Help consign live animal exports to the history books (consultation now CLOSED)

Posted on the 21st January 2021

The UK and Welsh Governments have announced a consultation and we need as many people as possible to respond. Animal Aid would like to see a complete ban on the needless live export of animals.

We are however, a step closer to banning some live farmed animal exports and improving conditions for those that will sadly continue to be unecessarily exported. Animal Aid has put together some supporter guidance notes below to help simplify the process.

The deadline for submitting responses is now 25th February, as confirmed on the DEFRA consultation site.

The Scottish government is running a separate consultation on live exports – find out more information here.

The reference document for England and Wales is available here to download

We have provided a full list of the consultation questions from the reference document and have included key points to incorporate into your responses at the bottom of this page. Please note that the question numbers vary slightly between the consultation document linked above and the online survey form (which starts the main consultation questions from number five) so be careful to ensure you are responding to the correct question if you use the online form.

There are three ways that you can respond – via email, via the online survey or by printing your response to complete and submitting it by post.

  • E-mail

A response can be sent by email to AnimalWelfare.Consultations@defra.gov.uk with the subject line ‘Consultation on improvements to animal welfare in transport December 2020’. Your response must include your name, email address and organisation (for organisation, you may put ‘Supporter of Animal Aid’ or another protection group if you are not a group representative)

  • Online Survey

Responses can be sent via the online survey on the Government website:

https://consult.defra.gov.uk/transforming-farm-animal-health-and-welfare-team/improvements-to-animal-welfare-in-transport/

  • Postal Responses

Responses can be printed and sent to:

Consultation Coordinator,
Defra
2nd Floor,
Foss House,
Kings Pool,
1-2 Peasholme Green,
York,
YO1 7PX

Q1: Do you agree that livestock and horse export journeys for slaughter and fattening are unnecessary? Please explain your views.

  • Supportive of a ban on the unnecessary export of animals full stop as this puts animals in danger, subjects them to potential human maltreatment and is detrimental to their positive health and welfare.
  • The live export of farmed animals causes stress, injury, dehydration, stress-linked disease. At the very least support no animal exports for slaughter or further fattening.
  • The live export of high numbers of sick or diseased animals is a particular concern, both for the welfare of the animals concerned and for the spreading of disease.
  • There is strong public opposition to live exports in Britain as demonstrated through polling.
  • Absolutely do not support the idea of a ‘Red Tractor’ type approval scheme for live exports, as has been mooted in the agricultural press.

Welcome the following improvements, should any live exports be allowed to continue:

  • Thermo-regulating trucks for internal and overseas journeys.
  • Accelerometers are retro-fitted to all vehicles.
  • Operation of onboard CCTV for live monitoring of animals on journeys, with rules stipulating the position, maintenance, storage and access of recorded data.

Q2: Do you agree that in order to prohibit livestock and horse export journeys for fattening where the animal will be slaughtered soon after arrival, these export journeys where animals are slaughtered within 6 months of arrival should be prohibited? Please explain your views.

  • Supportive of the prohibition of animals needlessly being exported to be slaughtered within 6 months, as an absolute minimum. Better that they are not exported full stop.
  • Regardless of the duration of fattening, better a total ban as it is difficult to enforce the 6 month rule.
  • We need to ensure that young un-weaned calves do not end up being transported for fattening in low-welfare veal rearing systems.
  • It is also vital to safeguard all farmed animals more generally from being exported onwards to North Africa or the Middle East, where animal welfare standards do not meet EU law.

Q3: Do you agree that the only exceptions to prohibiting live export journeys should be for poultry live exports, and animals going for breeding or production that will not be slaughtered within 6 months of arrival? Please explain your views.

Q3a. Exemption for poultry.

  • Poultry should not be exempted from the live export ban as they are just as capable of suffering poor health and welfare caused by long-distance transportation.
  • Young chicks are negatively impacted by fluctuating environmental conditions.
  • Pullets and end of lay hens have poor feather coverage leaving them susceptible to temperature fluctuations.
  • ‘Broiler’ chickens, end-of-lay hens and other poultry do not have their natural needs met or their welfare protected.

Q3b. Exemption for breeding

  • Strongly object to the exemption for breeding animals.
  • Concerned that documentation may be provided to demonstrate breeding purposes, whereas the animals are in reality intended for onward travel for fattening or slaughter.
  • Animals should certainly not be exported to be incarcerated in systems that would be illegal in the UK, such as sow stalls or barren battery cages.
  • Replacement of the trade in breeding animals including poultry with one in genetic material or fertilised eggs.

Q3c. Exemption for production/fattening

  • Concern that exemption may allow for the legal export of unweaned calves.
  • An absolute minimum of eight months but they should not be exported at all.

