EN    EN EN 
 
EN    EN  COMMISSION OF THE E UROPEAN COMMUNITIES 
Brussels, 16.6.2009 
SEC(2009) 777 final 
  
COMMISSION STAFF WORKING DOCUMENT 
Accompanying document to the 
  
Proposal for a 
 
REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL 
amending Regulation (EC) No 998/2003 of th e European Parliament and of the Council 
laying down the animal health requirem ents applicable to the non-commercial 
movement of pet animals 
  
SUMMARY OF THE IMPACT ASSESSMENT 
 
[COM(2009) 268 final] 
[SEC(2009) 776] 
 
 
 
EN 2   EN COMMISSION STAFF WORKING DOCUMENT 
Accompanying document to the 
  
Proposal for a 
 
REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL 
amending Regulation (EC) No 998/2003 of th e European Parliament and of the Council 
laying down the animal health requirem ents applicable to the non-commercial 
movement of pet animals 
  
SUMMARY OF THE IMPACT ASSESSMENT 
 
[COM(2009) aaa final] 
[SEC(2009) bbbb] 
 
EN 3   EN The item is part of the Commission ag enda planning/work programme under the 
reference 2008/SANCO/010. 
1. P ROBLEM IDENTIFICATION  
1.1. Legal background 
1.1.1. Legal obligation to review 
Regulation (EC) No 998/20031 of the European Parliament and of the Council (‘the 
Regulation’) lays down harmonised animal health requirements applicable to the 
non-commercial movement of pet animals w ithin and into the Community (‘general 
regime’). 
However, the Regulation grants a transi tional period to the United Kingdom (‘the 
UK’), Ireland, Malta, Sweden and Finland to make the entry of pet animals into their 
territory subject to compliance with certa in additional requirements to prevent the 
risk of introducing rabies, echinococcu s and ticks (‘transitional regime’).  
The Regulation lays down a legal obligation to review the rules by the end of the 
transitional period  and requests  the Commission to submit to the European 
Parliament and to the Council a report ba sed on experience gained and on a risk 
evaluation together with proposals for the re gime to be applied at the end of the 
transitional period. The Comm ission adopted its report on 8 October 2007, together 
with a proposal for a Regulation of the Eu ropean Parliament and of the Council to 
briefly extend the transitional measures un til September 2009 (furth er deferred to 30 
June 2010 by Regulation (EC) No 454/20082) to allow sufficient time to consider all 
aspects and consult all interested parties on the options.  
Based on its report, the outcome of variou s consultations conduc ted, including the 
consultation of the European Food Safe ty Authority ('EFSA'), and available 
information on the diseases concerned in  the whole EU, the Commission is now 
assessing the long-term options, and in part icular the case for extending the general 
regime to the Member States curr ently under the transitional regime. 
1.1.2. General regime 
The Regulation provides that  pet animals travelling w ith their owner from one 
Member State to another must be identified and accompanied by an EU passport which provides proof of a valid anti-rabies vaccination. The regime applicable to pet 
animals entering the EU from listed or non-listed third count ries depends on the 
quality of the guarantees provided by the th ird country of origin as regards rabies. 
1.1.3. Transitional regime 
This regime which has been granted to Finland, Ireland, Malta, Sweden and the UK, 
is summarised in Table 1
. This is a combination of EU and national rules. It provides 
                                                 
1 http://eur-lex.europa.eu/LexUriServ/site/e n/consleg/2003/R/02003R0998-20081122-en.pdf . 
2 http://eur-lex.europa.eu/LexUriServ/LexUriSe rv.do?uri=OJ:L:2008:145:0238:0239:EN:PDF   
 
