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 laying down the animal health requirements applicable to the non-commercial movement of pet animals   IMPACT ASSESSMENT
Date: 2009-06-16
Institutions: European Commission
Subjects: EU action, animal health, animal welfare, domestic animal, health certificate, transport of animals, veterinary inspection

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SANCO/4560/2009 (POOL/D1/2009/4560/4560IA-EN.doc) 

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COMMISSION OF THE EUROPEAN COMMUNITIES 

Brussels, 16.6.2009 
SEC(2009) 776 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 laying down the animal health requirements 
applicable to the non-commercial movement of pet animals 

IMPACT ASSESSMENT 

{COM(2009) 268 final} 
{SEC(2009) 777} 

Lead DG: DG SANCO 
Other involved services: AGRI, ENTR, SG, TAXUD, TRADE 
Agenda planning: 2008/SANCO/010 
The report commits only the Commission’s services involved in its preparation and the text is 
prepared as a basis for comment and does not prejudge the final form of any decision to be 
taken by the Commission. 

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TABLE OF CONTENTS 

1. 

2. 

2.1. 

2.2. 

Executive summary...................................................................................................... 7 

Procedural issues and consultation of interested parties ............................................ 10 

Procedural issues........................................................................................................ 10 

Consultation of interested parties............................................................................... 10 

2.2.1.  Public consultation..................................................................................................... 10 

2.2.2.  Consultation of competent authorities ....................................................................... 11 

2.2.3.  Consultation of the European Food Safety Authority (EFSA) .................................. 12 

2.2.4.  Consultation of EU-approved serology laboratories.................................................. 12 

2.2.5.  Consultation of the Union of European Veterinary Practitioners (UEVP) ................ 12 

2.2.6. 

Inter-Service Steering Group (ISSG) ......................................................................... 13 

2.2.7. 

Impact Assessment Board (IAB) ............................................................................... 13 

3. 

Problem identification................................................................................................ 14 

3.1. 

Legal background....................................................................................................... 14 

3.1.1.  Legal obligation to review the Regulation ................................................................. 14 

3.1.2.  General regime ........................................................................................................... 15 

3.1.2.1.  Movements within the EU ......................................................................................... 15 

3.1.2.2.  Entry into the EU ....................................................................................................... 15 

3.1.3.  Transitional regime .................................................................................................... 16 

3.1.3.1.  Rabies......................................................................................................................... 16 

3.1.3.2.  Echinococcus/ticks..................................................................................................... 17 

3.1.3.3.  Bilateral regime between Sweden and Denmark ....................................................... 17 

3.1.4.  Free movement regime between the UK and Ireland................................................. 17 

3.2. 

Issues to tackle ........................................................................................................... 20 

3.2.1.  The current national rules are complex and place a considerable burden on pet 

owners ........................................................................................................................ 20 

3.2.2.  Equivalence of health status for rabies, Echinococcosis (E. multilocularis) and ticks 

in the Member States.................................................................................................. 23 

3.2.2.1.  Rabies......................................................................................................................... 23 

3.2.2.2.  Echinococcosis (Echinococcus multilocularis).......................................................... 26 

3.2.2.3.  Ticks........................................................................................................................... 26 

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3.3. 

The principle of subsidiarity ...................................................................................... 26 

4. 

5. 

6. 

Objectives................................................................................................................... 26 

Key policy options ..................................................................................................... 26 

Impact analysis........................................................................................................... 28 

6.1. 

Preliminary remarks ................................................................................................... 28 

6.1.1.  Costs incurred by owners to prepare a pet ................................................................. 29 

6.1.2.  Administrative costs................................................................................................... 31 

6.2. 

Analysis of impacts of option 1: No action................................................................ 31 

6.2.1.  Economic impacts ...................................................................................................... 32 

6.2.1.1.  Pet owners .................................................................................................................. 32 

6.2.1.2.  Authorised veterinarians ............................................................................................ 33 

6.2.1.3.  EU-approved rabies serology laboratories ................................................................. 33 

6.2.1.4.  Suppliers of anti-parasite treatments.......................................................................... 34 

6.2.1.5.  Transport companies ('carriers') ................................................................................. 34 

6.2.1.6.  Quarantine facilities ................................................................................................... 34 

6.2.1.7.  Competent authorities ................................................................................................ 35 

6.2.1.8.  Third countries ........................................................................................................... 35 

6.2.1.9.  Others ......................................................................................................................... 35 

6.2.2.  Social impacts ............................................................................................................ 35 

6.2.2.1.  Employment ............................................................................................................... 35 

6.2.2.2.  Welfare of citizens ..................................................................................................... 36 

6.2.2.3.  Public health............................................................................................................... 36 

6.2.3.  Environmental impacts .............................................................................................. 38 

6.3. 

Analysis of impacts of option 2: Extension of the transitional regime...................... 38 

6.3.1.  Economic impacts ...................................................................................................... 39 

6.3.2.  Social impacts ............................................................................................................ 39 

6.3.3.  Environmental impacts .............................................................................................. 39 

6.4. 

Analysis of impacts of option 3: Adjustment of the current rules applicable to all 
Member States............................................................................................................ 39 

6.4.1.  Economic impacts ...................................................................................................... 40 

6.4.1.1.  Pet owners .................................................................................................................. 40 

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6.4.1.2.  Authorised veterinarians ............................................................................................ 40 

6.4.1.3.  EU-approved rabies serology laboratories ................................................................. 40 

6.4.1.4.  Anti-parasite treatment suppliers ............................................................................... 41 

6.4.1.5.  Transport companies ('carriers') ................................................................................. 41 

6.4.1.6.  Quarantine facilities ................................................................................................... 41 

6.4.1.7.  Competent authorities ................................................................................................ 41 

6.4.1.8.  Third countries ........................................................................................................... 41 

6.4.2.  Social impacts ............................................................................................................ 41 

6.4.2.1.  Employment ............................................................................................................... 41 

6.4.2.2.  Welfare of citizens ..................................................................................................... 42 

6.4.2.3.  Public health............................................................................................................... 42 

6.4.3.  Environmental impacts .............................................................................................. 42 

6.5. 

Analysis of impacts of option 4: Continuation of the transitional regime on a 
permanent basis ......................................................................................................... 42 

6.5.1.  Economic impacts ...................................................................................................... 42 

6.5.1.1.  Pet owners .................................................................................................................. 42 

6.5.1.2.  Authorised veterinarians ............................................................................................ 43 

6.5.1.3.  EU-approved rabies serology laboratories ................................................................. 43 

6.5.1.4.  Anti-parasite treatment suppliers ............................................................................... 44 

6.5.1.5.  Transport companies ('carriers') ................................................................................. 44 

6.5.1.6.  Quarantine facilities ................................................................................................... 45 

6.5.1.7.  Competent authorities ................................................................................................ 45 

6.5.1.8.  Impact on third countries ........................................................................................... 45 

6.5.2.  Social impacts ............................................................................................................ 45 

6.5.2.1.  Employment ............................................................................................................... 45 

6.5.2.2.  Welfare of citizens ..................................................................................................... 46 

6.5.2.3.  Public health............................................................................................................... 46 

6.5.3.  Environmental impacts .............................................................................................. 46 

7. 

7.1. 

7.2. 

Comparison of the different options .......................................................................... 46 

Comparison of impacts .............................................................................................. 46 

Discussing the options ............................................................................................... 51 

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8. 

9. 

Monitoring and evaluation ......................................................................................... 54 

Conclusion ................................................................................................................. 55 

ANNEX 1................................................................................................................................. 57 

ANNEX 2................................................................................................................................. 59 

ANNEX 3................................................................................................................................. 60 

ANNEX 4................................................................................................................................. 63 

ANNEX 5................................................................................................................................. 65 

ANNEX 6................................................................................................................................. 66 

ANNEX 7................................................................................................................................. 68 

ANNEX 8................................................................................................................................. 69 

ANNEX 9................................................................................................................................. 73 

ANNEX 10............................................................................................................................... 75 

ANNEX 11............................................................................................................................... 77 

ANNEX 12............................................................................................................................... 78 

ANNEX 13............................................................................................................................... 81 

ANNEX 14............................................................................................................................... 82 

ANNEX 15............................................................................................................................... 83 

ANNEX 16............................................................................................................................... 84 

ANNEX 17............................................................................................................................... 85 

ANNEX 18............................................................................................................................... 89 

ANNEX 19............................................................................................................................... 90 

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ANNEX 20............................................................................................................................... 93 

ANNEX 21............................................................................................................................... 95 

ANNEX 22............................................................................................................................... 99 

ANNEX 23............................................................................................................................. 102 

ANNEX 24............................................................................................................................. 103 

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1. 

EXECUTIVE SUMMARY 

The  item  is  part  of  the  Commission  agenda  planning  /work  programme  under  the 
reference 2008/SANCO/010. 

Regulation (EC) No 998/20031 of the European Parliament and of the Council ('the 
Regulation')  lays  down  harmonised  animal  health  requirements  applicable  to  non-
commercial  movements  of  pet  animals  within  and  into  the  Community  ("general 
regime"). 

The  rules  established  by  the  Regulation  are  the  outcome  of  a  controversial 
discussion, in particular on rabies, which resulted in a delicate compromise granting 
certain special conditions to five Member States for a transitional period of time. 

Indeed, the Regulation grants a period of five years starting from the date of its entry 
into  force,  i.e.  until  3  July  2008  (extended  to  30  June  20102),  to  Finland,  Ireland, 
Malta, Sweden and the United Kingdom to make the entry of pet animals into their 
territory  subject  to  compliance  with  certain  additional  requirements  to  prevent  the 
risk of introducing rabies, echinococcus 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  based  on  experience  gained  and  on  a  risk 
evaluation  together  with  appropriate  proposals  for  determining  the  regime  to  be 
applied at the end of the transitional period. The Commission adopted its report3 on 
8 October 2007 together with a proposal to the Council and the European Parliament 
to briefly extend the transitional measures until September 2009 (further deferred to 
30  June  20102)  to  allow  sufficient  time  to  consider  all  aspects  and  consult  all 
interested parties on the options. 

In the light of its report, the outcome of various recent consultations conducted and 
the available updated information on the diseases concerned - rabies, Echinococcosis 
and/or tick-borne diseases - in the whole EU, the Commission should now assess the 
long-term options and in particular the case for extending the general regime to the 
Member States currently operating under the transitional regime. 

When evaluating the available options for determining the regime to be applied after 
the end of the transitional period, the Commission's primary objective is to ensure a 
sufficiently high, risk–adequate and proportionate level of protection of animal and 
public health. The operational objective is to determine the regime that will supplant 
the  transitional  regime  as  of  1  July  2010.  These  are  the  purposes  of  the  current 
impact assessment. 

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http://eur-lex.europa.eu/LexUriServ/site/en/consleg/2003/R/02003R0998-20081122-en.pdf. 
In  order  to  take  account  of  amendments  requested  by  the  European  Parliament  in  relation  to  the 
forthcoming  elections  for  the  European  Parliament  in  2009,  The  Council  and  European  Parliament 
eventually  agreed  to  defer  the  date  proposed  by  the  Commission  to  30  June  2010  by  adopting 
Regulation (EC) No 454/2008 of 21 May 2008 of the European Parliament and of the Council. 
http://ec.europa.eu/food/animal/liveanimals/pets/petreport_en.htm  

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The  Commission  has  accordingly  identified  four  policy  options  and  impacts  of  an 
economic, social and environmental nature were considered for each of them: 

Option  1:  No  action  -  this  option  means  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.  

Option  2:  Extension  of  the  transitional  regime  –  this  option  means  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 rabies situation in those 
Member  States  would  fully  address  the  risks  identified  by  EFSA  and  render  its 
recommendations  for  mitigating  measures  obsolete.  This  option  would  require  a 
Commission  proposal  to  the  European  Parliament  and  the  Council  extending  the 
transitional period for the five Member States that currently apply special rules and 
clarifying the regime that would apply as from 1 January 2012. 

Option  3:  Adjustment  of  the  current  rules  applicable  to  all  Member  States  –  this 
option means ending the specific conditions applied by the five Member States and 
implementing  a  harmonised  regime  by  means of  a  technically  reviewed  Regulation 
based on a Commission proposal taking into account the EFSA opinions. 

