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 accurate to trace an animal in the event of an outbreak.
In the longer term, full, digitalised traceability of equines will provide much greater assurance from a biosecurity perspective and allow for any potential outbreaks to be dealt with quickly. This includes real time tracking of equine movements from arrival at BCPs and between registered premises2. In the long term, we would like to see this integrated with all systems and databases relating to equine traceability, both throughout the UK and with key trading partners. For example, this would give greater certainty in tracing equines in the face of a disease outbreak, such as the recent Equine
1 In January and February 2021, movement figures obtained from a sample of large equine transporters indicate that volumes of movements were in the region of 33% of the normal volumes at that time of year. 2 Meaning registered on a central database accessible to the competent authority and enforcement agencies. Thoroughbred premises – breeding and racing – are registered with the governing body of the sport. Herpes Virus outbreak in Valencia. Whilst the FEI have mechanisms in place to prevent the spread of disease and ensure the animals in question receive treatment in situations like this, in this instance we understand that some equines moved off the premises before the outbreak was confirmed. FEI is working with competent authorities to identify these equines and ensure correct procedures are put in place to contain the virus and we would urge that this should be the norm for any potential disease risk, however small. We recognise that FEI equines and racehorses being transported to competition are, in general, more traceable than other equines, and if they pose a non-notifiable disease risk then the FEI and racing regulators can prevent them competing. However, unless competent authorities are given access to FEI or Weatherbys’ systems, or relevant information is shared, then these equines could return home (including to Great Britain) and interact with other equines without appropriate procedures being put in place. Furthermore, we are also aware that equines are often transported to these events which are not registered to take part (for example, youngsters whose owners want them to have exposure to large events before they compete) and these may be harder to trace, although the new EU Animal Health Law requirements may go some way to addressing this. In addition, infected equines will have rested at premises when being transported to and from the event, and if these are shared premises and/or are not properly disinfected between occupants then the disease could be unknowingly spread. As already suggested, a first step could be for traceability systems that are put in place for High Health Horses to be 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. If, as we recommend, digital traceability becomes a requirement, we would like to be actively involved from first principles in the cocreation of systems to ensure that they are fit for purpose.
While the industry has systems in place to obtain, collate and distribute information on equine disease outbreaks, such as the International Collating Centre, 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. We would urge that discussion is held between the UK and the EU to determine whether the UK could regain access to this system.
The Animal Health & Welfare Board for England’s Health & Welfare Pathway is currently being developed by the equine sector and, of the four key pillars it contains, two are Better Health and Better Future. To enable industry to be able to manage its own concerns, certain enablers are required of government first. For example, the current outbreak of EHV-1 will need to be managed by industry since it is not a notifiable disease. In order to do this, investment in digital traceability, inclusion of equine premises location and movements tracing would be something government could effect, both under the Pathway and within the revised equine identification statutory instrument review, in order for industry to be empowered to take responsibility. Enabling robust surveillance and mandating a minimum standard of biosecurity measured between hired facility occupants would go a long way to achieving this.
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?
Delays and increased journey time
There are significant implications for the equine sector of the new UK-EU agreement, which are already being seen. Some of these will be more challenging to resolve than others. A barrier that we anticipate will be fairly simple to resolve is that there is currently confusion and uncertainty as to where the ATA Carnets need to be stamped prior to departure. Is it STOP24, Manston or Dover Port? We are hopeful that we will receive clarity on this quickly. This does, however, further highlight the general confusion around the new requirements that have been brought in, the need for training of officials, and the lack of clear direction coming from relevant authorities to those involved in moving equines between the EU – GB – NI.
More challenging are the delays facing equines moving into the EU – particularly via Calais. Further BCPs have been approved at ports in France and one is due to be approved in The Netherlands (Rotterdam). Most movement from GB to Continental Europe via ferry continue to be over the short straits or via Eurotunnel (at time of submission).