EN 4   EN for additional entry requirements, which vary according to the Member State of 
destination and the disease.  It also provides for exemptions between the Member 
States currently under the tr ansitional regime and even with other Member States 
(e.g. Denmark), so called bilateral arrangements. 
1.1.4. Free movement regime 
The UK and Ireland apply a mutual free m ovement regime for dogs and cats without 
the need for pet identification (marking) or passports. This regime is neither part of 
the general regime nor of the transitio nal regime provided for by the Regulation. 
1.2. Issues to tackle  
1.2.1. The current national rules are compl ex and place a considerable burden on pet 
owners  
The transitional regime allows Finla nd, Ireland, Malta, Sweden and the UK to 
maintain their national rules, irrespective of the pet health status of the Member State 
of origin. These rules — additional animal health requirements and/or transport and 
route requirements — differ considerabl y, making it difficult for travellers to 
understand the conditions in force in th e Member States and hampering long 
journeys that pass throug h these Member States.  
This situation not only causes additional costs for pet owners (See Table 2  — 
estimated costs), but has give n rise to complaints from individuals and Member State 
authorities. 
1.2.2. Equivalence of health status for rabies, Echinococcosis (E. multilocularis) and ticks 
in the Member States — EFSA opinions 
1.2.2.1. Rabies 
The EFSA recommended applying risk mitigating measures to primo-vaccinated pet 
animals coming from areas where the prev alence of rabies in the pet population is 
more than one case per million pets per year, namely the Baltic States.  
Countries where the rate of reported rabi es cases in wildlife was higher (e.g. Baltic 
States) have made over the past three years additional efforts to eradicate the disease 
and continue to monitor the situation. 
As a result, the disease occurrence in domestic animals has diminished and the 
situation can now be considered as roughly equivalent in all EU-27 Member States 
and comparable to the situation in those EU-15 Member States where rabies in wildlife had still been a significant probl em when Regulation (EC) No 998/2003 was 
adopted. 
No cases of rabies caused by legal cro ss-border pet moveme nts within the EU, 
including from the Baltic States, have been  recorded for many years, particularly 
since the Regulation entered into force.  
The Community criteria so far applicable to the listing of a third country are not 
based on the prevalence of rabies in the pe t population used by the EFSA, since they 
 
EN 5   EN take into account the impleme ntation of regulatory measur es to preven t and control 
rabies, how competent authorities guarantee the validity of the certification and the 
quality of the monitoring sy stem and vaccines. Thus, third countries, such as the 
United States of America and the Russian Federation, have been accepted by the EU 
under the general regime, despite having a highe r incidence of rabies  in wildlife than 
the Baltic States. 
1.2.2.2. Echinococcosis (Echinococcus multilocularis) 
According to the EFSA, a number of is olated surveys in wildlife show great 
variations from one country to another and even between regions in the same country. Therefore it is extrem ely difficult to compare epid emiological situations and 
any evaluation of the epidemiology can only be an approximation. Very few data on the infection rates of pet dogs and cats are av ailable, and existing data are difficult to 
interpret due to a lack of inform ation on the sampling strategies.  
Surveys conducted in Finland to detect E. multilocularis  in dogs and rodents have so 
far yielded negative results. Ireland, Malta, Sweden and the UK have not provided 
any information on surveillance in domes tic dogs but claim absence in wildlife and 
indigenous people.  
From the limited number of published surv eys on infection in pets in Europe, it 
seems that tapeworm infection rates in domestic carnivores are low, most likely due to low exposure to the intermediate stages of the parasite and to routine deworming.  
Imported human cases have been reported in non-endemic areas. This shows that the 
risk of people travelling to endemic ar eas (whether or not from non-endemic areas) 
and contracting the disease by accidentally ingesting tapeworm eggs through contact 
with infected pets or contaminated wild or  cultivated fruits and vegetables cannot be 
excluded.  
1.2.2.3. Ticks 
According to the EFSA, tick species harbour ed by pets are widespread in Europe, 
including in the UK, Ireland and proba bly Malta. Surveillance systems for tick 
species and tick-transmitted diseases are limited and incomplete. The current available data indicate a lack of syst ematic specimen collection, epidemiological 
background and effective control measures. Some of the available information is 
either anecdotal or outdated. 
2. O
BJECTIVES  
The overall objectives are to be seen in th e light of the free circulation of people (EC 
Treaty) and the new Animal Health Strategy.  
The specific objectives are: 
• To harmonise requirements to rem ove disproportionate obstacles to the 
movement of pets for non-commercial pur poses across the EU or entering the 
EU from third countries, while properly pr otecting public and animal health , in 
particular with regard to rabies.  
 