Option 4: Continuation of the transitional regime on a permanent basis – this option 
means  an  indefinite  extension  of  the  transitional  regime  and  therefore  enables  the 
Member  States  claiming  free  status,  including  Finland,  Ireland,  Malta,  Sweden  and 
the UK, to systematically request additional guarantees. This option would require a 
Commission  proposal  to  the  European  Parliament  and  the  Council  to  ensure  equal 
treatment of all Member States. 

A Commission proposal to the European Parliament and the Council, as per options 
2,  3  and  4,  should  in  any  case  enhance  legal  clarity  by  addressing  some  unclear 
provisions of the current Regulation, in particular concerning the regime that would 
apply in all Member States at the end of the transitional period. However, any such 
proposal might lead, at Council and European Parliament level, to reopening of the 
debate  on  some  fundamental  aspects  of  the  Regulation  not  covered  by  the  present 
impact assessment and for which a delicate compromise was achieved in 2003. 

Following  on  from  the  impact  assessment,  preference  has  been  given  to  options  1 
and 2, which are similar in principle. Either would entail removing, sooner or later, 
the  unjustified  disparities,  discrimination  and  burden  felt  by  citizens  including 
citizens  from  the  five  Member  States  who  are  affected  by  additional  requirements 
when returning from abroad. At the same time, both options would maintain a high 
level  of  safety  for  pet  movements  within  and  into  the  EU,  by  applying  the  general 
regime, which has proved to be effective in preventing human and pet animal cases 
of rabies caused by lawful movement of pets between and into Member States.  

Both  options  also  take  into  account  most  of  the  EFSA  recommendations,  in 
particular  those  related  to  echinococcus  and  ticks.  As  regards  rabies,  EU-supported 
national eradication programmes in Member States with sylvatic rabies have recently 
led to a quasi-equivalent situation in all Member States which is comparable to the 
situation  in  those  EU-15  Member  States  where  rabies  in  wildlife  was  still  a 

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significant  problem  when  Regulation  (EC)  No  998/2003  was  adopted.  The  current 
situation  does  not  justify  the  implementation  of  differentiated  and  discriminatory 
rules  according  to  the  country  of  origin.  Beefing  up  the  risk  assessment  with 
elements other than those used by EFSA has proved to be effective in preventing the 
introduction of rabies through pet movements from listed third countries such as the 
USA and the Russian Federation with a significantly higher prevalence of rabies in 
wildlife than Member States with remaining sylvatic rabies. 

Both options would ensure that there is sufficient time for the competent authorities 
of Finland, Ireland, Malta, Sweden and the UK to provide the public with clear and 
easily accessible information concerning the new rules.  

There is a slight advantage in selecting option 2 over option 1. In terms of lowering 
the  public  health  risk,  a  reasonable  extension  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 
will  render  the  EFSA  recommendations  on  risk  mitigation  redundant.  Moreover,  in 
accordance  with  the  Regulation,  by  2011  electronic  identification  will  be  the  only 
means of identifying an animal. This should ensure additional safety and security of 
the  movement  of  pet  animals  since  the  new  system  in  place  would  avoid 
falsifications and make the identification information easier to read. Option 2 would 
also  clarify  the  regime  that  would  apply  at  the  end  of  the  transitional  period  in  all 
Member States.  

Given  the  enlargement  of  the  Schengen  area  and  the  consequent  disappearance  of 
control  points,  such  a  delay  could  be  sufficient  to  dispel  remaining  concerns  and 
prejudices  about  the  perceived  risks  related  to  pet  movements  and  thus  facilitate 
acceptance of the general regime in all Member States.  

In contrast, options 3 and 4 do not appear to contribute meaningfully to solving the 
most  acute  problems  voiced  by  administrations  and  citizens  affected  by  a 
complicated,  burdensome  and  inconsistent  system  of  excessive  and  unjustified 
animal health requirements regarding the diseases concerned. 

Option 3 would take full account of the EFSA opinion on rabies, which recommends 
additional risk-mitigating measures for certain categories of pet animals coming from 
Baltic  States.  It  would,  however,  not  only  increase  confusion  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  those  Member  States  an  unjustifiable  bad  reputation  and  discriminate  against 
them in favour of certain listed third countries. This is contrary to the fundamental 
principles  of  the  EU  Treaty.  It  would  also  disregard  Member  States'  requests  for 
simplification based on field evidence. 

Moreover,  when  redesigning  the  rules  for  movement  of  pets  on  technical  grounds 
(option 3), the most likely scenario would be that those Member States that currently 
benefit  from  the  transitional  regime  would  have  no  reason  to  depart  from  their 
traditionally  very  restrictive  policy,  other  equally  rabies-free  Member  States  might 
well  perceive  the  general  regime  as  excessive,  and  the  Baltic  States,  given  their 
improved situation, might see it as discriminatory. The result would be a compromise 

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that further diversifies the movement conditions and dismantles an efficient and well-
tried regime without improving the overall level of protection within the EU. 

Option 4 would assign to the five Member States, and possibly to other free Member 
States in the future, a particular status with regard to the diseases concerned which is 
not supported by the relevant scientific EFSA opinions. It is a far cry from the desire 
of most Member States to achieve harmonisation and simplify pet movements within 
and into the EU, considering the similarity of the animal health situation in the EU. It 
would  continue  to  prove  onerous  for  citizens  including  those  re-entering  the  five 
Member  States  and  possibly  other  free  Member  States.  This  option  is  likely  to  be 
opposed by most of the Member States as it will appear to be granting scientifically 
unjustified privileges. 

2. 

PROCEDURAL ISSUES AND CONSULTATION OF INTERESTED PARTIES 

2.1. 

Procedural issues 

The  item  is  part  of  the  Commission  agenda  planning  /work  programme  (reference 
2008/SANCO/010). 

This  Impact  Assessment  ('the  IA')  follows  the  structure  given  in  the  Commission’s 
IA guidelines SEC (2005)791 of 15 June 2005.  

2.2. 

Consultation of interested parties 

In  accordance  with  Article  23  of  Regulation  (EC)  No  998/2003  of  the  European 
Parliament and of the Council laying down the animal health requirements applicable 
to the non-commercial movement of pet animals ('the Regulation'), the Commission 
was  required  to  submit,  before  1  February  2007,  a  report  together  with  appropriate 
proposals for a revised regime, based on a risk evaluation and on experience gained 
by the Member States. 

To  this  end,  the  Commission  has  officially  consulted  the  European  Food  Safety 
Authority (EFSA) and the competent authorities of Member States. The Commission 
Report to the European Parliament and the Council was adopted on 8 October 20074. 

Moreover,  in  order  to  collect  data  for  producing  its  impact  assessment,  the 
Commission has also consulted other interested parties. 

2.2.1.  Public consultation 

The  above-mentioned  Commission  report  has  been  placed  on  the  DG  SANCO 
website and interested parties have had the opportunity to send their comments on it, 
including the last section of the report, which lists preliminary options to adapt the 
regime. No reaction from the public has been recorded so far. 

The  Commission  has  also  registered  an  increase  of  Parliamentary  questions  in 
relation to the Regulation and mainly concerning complaints from British, Irish and 

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COM(2007) 578 final. 

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Swedish  citizens  on  the  difficulties  encountered  in  moving  pets  to  those  Member 
States under the transitional regime. 

2.2.2.  Consultation of competent authorities 

With  a  view  to  producing  its  report,  the  Commission  officially  requested  the 
27 Member States' competent authorities in October 2006 to provide information on 
experience  gained  so  far  with  the  implementation  of  Articles  6,  8  and  16  of  the 
Regulation  (Annex  1).  This  drew  a  significant  response  from  20  Member  States5 
ranging from a detailed report based on external surveys to a short statement. 

In order to help EFSA with its opinions on echinococcosis and ticks, the Commission 
officially requested in December 2005 that the five Member States which have been 
allowed  to  retain  their  national  rules  according  to  Article  16  of  the  Regulation 
provide a report on the situation with regard to those diseases, setting out grounds for 
the need for additional guarantees to prevent the risk of introduction of those diseases 
(Annex 2). Except Malta, four Member States did provide a report. 

With  a  view  to  producing  this  impact  assessment,  on  27  September  2007  the 
Commission  officially  requested  the  five  Member  States  that  have  been  allowed  to 
retain  their  national  rules  to  provide  all  the  information  they  consider  relevant  and 
useful  for  drawing  up  the  impact  assessment,  in  particular  the  impact  on  approved 
transport companies ('carriers') and quarantine facilities if national rules were to be 
withdrawn  and  the  outcome  of  any  stakeholder  consultation  (Annex  3).  The  five 
Member States did provide a detailed answer. 

In  addition,  on  23  November  2007  the  Commission  officially  requested  the  27 
Member  States  to  provide  information  on  the  average  costs  of  preparation  of  a  pet 
animal incurred by pet owners before movement (Annex 4). This information serves 
as  a  basis  for  any  calculation  of  economic  impacts  of  each  option  identified.  19 
Member States6 did provide a detailed answer. 

In the same context, on 20 December 2007 the Commission also officially requested 
Malta, Ireland, Sweden and the United Kingdom ('the UK') to provide information on 
any arrangements regarding rabies which may exist between them in accordance with 
the  provisions  of  the  last  paragraph  of  Article  6  of  the  Regulation  (Annex  5).  The 
four Member States provided a detailed answer. 

Following  the  initial  consultations,  more  detailed  information  was  sought  from  the 
competent authorities of some Member States (e.g. Sweden in the framework of the 
bilateral  agreement  existing  between  Sweden  and  Denmark  established  by 
Commission Decision 2004/557/EC7). 

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Except  RO  and  BG  who  were  not  yet  part  of  the  EU;  EE,  GR,  HU  and  MT  did  not  respond  to  the 
consultation. 
AT, BG, DE, FR, GR, PL, SI and SK did not respond to the consultation. 
OJ L 249, 23.7.2004, p. 18. 

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2.2.3.  Consultation of the European Food Safety Authority (EFSA) 

The  European  Food  Safety  Authority  (EFSA)  was  requested  to  issue  a  scientific 
opinion to assist the Commission in its science-based review of the Regulation. 

• 

• 

The Commission asked EFSA on 11 January 2006 to issue a scientific opinion 
on  an  assessment  of  the  risk  of  rabies  introduction  into  the  UK,  Ireland, 
Sweden  and  Malta,  as  a  consequence  of  abandoning  serological  tests 
measuring protective antibodies to rabies. The scientific opinion and its related 
press release were published on 28 February 20078. 

The Commission also asked EFSA on 17 July 2006 to issue a scientific opinion 
on an assessment of the risk of echinococcosis/ticks introduction into the UK, 
Ireland,  Sweden,  Malta  and  Finland  as  a  consequence  of  abandoning  the 
national  rules.  The  scientific  opinions  on  "echinococcosis"  and  "ticks"  were 
respectively published on 26 January 20079 and 19 March 200710.  

Following  its  initial  opinion  on  echinococcosis  risk  and  in  response  to  a  special 
request from Sweden, EFSA was asked by the Commission on 30 October 2008 to 
provide  scientific  advice  on  whether  recent  additional  information  provided  by 
Sweden  would  change  its  previous  scientific  opinion  on  the  subject  (Annex  6).  In 
response, EFSA confirmed that the information provided did not add significant new 
elements and therefore would not change conclusions and recommendations made in 
the opinion (Annex 7). 

2.2.4.  Consultation of EU-approved serology laboratories 

With  a  view  to  producing  this  impact  assessment,  on  27  September  2007  the 
Commission  officially  requested  36  laboratories  that  are  approved  to  perform 
serological  tests,  situated  in  the  EU  and  Switzerland  (out  of  the  54  worldwide 
laboratories), to monitor the effectiveness of rabies vaccines, to fill in a questionnaire 
aiming at evaluating the potential impact on their activities of a regime which may 
restrict the implementation of a test (Annex 8). 

2.2.5.  Consultation of the Union of European Veterinary Practitioners (UEVP) 

The  UEVP  is  an  organisation  of  27  national  organisations  for  veterinary 
practitioners. UEVP is affiliated to the Federation of Veterinarians of Europe (FVE) 
and the largest of FVE's sections. 

UEVP took the initiative to call the Commission's attention on several occasions in 
2006 and 2007 to various issues regarding the review of the Regulation. In response 
to  the  publication  of  the  Commission's  report  on  its  website,  UEVP  expressed  its 
opinion  on  the  review  of  the  regime  provided  for  in  Article  23  of  the  Regulation 
(Annex 9). 

