10 Feb 2021

DEFRA Consultation Deadline Extended

The Cattle Information Service would like to raise awareness to customers that DEFRA have extended their deadline on the Improvements to Animal Welfare in Transport Consultation to Thursday 25th February. Whilst Holstein UK have submitted a thorough response, we would encourage members to submit their own responses, to ensure a large voice from the industry.  

Below is an outline of the main proposals within the consultation, along with a condensed response which Holstein UK provided, which you are free to use.  

Complete your response


Defra reference the 2019 report by the Farm Animal Welfare Committee as their basis for many of the recommendations. View the report

It should be noted that this is an England and Wales consultation, with a similar consultation being issued in Scotland.  The proposals include all journey times of 65km or more, regardless of their reason e.g., for slaughter, show or sale. 

1. (Q5 – Q9) Exports of live animals for slaughter/fattening would be banned.

I. The journey time for animals in the South of England to the EU can be shorter than that to other parts of the UK.  For example, crossing time from Dover to Calais is just 1.5hrs, whilst the Islands of Scotland can see times of upto 13 hours to reach Scottish mainland.  

II. Vets and officials are present at ports, markets and stopping places, these work to ensure the health and welfare of the animals whilst in transit. 

III. The FAWC overarching recommendations are that compliance needs to be controlled, and the roll-out of top-up training or the re-sitting of exams. 


2. (Q10 – Q16) A proposed maximum journey time of 21 hours for cattle (upto 29 hours with APHA consent), and upto 9 hours for calves under 9 months.  This includes loading, unloading, rest periods and time at market or collection centre.  After this time has elapsed, a minimum 7-day rest period should be observed for cattle (48 hours for other animals).

I. Current regulations mean any journeys of 65km or more require the correct transport documentation, including: Transporter Authorisation; Certificates of Competence; and where necessary Vehicle Approval Certificates.  The FAWC recommend that more needs to be done in controlling the compliance of this, and further scientific evidence gathered, rather than drastic changes to the current legislation.  

II. There needs to be a focus on the definition of fitness for transport of the animals as this is where many of the issues arise.  

III. The FAWC report states that there has been no difference in the behaviour or physiology of cattle transported for 14 to 31 hours.  

IV. The agricultural industry has become more consolidated, as a result of this, animals have to travel further to reach markets and shows, with some farmers living in remote locations.  Any reduction in journey times, will have a direct impact on the viability of both farm businesses and related businesses, such as auction markets and shows.  Specifically, pedigree sales would find a decrease in the number of eligible buyers and sellers.  In the past UK animals have been sold overseas, tighter restrictions of journey times would make this much more difficult.   

V. The 7-day rest period is unfeasible for cattle, due to the added cost of making animals wait, the potential increased biosecurity risk that this adds along with the impact on the animal’s health and welfare.  

VI. Dairy cattle in lactation require regular milking, and so journeys are worked around this. 

VII. Animals would travel longer distances to shows, during which they would stay at the show for a few days before returning home.  It is not feasible for these animals to remain at the show for 7 days before moving on.  The showing of agricultural animals at these shows has a huge social economical benefit. 

VIII. The health and welfare of animals is at the heart of the UK farmer, and they will not want to do anything which jeopardises their investment in their animals.  


3. (Q19 – Q24) Stricter requirements for journeys outside of a temperature range of 5C to 30C, when the vehicle is unable to regulate the internal temperature for the entire journey. 

I. The NFU states that over the last 20 years there would have been on average 56 days per year where animals would not have been able to have been moved due to temperatures of below 5C.  There is a huge lack of clarity regarding this proposal, as to if it is the temperature at loading or throughout the journey.  

II. Many lorries and trailers are unable to thermo-regulate the temperature, and it is uneconomical for them to be adapted to do so, or for farmers to purchase ones which can.  

III. Regulations like this further reduce the market opportunities for UK farmers, producing further economic uncertainty on their business and also negatively impacting on the food supply chain.

IV. Low temperatures would cause the closer of auction markets and slaughterhouses, due to no animals being able to be transported.

V. It has been proven that cattle prefer airy, colder conditions, with their skin being leather, they are suited to colder temperatures.  

VI. The FAWC report also does not recommend the lower temperature be applied for cattle. 

VII. The transporting of animals at 30C or above would be rare, and the driver would manage this to try and mitigate it.  There could be measures put in place when this is likely to happen, such as stocking densities.  


4. (Q25 – Q29) Space allowances for animals in vehicles should be calculated according to an allometric system.  Proposed minimum headroom requirement for dairy cattle of 20cm.  

I. The use of partitions in the transporting of cattle is required for welfare reasons of the animal.  By using partitions or restricting the amount of space animals have whilst being transported prevents bumps, falls and too much moving around which can result in animals being trodden on.  

II. Further information on the proposed calculations is required.  

III. The FAWC reported that one of the main areas of upset for animals during transport was the loading and unloading.  This should be carried out by someone experienced, whilst consideration should be given to grouping animals according to size and age.  

IV. Animals come in all shapes and sizes, ensuring there is 20cm of head room is not feasible. Livestock transport is at set sizes and cannot be easily altered, and the use of hauliers for potentially short journeys is not economical.  

V. The NFU report that the FSA state there is no clear indications that there are any welfare concerns associated with headroom availability.   


5. (Q30 – 31) No animals to be transported via sea during Beaufort Wind Force of 6 or above.

I. There is a lack of evidence around this proposal.  Any delay to a sea crossing will have a direct impact on the animal’s total journey time.  What considerations would be given to this?