Written Evidence submitted by – The Invertebrate Conservation Trust (maab0038)

Introduction:

Buglife – The Invertebrate Conservation Trust is the charity that represents the needs of all invertebrate species. Buglife has 35 member organisations, including all the leading invertebrate specialist societies, and over 2,000 individual supporters. Buglife aims to halt the of invertebrates and to achieve sustainable populations of invertebrates.

Buglife is responding to this inquiry to provide evidence considering invertebrates moving across borders, through intentional trade and as stowaways. Most analyses on wildlife trade are biased towards vertebrates, however, research suggests that a significant amount of illegal and legally traded wildlife include invertebrate species1. Invertebrates make up over one-third of indirect imports in CITES-listed taxa to the UK2. Due to their relatively small size, the movement of invertebrates is often overlooked and can go unnoticed.

1. Does the UK have sufficient resources and capacity to certify, record and inspect animal movements across its borders?

Buglife is concerned that Invasive Non-Native Species (INNS) continue to make their way to the UK (accidentally or otherwise), and there are insufficient biosecurity measures in place to prevent this.

INNS are one of the greatest threats to across the planet3. The introduction of INNS to ecosystems typically leads to a reduction in species richness and abundance and the degradation of the environment.

There are 3,224 non-native species in Great Britain, 2,010 of which are classified as established (reproducing in the wild). 193 non-native species are exerting a negative impact on native biodiversity, the majority of which are terrestrial species (46 freshwater species, 39 marine species and 108 terrestrial species)4. The arrival rate for terrestrial invertebrates has continued upwards overtime in at a faster rate than other major groupings (Marine, Freshwater, and Terrestrial Plants)5.

Flatworms

The international trade in pot plants poses a particular threat. Billions of pounds worth of plants and trees are transported around the world every year. They may bring colour to homes and gardens but with them, they bring unwanted organisms in the soil. Non-native species such as the New Zealand flatworm, Arthurdendyus triangulatus (= Artioposthia triangulata) can wreak havoc on native wildlife, while invasive slugs such as the Spanish slug (Arion vulgaris) can harm garden plants and crops.

Over £1billion of live plants and planting material are imported into the UK each year6. It is currently not possible to ensure the growing medium is entirely free from INNS and only a percentage of plants entering the UK are checked.

Non-native land flatworms have been accidentally introduced to the UK in imported pot plants and newly arrived species continue to be discovered7. Once introduced these flatworms can reproduce rapidly, cannot be eradicated, and pose a risk to native soil invertebrates such as earthworms by feeding on them8. There are 5 native species of flatworm in the UK but between 14 and 16 non- native species. Scientists have found that in some areas, non-native flatworms can reduce local earthworm populations by 20%9 – this could have a huge impact on soil health and agriculture, as well as our native soil wildlife. One species, the New Zealand Flatworm, is listed on the Invasive Alien Species (Enforcement and Permitting) Order 2019, as part of the retained EU Regulation following Brexit10. Three further species of non-native flatworms are included on Schedule 9 of the Wildlife and Countryside Act 1981, which states that it is an offence to introduce or release them into the wild11.

Local horticulturalists are capable of growing plants for domestic markets, so almost all international trade in live plants is unnecessary. Eradicating invasive species after they have become established can be expensive or impossible, and so preventing the spread of invasive non-native species is key to limiting harm. Improved biosecurity practices are essential. Until there is a proven way to sterilise both pot plants and the potting medium, and this is implemented, cross-border trade in pot plants should be prohibited.

There are no recorded natural enemies and no biological or pesticide control methods for non- native flatworms, the key control measure is to prevent their introduction to new areas.

Crayfish

We have at least 6 species of introduced crayfish living in the wild in England, fewer in Wales and Scotland but none in Northern Ireland. Most of these species were introduced to provide food or angling bait but then escaped into the wild. Some are extremely harmful to our only UK species, the White-clawed crayfish (Austropotamobius pallipes), and our rivers12.