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10 

http://www.efsa.europa.eu/EFSA/efsa_locale-1178620753812_1178620772660.htm  
http://www.efsa.europa.eu/EFSA/efsa_locale-1178620753812_1178620772901.htm  
http://www.efsa.europa.eu/EFSA/efsa_locale-1178620753812_1178620771045.htm  

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12 

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2.2.6. 

Inter-Service Steering Group (ISSG) 

Given  the  cross-cutting  nature  of  the  issues  concerned,  the  Commission  set  up  an 
ISSG  to  collect  specialised  inputs  and  bring  a  wider  perspective  to  the  process 
(Annex 10). 

DGs AGRI, ENTR, SG, TAXUD and TRADE were invited to attend meetings and to 
express comments of which account was taken as far as possible. However, it should 
be noted that the interest of the DGs was limited. 

2.2.7. 

Impact Assessment Board (IAB) 

A  draft  impact  assessment  was  submitted  to  the  IAB  on  20  February  2008  and 
discussed  at  the  Board's  meeting  of  17  March  2008.  The  opinion  of  the  IAB 
published on 19 March 2008 included a number of recommendations for improving 
the impact assessment report. The key amendments made to the impact assessment 
following the issuing of the Board's initial opinion are as follows: 

• 

• 

• 

• 

Refining the comparison of options by defining a clear baseline (option 4) for 
comparing  options.  In  addition,  remarks  on  possible  differentiation  per  group 
of  countries  (Member  States  currently  under  the  transitional  regime;  Member 
States applying the general regime; the UK/Ireland; listed third countries; non-
listed third countries) have been added in the "analysis of impacts" section as 
much as possible.  

Clarifying  in  the  "problem  definition"  section  the  special  regime  applying  to 
pet animals moved between the UK and Ireland. 

Providing additional data on the rabies situation in EU-15 Member States at the 
time when the Regulation was adopted as well as additional data from EU-27 
Member States still affected by epidemics of wildlife rabies. 

Shortening  the  text  to  approximately  30  pages  excluding  annexes,  executive 
summary and tables. 

The  draft  impact  assessment  report  was  re-submitted  to  the  IAB.  The  IAB's  final 
opinion published on 20 January 2009 requested the following amendments: 

• 

• 

Refining the overview table comparing the various options for action (section 
7) to adequately address the recommendations of the previous IAB opinion. 

Clarifying  and  analysing  the  implications  of  the  various  options  as  regards 
continuation  of  the  free  movement  regime  practised  between  Ireland  and  the 
UK. 

The revision of the impact assessment in line with the recommendations of the IAB 
led to a change in the preferred option. 

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3. 

PROBLEM IDENTIFICATION 

3.1. 

Legal background 

3.1.1.  Legal obligation to review the Regulation 

With  a  view  to  completion  of  the  internal  market  associated  with  the  abolition  of 
veterinary  checks  at  the  Community's  internal  frontiers,  harmonised  animal  health 
requirements  were  adopted  by  Council  Directive  92/65/EEC11  as  regards  intra-
Community  trade  in  and  imports  from  third  countries  of  all  animals  and  animal 
products,  including  dogs,  cats  and  ferrets.  However,  as  the  non-commercial 
movement  of  pet  animals  was  a  very  sensitive  issue,  in  particular  in  relation  to 
rabies, rules for such movements were only adopted in 2003. 

Regulation  (EC)  No  998/2003  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  within  and  into  the  Community  ("general 
regime"), with certain derogations being granted for a transitional period of time to 
five Member States ("transitional regime").  

Indeed,  although  measures  adopted  at  Community  level  were  deemed  necessary  in 
this  field,  complete  harmonisation  was  not  achieved  with  the  Regulation.  In  the 
course of the negotiations, it appeared necessary for Finland, Ireland, Malta, Sweden 
and the UK to make the entry of pet animals into their territory subject to compliance 
with  certain  additional  requirements  to  prevent  the  risk  of  introducing  certain 
diseases. 

Thus  the  Regulation  allowed  those  five  Member  States  to  maintain  their  national 
rules  -  additional  pre-entry  measures  such  as  blood  testing  and/or  anti-parasite 
treatment  requirements  -  provided  that  this  was  for  a  transitional  period  to  be 
reviewed on scientific grounds five years on from the date of entry into force of the 
Regulation.  

Article 23 of the Regulation provides for a legal obligation to review the Regulation 
at  the  end  of  the  transitional  period  and  requires  the  Commission  to  submit  to  the 
European Parliament and to the Council, before 1 February 2007, a report based on 
experience  gained  and  on  a  risk  evaluation  together  with  appropriate  proposals  for 
determining the regime to be applied for Articles 612, 813 and 1614 of the Regulation 
at the end of the transitional period.  

On 8 October 2007 the Commission adopted such a report together with a proposal 
for a Regulation of the European Parliament and of the Council to defer the ending of 

11 
12 

13 

14 

OJ L 268, 14.9.1992, p. 52. 
Article  6  lays  down  rabies  testing  requirements  applicable  to  the  entry  of  dogs  and  cats  into  Ireland, 
Malta, Sweden and the UK. 
Article  8  lays  down  the  animal  health  requirements  applicable  to  the  entry  of  dogs,  cats  and  ferrets 
originating  from  third  countries,  listed  or  not  listed  in  part  C  of  Annex  II  to  the  Regulation.  Distinct 
conditions  regarding  rabies  testing  for  pets  entering  Ireland,  Malta,  Sweden  and  the  UK  and  for  pets 
entering the rest of the Member States are described. 
Article  16  lays  down  anti-parasite  pre-entry  treatment  requirements  applicable  to  the  entry  of  pet 
animals into Finland, Ireland, Malta, Sweden and the UK. 

EN 

14 

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the transitional period to 31 August 200915. The purpose of this short extension was 
to  allow  enough  time  for  collecting  data,  consulting  all  interested  parties  and 
reviewing  the  impacts  of  the  different  options.  In  order  to  take  account  of 
amendments  requested  by  the  European  Parliament  in  connection  with  its 
forthcoming  elections  in  2009,  the  Council  and  Parliament  eventually  agreed  to 
extend  the  transitional  period  to  30  June  2010  by  adopting  Regulation  (EC)  No 
454/200816 of 21 May 2008. 

Based on this report, the outcomes of the various recent consultations conducted and 
available updated information on the situation with regard to the diseases concerned - 
rabies, Echinococcosis and/or tick-borne diseases - in the whole EU, the Commission 
should now evaluate to what extent it is scientifically justified for the five Member 
States to retain their national rules. It should also assess whether an alternative less 
restrictive system could be envisaged, provided that it can offer an equivalent level 
of safety commensurate with the risk posed by pet animal movements.  

3.1.2.  General regime 

3.1.2.1.  Movements within the EU 

The  Regulation  stipulates  that  pet  animals  travelling  with  their  owner  from  one 
Member  State  to  another  must  be  identified  and  accompanied  by  an  EU  passport 
(Annex 11). 

The  passport  laid  down  in  Commission  Decision  2003/803/EC17  contains  certain 
obligatory information about the pet, such as its identification number and the proof 
of  a  valid  anti-rabies  vaccination  certified  by  a  veterinarian  authorised  for  the 
purpose by the competent authority. The passport is valid throughout the life of the 
pet. The veterinarian can only issue a passport if he has verified beforehand that the 
animal  is  properly  identified,  either  with  a  micro-chip  or  until  3  July  2011  a  tattoo 
(Article 4 of the Regulation). 

3.1.2.2.  Entry into the EU  

The  regime  applicable  to  pets  entering  the  EU  from  third  countries  depends  on  the 
quality  of  guarantees  provided  by  the  third  country  of  origin  regarding  rabies.  The 
Regulation established three categories of third countries: 

(1)  The first category - section 2 of part B of Annex II to the Regulation - concerns 
third  countries,  for  example  Liechtenstein,  Norway,  San  Marino  and 
Switzerland,  which  belong  from  the  animal  health  standpoint  to  the  same 
geographical  region  as  the  Community.  The  general  regime  applicable  to 
movements  within  the  EU  applies  to  pet  animals  coming  from  those  third 
countries.  

15 
16 
17 

COM (2007) 572 final. 
OJ L 145, 4.6.2008, p. 238. 
OJ L 312, 27.11.2003, p. 1. 

EN 

15 

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(2)  The  second  category  -  part  C  of  Annex  II  to  the  Regulation  -  concerns  third 
countries  conditionally  named  "listed  third  countries"18  which  are  either 
countries  free  of  rabies  or  countries  in  respect  of  which  the  risk  of  rabies 
entering the Community as a result of movements of pets from their territories 
has been found to be no higher than the risk associated with such movements 
between  Member  States.  The  general  regime  applicable  to  movements  within 
the  EU  applies  to  pet  animals  coming  from  those  third  countries.  Third 
countries  listed  under  this  part  are  for  example  Australia,  Belarus,  Canada, 
Malaysia, Mexico, Russia and the United States of America. 

(3)  The third category concerns third countries not listed in part C of Annex II to 
the Regulation, designated as "non-listed third countries"19, for example Brazil, 
India,  Morocco,  Republic  of  Korea,  Serbia  and  South  Africa.  Pet  animals 
coming from those third countries must undergo rabies antibody titration with 
favourable  results,  carried  out  by  an  EU-approved  laboratory  on  a  blood 
sample  taken  at  least  30  days  after  vaccination  and  three  months  prior  to 
movement. 

Moreover,  under  the  general  regime,  paragraph  3(b)  of  Article  8  of  the  Regulation 
provides  that  the  movement  of  pet  animals  (dogs,  cats  and  ferrets)  between, 
respectively,  San  Marino,  the  Vatican  and  Italy,  Monaco  and  France,  Andorra  and 
France  or  Spain,  and  Norway  and  Sweden  may  continue  under  the  conditions  laid 
down by national rules in force on 3 July 2004. According to the Swedish Board of 
Agriculture  website20,  there  are  no  requirements  for  moving  dogs  and  cats  directly 
from Norway into Sweden, and vice versa.  

3.1.3.  Transitional regime 

The transitional regime, which has been granted to Finland, Ireland, Malta, Sweden 
and  the  UK,  is  summarised  in  Table  1  and  consists  of  a  combination  of  EU  and 
national  rules.  This  regime  provides  both  for  additional  entry  requirements,  which 
vary  according  to  the  Member  State  of  destination  and  the  disease,  and  for 
exemptions between the Member States under the transitional regime. 

3.1.3.1.  Rabies 

Article 6(1) of the Regulation provides for the transitional application of mandatory 
additional  rabies-risk  mitigating  measures  in  relation  to  pet  animals  of  the  species 

18 

19 

20 

To  be  listed,  the  competent  authority  of  the  third  country  concerned  must  submit  an  application 
containing  detailed  information  demonstrating  its  status  with  regard  to  rabies  and  compliance  with 
certain  conditions  relating  to  notification,  monitoring,  veterinary  services,  prevention  and  control  of 
rabies and regulation of vaccines. Where the application is eligible, the Commission adopts a Decision 
under  the  Comitology  procedure  to  include  the  new  third  country  in  part  C  of  Annex  II  to  the 
Regulation. 
When a third country is not listed in part C of Annex II to the Regulation, this could mean that  
• 
• 
• 

it does not fulfil the conditions to be listed, 
an application is under consideration, 
no  application  has  been  submitted  for  lack  of  needs.  Indeed,  an  application  is  usually  
submitted  by  the  competent  authorities  when  needs  arise  from  expatriated  EU  citizens 

returning home after a professional stay abroad. 
http://www2.sjv.se/webdav/files/SJV/trycksaker/Pdf_ovrigt/ovr76gb.pdf 

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16 

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listed in part A of Annex I (dogs and cats) entering Ireland, Malta, Sweden and the 
UK  from  other  Member  States  and  possible  exceptions  to  them.  Thus,  the  last 
paragraph of  Article 6(1)  allows  those four  Member  States to exempt pet dogs and 
cats moving between them from the vaccination and antibody titration requirements 
in accordance with national rules in force on 3 July 2004. 

Article 8(1) of the Regulation provides for the transitional application of mandatory 
additional  rabies-risk  mitigating  measures  in  relation  to  pet  animals  of  the  species 
listed  in  parts  A  and  B  of  Annex  I  (dogs,  cats  and  ferrets)  entering  Ireland,  Malta, 
Sweden and the UK from third countries. 

Annexes 12 and 13 provide detailed information respectively on the various national 
protocols in force in the Member States concerned and on the various arrangements 
existing between those Member States.  