EN 6   EN • To provide EU rules that are proportiona te, avoid causing difficulties and give 
clear benefits in terms of clarity and simplification for travelling pet owners. 
The operational objective is to determine the regime to be applied as from 1 July 
2010. 
3. K EY POLICY OPTIONS  
The Commission has identified four polic y options to achieve the objectives: 
Option 1 : No Action  
This would mean that after 30 June 2010, Finland, Ireland, Malta,  Sweden and the 
UK will no longer make the entry of pet animals into their territory subject to additional requirements regarding rabies, echinococcus and ticks. The particular 
bilateral arrangements existing between those Member States will also cease. 
Option 2
: Extension of the transitional regime 
This would mean a further temporary extension of the transitional period until the 
end of 2011, which is when the Commission expects to end EU support to national 
programmes to eradicate sylvatic rabies in the Baltic States. A substantially 
improved situation in those Member States would fully address the risks identified 
by the EFSA and render its recommendations for mitigating measures obsolete.  
Option 3 : Adjustment  of the current rules applic able to all Member States 
This would mean ending the specific conditions applied by the five Member States 
including the bilatera l arrangements and proposing a technically reviewed regime in 
line with the EFSA which recommends that th e health status of the Member State of 
origin should determine the regime.  
Option 4 : Continuation of the transition al regime on a permanent basis 
This would mean an indefinite extension of the transitional regime and therefore 
enable the five Member States to systematically request additional guarantees. It is not excluded that other Member States comp lying with OIE criteria for a rabies-free 
country or claiming a special status wi th regard to tick borne disease or 
echinococcosis, would equally request additional conditions.  
4. I
MPACT ANALYSIS  
4.1. Preliminary remarks 
Under the Regulation, the cost of prepar ing a pet dog or cat for travel varies 
according to the country of origin and the Member State of destination (See Table 2  
— cost of a travel for the first time, mean ing that identificati on, vaccination and, 
where necessary, antibody titration must  be carried out before travel). 
 
EN 7   EN Table 2 does not take into account the particular arrangements existing between the 
Member States under the transitional regime that may lead to a significant reduction 
of preparation costs.  
Table 2 shows that it is more expensive for an EU citizen to travel with its pet to 
Member States under the transi tional regime, except to Finla nd, than to return from a 
non-listed third country unde r the general regime. 
4.2. Option 1 
4.2.1. Economic impacts 
This option would certainly benefit citizen s by removing the costs due to additional 
requirements requested by the Member States under the transitional regime. 
Conversely, citizens originating in and moving between Member States currently 
under the transitional regime will be affected  since the bilateral arrangements will 
cease. 
Authorised veterinarians w ould certainly benefit from an expected increase in 
numbers of travelling pets. 
The impact of this option on EU-approved labs should be minimal since laboratory 
incomes generated by testing pet animals en tering or re-entering the EU from non-
listed countries would not be  affected. Impacts would be  more important for labs 
which have exclusively oriented their act ivities to respond to  those obligations. 
There should be no or marginal impacts on suppliers of medicines for the treatment 
against tick or echinococcus since such tr eatments are also recommended for animal 
and public health reasons. 
This option is unlikely to have negative impacts on transport companies ('carriers') 
since the checking system would be simplif ied. It can be assumed that with this 
option, new business opportunities will be open to carriers to offer their services to 
travellers with pet animals. 
This option may have a significant impact on the business of the quarantine facilities 
in Ireland, Malta, Sweden and the UK. A nu mber of facilities which license into 
long-term quarantine pet animals originati ng in non listed third countries may cease 
operations. However short-term stays may re main for reasons other than incorrect 
anti-tick/echinococcus treatment.  
4.2.2. Social impacts 
EU-approved labs may suffer if this option is selected. However, most labs intend to 
redeploy staff to other lab activities.  
This option, which simplifies the rules, may have a positive impact on tourism and 
therefore on employment in general. 
Pets will no longer be separated from their owners as the long-term quarantine 
system will disappear. 
 
EN 8   EN As regards public health impacts, the risk  of introducing rabies by pets travelling 
from the Baltic States under the general regime can be esti mated with high degree of 
certainty to be no higher than the risk a ssociated with movements between the other 
Member States or from listed third countries , such as the United States of America or 
the Russian Federation, despite a more sinist er rabies situation in their wildlife. 
Pets are not the only cause of human infec tion from alveolar echinoccocosis. It is 
therefore unjustified to concentrate risk-mitigating measures exclusively on pet animals travelling with their owners. No causative impacts on public health, and in 
particular on the extension of the geogra phical distribution of tick species and tick 
borne diseases, will necessarily be recorded. 
4.2.3. Environmental impacts 
The simplification would certainly lead to an increase in the number of pet 
movements. However, impacts of this opt ion on the environment are difficult to 
quantify.  
4.3. Option 2 
4.3.1. Economic impacts 
Until the end of 2011, citizens will continue  to pay additional costs and probably 
contribute to sustaining the income of ve terinarians and EU-approved laboratories. 
This will also help temporarily sustain carriers and quarantine facilities' incomes due 
to the monopoly situation gene rated by the current system. 
4.3.2. Social impacts 
Until the end of 2011, no impact on employment  is expected and trip disturbances 
will remain. 
As regards the public health impacts, the recent figures published in Rabies Bulletin 
Europe  indicate that rabies is likely to be er adicated in the Baltic States by the end of 
this extension period. This option would help make pet movements in EU safer and 
as a result decrease the potential risk to public hea lth. However, as no human cases 
of rabies have been traced to pets travelling from the Baltic States, the difference is expected to be very minimal. 
4.3.3. Environmental impacts 
No major change from the current situation is expected. 
4.4. Option 3 
4.4.1. Economic impacts 
This option would lead to additional cost s for owners of primo-vaccinated pets 
originating in the Baltic Stat es, as recommended by the EFSA.  
 