Q3d. Concerns about registered horse exemptions, especially retired registered horses 

  • Particular concerns about possible exemptions for registered horses, especially relating to the protection of retired registered horses.
  • In practice, unless going to slaughter, registered horses and ponies have been transported without the requirements for water and feed intervals, rest periods, maximum journey times, or the need for a journey log.
  • Legislation and guidance needs to be clear that these regulations apply to both registered and unregistered horses.

Q4: What would be the financial impact to your business or organisation of no longer being able to export livestock or horses for slaughter or fattening? Please explain any impacts provided.

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Q5: What alternatives would your business or organisation explore if it was not able to export livestock or horses for slaughter or fattening?

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Q6: Do you agree with the proposed maximum journey times as outlined in Table 1? Please explain your views and highlight any potential regional impacts that your business or organisation might experience.

  • Animals should not be transported at all. The absolute maximum journey time should be 8 hours, and that exemptions to that should only be for shorter (not longer) maximum journey times for particular animals, depending on age, species and other factors.
  • Important that the system of maximum journey times doesn’t enable a repeat cycle of travel-rest-travel.
  • There is a risk of excessive journeys to Middle East or Africa, if overall time is not limited.

Q7: Do you see a need for any exceptions to the maximum journey times and, if so, why? Please provide evidence.

  • No need for exemptions allowing longer journeys. Concerned this will be used to circumvent the regulations designed to protect animals.

Q8: In the case of such exceptions, what requirements should be put in place to ensure animal welfare is protected?

  • Exceptions to maximum journey times should not be permitted. If this did ever occur transporters must be required to provide full explanations and these should be made publicly available to be scrutinised.

Q9: What would be the financial impact to your business or organisation due to new maximum journey times being implemented? Please explain any impacts provided. 

n/a

Q10: Including loading, unloading and stops, how long is your average journey for the livestock, poultry or horses that your business or organisation manage?

n/a

Q11: Do you agree that a new journey should not start until a minimum of 48 hours have elapsed after the previous journey? Please explain your views.

  • A new journey should not be allowed to commence, even after a 48-hour rest period.
  • The eight-hour limit should be followed in all cases, and animals should reach their destination within that time or not be transported at all.
  • Limits are limits and are not to be exceeded.

Q12: Do you agree that there should be a minimum 7-day rest period for cattle? Please explain your views.

  • A new journey should not be allowed to commence for cows, even after a seven-day rest period.
  • An eight-hour limit should be followed in all cases, and ‘cattle’ should reach their destination within that time. Ultimately they should not be transported at all.

Q13: Do you agree that we should prohibit both short and long poultry journeys when the external temperature is outside of a temperature range of 5-25oC, unless the vehicle is able to regulate the internal temperature within this range for the duration of the journey by means of a thermo-regulation system, and that this temperature range should be 5-25oC? Please explain your views. 

  • Poultry should not be exempted from the live export ban as they are just as capable of suffering poor health and welfare caused by long-distance transportation.
  • Any poultry journey should not take place where outdoor temperatures are outside the 5-22ºC temperature range.
  • Poultry are particularly vulnerable to temperature fluctuations, and poorly feathered birds are especially at risk from the cold.
  • However, the permissible temperature range should not be determined solely by the temperature at the start of the journey but must also take into account the likely temperature during the journey time.
  • Journeys starting within this temperature range, but likely to reach above or below it during the journey should not be permitted to commence. This additional consideration needs to be clearly stated in legislation and guidance.
  • Modern vehicles are capable of mechanically regulating and monitoring internal temperature and humidity, and this can operate independently of vehicle engines. We believe that live poultry transportation should only be permitted in vehicles using such effective and working thermo-regulation.
  • We are particularly concerned about the vulnerability of day-old chicks.

Q14: What would be the financial impact to your business or organisation of prohibiting both short and long poultry journeys when the external temperature range is outside of 5-25oC? Please explain any impacts provided.

n/a

Q15: Do you agree that we should prohibit both short and long livestock and horse journeys when the external temperature is outside of a temperature range of 5-30ºC, unless the vehicle is able to regulate the internal temperature within this range for the duration of the journey by means of a thermo-regulation system, and that this temperature range should be 5-30oC? Please explain your views.

  • Welcome measures to ensure animals are never transported outside of safe defined limits.
  • Any journey should not take place where outdoor temperatures are outside the 5-30ºC temperature range. However, 30ºC is too high for the upper temperature limit and 5C too low for the lower limit for certain species of animal and at different life stages.
  • Stress the importance of improving enforcement and compliance.

Q16: What would be the financial impact to your business or organisation of prohibiting both short and long livestock and horse journeys when the external temperature range is outside of 5-30oC? Please explain any impacts provided.