Despite the majority of equine movements from GB to continental Europe being via Calais, the port is not sufficiently resourced or appropriately structured to meet the demand. Current reported wait times are typically 4-5 hours but can be up to 10 hours. On top of already long journeys, these avoidable delays are a risk to equine welfare. We believe that the unnecessarily long and complicated EHCs play a significant role in this delay, with each page being checked thoroughly by officials at Calais. Volumes of movements are currently low compared to average movement data for this time of year. On 3 February, 60 horses arrived at SIVEP Calais on the same day and the officials were unable to cope. We therefore have little confidence that there is the capacity to efficiently handle normal movement volumes. Furthermore, Calais port is only open 08:30 – 18:00, so the number of equines that can be moved in one day via this BCP is further limited3. It also means that transporters cannot take advantage of cheaper and cooler (in summer) night ferries.
Any avoidable extension or delay to the journey is unacceptable from a welfare perspective. Transportation is a stressful and tiring experience for many horses, as they travel standing and need to constantly readjust themselves to the movement of the vehicle. Increased stress levels have been found to be a precursor to transport-related respiratory disease4. All equines – including the experienced travellers – can find being transported a stressful experience5. According to Padalino6 journey duration is a risk factor for the development of transport-related health problems in equines, with a marked increase in the proportion of the most severe problems occurring after 20 hours of transit. Indeed, increased stress levels have been found to precede transport related respiratory disease. Roy et al.7 found that equids in Canada were at increased risk of dehydration during transport when long-distance journeys occurred during warmer months. Furthermore, Austin et al 19958 estimated the risk of developing equine pleuropneumonia (“Shipping fever”) and found
3 Current volumes (pre EHV) processed are on average around 33% of normal volumes, from data shared by those shipping equines. 4 Padalino B, Raidal S.L., Knight P., Celi P., Jeffcott L., Muscatello G. (2018) Behaviour during transportation predicts stress response and lower airway contamination in horses. PLoS ONE 13(3): e0194272. 5 Schmidt A., Biau S., Möstl E., Becker-Birck M., Morillon B., Aurich J., Faure J.M. and Aurich C., 2010. Changes in cortisol release and heart rate variability in sport horses during long-distance road transport. Domestic animal endocrinology, 38(3), pp.179-189. 6 Padalino B, Hall E, Raidal S, Celi P, Knight P, Jeffcott L, Muscatello G. Health Problems and Risk Factors Associated with Long Haul Transport of Horses in Australia. Animals (Basel). 2015 Dec 10;5(4):1296-310. doi: 10.3390/ani5040412. PMID: 26690482; PMCID: PMC4693216. 7 Roy R.C., Cockram M.S. and Dohoo I.R., 2015. Welfare of horses transported to slaughter in Canada: Assessment of welfare and journey risk factors affecting welfare. Canadian journal of animal science, 95(4), pp.509-522. 8 Austin, S.M.; Foreman, J.H.; Hungerford, L.L. Case-control study of risk factors for development of pleuropneumonia in horses. J. Am. Vet. Med. Assoc. 1995, 207, 325–328. [PubMed] that it increased with journey duration, especially when the duration exceeds 10 hours. This may be due partly to posture during transport as mucociliary clearance is compromised in horses when the head is held elevated (normal travelling position) vs. head lowered to where the cranial trachea is lower than the caudal trachea.
Transportation should therefore ideally be by the most time efficient route for all equines, where road quality allows, to keep journey times to a minimum. Furthermore, equines are often moved during the cooler parts of the day – particularly in the summer. This time of day also coincides with roads being quieter, and greater available capacity on ferries, allowing for transporters to avoid delays due to congestion and keeping journey time to a minimum.
Alongside a fit-for-purpose, ideally digital, EHC – recognising that Great Britain has a good record of equine health with a lower prevalence of endemic equine infectious diseases than the EU - we would therefore like to see:
Animal welfare being given top priority at BCPs. BCP processing to be streamlined such that it is a simple validation and central recording of ID against preapproved health documentation. Clear timeboxed sequence for inspection of documentation and identification and central recording of horses on arrival at Border Control Posts (BCPs). Calais processing volumes are now proposed to be 10 horses per half hour; however, this is not proving to be the case and capacity to process needs to improve to enable the normal short straits transit volumes to be handled easily. Longer opening times at Calais port and new BCPs, which have appropriate facilities and adequately trained staff, across mainland Europe (not just France). Prioritisation for live animals over POAO and products containing plants - currently horseboxes line up in the same queues at the SIVEP as all other vehicles carrying products of animal origin or plant origin. o Recognising that ‘high health horses’ travelling for competition (FEI and racing) have greater individual traceability and are a lower risk to the general EU domestic population, these equines should be fast-tracked. This will hopefully also benefit ‘unregistered equines’, as if those that are ‘high health status’ are able to move through more quickly than they are currently able to, then the delay for ‘unregistered equines’ should also be reduced. We would also suggest that thoroughbreds being moved for breeding purposes should also be fast tracked, if individual traceability of those equines can be proven (digital identification and record of movement on/off premises). This will require the adoption of the status of high health horse, and its associated requirements for vaccination and traceability, to be included under definition of high health horse in the new statutory instrument.