3.1.3.2.  Echinococcus/ticks 

Article 16 of the Regulation authorises Member States that had such requirements on 
the date on which the Regulation came into force to require pre-entry anti-parasitic 
treatment (Echinoccoccus and ticks). Various national rules are in force in Finland, 
Ireland, Malta, Sweden and the UK, including exceptions (Annex 12). 

3.1.3.3.  Bilateral regime between Sweden and Denmark 

Commission Decision 2004/557/EC21 provides that, by derogation from Article 6 of 
the  Regulation  and  until  the  end  of  the  transitional  period,  transit  of  dogs  and  cats 
between the Island of Bornholm and other parts of the territory of Denmark through 
Sweden  is  permitted  according  to  the  conditions  agreed  between  the  two  Member 
States (Annex 14). 

3.1.4.  Free movement regime between the UK and Ireland 

In line with the transitional regime for dogs and cats, the UK and Ireland mutually 
derogate from the anti-rabies vaccination requirements. As a perceived consequence 
of this derogation, the UK and Ireland also apply a mutual free movement regime for 
dogs and cats without the need for pet identification (marking) or passports. 

Unlike the case highlighted in section 3.1.2.2, this free movement regime is not part 
of either the general or the transitional regime since the Regulation does not provide 
for any derogation in regard to the identification rules for movements within Member 
States. 

This  historically  established  system  that  is  based  on  the  anti-rabies  vaccination 
waiver remained in place despite the entry into force of the Regulation, adopted by 
the Council and European Parliament. 

During the consultations, the competent authorities of the UK and Ireland considered 
that  a  significant  number  of  people  would  be  affected  by  discontinuing  the  free 

21 

OJ L 249, 23.7.2004, p. 19. 

EN 

17 

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movement  regime  between  those  countries.  Some  4-5  million  people22  travel 
between the two countries each year, many of whom are accompanied by their pets. 
According to the UK and Ireland, removing this free movement regime would place 
new  regulatory  and  cost  burdens  on  pet  owners  whereas  the  Regulation  is  directly 
applicable in Member States. 

in 

that  as 

the  case  of  a  non-vaccination  policy 

Ireland  maintains 
the 
identification/passport  requirements  serve  no  animal/public  health  purpose,  and 
the  consequent  significant  cost  and 
implementing  such  requirements,  with 
inconvenience to Ireland-UK commuters would risk bringing EU law into disrepute 
and undermine EU standards with regard to unnecessary regulation. It concludes that 
such requirements could well be deemed an unjustified obstacle to movement. 

The free movement regime mutually applied by the UK and Ireland for dogs and cats 
is  not  in  line  with  the  Regulation.  However,  it  must  be  acknowledged  that  the 
Council  and  European  Parliament  have  in  the  past  accepted  that  a  free  movement 
scheme applies on a permanent basis for movements of all pet species between, for 
example, Norway and Sweden (as explained in section 3.1.2.2). 

A complete analysis of this issue falls outside the scope of this impact assessment. 

22 

Those figures are estimates provided by the UK and are not included in the figures in Annex 15. 

EN 

18 

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Table 1:Overview of the rules currently applied by Member States under the transitional regime 
Legal Nature 

IE  MT 

SE 

UK FI 

Measures 
Identification  by  passport  and  microchip
or tattoo until 2011 (Article 4) 
Valid anti-rabies vaccination (Article 5) 
Simplified  import  regime  for  pet  animals 
(Article 8(3)(b)) 
Microchip compulsory 
Mandatory antibody titration before entry 
into their territory to confirm a protective 
level of anti-rabies antibodies 
anti-rabies 
Exemptions 
vaccination 
titration 
requirements for pet dogs and cats moving 
between these Member States24 
Pet  animals  entering  from  listed  third 
countries must comply with same rules as 
pets from other EU Member States  
Pet animals entering from non-listed third 
countries are to be put in quarantine 

the 
antibody 

from 
and 

Mandatory  anti-parasite  treatment  against 
Echinococcus/ticks 

and 

antibody 

Exemptions from the passport, anti-rabies 
vaccination 
titration 
requirements  for  Danish  dogs  and  cats 
transiting through Sweden  
Exemptions  from  anti-parasite  treatment 
against Echinococcus/ticks26 

x 

x 

x 

x 

x 

x 

x 

x 

x 

x 

x 

x 

x 

x 

x 

x 

x 

x 
Norway23 

x 

x 

x 

x 

x 

x 

x 

x 

x 

x 

x 

n/a

n/a

x 

n/a

x 

n/a

x 

n/a

x 

x 

Denmark25

x 

x 

x 

x 

x 

Approved transport companies  

x 

x 

Exemptions  from  the  identification  and 
passport  requirements  for  pet  dogs  and 
cats moving between Ireland and the UK 

x 

x 

x 

General Regime 

)
1
(
6

e
l
c
i
t
r

A

)
1
(
8

e
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A

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A

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A

n
i

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l
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g
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l

o
N

s
i
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l
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6
1

1
2

6
1

n
o
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R

n
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C

s
e
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l
a
n
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a
N

s
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u
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l
a
n
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e
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F

23 
24 
25 
26 

EEA-agreement. 
See details in Annex 11. 
See details in Annex 12. 
See details in Annex 10. 

EN 

19 

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3.2. 

Issues to tackle  

3.2.1.  The  current  national  rules  are  complex  and  place  a  considerable  burden  on  pet 

owners  

Preliminary remarks on pet movements 

It is very difficult – or even impossible - to have reliable figures on the number of pet 
animals in the EU as well as the number of pet animals which move throughout and 
into  Europe,  and  are  consequently  affected  by  any  rules  on  movements.  However, 
there are indications that pet movements are generally on the rise (in parallel with an 
increase in movements of people).  

As regards the number of pets overall in the EU, according to EFSA, the number of 
dogs and cats may be estimated from human population by using a formula published 
by Jones et al. 2002, i.e. 1.0 dog and 1.1 cats per 10 people.  

As regards pet movements, the number of pet passports issued does not provide an 
accurate estimation of movements as passports are issued for the whole life of a pet 
animal, allowing multiple movements. According to the Member States' consultation, 
no  statistics  on  pet  movements  are  available  with  the  exception  of  the  UK,  Ireland 
and  Malta,  as  those  countries  are  islands  accessible  through  a  limited  number  of 
guarded ports of entry at which information on movements is partly recorded by the 
customs services. Movements may concern animals moving within and into the EU 
but  also  pets  re-entering  a  Member  State  after  a  trip  abroad.  For  example,  the  UK 
competent authorities have reported that 60% of the animals entering the UK are UK 
animals returning from visits abroad. In addition, in the case of the UK, the figures 
on  pet  movements  are  certainly  underestimated  since  the  competent  authorities 
acknowledge  that  figures  which  relate  to  animals  entering  the  UK  do  not  include 
animals coming from Ireland as this information is not collected. 

Despite  these  limitations,  current  available  figures  from  these  Member  States, 
including  very  recent  ones  (Annex  15),  show  that  Ireland,  Malta  and  the  UK  have 
registered an impressive increase of movements since the entry conditions into those 
Member States were adjusted by the Regulation. 

Extra burden and practical difficulties encountered by pet owners 

The fact that the existing national rules differ considerably between the five Member 
States  makes  it  difficult  for  travellers  to  understand  the  applicable  conditions  and 
hampers  long  journeys  that  pass  through  these  Member  States:  a  dog  fulfilling  the 
requirements for travelling from Portugal to Ireland does not automatically fulfil the 
requirements  for  travelling  to  Sweden.  Overall,  the  system  seems  discriminatory, 
unnecessarily complex and burdensome for pet owners.  

The  following  elements  in  relation  to  additional  animal  health  requirements  or 
obligations on transport/routes represent a burden and difficulties for pet owners: 

EN 

20 

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(1)  Additional animal health requirements 

• 

• 

• 

• 

Blood  testing  and  tapeworm  treatment  protocols  are  not  identical  in  the 
five Member States entitled to apply their national rules.  

Blood  testing  and  tapeworm  treatments  create  burdens  since  time  is 
needed  to  accomplish  all  the  requested  procedures  and  therefore  last-
minute trips are impossible.  

Anti-parasite  treatments  have  strict  deadline  constraints  and  cause  extra 
problems  for  pet  owners.  High  veterinary  fees  related  to  anti-parasite 
treatment could be incurred if the service together with the certification is 
provided  during  the  weekend  or  on  a  bank  holiday  or  if,  when  making 
long-distance trips, owners have to visit another veterinarian en route to 
the final destination to meet the deadline constraints of the anti-parasite 
treatment  protocols.  In  addition,  it  is  evident  that  a  market-dominating 
position  in  key  exit  ports  can  increase  prices  for  simple  and  routine 
application  of  medication  to  exorbitant  levels,  leading  to  consumer 
complaints. 

Certain  obligations  for  pets  in  transit  appear  to  be  inconsistent.  For 
example,  anti-parasite  treatment  is  required  in  the  case  of  transit  from 
Denmark via Sweden to Bornholm (Denmark) although the animal stays 
in the transit country for a very short time, legally limited to four hours, 
and  is  not  allowed  to  leave  the  vehicle.  Because  this  may  become  a 
serious  animal  welfare  issue  and  in  order  to  alleviate  the  burden  on 
commuters  travelling  between  Sweden  and  Denmark,  a  specific  four-
week certificate has been introduced by Sweden. 

(2)  Transport and routes requirements 

Apart from the national animal health requirements, national rules imposed by 
the UK, Ireland and Malta have established a particular checking system which 
obliges  pet  owners  to  use  only  certain  transport  companies  ('carriers')  and 
routes to bring in dogs, cats and ferrets, thus ensuring in practice a 100% rate 
of checks at frontiers. 

This  obligation  entailing  systematic  checks  on  pet  animals  by  the  Member 
State of destination is against the principles of Council Directive 90/425/EEC 
of 26 June 199027, which specifically abolished checks at frontiers. 

Because this Directive categorically does not apply to veterinary checks carried 
out  on  the  movements  between  Member  States  of  pets  accompanied  by  and 
under the responsibility of a natural person, where such movements are not the 
subject  of  a  commercial  transaction,  the  provisions  of  Article  1  of  Council 
Directive 92/65/EEC of 13 July 199228 assume particular importance by stating 
that "this Directive shall not affect the national rules applicable to pet animals, 

27 
28 

OJ L 224, 18.8.1990, p. 29. 
OJ L 268, 14.9.1992, p. 52. 

EN 

21 

   EN 

 
 
 
 
                                                 
although their retention may not jeopardize the abolition of veterinary checks 
at the frontiers between Member States".  

These requirements have led to the following practical difficulties: 

• 

• 

• 

• 

• 

• 

• 

There may be a limit to the total number of animals that a company will 
permit to travel on each boat or aircraft. It is for the pet owner to check 
with the company before booking tickets that they are prepared to carry 
pets.  

Transport companies may have their own additional conditions of travel. 
These conditions may include a health declaration for the pet. Pets going 
to  the  UK  and  Ireland  by  air  must  travel  as  cargo,  unless  they  are 
registered  assistance  dogs  entering  with  an  approved  airline,  on  a  route 
that  permits  them  to  travel  in  the  cabin.  In  addition,  as  regards  trains, 
travelling  with  Eurostar  (between  Belgium/France  and  the  UK)  is  only 
accessible  to  registered  assistance  dogs  while  the  non-registered  ones 
have access only to Eurotunnel Shuttle Service. 

The costs imposed on pet owners may be very high. To give a concrete 
example, bringing a pet into Ireland from continental Europe by plane as 
cargo costs €910 (including 'carriers' and airline costs) compared to €70 
for  a  pet  entering  Belgium  from  any  EU  Member  State  via  a  Belgian 
airlines company when the pet weighs more than 6 kg. When pets weigh 
6 kg or less including dog bag, they are allowed to travel in the cabin and 
the cost is €30.  

Approved  routes  may  change  and  new  ones  may  be  added.  Others  may 
operate irregularly or seasonally. 

Pets  entering  those  countries  by  means  of  an  unapproved  transport 
company or route may be quarantined until they can be shown to comply 
with all the necessary rules. 

Some companies may not wish to carry ferrets.  

It is not possible to bring a pet into the UK from a private boat or plane.  

Overall,  as  a  result  of  these  complex  systems  and  measures,  pet  owners  may 
have to use the services of pet relocation companies arranging the full door-to-
door transportation of their pets, at additional cost to them. 