We continue to see crayfish released into the UK, including high profile cases such as the recent series of ‘I’m a Celebrity…’ having used Turkish (also called Narrow-clawed) crayfish (Astacus leptodactylus). This is an invasive species that damages aquatic ecosystems. It is strictly controlled, being listed as an invasive non-native species under the Wildlife and Countryside Act 1981 and keeping them is outlawed by the Prohibition of Keeping of Live Fish (Crayfish) Order 1996.

An investigation by Buglife discovered that no licence was applied for by the show in Wales or the UK13. The Welsh Government concluded that they were “unable to find any evidence that a licence application was made in this instance”, while Defra confirmed that “no licence was applied for in this case, and Cefas [the licensing authority] would not have issued one for the purpose for which they were used”.

This example shows failings in existing regulation and biosecurity measures, which are not enforced, are misunderstood, or ignored.

Bees

Threats to wild pollinators from pathogens and other parasitic organisms (e.g. microsporidian fungi, parasitoids) indicate that a key source is managed honeybees14. There is concern regarding the use and particularly the importation of managed bees (including honeybees, and bumblebees used in polytunnels) as this may introduce exotic parasites (or parasite strains) which subsequently spill over to wild populations15 16 . Pathogens and parasitoids are known to be important mortality factors for wild bees17 18 and have been implicated in losses in species diversity19 20. By allowing managed and/or imported bees to mix with wild pollinators, there is the potential for disease emergence.

There is growing evidence from around the world that pathogens (and other parasitic organisms) can be shared between managed bees and the wider pollinator community21 22. In a review of available data, it was reported that managed bees can have negative effects on wild bees through parasite spillover, spillback and facilitation23. The study noted a striking association between the use of managed bees and local declines and of wild bees, suggesting that multiple instances of disease transmission have already occurred between managed and wild bees, including within the UK.

A study in 2013 found that 73% of the native bumblebee colonies which were imported into the UK and supposed to be free from parasites and diseases, carried parasites that could be harmful to the health of bumblebees and other pollinators such as honeybees24.

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?

As the movement of goods and people across our border’s changes in the wake of Brexit, so too will the dispersal, introduction, and establishment of INNS. Non-European species are twice as likely to become invasive once established, compared to European species25. This will be further exacerbated by the effects of climate change, as warmer conditions and ecological disruption assist species introduction and establishment.

INNS must be factored into new bilateral trade deals, not only those directly concerning the movement of animals, through risk assessments and enhanced biosecurity measures introduced at points of entry. This is particularly important at the border between GB and the island of Ireland to ensure it is not possible to avoid import regulations. We have already seen examples of this route as a suggested way to import invertebrates into the UK from Europe26.

While the UK has left the European Union, it is critical to retain, and ensure no regression of, the EU Invasive Alien Species Regulation. Cross border cooperation on the movement of species is crucial to protecting biodiversity.

Buglife is concerned that newly announced freeports will lead to an increase in illegal wildlife trade and INNS. A proposed relaxation of customs processes poses environmental risks beyond the geographic location of the freeport itself. Freeports would weaken the UK’s ecological barrier – Free Trade Zones and freeports have been identified as particularly high-risk sites for the accelerated introduction and early establishment of INNS27.

The implications of freeports for illegal trade in endangered species and animal products are also significant. Endangered species should be identified as excluded goods, and freeports should ensure all required checks are in place to protect against increases in this trade.

The rise in online trade also creates a threat to the movement of invertebrates to, and from the UK. Increased demand and ease of access are driving online sales of invertebrates and plants. Buyers are often unaware of the origin of these species or the risks they create, or are readily willing to break international laws to add to collections28. This route of animal movement must be addressed and better regulated. It is important to raise awareness with the wider public to understand the impact online sales can have on biodiversity and prevent unregulated online sales.