Alongside sufficient well-resourced BCPs throughout Great Britain, we would urge that location is taken into consideration when authorising BCPs for equines to help ensure journey length is kept to a minimum. For example, we would suggest there must be a BCP authorised to take equines in Northern England to allow journeys to/from Rotterdam. If this does not exist, then – dependent on ferry companies – transporters will be able to move an animal from Northern England to Rotterdam but not the other direction. These animals being imported from The Netherlands will instead either have to take a longer ferry journey into Dover (if this route becomes available) or a longer road journey via France, with implications for welfare that have already been outlined. Impact on equine sector
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%9. Furthermore, as there is no mutual recognition of vehicle authorisations for equine transport, transporters are having to pay costs of around £900 for the ferry journey to the EU and inspection of their vehicle – before they can even transport animals.
From an equine sport perspective, this is an incentive for British competitors to relocate to the EU. It is also a disincentive for EU competitors to compete at UK events meaning that the competition and international equestrian events (both sport and trade) may become unviable, and the UK may no longer occupy its current position on the world stage. For context, FEI registered athletes competing in the EU in 2019 equalled 2 123, and the number of horses moved by those athletes equalled 10 274. The cost reflected in the number of journeys seen in this sector is proving highly significant.
Another consequence is that reputable and compliant equine shippers are undercut by those who do not comply, resulting in compromise to these businesses, and possibly their loss. This will impact businesses that have moved UK international equine athletes across the globe for decades. This is not only true for transporters moving equines for elite sport, but also those who move equines that are kept for other purposes, including leisure and breeding. We are concerned that these non- compliant low-cost transporters will exploit loopholes, or simply move animals illegally, thus undermining the biosecurity measures that have been put in place and compromising equine welfare.
The same cost issues apply for OVs and receiving agents in the EU. OVs are beginning to raise their fees, to reflect the time it takes them to complete EHCs, further increasing the costs on equine owners to export their animals.
It is too early to assess the impact on those equines that are being moved for reasons other than competition or Thoroughbred breeding. However, we have heard that the increased costs and bureaucracy have started to act as a deterrent to movements of these types of equines to Continental Europe and we may see a rise in ‘at risk’ equines as a consequence, as they hold no value to their owners. An alternative is that the more unscrupulous equine dealers identify alternative illegal routes that will enable them to bypass the checks – this could be by moving equines in vehicles that are not authorised, or appropriate, for equine transport.
Moving equines via the British land bridge
Another unintended consequence of increased friction at BCPs due to cost and capacity issues, is that horses are being moved directly from the north coast of France (Roscoff/St Malo/Cherbourg) to the south coast of Ireland (Cork/Rosslare/Dublin), avoiding the land bridge and any ID, physical and documentary checks altogether. This 18+ hour sea crossing is not in the best interests of equine welfare and illustrates the issues that will likewise occur if the proposed locations of BCPs are not fully scoped. These horses may either stay in Ireland or make their way out of Belfast into GB unrecorded.
There is an Intra Trade Animal Health Certificate (ITAHC) that allows equines to be moved to/from Ireland, via Great Britain, to other EU Member States without an inspection at a Border Control Post. These processes need to be as simple as possible, while also ensuring that non-compliant transporters are not able to benefit from them – for example, by unloading animals in Great Britain
9 For further information, see the cost comparisons document (Annex I). and transporting a new load onto the EU. Digitalising the movements process and ensuring intelligence is effectively shared between enforcement agencies – including between Great Britain and the EU – will help towards achieving this. It is also worth noting – the crucial welfare points notwithstanding – the existence of the land bridge does also create an unlevel playing field and does indicate that the prevailing health environment in Great Britain is considered high enough for the EU under certain circumstances.