Although not illegal, this situation has given rise to complaints from individuals and 
Member States' authorities as summarised in Annex 16. 

EN 

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3.2.2.  Equivalence of health status for rabies, Echinococcosis (E. multilocularis) and ticks 

in the Member States  

3.2.2.1.  Rabies 

Epidemiology and disease control measures 

Detailed  information,  including  EU  contribution  to  the  rabies  monitoring  and 
is 
eradication  programmes 
summarised in Annex 17.  

in  Member  States  and  neighbouring  countries, 

Countries  with  a  higher  rate  of  reported  rabies  cases  in  wildlife  (e.g.  Baltic  States) 
have made extensive efforts and have continued to monitor the situation. As a result, 
the  situation  can  now  be  considered  as  roughly  equivalent  in  all  Member  States  of 
the EU-27, comparable to the situation in those EU-15 Member States where rabies 
in wildlife had still been a significant problem when Regulation (EC) No 998/2003 
was  adopted.  Indeed,  at  that  time,  sylvatic  rabies  still  occurred  in  some  remaining 
pockets in Germany (see Annexes 18-19). 

Illegal movements of animals  

In  addition  to  the  reduction  of  rabies  in  wildlife,  successful  control  of  rabies  in 
domestic animals in the EU depends on the efficiency of the control measures aiming 
at  preventing  and  detecting  illegal  movement  of  non-eligible  domestic  animals. 
Indeed, recent "imported" rabies cases in certain Member States were associated with 
the illegal introduction of pets, mainly non-vaccinated puppies or pets not vaccinated 
according to the rules.  

The  risk  of  introducing  rabies  into  the  EU  is  high  in  places  with  a  serious  urban 
rabies problem among stray dogs, such as Morocco or India. Therefore, this residual 
risk should be controlled by information campaigns for the public (e.g. by means of 
posters) enlightening them about the risks associated with contact with pet animals of 
unknown health status and appropriate penalty systems discouraging adoption of pets 
overseas, unless they can be introduced in accordance with the law. 

Conversely,  it  should  be  emphasised  that  no  rabies  cases  caused  by  legal  cross-
border  pet  movements  within  the  EU  have  been  recorded  for  many  years  and 
particularly since the Regulation entered into force.  

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Recent  data  on  rabies  in  the  EU  and  in  neighbouring  countries  (from  various 
sources)  

(1)  EFSA  

For  its  opinion  referred  to  above,  EFSA  used  information  reported  by  40 
European  countries'  competent  authorities  and  available  in  the  Rabies 
Information System of the WHO Collaboration Centre for Rabies Surveillance 
and Research (commonly known as Rabies Bulletin Europe29). 

The most recent data used by EFSA in its assessment are from the year 2005. 

EFSA  concluded  that  the  rabies  situation  in  the  25  Member  States  varies 
greatly.  Some  countries  are  considered  free  from  rabies,  while  in  others  it  is 
still prevalent at a lower or higher level. Based on estimates of pet population 
as a fraction of human population as described in section 3.2.1 (there may be 
some  doubts  as  to  whether  this  model  can  be  easily  adapted  to  countries  in 
transition), EFSA has estimated the prevalence of pet rabies in Europe in 2005, 
with  the  highest  prevalence  being  found  in  the  Baltic  States.  Overall,  the 
prevalence of pet rabies in the three Baltic States was about 15 per million in 
2005  (or  1.5*10-5).  In  Poland,  Hungary  and  Slovakia  the  prevalence  in  2005 
was around 10-7 (two orders of magnitude lower than in the Baltic States) while 
in the remaining Member States the prevalence was nil. 

(2)  WHO 'Rabies Bulletin Europe' 

More recent figures extracted from this Bulletin show that the total number of 
rabies cases in pet animals in the EU recorded in 2007 (27 Member States) is 
217  as  compared  with  389  in  2005  (25  Member  States  +  Bulgaria  and 
Romania). The highest figures recorded for pet animals in EU-27 in 2007 are 
found in Lithuania (77), Romania (64) and Latvia (53). Estonia did not record 
any while Bulgaria (13) and Poland (8) recorded very few. In Europe, Ukraine 
(1164),  the  Russian  Federation  (1056)  and  Belarus  (140)  account  for  the 
highest  prevalence.  Croatia  (27)  records  the  highest  number  of  cases  in  the 
Western Balkan countries. 

Data show a remarkable decline of rabies cases in domestic and wild animals 
in  the  Baltic  States,  in  particular  in  Lithuania,  mostly  due  to  effects  of  oral 
rabies  vaccination  of  wildlife,  the  implementation  of  compulsory  vaccination 
of  dogs  and  cats  combined  with  control  of  the  population  of  stray  and  feral 
dogs and cats inducing a sufficient level of vaccination coverage and reducing 
the occurrence of the disease in these species.  

29 

http://www.who-rabies-bulletin.org/Queries/Distribution.aspx  
This is the main institution officially monitoring the rabies situation in wildlife, domestic animals and 
humans in the EU and in bordering countries. It publishes on a quarterly basis the information provided 
by  the  competent  authorities.  The  database  contains  factual  rabies  cases  with  no  information  on  the 
origin of each case reported. That information (indigenous or imported cases) is available in the yearly 
"EFSA  Community  Summary  Report  on  Zoonoses,  Zoonotic  Agents,  Antimicrobial  resistance  and 
Food Borne Outbreaks in the European Union". 

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24 

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The  latest  2008  figures  newly  communicated  by  Member  States  to  Rabies 
Bulletin Europe confirm this encouraging trend in the Baltic States.  

Bulgaria also maintains a very low rate both in pet animals and wildlife. 

Although  Romania  still  registers  a  high  number  of  cases  in  wildlife,  the 
situation  seems  to  be  stable  in  pet  animals.  Although  the  Community  has 
approved  the  rabies  eradication  programme  for  Romania  and  allocated  the 
necessary  resources,  the  implementation  of  this  programme  is  still  hampered 
by technical difficulties. 

In  Europe,  the  situation  in  Ukraine,  the  Russian  Federation  and  Belarus  is 
unchanged. 

The situation in Croatia is comparable to the one in Romania. 

Comparative data for those countries from the years 2003 to 2008 compiled by 
Rabies Bulletin Europe have been summarised in Annex 19.  

(3)  FVO missions to evaluate rabies eradication programmes 

Two missions of the Food and Veterinary Office (FVO) took place respectively 
in  May  and  June  2007  to  evaluate  the  progress  of  rabies  eradication  in 
Lithuania30  and  Latvia31  in  the  framework  of  Council  Decision  90/424/EEC 
(co-financing by the Community budget).  

Both Member States border areas that are still infected with rabies and do not 
carry out any systematic vaccination. The current eradication strategy based on 
oral  immunisation  of  wildlife  twice  a  year  has  been  applied  nationwide  since 
the spring campaign of 2006 and is complemented by manual distribution close 
to or into urban settlements starting from spring 2007. The decrease in cases is 
significant. 

Latvia  and  Lithuania  have  adopted  national  legislation  imposing  compulsory 
vaccination of all dogs and cats. The last indigenous human cases were notified 
in 2003 and 2000 respectively. 

The  peak  number  of  rabies  outbreaks  was  reached  in  Latvia  in  2003  and  has 
since then steadily decreased with a 50% drop in cases from 2006 to 2007. 

The rabies situation in Lithuania was deteriorating markedly until May 2006 in 
the country as a whole, and, in particular, in the wildlife population. Since the 
start  of  oral  vaccination  in  March/April  2006,  the  incidence  of  outbreaks  of 
rabies  has  decreased  considerably,  above  expectations  in  wild  animals. 
Equally, since October 2006 the outbreaks in domestic animals have started to 
decrease.  

30 
31 

http://ec.europa.eu/food/fvo/act_getPDF.cfm?PDF_ID=6491 
http://ec.europa.eu/food/fvo/act_getPDF.cfm?PDF_ID=6403 

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25 

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3.2.2.2.  Echinococcosis (Echinococcus multilocularis) 

EFSA provided information on the disease situation32, which has been summarised in 
Annex 20.  

3.2.2.3.  Ticks 

EFSA has provided information, in particular on the ticks' geographical distribution33 
(Annex 20).  

3.3. 

The principle of subsidiarity  

The  problem  is  clearly  of  a  trans-national  nature  which  cannot  be  satisfactorily 
regulated by Member States acting on their own, as it means increasing public health 
and  animal  health  risks  as  well  as  risking  the  introduction  of  disguised  barriers  to 
movements.  Restrictions  on  free  circulation  of  pet  animals  must  be  justified  in  a 
proportional  manner, based on solid reasons  (e.g. public health) justifying  the need 
for additional measures creating barriers to free circulation between countries.  

4. 

OBJECTIVES 

The overall objectives are to be seen in the light of the free circulation of people (EC 
Treaty) and of the new Animal Health Strategy. 

The specific objectives are: 

• 

• 

To  harmonise  requirements  so  as  to  remove  disproportionate  obstacles  to  the 
movement of pets for non-commercial purposes across the EU or entering the 
EU from third countries while properly protecting public and animal health, in 
particular with regard to rabies.  

To provide EU rules that are proportionate, avoid causing difficulties and give 
clear benefits in terms of clarity and simplification for travelling pet owners. 

The operational objective of the review is to determine the regime to be applied with 
effect  from  1  July  2010  for  Articles  6,  8  and  16  of  the  Regulation,  which  include 
transitional measures. 

5. 

KEY POLICY OPTIONS 

Accordingly,  the  Commission  has  identified  four  policy  options  entailing  legal  and 
administrative intervention, all related to Articles 6, 8 and 16 of the Regulation: 

32 

33 

Based on mandatory reports sent by Finland, Ireland, the UK and Sweden and the EFSA's Community 
Summary Report on Zoonoses, Zoonotic Agents, Antimicrobial resistance and Food Borne Outbreaks 
in the European Union in 2005 which are based on the annual Member States' reports 
Based on reports sent by Ireland and on the review produced by DEFRA (the UK). 

EN 

26 

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Option 1: No action  

This  would  mean  that  after  30  June  2010,  Finland,  Ireland,  Malta,  Sweden  and  the 
UK  will  no  longer  make  entry  into  their  territory  subject  to  the  requirements 
provided  for  in  Article  6(1)  for  dogs  and  cats  and  in  Article  16  for  dogs,  cats  and 
ferrets.  

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  rabies  situation  in  those  Member  States  would  fully  address  the  risks 
identified  by  EFSA  and  render  its  recommendations  for  mitigating  measures 
obsolete. 

This  option  would  require  a  Commission  proposal  to  the  European  Parliament  and 
the Council extending the transitional period and clarifying the regime to be applied 
with effect from 1 January 2012 for Articles 6, 8 and 16. 

Option 3: Adjustment of the current rules applicable to all Member States  

This would mean ending the specific conditions applied by the five Member States 
and proposing a technically reviewed regime in line with EFSA recommendations34. 
This  option  would  require  a  Commission  proposal  to  the  European  Parliament  and 
the Council composed of the following elements: 

(1)  Application of the general regime in the EU;  

(2)  Withdrawal of any national measures; 

(3)  Additional  safeguard  measures  for  certain  categories  of  animals  coming  from 
Member States and third countries with a less favourable rabies situation. 

Option 4: Continuation of the transitional 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  impossible  that  other  Member  States  complying  with  OIE  criteria  for  a  rabies-
free country or claiming a special health status with regard to tick-borne diseases and 
Echinococcosis  would  equally  request  additional  conditions.  This  option  would 
require a Commission proposal to the European Parliament and the Council to ensure 
equal  treatment of all Member States. This option  does not  assume  continuation of 
the free movement regime between the UK and Ireland. 

34 

EFSA  highlighted  a  possible  residual  risk  of  importing  rabies  with  primo-vaccinated  pet  animals 
coming from areas where the incidence of rabies in pets is more than one case per million pets per year. 
It  recommends  that  for  pets  coming  from  those  areas,  risk  mitigating  measures  such  as  waiting  time 
following  primo-vaccination  and  serological  testing  or  a  second  injection  of  vaccine  should  be 
introduced to take account of low responders to the classic scheme of vaccination and of the case of an 
animal  vaccinated  while  incubating  the  disease  or being  exposed  to  the virus  while  building up post-
vaccination immunity. 