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Q17: Do you think that there are other species that should be considered as vulnerable and have a smaller external temperature range applied, outside of which journeys cannot take place? Please provide evidence.

  • Young chicks, including day-old chicks are particularly vulnerable, they require specific attention, especially when being transported.
  • Young, unweaned animals are especially vulnerable, regardless of species. They should not be subjected to commercial live export. They suffer immensely. Where they do travel, particular attention is needed to ensure their thermal comfort and optimum humidity.

Q18: What proportion of your current transportation vehicles have the facility to regulate temperature and provide ventilation?

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Q19: For your vehicles which do not have the facility to regulate temperature and provide ventilation, what would be the cost of retrofitting to enable them to regulate temperature and provide ventilation?

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Q20: Are there any other steps that can be taken to ensure animal welfare can be maintained in extreme weather? Please provide evidence.

  • No animal species should be transported, but especially not in temperature as high as 30ºC and under 5ºC.
  • Vehicles on the Joline live export ship have regularly broken temperature rules and had defective fan systems, as reported by live exports campaigners.
  • Animals can be left without access to water.
  • As well as temperature, humidity is an important factor affecting the welfare of animals during transportation, particularly in relation to heat stress. For example, at high humidity, a temperature of 20ºC can be very dangerous to broiler chickens.
  • Humidity sensors should be used in vehicles to regulate/monitor humidity.
  • Issues with animals being transported in heavy fleece in summer and shorn in winter from Ramsgate, as flagged by live exports campaigners.

Q21: Do you agree that we should use allometric principles as a basis for future space allowance calculations? Please explain your views.

  • Space allocations must be sufficient to allow room for all animals to reach water points, for inspection to take place and for animals to lie down. Must ensure no adverse effect on temperature or ventilation.
  • Extremes of temperatures should be planned for and journeys delayed.
  • Meticulous inspection should be undertaken to ensure compliance.

Q22: Do you think that reforms to space allowances based on allometric principles should apply to both short and long journeys? Please explain your views.

  • Widely acknowledged that journeys over 8 hours have significant welfare impacts on animals in transit.
  • Journeys longer than 8 hours cannot be justified and should be banned.

Q23: Do you agree with the proposed species-specific headroom requirements? Please explain your views.

  • The proposed headroom requirements remain insufficient to provide adequately for the welfare of all species mentioned, but especially pigs.
  • There should always be sufficient headroom as a lack of it causes discomfort and therefore stress, no animal should have to travel with bowed heads no matter what the distance.
  • Headroom is important for both the maintenance of normal posture and also to ensure sufficient ventilation. Allow sufficient clearance to allow heat to escape.

Q24: Do you think that the proposed species-specific headroom requirements should apply to both short and long journeys? Please explain your views.

  • Space should be sufficient for comfort regardless of journey length. Lack of room for any species during transportation will create welfare issues.

Q25: What would be the financial impact to your business or organisation of the proposed headroom requirements for both short and long journeys? Please explain any impacts provided.

n/a

Q26: Do you agree that we should prevent animals from being transported in rough weather at sea and that animals should not be transported during Beaufort Wind Force 6 or above? Please explain your views.

  • Need clearer emphasis on the likely conditions during a crossing, not just at its commencement.
  • Animals should not be trasported overseas and their welfare put at risk. Often they are travelling to be held in conditions that would be illegal in the UK. If live transportation were to continue by sea, it should never be permitted in rough weather. However, this should be defined as Beaufort Wind Force 5, not Beaufort Wind Force 6. This would be in keeping with the recommendation of the EU Scientific Committee on Animal Health and Animal Welfare (SCAHAW).

Q27: What would be the financial impact to your business or organisation of prohibiting transport during Beaufort Wind Force of 6 or above? Please explain any impacts provided.

n/a

Q28: Do you think that there should be any exceptions to the previously mentioned proposals alongside the specific exceptions already outlined, excluding the proposal to prohibit live exports for slaughter and fattening? Please provide evidence.

  • No, exceptions should not be permitted. The prohibitions and restrictions are in place in order to protect animals. Exceptions will compromise this.

Q29: What conditions should be met in order to ensure animal welfare is protected in the case of other exceptions? 

  • Exceptions must not be allowed to be used as a means of circumventing regulations.
  • If exceptions are permitted there must be stringent record keeping and scrutiny, especially regarding trends in exceptions. Public disclosure of exceptions is crucial.

Q30: Do you think that it should be possible to obtain permission to use an exception on an ongoing basis to avoid the need for transporters to apply before every applicable journey? Please explain your views.

  • No. The prohibitions and restrictions are in place in order to protect animals, and exceptions will compromise this.
  • Permission to use exceptions on an ongoing basis is effectively a means to routinely circumvent legislation. This is wholly inappropriate and should not be permitted.

 

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