While we recognise that this is predominantly an EU issue, we are concerned that if border control posts in Great Britain are not adequately resourced with appropriate systems in place, then further barriers will be added. We would also suggest that equivalence for transporter authorisations (vehicle authorisations and certificates of competence) would help facilitate the use of Great Britain as a land bridge. There is an opportunity for this to be legislated for via the EU’s review of its ‘Welfare During Transport’ legislation.
4. How should the Government balance animal health and welfare alongside economic interests?
In this instance, we believe that animal health and welfare and economic interests are aligned from an equine perspective. As outlined above, we believe the current bureaucracy is unnecessary and there is an opportunity to digitalise and streamline to ensure ease of movements of equines and reduce journey times, while still keeping in place adequate protections from a biosecurity and welfare perspective.
However, we would like to see Defra involved in assessing the impact on equines of policies that do not originate from their department but that will have consequences for equine health and welfare.
We are hopeful that the sanitary and phytosanitary (SPS) Joint Committee framework, as provided for in the trade and co-operation agreement, will be a key basis for improving the situation. We look forward to its formation and will be looking to engage fully in any such process.
Common Veterinary Area:
While we have offered a number of solutions, we would ideally like to see the UK Parliament and Government 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. This approach would prevent a biosecurity border around Great Britain that might enable our national herd to be better protected against incursions of those infectious diseases that are much more prevalent than in Great Britain. We would therefore urge that full digital traceability of equines is aligned with this approach to help protect our national herd from biosecurity threats, reduce the risk of introducing infectious diseases and enhance our ability to control infectious disease outbreaks.
A CVA provides a common space for the control of animal diseases, the trade in animals and products of animal origin and the import of these animals and products from third countries. Such an area exists between Switzerland and the EU, ensuring that EU and Swiss regulations on the prevention of epizootic diseases are consistent and lead to the same outcomes. The resulting veterinary area allows for equivalent trading conditions for both partners. The Swiss example demonstrates how such an agreement can maintain trade flows and reduce technical obstacles to trade by reducing or removing non-tariff trade barriers.
Such a veterinary area would need to include digital traceability of movements and would alleviate the need for checks between Great Britain and the EU (including those equines entering Northern Ireland from Great Britain), whilst still allowing for targeted or intelligence-led checks to prevent non-compliant movement as necessary. This would help ease the movement of equines whilst reducing needless stress for the animals and safeguarding a high standard of animal health and welfare.
We would propose that such an agreement should cover:
the control of certain animal diseases and their notification trade between Great Britain and the EU/NI in live animals for competition and breeding purposes, animal sperm, egg cells and embryos the import of these animals and products from other territories into the veterinary area A provision for the dynamic alignment of future standards adopted by either territory. That is to say if one territory were to adopt new legislation, thereby raising the bar of animal disease prevention and control in a certain sector, the other should ensure that it provides for a similar standard according to their own requirements. o British Horse Council will always seek higher standards rather than supporting any potential future regression.
The governance and correct implementation of the CVA should come under the responsibility of specialised Joint Veterinary Committee comprising chief veterinary officers or appropriate veterinary experts or animal health officials, including from all four UK administrations, itself under the remit of the Joint Committee established by the Withdrawal Agreement (which has ultimate responsibility in overseeing the functioning of the Northern Ireland Protocol).
Live animal exports:
5. What impact will ending live animal exports for slaughter and fattening have on UK farmers, processors and other businesses?
From an equine perspective we do not envisage this will have any impact on UK businesses, as there are very few, if any, equines bred for slaughter in the UK.
We believe that equines should be slaughtered as close to their point of origin as possible. World Horse Welfare has collated detailed dossiers of evidence as a base for a revision of journey times and other conditions of transport, utilising both science and practical field experience for slaughter horses. This found that, by their very nature, equines transported to slaughter may be more susceptible to health and welfare risks on long journeys. This increased susceptibility occurs for a variety of reasons, including inexperience of travelling, being unused to being handled and lack of fitness for the intended journey. For this reason, we agree in principle with a ban on movements for slaughter and fattening out of Great Britain to ensure equines are not transported for longer journeys in either direction.