EN 

27 

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NB:  A  Commission  proposal  as  foreseen  in  options  2,  3  and  4  would,  in  any  case, 
enhance legal clarity. However, such a proposal might lead, at Council and European 
Parliament level, to reopening of the debate on aspects of the Regulation not covered 
by the present impact assessment.  

6. 

IMPACT ANALYSIS 

6.1. 

Preliminary remarks 

This  impact  assessment  combines  quantitative  and  qualitative  approaches  to  ensure 
that  adequate  consideration  is  given  to  a  broad  range  of  economic,  social  and 
environmental impacts.  

Each option is analysed and evaluated with all elements available and where possible 
in a monetised form.  

This  impact  assessment  is  based  on  the  evidence  obtained  through  the  various 
consultations,  including  data  supplied  by  Member  States'  competent  authorities, 
EFSA  and  other  stakeholders  likely  to  be  affected  as  well  as  available  updated 
information on the situation with regard to rabies, Echinococcus and/or ticks in the 
EU territory. 

The  quantification  of  impacts  needs  preliminary  knowledge  of  some  core  elements 
and  data,  in  particular  detailed  costs  incurred  by  pet  owners  to  prepare  a  pet  under 
the general and transitional regimes.  

The  Commission  collected  information  on  those  costs  through  the  various 
consultations launched at the end of 2007. 

As  already  explained  in  section  3.1.4,  an  impact  analysis  on  the  free  movement 
regime  between  the  UK  and  Ireland  and  its  future should not be carried out within 
the  context  of  this  impact  assessment  report.  However,  to  better  understand  the 
implications  of  this  issue, it will be further developed in section 7 ("comparison of 
the different options"). 

Data  limitations:  it  should  be  noted  that  although  the  various  consultations  did 
provide extensive data, any calculation of global costs needs to be based on a precise 
knowledge of the number of pet movements within and into the EU. Unfortunately, as 
mentioned in section 3.2.1, this information is not available in most of the Member 
States.  

The  evaluation  of  likely  impacts  of  an  economic,  social  and  environmental  nature 
must  be  directed  towards  the  different  actors  concerned:  pet  owners,  authorised 
veterinarians  issuing  passports  (certification),  carrying  out  sampling  and  delivering 
anti-parasite  treatment,  suppliers  of  anti-rabies  vaccine  and  anti-parasite  medicinal 
products,  EU-approved  laboratories  performing  the  serological  tests  to  monitor  the 
effectiveness of rabies vaccines, approved transport companies, approved quarantine 
facilities and competent authorities.  

As regards suppliers of anti-rabies vaccine, there is no need to develop any further 
recommends 
calculation  of 

impacts  of  whatever  nature,  because  EFSA 

EN 

28 

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unambiguously  that  the  anti-rabies  vaccination  should  remain  the  minimum 
requirement before moving a pet animal within and into the EU.  

6.1.1.  Costs incurred by owners to prepare a pet 

Under  the  Regulation,  the  total  cost  of  preparing  a  pet  animal  for  travel  varies 
according to the country of origin and the Member State of destination. The average 
costs for a dog of average size travelling within the EU or re-entering the EU after a 
trip abroad are detailed in Annex 21 and summarised in Table 2.  

Those costs do not take into account the particular arrangements existing between the 
Member States (as explained in section 3.1.3 - transitional regime), which may lead 
to a significant reduction of preparation costs. Obligations in the form of electronic 
identification and/or vaccination under national law are also to be considered when 
comparing the costs.  

Moreover,  since  only  Member  States  could  be  asked  to  provide  the  different  costs 
linked  to  the  preparation  of  a  pet  before  movement  and  no  figures  from  third 
countries  are  available,  only  costs  for  re-entering  the  EU  from  listed  or  non-listed 
third countries can be estimated. 

In addition, the costs presented in Table 2 relate to preparing a pet animal to travel 
for the first time, meaning that identification (marking + passport), vaccination and 
where necessary titration must be carried out before movement.  

The costs presented in Table 2 show that it is more expensive for an EU citizen to 
travel with a pet to Member States under the transitional regime, except Finland, than 
to return from a non-listed third country under the general regime. 

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29 

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Table 2: COMPARATIVE COSTS for a dog of average size 
Anti-
echinococcus 
treatment 

Sampling + 
certification 

Vaccination 
documented in 
the passport 

Anti-tick 
treatment 

test 

'Carriers' 

Quarantine 

Total 

Identification 
(microchip + 
passport) 

€42.9335 
(€15 to 95.5) 
€42.9335 
(€15 to 95.5) 

€42.9335 
(€15 to 95.5) 

€22.5 35 
(€2 to 63) 
€22.535 
(€2 to 63) 

€22.535 
(€2 to 63) 

General regime 

- 

- 

- 

- 

€29.235 
(€5 to 53) 

€50 
(€30 to 88) 

Transitional regime 

- 

- 

- 

- 

- 

- 

- 

- 

- 

€50.5 
(€15 to 107) 

€26.7 
(€2 to 63) 

€34 
(€5 to 69) 

€50 
(€30 to 88) 

€18.8 
(€5 to 56) 

€16.8 
(€1 to 39.3)  

€50.5 
(€15 to 107) 

€50.5 
(€15 to 107) 

€26.7 
(€2 to 63) 

€26.7 
(€2 to 63) 

- 

- 

€34 
(€5 to 69) 

€50 
(€30 to 88) 

- 

- 

- 

- 

- 

- 

- 

€16.8 
(€1 to 39.3)  

€16.8 
(€1 to 39.3)  

- 

UK: N/A 
IE: ferry=€20, 
plane=€910, 
MT: €72 
- 

- 

- 

- 

- 

- 

- 

- 

- 

UK: €3480 
IE: €2500 
MT: €1000 
SE: 3€350 

€65.43 

€65.43 

€144.63 

€196.8 
(+'carriers' 
costs) 

€178 

€94 

€3480 
€2500 
€1000 
€3350 

Pet 
within EU 

travelling 

Pet  re-entering  EU 
from 
third 
listed 
countries  
Pet  re-entering  EU 
non-listed 
from 
third countries 

entering/re-
Pet 
entering  UK, 
IE, 
MT from the rest of 
EU  

entering/re-
Pet 
entering  SE  from 
the rest of EU  
Pet 
entering/re-
entering FI from the 
rest of EU  
Pet  entering  UK, 
IE,  MT,  SE  from 
non-listed 
third 
countries  

35 

Figures excluding those provided by the UK, IE, MT, SE and FI. 

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30 

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6.1.2.  Administrative costs 

Because administrative costs and compliance costs are closely interlinked, we have not 
in many cases drawn up a distinction between compliance and administrative costs for 
the  different  private  parties  concerned.  In  any  case,  administrative  costs  are  very 
marginal for operators and embedded in compliance costs.  

For  example,  when  veterinarians  give  pets  an  anti-rabies  vaccination  for  travelling 
reasons (compliance costs) they have to certify it on the passport (administrative costs). 
In  such  cases,  administrative  costs  represent  a  very  short  amount  of  their  time  (1-2 
minutes) as part of a consultation and can therefore be considered as insignificant. 

As  regards  administrative  costs  for  Member  States'  competent  authorities,  these  are 
mainly incurred by two types of obligations: (1) controls at borders that are performed 
either by competent authorities themselves or by approved 'carriers' acting on behalf of 
the  competent  authorities  and  (2)  information  obligations  vis-à-vis  the  public  on  the 
regime  and  the  different  treatments  that  they  should  administer  to  their  pets  when 
travelling within the EU.  

As regards control costs, these are likely to remain more or less the same in the different 
options – the controls will stay in place whatever regime may apply to the five Member 
States currently under the transitional regime.  

As regards information costs, in the current context, additional information needs to be 
provided because of the complexity of the rules applicable in each country. On the other 
hand,  if  the  regime  is  simplified,  it  would  be  necessary  at  the  beginning  to  inform  pet 
owners adequately and therefore information costs may rise. But these costs will in the 
medium  term  be  reduced  as  the  rules  will  be  simpler  and  therefore  necessitate  less 
specific information on the regime. Overall, these information costs may slightly change 
over time but not to a substantial extent and the variation in this type of costs is expected 
to be minimal. 

Therefore, a detailed and quantified analysis of administrative costs using the Standard 
Cost Model was not carried out as it was considered disproportionate. 

6.2. 

Analysis of impacts of option 1: No action  

This would mean that after 30 June 2010, Finland, Ireland, Malta, Sweden and the UK 
will  no  longer  make  entry  into  their  territory  subject  to  the  requirements  laid  down  in 
Article 6(1) for dogs and cats and in Article 16 for dogs, cats and ferrets. 

EN 

31 

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6.2.1.  Economic impacts 

6.2.1.1.  Pet owners 

Pet owners from the Member States other than those currently under the transitional 
regime: 

As described in section 6.1.1, the additional requirements requested by the five Member 
States currently under the transitional regime result in additional costs for citizens. This 
option would certainly benefit travellers by removing those costs. 

Table 2 shows the comparative costs. 

Only  identification  and  a  valid  anti-rabies  vaccination  would  remain  as  obligatory 
measures to be fulfilled and, for a pet properly vaccinated according to the specifications 
of the vaccine, a last-minute departure will always be possible. 

As  already  mentioned  in  section  6.1.1,  in  some  Member  States  anti-rabies  vaccination 
for  travelling  may  not  incur  additional  costs  since  it  is  already  an  obligation  under 
national law.  Combined with  the mandatory identification  of dogs currently applicable 
in most of the Member States, the preparation of a pet animal will no longer represent a 
cost obstacle for travellers throughout the EU. 

Pet owners from the five Member States currently under the transitional regime: 

Bilateral arrangements are part of the transitional regime. Therefore if the latter ceases, 
those  arrangements  described  in  Annexes  12,  13  and  14  will  cease  with  the  following 
consequences:  

• 

• 

• 

Travellers  from  Ireland,  Malta,  Sweden  and  the  UK  would  be  affected  by  the 
ending of totally liberated movement between some of these Member States. They 
will have to comply with the vaccination requirements and connected costs. 

Travellers  from  Sweden  and  Denmark  would  be  affected  by  the  ending  of  the 
derogation provided for in Commission Decision 2004/557/EC. They will have to 
comply with the vaccination and passport requirements and connected costs.  

Specific  arrangements  between 
regarding  anti 
E. multilocularis treatment would not be affected as far as the general regime does 
not include such a requirement. 

five  Member  States 

the 

NB:  Specific arrangements existing between Sweden and Norway under Article 8(3)(b) 
of the Regulation would not be affected as they are part of the general regime, as 
explained in section 3.1.2.2.  

EN 

32 

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Pet  owners  originating  in  or  returning  from  non-listed  third  countries  and  entering 
the four Member States applying the quarantine placement 

This option would certainly benefit pet owners that are currently not inclined to travel 
because of the quarantine measures and linked costs.  

6.2.1.2.  Authorised veterinarians  

Overall, since the limited constraints related to anti-rabies vaccination and identification 
requirements may encourage pet owners to bring their pets with them when travelling, 
veterinarians would certainly benefit from this option.  

The following elements should also be taken into account: 

• 

• 

• 

The  ending  of  bilateral  arrangements  (e.g.  Ireland,  Malta,  the  UK,  Sweden  and 
Denmark) may increase veterinarians' incomes related to anti-rabies vaccination in 
formerly non-vaccinating Member States since veterinarians will have to deal with 
a new population of unvaccinated pets.  

As  animal  sampling  would  disappear  with  the  general  regime  within  the  EU, 
veterinarians  may  initially  face  a  minor  decrease  in  their  activities.  This  would 
apply  to  veterinarians  both  in  Member  States  currently  under  the  transitional 
regime and in the others. However, the impact on authorised veterinarians should 
not  be  considered  negative  in  so  far  as  they  will  continue  to  sample  animals 
departing  for  non-listed  third  countries  which  have  to  meet  the  requirements  for 
returning to the EU.  

Delivery  of  anti-parasite  treatment  should  not  seriously  decrease,  as  such 
preventive  systematic  deworming  of  carnivores  is  recommended  to  be  applied  at 
least twice a year for wider public health reasons than travelling reasons (Source 
UEVP recommendations). 

6.2.1.3.  EU-approved rabies serology laboratories 

The impact of this option on serology laboratories should be very minimal. 

Indeed, laboratory incomes generated by the entry of pet animals into the EU from non-
listed  third  countries  or  the  return  of  EU  pet  animals  after  a  trip  to  non-listed  third 
countries will not be affected. 