EN 9   EN Veterinary incomes should not increase s ubstantially since the population concerned 
is rather limited. 
This option would have a similar impact on anti-parasite suppliers, carriers and 
quarantine facilities than Option 1.  
4.4.2. Social impacts 
Since the population of pet animals covered by specific additional rules is rather 
limited, the impacts on pet owners an d tourism would also be limited. 
Practical findings have indicated that the negative impacts on public health would be 
marginal. 
4.4.3. Environmental impacts 
No major impacts on the environment can be predicted since the impact of this 
option on the number of pet move ments cannot be quantified. 
4.5. Option 4 
4.5.1. Economic impacts 
In the longer term, citizens will continue to face additional costs when going or 
returning to Member States currently under the transitional regime. On the contrary, 
citizens originating in and moving betw een Member States currently under the 
transitional regime will continue to be nefit from the bilateral arrangements. 
This option will probably help sustain the income of EU-approved labs and due to 
the monopoly situation generate d by the current system, the income of carriers and 
quarantine facilities as well. 
4.5.2. Social impacts 
The work of EU-approved serology laborator ies, ‘carriers’, qua rantine facilities, 
authorised veterinarians and anti-parasite  treatment suppliers would continue and 
should not give rise to particular unemployment risks. 
Pet animals entering the EU from non-lis ted third countries or those not in 
compliance with the national rules (short-term quarantine stays) would still be put in 
quarantine. In these cases, social (and/or welfare) im pacts should be considered 
where pet animals are separated from th eir owners for at least six months. 
It can be reasonably assumed that there will be no significant clear benefits in terms 
of public health (as ex plained in section 1.2.2.1). 
4.5.3. Environmental impacts 
Although pet travel is on the increase and may impact the en vironment, it is difficult 
to establish a correlation between the curre nt restrictive regimes and the number of 
pets (and pet owners) travelling. 
 
EN 10   EN 4.6. Conclusions 
Options 3 and 4  do not appear to provide added value to solving the most acute 
problems voiced by administrations and citizens affected by a complicated, burdensome and inconsistent system of ex cessive and unjustified animal health 
requirements, in particular regarding rabies. 
Option 3 would not only increase confusi on amongst travellers dealing with new 
regimes according to the country of origin, but also completely disregard other risk-relevant aspects considered in listing third countries. It would give the Baltic States 
an unjustifiable bad reputation and discrimi nate against them in favour of certain 
listed third countries. This is contrary to th e fundamental principles of the EU Treaty. 
It would also disregard Member State requests for simplification based on field 
evidence. 
Option 4 would continue to place a heavy burden on citizens trav elling to or re-
entering the five Member States and possi bly other disease-free Member States.  
These options are a far cry from the desire of most Member States to achieve 
harmonisation and simplify pet movements w ithin and into the EU, considering the 
similarity of the animal health situation in the EU. 
Options 1 and 2  are similar in principle. Either  would entail removing, sooner or 
later, the unjustified disparities, discri mination and burden on citizens, including 
citizens from the five Member States w ho are affected by a dditional requirements 
when returning from abroad.  
At the same time, both options would maintain a high level of safety for pet animals 
travelling within and into the EU by appl ying the general regi me, which has proven 
to be effective in preventing human and pet animal cases of rabies caused by lawful movement of pets between and into Member States.  
There is a slight advantage in selecting Option 2 over Option 1. In terms of lowering 
the public health risk, a reasonable extens ion of the transitional measures would 
defer the application of the general regime throughout the EU to a point in time when 
EU-supported measures to eradicate remaining pockets of sylvatic rabies in the EU 
(and neighbouring territories) will rende r the EFSA recommendations on risk 
mitigation redundant.  
5. M
ONITORING AND EVALUATION  
To ensure that the new regime achieves the objectives set in Section 2, the 
Commission will regularly monitor several indicators to assess its performance. 
Data on indicators will be collected through di fferent existing sources of information. 
Additional data may be genera ted, especially surveys and/or interviews to measure 
the level of satisfaction among the populati on/pet owners. Data from Member State 
authorities (on pet movements and on public health) will be collected regularly at EU 
level as part of reinforced  cooperation processes with Me mber States by the Standing 
Committee for Food Chain and Animal Health (SCoFCAH).  
 