The minimum values legislation that is designed to prevent the indiscriminate export of ponies for the meat trade is still in UK legislation. However, it has not been used since 2005 as it was deemed contrary to EU laws. Currently, horses can be legally transported for slaughter from the UK if the correct paperwork has been completed.
There have been no declarations of equines being exported for slaughter for many years; however, in reality, as horses and ponies are exported for a variety of reasons, there is no way to guarantee that a horse declared as being exported for riding will not be sold at a market directly for meat. Until there is full traceability within and outside of the UK it is not possible to know where exported horses end up. Ideally, checks should be made by EU Member States that equines that are declared as being transported for purposes other than slaughter are not being transported directly to slaughter. In addition, checks on equines as they enter and leave Great Britain should be tightened up, now we have left the EU, including the introduction of spot checks. These increased checks can help prevent non-compliant movement of equidae.
It should be noted that, while we do not believe the ban on live exports for slaughter and fattening will have any impact on any legitimate businesses involved in this trade, we do know that equines are being exported without being declared as going for slaughter. We believe this includes equines being moved to slaughter that are signed out of the food chain, as not all EU countries check the UK Central Equine Database to see whether the equine is signed out and paper passports are unfortunately all too open to fraud. While the export ban will not impact them, as they are not declared, we have heard reports that the additional costs associated with moving them has impacted this illegal trade. As highlighted previously, this may mean that these equines are stuck in the UK and will be ‘unwanted’ if they cannot be sold on, or the dealers will identify ways to illegally transport them and evade the additional costs. Consideration will need to be given as to how to prevent these illegal movements and also how best to prevent further pressure on the equine welfare sector, if we do see a rise in unwanted equines.
6. Does the UK have sufficient capacity to slaughter and process animals that are currently exported? If not, what could be improved?
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). 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. Access to humane species-specific slaughter is important to ensure horse owners who find the alternative of euthanasia and disposal prohibitively expensive, have an affordable end-of-life option available to them. Furthermore, often the slaughterhouse is the only viable end-of-life option for equines who are not signed out of the food chain and would otherwise be unwanted and left to suffer.
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
N/A
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?
N/A
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
While we fully support the goals of the EU Animal Health Law, improving the protection from disease of equines located in the EU, we are concerned that adding further requirements to a system that is flawed will only exacerbate the problems we are currently seeing - including potentially increasing waiting times further at the BCPs. Furthermore, we believe that Covid-19 has meant that the equine industry and competent authorities have been unable to adequately prepare for the full implementation of this legislation.
Industry is currently in discussions with the Commission to identify whether the date that the AHL comes into force can be delayed until January 2022, however we do not expect this to be successful.
The Animal Health Law does allow for equines being transported for competition to benefit from derogations, including residency requirements, however thoroughbreds being transported for breeding or for sale at public auction are not captured. We would like to see a definition of high health status agreed between the EU and the UK, to allow for ease of movement going forward, however this must be tied to greater traceability of these equines including registration of equine premises and a centralised digital database to track key movements.
The new EU identification regulations under the Animal Health Law, which will supersede 2015/262, have missed a valuable opportunity to allow for digital technology to take precedence over paper in identifying and moving horses both domestically and across borders. It is imperative we do not miss this opportunity in this valuable review of our own processes.
10. Will the rules and checks on the movement of equines be strong enough to prevent illegal activity? If not, what could be improved?
We are concerned that the rules and checks will not be strong enough if they are not applied consistently. Enforcement agencies also need to be given adequate resources and training, and collaboration between them needs to be improved.
Currently, information-sharing between enforcement agencies is patchy, at best, and we have anecdotal evidence to show that this is an impediment to ensuring non-compliant transporters are identified and action is taken. For example, when dealing with incorrect customs paperwork for a consignment of equines, border force may identify additional concerns with the animals or the vehicle they are being transported in. However, as APHA’s presence is regional, with each office covering a large geographical area, often this intelligence is not passed onto APHA and the transporter is not investigated or risk-assessed for future surveillance. While we expect that APHA will be present at BCPs going forward, they will not be present at all ports and if transporters are moving illegally (i.e., not via BCPs) then the onus will be on border force to identify movements that may be of concern and share the intelligence with APHA to allow for further investigation if required.