Serology regarding pet movements accounts for between 5% and 95% of the work of the 
rabies  laboratories  consulted.  Economic  impacts  will  therefore  depend  on  the  type  of 
laboratory  concerned.  The  impact  would  be  greater  for  those  laboratories  whose 
activities are geared exclusively to responding to those obligations. This would concern 
only  five laboratories  out  of  the  25  that  replied  to  the  consultation,  with  staff  numbers 
ranging from 3 to 13.  

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In  addition,  from  the  consultation,  it  appears  that  pet  serology  activities  may  have 
produced specific income which provides infrastructure, equipment and technical staff to 
further develop laboratory activities and not necessarily the serology part. However, in 
the  event  of  a  significant  decrease  in  serology  activities,  most  of  the  laboratories 
envisage shifting to other activities such as rabies research including lyssaviruses in bats 
or oral vaccination programmes in wildlife. 

Nevertheless, it should be noted that if this option is selected, the quarantine placement 
which applies to pets entering Ireland, Malta, Sweden  or the UK from  non-listed third 
countries  will  be  replaced  by  pre-testing  requirements  applicable  under  the  general 
regime.  A  transfer  of  laboratory  incomes  to  that  category  of  pets  is  therefore  to  be 
expected. It may be high since it would concern expatriate citizens willing to come back 
home  with  their  newly  adopted  pet  animal  after  a  professional  stay  abroad  or  citizens 
who may wish to travel to countries that have until now been inaccessible because of the 
quarantine measures. 

6.2.1.4.  Suppliers of anti-parasite treatments 

There should be no or only marginal impact on suppliers of medicines for treating ticks 
or Echinococcus. Indeed, it  is  clear  that activities of suppliers  will not  stop since anti-
parasite  treatments  are  not  only  recommended  for  travelling  purposes  but  also  for 
general animal and public health reasons as explained in section 6.2.1.2. 

6.2.1.5.  Transport companies ('carriers') 

It  can  be  assumed  that  with  this  option,  new  business  opportunities  will  open  up  for 
'carriers' to offer their services to travellers with pets. 

The UK considers that this option is unlikely to have a negative impact on 'carriers' as 
the  rules,  including  the  checking  system,  would  be  simplified.  This  is  also  likely  to 
create greater market opportunities for pet owners and 'carriers' as the costs for owners 
will be reduced. This would also lead to an increase in the number of pets travelling to 
the UK due to the substantially reduced cost of preparing pets.  

Ireland considers that the checking process would be simplified. However, the number 
of pets entering the country would probably increase. 

Malta envisages a reduction of the overall costs. 

6.2.1.6.  Quarantine facilities 

From the consultation, it appears that this option may have a significant impact on the 
business of quarantine facilities in Ireland, Malta, Sweden and the UK. It is envisaged 
that a number of these facilities may cease operations due to the likely fall in the number 
of animals being licensed into long-term quarantine. 

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However,  quarantine  facilities  will  still  be  used  for  short-term  stays  for  reasons  other 
than  an  anti-tick/echinococcus  treatment  not  properly  administered,  such  as  microchip 
failure/loss.  

6.2.1.7.  Competent authorities 

The  UK  reported  a  significant  impact  in  the  short  term  due  to  the  need  to  publicise, 
explain and put in place new import rules and arrangements. In the longer term, certain 
obligations  and  administrative  tasks  will  still  have  to  be  fulfilled  in  terms  of  ensuring 
that  legislative  requirements  are  met  and  enforced.  But  these  are  evaluated  as  not 
significant. 

Malta reported that the work involved is minor and already part of their normal duties. 

Ireland reported that this option would simplify the prior approval process, thus reducing 
the workload of headquarters staff on individual files. However, the subsequent increase 
in numbers of pets entering the country may mean that the overall workload would not 
diminish – it is not possible to measure this aspect at this stage. This option would not 
affect the spot-checking regime involving staff at ferry ports/airports, as the increasing 
number of pet imports would be likely to increase the workload. 

Sweden  reported  that  direct  costs  will  be  less  due  to  fewer  administrative  tasks  for 
administrative staff, clinical practitioners and customs authorities.  

As  regards  Finland,  this  option  would  not  have  any  marked  influence  on  the 
administrative tasks and costs. 

6.2.1.8.  Third countries 

This  option  would  ease  travelling  with  pet  animals  especially  for  those  originating  in 
non-listed third countries because they would fall under the general regime. 

6.2.1.9.  Others 

Through  the  consultation,  Finland  and  Sweden  raised  the  need  to  maintain  the 
transitional  regime  as  regards  E.  multilocularis  and 
the  potential  associated 
consequences if that regime is discontinued. The image of Sweden and Finland as nature 
tourism  countries  would  be  seriously  harmed  and  the  fruit  and  berry  industry  would 
suffer  with  regard  to  the  production  of  Nordic  specialities  in  Sweden  and  the  related 
export incomes in Finland. 

6.2.2. 

Social impacts 

6.2.2.1.  Employment 

Activities  of  EU-approved  serology  laboratories  may  suffer  if  this  option  is  selected. 
However,  the  impact  would  be  very  limited.  Some  laboratories  envisage  redundancies 
due  to  a  decrease  in  activities.  One  private  UK  laboratory  (90%  activity  dedicated  to 

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serology regarding pet movements) does not rule out closure of the laboratory with 13 
full-time employees and potential difficulties of reorganisation. 

However, most of the laboratories intend to redeploy staff to other laboratory activities. 

The  likely  fall  in  the  number  of  animals  being  licensed  into  quarantine  may  induce  a 
negative impact on the business of quarantine facilities. According to Ireland, Malta and 
the UK, respectively two, nine and four to five employees per facility would be affected. 

On the other hand, this option may have a positive effect on tourism and consequently 
on employment in so far as travellers will no longer be concerned about the additional 
logistic and financial requirements. 

6.2.2.2.  Welfare of citizens 

If this option is selected, the quarantine placement which applies to pet animals coming 
from non-listed third countries or to those not in compliance with the national rules will 
be lifted.  

In so far as the general regime will be applicable to pets coming from non-listed third 
countries, social (and/or welfare) impacts should be considered positive since pets will 
no longer be separated from their owners. 

Indeed, experience has shown that most of the applications submitted by the competent 
authorities  of  newly  listed  third  countries  are  supported  by  British  expatriates,  the 
quarantine  measure  being  a  serious  obstacle  to  their  return.  Impacts  of  this  option  on 
British expatriates should therefore be positive. 

Those  considerations  cannot  determine  the  level  of  harmonising  movements  of  pet 
animals  within  the  EU,  as  these  practical  difficulties  are  faced  by  almost  all  Member 
States.  

6.2.2.3.  Public health 

Selecting  this  option  would  mean  the  ending  of  rabies  antibody  titration  requirements 
and pre-treatment requirements in regard to E. multilocularis and ticks.  

The assessment of the risk of those diseases of zoonotic potential being introduced into 
the five Member States concerned if national rules were abandoned has been carried out 
by EFSA. 

Rabies 

Based  on  figures  for  the  year  2005,  EFSA  recommends  the  introduction  of  additional 
measures for certain categories of pets coming from Baltic States. Poland, Hungary and 
Slovakia  were  singled  out  by  EFSA  as  not  representing  a  particular  risk.  However, 
according to the figures given in Annex 19 and commented on in section 3.2.2.1, and in 
the light of additional elements, this recommendation should be graded as follows:  

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1. 

The improvement of the rabies situation in the Baltic States is remarkable: 

• 

• 

• 

The  total  number  of  rabies  cases  recorded  by  Estonia  has  decreased  from 
266 in 2005 to 3 in 2008. 

Latvia  has  also  recorded  a  significant  decrease,  with  the  number  of  rabies 
cases in total/pets falling from 421/49 in 2005 to 110/18 in 2008.  

Lithuania  has  also  recorded  a  remarkable  decrease,  with  the  number  of 
rabies cases in total/pets falling from 1652/181 in 2005 to 69/11 in 2008. 

Some  of  these  figures  are  comparable  to  those  recorded  in  2005  by  Poland 
(138/12), which had the highest number of cases in the EU, and to those recorded 
by  the  remaining  affected  Member  States  when  the  Regulation  was  adopted 
(Annex  18).  In  view  of  these  results,  the  long-term  strategy  for  eradication  of 
rabies applied by the Baltic States can be considered successful and encouraging 
for the future. 

2. 

3. 

Since  the  entry  into  force  of  the  Regulation,  no  rabies  cases  imported  from  the 
Baltic States have been reported in the Member States applying provisions of the 
general regime. The potential risk posed by the Baltic States is therefore reduced 
by the high level of vaccination coverage of wildlife and domestic animals.  

It  should  be  noted  that  the  Regulation  provides  for  criteria36  for  the  listing  of  a 
third  country  and  these  criteria,  which  are  not  the  ones  used  by  the  EFSA  to 
evaluate the risk posed by the Baltic States, should also be taken into account for 
this impact assessment.  

The Community criteria so far applicable are not built on the prevalence of rabies 
in  pets  but  on  the  implementation  of  regulatory  measures  to  prevent  and  control 
rabies, how the competent authorities guarantee the validity of the certification and 
the quality of the monitoring system and vaccines.  

This  approach  applied  since  the  entry  into  force  of  the  Regulation  could  be 
considered a success since no imported cases have been registered in the EU for 
pets originating in listed countries. Thus, third countries such as the United States 
of  America  and  the  Russian  Federation,  where  the  vast  majority  of  rabies  cases 
occur  in  wild  animals  like  raccoons,  skunks,  bats,  wolves,  badgers  and  foxes, 
which  were  able  to  demonstrate  their  capacity  to  control  the  disease,  have  been 
accepted by the EU under the general regime despite having a higher incidence of 
rabies in wildlife than the Baltic States.  

Therefore,  the  risk  of  introducing  rabies  as  a  result  of  lawful  movements  of  pets 
from  the  Baltic  States  under  the  general  regime  can  be  estimated  with  a  high 

36 

Article 10 of the Regulation. 

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degree  of  certainty  to  be  no  higher  than  the  risk  associated  with  movements 
between the other Member States and from listed third countries.  

E. multilocularis  

EFSA  reported  that  the  risk  of  introducing  E.  multilocularis  from  endemic  areas  into 
countries where the intermediate host is present, but which are considered free from the 
disease on the basis of national surveys, is greater than negligible.  

However, estimation of the risk is impaired by a lack of reliable data. In addition, it is 
impossible to quantify the risk incurred by humans in so far as certain countries are more 
exposed to the risk of introduction of E. multilocularis through trans-boundary wildlife 
movements than through movements of potentially infected pet animals. 

Although EFSA acknowledges the zoonotic potential of the parasite, it considers that not 
only pets are responsible for human infection cases.  

There  is  a  risk  of  humans  contracting  the  disease  in  endemic  areas  via  accidental 
ingestion of tapeworm eggs through contact with infected pets or with wild or cultivated 
fruits  and  vegetables  contaminated  by  foxes.  Therefore,  if  alveolar  echinoccocosis  is 
considered  a  significant  public  health  problem,  it  is  then  unjustified  to  concentrate  the 
risk-mitigating  measures  exclusively  on  pet  animals  travelling  with  their  owners.  No 
negative  impacts  on  public  health  and  in  particular  on  the  introduction  of  E. 
multilocularis will necessarily be recorded. 

Ticks 

EFSA's  opinion  does  not  correlate  the  well-known  extension  of  the  geographical 
distribution of many tick species to the increased mobility of dogs and cats but rather to 
the potential impacts of climatic changes. Therefore any measures recommended for the 
control of ticks only on pets may have a limited effect on preventing further introduction 
and expansion of tick species.  

No  causative  impacts  on  public  health  and  in  particular  on  the  extension  of  the 
geographical distribution of tick species will necessarily be recorded. 

6.2.3.  Environmental impacts 

If  this  option  is  selected,  there  is  likely  to  be  an  increase  in  the  number  of  pet 
movements in the future as a result of fewer constraints on pet owners. 

However,  environmental  impacts  of  more  pets  (and  pet  owners)  travelling  are 
impossible to assess outside the context of mobility in general.  

6.3. 

Analysis of impacts of 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 

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to eradicate sylvatic rabies in the Baltic States. A substantially improved rabies situation 
in those Member States would fully address the risks identified by EFSA and render its 
recommendations for mitigating measures obsolete. 