EN 11   EN External evaluations at this stage are considered disproportionate. The monitoring 
mechanisms will provide sufficient informa tion to assess the ca se for revising the 
Regulation at a later stag e (in 5-10 years) unless the situation changes. 
 
EN 12   EN Table 1 : Overview of the rules applied by Member States under the transitional regime 
Legal 
regime Measures IE MT SE UK FI  
Identification by passport and microchip or tattoo 
until 2011 (Article 4) x x x x x 
Valid anti-rabies vaccination (Article 5) x x x x x General 
Regime Simplified import regime for pet animals (Article 
8(3)(b))   Norway   
Microchip compulsory x x  x n/a 
Mandatory antibody titration before entry into their 
territory to confirm a protective level of anti-rabies antibodies x x x x n/a Article 6(1) Exemptions from the anti-rabies vaccination and 
antibody titration requirements for pet dogs and cats moving between these Member States x x x x n/a 
Pet animals entering from listed third countries 
must comply with same rules as pets from other EU Member States  x x x x n/a Article 8(1) Pet animals entering from non-listed third countries 
are to be put in quarantine x x x x n/a Article 
16 Mandatory anti-parasite treatment against 
Echinococcus/ticks x x x x x Community provisions 
Article 
21 Exemptions from the passport, anti-rabies 
vaccination and antibody titration requirements for Danish dogs and cats transiting through Sweden    Denmark
3  Article 
16 Exemptions from anti-parasite treatment against 
Echinococcus/ticks x x x x x Transitional regime  
National Rules 
No legal basis in 
Regulation Approved transport companies  x x  x  Free movement regime 
National Rules 
No legal basis in 
Regulation Exemptions from the identification and passport 
requirements for pet dogs and cats moving between Ireland and the UK x   x  
                                                 
3 Commission Decision 2004/557/EC (OJ L 249, 23.7.2004, p. 18). 
 
EN 13   EN Table 2 : ESTIMATED COSTS  
for a dog of average size travelling within the EU or re-entering the EU after a trip abroad ( source: Member States' competent authorities ) 
 Identification 
(microchip + 
passport) Vaccination 
documented in 
the passport Sampling + 
certification test Anti-tick 
treatment Anti-
echinococcus 
treatment ‘Carriers’ Quarantine Total 
General regime 
Pet travelling 
within EU €42.934 
(€15 to 95.5) €22.504 
(€2 to 63) - - - - - - €65.43 
Pet re-entering EU 
from listed third 
countries  €42.934 
(€15 to 95.5) €22.504 
(€2 to 63) - - - - - - €65.43 
Pet re-entering EU 
from non listed 
third countries €42.934 
(€15 to 95.5) €22.504 
(€2 to 63) €29.204 
(€5 to 53) €50 
(€30 to 88) - - - - €144.63 
Transitional regime 
Pet entering/re-
entering UK, IE, 
MT from the rest of EU  €50.50 
(€15 to 107) €26.70 
(€2 to 63) €34 
(€5 to 69) €50 
(€30 to 88) €18.80 
(€5 to 56) €16.80 
(€1 to 39.30)  UK: N/A 
IE: ferry=
€20, 
plane=€910, 
MT: €72 - € 196.80 
(+ carriage 
costs) 
Pet entering/re-entering SE from the rest of EU  €50.50 
(€15 to 107) €26.70 
(€2 to 63) €34 
(€5 to 69) €50 
(€30 to 88) - €16.80 
(€1 to 39.30)  - - €178 
Pet entering/re-
entering FI from the 
rest of EU  €50.50 
(€15 to 107) €26.70 
(€2 to 63) - - - €16.80 
(€1 to 39.30)  - - €94 
Pet entering UK, 
IE, MT, SE from 
non listed third countries  - - - - - - - UK: €3480 
IE: €2500 MT: €1000 SE: €3350 €3480 
€2500 €1000 €3350 
                                                 
4 Figures excluding those provided for by the UK, IE, MT, SE and FI. 
 
EN 14   EN