Defra needs to be expanded to ensure inclusion of Dover (ferry and tunnel), Holyhead, Portsmouth, Harwich, Fishguard, Hull and Harwich, as well as Cairnryan and Pembroke. 2. How effectively will the UK be able to conduct animal disease surveillance and respond to outbreaks? The UK Government has introduced the IPAFFS system to ensure APHA is notified of imports of animals into Great Britain. However, if this system proves to be similar to TRACES, we question whether the information will be sufficiently
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