4. How should the Government balance animal health and welfare alongside economic interests?

Invasive species legislation in the UK is inadequate and has not been suitably updated or resourced to reflect the scale of the threat posed by INNS both to resident biodiversity and the economy29. On average INNS cost the UK economy £1.8 billion per year30. It is significantly cheaper to prevent INNS from establishing than it is to remove species once established. Biosecurity and closing pathways should be the first line of defence to prevent the introduction of new INNS. Resources and funding for INNS management and biosecurity must be increased. The government should commit to the recommendation made by the Environmental Audit Committee in October 2019, to triple the invasive species biosecurity budget to £3 million. A further £3 million should also be provided to form a dedicated invasive species inspectorate31. The government should work with devolved nations to ensure robust biosecurity measures are in place at all entry points to the UK.

By preventing INNS from establishing themselves in the UK, not only will the Government save money, but they will also prevent impacts on native flora and fauna and therefore protect animal and plant health.

March 2021

1 https://www.sciencedirect.com/science/article/pii/S0006320720300677?via%3Dihub 2 https://data.jncc.gov.uk/data/3181e8bd-3f5c-4073-84d2-9e7ecfd94350/JNCC-Report-626-Rev1-WEB.pdf 3 https://www.zsl.org/sites/default/files/LPR 2020 Full report.pdf 4 https://jncc.gov.uk/our-work/ukbi-b6-invasive-species/ 5 http://nora.nerc.ac.uk/id/eprint/7796/1/HillN007796CR.pdf 6https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/875366/ planthealth-trade-statsnotice-26mar20.pdf 7 https://www.cabdirect.org/cabdirect/abstract/19970305550 8 https://peerj.com/articles/297/ 9 https://link.springer.com/article/10.1007/s10530-012-0309-7 10 https://www.legislation.gov.uk/uksi/2020/1388/part/7/chapter/3/made 11 https://www.legislation.gov.uk/uksi/2010/609/pdfs/uksiem_20100609_en.pdf 12 https://cdn.buglife.org.uk/2019/05/Invasive-crayfish-species-Profiles_0.pdf 13 https://www.buglife.org.uk/news/im-a-celebrity-get-me-out-of-here-exploited-illegal-crayfish/ 14 https://onlinelibrary.wiley.com/doi/abs/10.1111/j.1600-0706.2011.19832.x 15 https://www.annualreviews.org/doi/10.1146/annurev.ento.53.103106.093454 16 https://digitalcommons.unl.edu/cgi/viewcontent.cgi?article=1840&context=usdaarsfacpub 17 https://pubmed.ncbi.nlm.nih.gov/9632470/ 18 https://www.apidologie.org/articles/apido/abs/1991/02/Apidologie_0044- 8435_1991_22_2_ART0004/Apidologie_0044-8435_1991_22_2_ART0004.html 19 https://conbio.onlinelibrary.wiley.com/doi/full/10.1111/j.1755-263X.2012.00234.x 20 https://pubmed.ncbi.nlm.nih.gov/21199943/ 21 https://www.cabi.org/isc/abstract/20063100241 22 https://pubmed.ncbi.nlm.nih.gov/16300785/ 23 https://pubmed.ncbi.nlm.nih.gov/28560161/ 24 https://besjournals.onlinelibrary.wiley.com/doi/full/10.1111/1365-2664.12134 25 http://data.parliament.uk/writtenevidence/committeeevidence.svc/evidencedocument/environmental- auditcommittee/invasive-species/written/104755.pdf 26 https://www.theguardian.com/environment/2021/feb/02/beekeeper-stung-by-post-brexit-ban-and-threat- to-burn-15m-bees 27 https://besjournals.onlinelibrary.wiley.com/doi/full/10.1111/j.1365-2664.2008.01600.x 28 https://www.nationalgeographic.com/animals/article/bug-smuggling-big-business 29 https://www.wcl.org.uk/docs/Prevention_is_Better_than_Cure_Report_2020.pdf 30 https://www.researchgate.net/publication/298559361_The_Economic_Cost_of_Invasive_Non- Native_Species_on_Great_Britain 31 https://publications.parliament.uk/pa/cm201919/cmselect/cmenvaud/88/88.pdf