We therefore strongly recommend that all parties involved in enforcement should operate in a well- aligned, collaborative and unified way. Existing information-sharing and liaison arrangements should be reviewed to help identify improvements and ensure that relevant intelligence is shared and acted upon. This could include how enforcement performance is monitored and managed, and how the authorities are using the powers they hold.
The rules and checks also need to be consistently applied. The consequences of this not happening can already be seen, with Belfast and Larne identified as ‘easy routes’ for transporters to avoid bureaucracy and customs charges. While the checks at Calais are unduly onerous, we would suggest that the opposite is true at the ports in Northern Ireland. There are reports that equines are being moved into Northern Ireland without appropriate identification checks, as the vets are not appropriately trained and therefore scanning the microchips is putting their safety at risk, alongside that of the equines. We understand that agencies at the border are simply waving transporters through if the equine(s) is difficult and are not allowing the transporters to scan the equines for them (as we believe is happening at Calais). Furthermore, we have heard that equines are allowed through even if their paperwork is not properly filled in. One case picked up on social media involved an equine whose owner had not realised they had to have veterinary certification for travel into Northern Ireland from Great Britain. Instead of the vehicle being turned back, a local vet was asked to authorise the equine. While this ‘common sense’ approach is welcome in some regards, it does encourage transporters – both legal and illegal – to use this route as there are fewer delays. This lack of consistency in enforcement between BCPs will potentially encourage transporters to choose significantly longer routes for equines if they are being transported to Southern Ireland from England, particularly if they are then transported onwards via a 14+ hour ferry to Continental Europe.
If the same timeline is not followed throughout Great Britain, this potentially allows for a ‘backdoor’ at those ports that are applying less rigorous checks. We are already aware that Thoroughbred breeders are using this route from Southern Ireland to Great Britain, to avoid onerous VAT processes and costs that place additional strain on a sector that has been adversely impacted by Covid-19.
We would like to stress that these processes and checks must be digitalised and streamlined as much as possible, with physical checks at BCPs. Equines should only be unloaded if they are not all accessible on the lorry/trailer10 and this should only happen if there is adequate intelligence, or if enforcement agencies at the ports have concerns based on observations they have made. There must be a balance between ensuring checks are effective while not being unduly onerous on compliant transporters and increasing total journey time significantly and unnecessarily.
10 Research has shown that loading and unloading causes stress in equines and an increased risk of injury to both the equine and to the handler, irrespective of whether the animal is trained or untrained. Annex I: Costs of Travelling Horses to Europe post-Brexit Costs are based on an average scenario as an example only – some costs are variable
Pre-Brexit Cost Comment Post-Brexit requirement Cost Comment requirement Health papers signed £70.00 Quick visit by normal Increased time – 33-page form, yard vet – simple form Export Health Certificate £200.00* must be completed by an OV and completion paperwork continually rejected.
90 days before travel (additional Equine blood tests £100 test required if horse is a stallion)
Shipper fees £95.00 Optional Shipper fees £250.00* More paperwork, more involved, more work and required as the changes are implemented. Cost varies depending on level of service provided.
Ferry £450.00 Return Ferry £450.00* Return Attendance / dossier £114.00 At weekends, these costs are Border Control Point charges £140.00 double and 2.5 times on holidays. Vet tax £28.00 Fees are per horse Onward certificates £25.00
Or Eurotunnel £950.00 Return Or Eurotunnel £950.00 Return Fees are Surcharge (inc. BCP £325.00 per horse charges) Attendance/dossier £114.00 Vet tax £28.00 Onward certificates £25.00 Per year – optional previously but Carnet £800.00* now deemed a requirement to help expedite customs checks. Cost is highly variable. DEFRA lorry check £380.00 annual DEFRA lorry check £380.00 annual EU lorry check (travel, check £1500 Plus could require lorry and fees – Ireland or Belgium modifications to meet only at present) standards. Checks have to be done every five years for lorries under two years, those over two every three years. UK Type 2 Free Every 5 years UK Type 2 Transport Free Transporter Certificate Authorisation Certificate EU Type 2 Transport £170 Lasts 10 years Certificate Total by ferry £995 Total by ferry £4157 318% increase Total by Eurotunnel £1495 Total by Eurotunnel £4842 224% increase
* - these costs are variable/estimates, examples are based on average costs. - Costs based on a 12T horsebox and one horse travelling.
Table courtesy of British Equestrian Federation