This option would require a Commission proposal to the European Parliament and the 
Council  extending  the  transitional  period  and  clarifying  the  regime  to  be  applied  with 
effect from 1 January 2012 for Articles 6, 8 and 16 of the Regulation. 

6.3.1.  Economic impacts 

Impacts  on  pet  owners,  authorised  veterinarians,  EU-approved  rabies  serology 
laboratories, suppliers of anti-parasite treatments, 'carriers', quarantine facilities and third 
countries  are  of  the  same  nature  as  those  described  in  section  6.5.1,  but  on  a  shorter 
timescale. 

6.3.2. 

Social impacts 

In the shorter term, social impacts are of the same nature as those described in section 
6.5.2. 

Nevertheless,  as  regards  the  public  health  impacts,  by  the  time  this  extended  period 
comes to an end, rabies eradication is likely to be achieved in the Baltic States, taking 
into account the recent figures published in Rabies Bulletin Europe. This option would 
help upgrade the level of safety of pet movements in the EU and decrease the potential 
public  health  risk  accordingly;  however,  as  there  has  been  no  human  case  of  rabies 
attributable to movements of pets, the difference is expected to be very minimal. 

6.3.3.  Environmental impacts 

On a shorter timescale, environmental impacts are of the same nature as those described 
in section 6.5.3. 

6.4. 

Analysis  of  impacts  of  option  3:  Adjustment  of  the  current  rules  applicable  to  all 
Member States 

This  option  would  mean  ending  the  specific  conditions  applied  by  the  five  Member 
States  of  destination  and  implementing  a  harmonised  regime  based  on  a  technically 
reviewed Regulation in line with  the EFSA opinions  and  including differentiated rules 
according to the Member State of origin: 

• 

• 

EFSA  recommends  applying  a  regime  where  the  anti-rabies  vaccination  is 
supplemented  by  certain  risk-mitigating  measures  targeted  on  primo-vaccinated 
pet  animals  coming  from  Baltic  States:  a  serological  test  to  confirm  the  level  of 
antibodies against rabies or a second injection of vaccine carried out 4 to 6 weeks 
after the first injection is recommended. 

EFSA does not demonstrate a particular status of the five Member States currently 
under the transitional regime with regard to echinococcosis and tick-borne diseases 

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since  no  harmonised  programmes  are  in  place  to  allow  a  possible  comparison  of 
status. The regime would therefore not include measures against those diseases. 

Main elements of the EFSA conclusions are summarised in Annex 22. 

6.4.1.  Economic impacts 

6.4.1.1.  Pet owners 

There is a need to distinguish between two categories of pet owners: 

• 

• 

Owners  of  primo-  or  multiple-vaccinated  pets:  they  will  fall  under  the  general 
regime. 

Owners  of  primo-vaccinated  pets  originating  in  the  Baltic  States:  they  would  be 
obliged to subject their pets to a serological test or a second injection of vaccine 4 
to 6 weeks after the first vaccination. 

The economic impacts on the first category are already described in section 6.1.1. 

The economic impacts on the second category depend on the option chosen: serological 
test or second injection of vaccine. From a financial point of view, the preferred option 
should be the second injection of vaccine, which is cheaper than the test as described in 
Table  2  that  must  in  case  of  insufficient  immunity  anyway  be  supplemented  by  a 
subsequent booster immunisation. However, according to the legislation, an anti-rabies 
vaccination  is  valid,  and  as  such  suitable  for  travelling,  21 days  from  the  date  of 
completion  of  the  vaccination  protocol  for  the  primary  vaccination  (including  two 
injections of vaccine). By contrast, a test can be carried out within hours or a few days 
allowing the pet animal to be moved immediately upon certification of the test result. 

6.4.1.2.  Authorised veterinarians 

Veterinarians' incomes should not increase substantially since the population of the pet 
animals concerned (primo-vaccinated pets originating in the Baltic States) is quite small. 

6.4.1.3.  EU-approved rabies serology laboratories 

If the adjustments concerning the blood testing requirement were adopted, the activities 
of  EU-approved  laboratories  would  decrease  despite  the  implementation  of  tests  on 
primo-vaccinated  animals  from  the  Baltic  States.  This  should  not  represent  more  than 
10% of the current volume of activities. 

Therefore, the impact would be very close to that described in section 6.2.1.3, the loss 
for  laboratories  being  compensated  by  the  application  of  the  general  regime  to  pets 
entering  the  EU  from  non-listed  countries  that  will  no  longer  be  subject  to  quarantine 
measures but to testing measures whatever the destination in the EU. 

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6.4.1.4.  Anti-parasite treatment suppliers 

Since  this  option  does  not  entail  any  specific  requirement  with  regard  to  anti-parasite 
treatment, impacts would be the same as those described in section 6.2.1.4. 

6.4.1.5.  Transport companies ('carriers') 

Since  this  option  would  mean  termination  of  the  specific  conditions  applied  by  the 
five Member  States,  including  specific  checking  systems  in  place,  impacts  on  'carriers' 
would be the same as those described in section 6.2.1.5. 

6.4.1.6.  Quarantine facilities 

Since this option would mean termination of the specific conditions applied by the five 
Member  States,  including  quarantine  measures,  impacts  on  quarantine  facilities  would 
be the same as those described in section 6.2.1.6. 

6.4.1.7.  Competent authorities 

Since this option would mean termination of the specific conditions applied by the five 
Member  States,  impacts  on  administrative  tasks  and  costs  for  the  competent  authority 
would be the same as those described in section 6.2.1.7. 

In addition, if this option is chosen, impacts reported by the UK concerning the need to 
publicise,  explain  and  put  in  place  new  rules  and  arrangements  and  ensure  that 
legislative  requirements  are  met  and  enforced  should  also  concern  all  the  Member 
States.  

6.4.1.8.  Third countries 

Impacts of this option are of the same nature as those described in section 6.2.1.8 since 
the risk-mitigating measures recommended by EFSA are based on the country of origin 
and only apply to pet animals originating in the Baltic States. Rules for importing a pet 
animal will fall under the general regime whatever the destination in the EU. 

6.4.2. 

Social impacts 

6.4.2.1.  Employment  

Since  this  option  would  mean  termination  of  the  specific  conditions  applied  by  the 
five Member  States,  impacts  on  employment  would  be  the  same  as  those  described  in 
section 6.2.2.1. Since the population of pets affected by specific additional measures is 
quite small, pet owners should not be greatly inconvenienced and the impact on tourism 
should accordingly be limited. 

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6.4.2.2.  Welfare of citizens 

Since this option would mean termination of the specific conditions applied by the five 
Member States, impacts on welfare of citizens are the same as those described in section 
6.2.2.2. 

6.4.2.3.  Public health 

Despite the fact that EFSA considers that the rabies risk posed by the Baltic States is not 
negligible and that risk-mitigating measures should therefore apply to pets originating in 
those Member States, the impact of such measures on public health would be marginal. 
Indeed the pet population that would be concerned is very small and the effect of those 
additional  measures  could  be  questioned  in  light  of  practical  findings  as  mentioned  in 
section 6.2.2.3. 

As  regards  E.  multilocularis  and  tick  risks,  the  impacts  would  be  the  same  as  those 
described in section 6.2.2.3 since EFSA opinions have highlighted the lack of sufficient 
data justifying additional guarantees. 

6.4.3.  Environmental impacts 

Environmental  impacts  stemming  from  a  likely  increase  in  the  number  of  pet 
movements  due  to  termination  of  the  specific  conditions  applied  by  the  five  Member 
States are difficult to quantify. 

6.5. 

Analysis  of  impacts  of  option  4:  Continuation  of  the  transitional  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 
impossible  that  other  Member  States  complying  with  OIE  criteria  for  a  rabies-free 
country  or  claiming  a  special  health  status  with  regard  to  tick-borne  diseases  and 
Echinococcosis would equally request additional conditions. This option would require a 
Commission  proposal  to  the  European  Parliament  and  the  Council  to  ensure  equal 
treatment of all Member States. 

6.5.1.  Economic impacts 

6.5.1.1.  Pet owners 

The  additional  requirements  requested  by  the  five  Member  States  currently  under  the 
transitional regime result in continuing additional costs for travellers with pets. 

Indeed,  in  addition  to  identification  and  vaccination  costs  of  the  general  regime,  pet 
owners  are  obliged  to  conduct  a  series  of  tests  and  /or  treatments  with  different 
protocols, depending on the Member State of destination. Table 2 allows a comparative 
cost evaluation. 

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Except for Finland, the costs incurred by pet owners entering the UK, Ireland, Malta and 
Sweden are at least doubled or can be multiplied up to 10 times where carriers' costs are 
taken into account. For example, according to the data mentioned in sections 3.2.1 and 
6.1.3, the cost for a pet of less than 6kg to enter Ireland by air from Portugal would be 
€1 100 while the cost for the same pet to enter Belgium by air from Portugal would be 
€108.5.  

This  example  applies  to  pet  owners  coming  from  Member  States  other  than  those 
currently under the transitional regime and from listed third countries or those returning 
to one of the four Member States. 

Nevertheless,  it  should  be  noted  that  no  further  blood  tests  are  required  following  a 
satisfactory  result  as  long  as  the  animal  is  revaccinated  against  rabies  on  time.  This 
element must be taken into account when comparing the costs.  

Moreover, although pets' eligibility is, for the most part, established before travel, there 
may  be  cases  where  ticks/echinococcus  treatment  has  not  been  properly  administered, 
resulting  in  pet  animals  being  temporarily  quarantined  although  they  come  from  EU 
Member States, and causing unexpected expense likely to compromise travel plans. 

Another possible scenario is that, owing to a lack of boxes at the quarantine stations, pet 
owners  ready  to  enter  or  re-enter  one  of  the  four  Member  States  from  non-listed 
countries may have to wait before travelling, with economic consequences. 

6.5.1.2.  Authorised veterinarians  

Impact  on  authorised  veterinarians  may  be  considered  positive  in  so  far  as  they  will 
continue  to  sample  animals  and  deliver  an  anti-parasite  treatment  for  pets  entering  the 
five  Member  States.  In  a  way,  these  additional  requirements  may  contribute  to 
sustainable vets' incomes, although there is no way of quantifying them. 

In  addition,  when  these  services  are  requested  at  the  weekend,  due  to  protocol 
constraints, fees are higher. 

6.5.1.3.  EU-approved rabies serology laboratories 

Measures constituting a precondition for entry such as blood testing requested by those 
Member  States  currently  under  the  transitional  regime  involve  54  EU-approved 
laboratories  throughout  the  world  that  are  authorised  to  carry  out  serological  tests  to 
monitor  the  effectiveness  of  rabies  vaccines.  These  laboratories  are  situated  mainly  in 
Europe  but  also  in  14  third  countries.  To  be  recognised  and  maintained  as  approved, 
laboratories  must  participate  in  annual  proficiency  tests  organised  by  the  Community 
reference  laboratory  for  rabies  serology  located  in  Nancy  (AFSSA-France).  This 
proficiency testing scheme generates costs for the participating  laboratories because of 
the service offered by AFSSA. 

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Maintaining  the  pre-testing  requirements  would  generate  sustainable  incomes  for 
laboratories. From the consultation responses, it appears that about 145 000 analyses are 
performed  annually  by the  23  laboratories that responded (about a third are performed 
by the UK's laboratories), with an average rate of €50 per test. The global annual income 
rises  to  about  €7  250  000.  It  should  be  noted  that  the  above-mentioned  analyses  may 
concern pet animals of EU or third country origin.  

It  could  be  assumed  that,  considering  the  current  trend  towards  an  increase  of  pet 
movements within or into the EU, this global income could only increase.  

6.5.1.4.  Anti-parasite treatment suppliers 

As  in  the  case  of  authorised  veterinarians,  impacts  on  suppliers  of  anti-tick  or  anti-
Echinococcus  treatment  may  be  considered  positive  since  they  will  have  to  further 
respond to the demand. However, as mentioned in section 6.2.1.2, activities of suppliers 
are  not  exclusively  linked  to  pet  travel  but  rather  to  general  animal  and  public  health 
aspects. 

6.5.1.5.  Transport companies ('carriers') 

Carriers  (ferry,  rail  and  airline  companies)  are  part  of  the  national  checking  system 
installed  by  the  UK,  Ireland  and  Malta  to  monitor  and  control  the  eligibility  of 
movements of pet animals into their territory. 

If the transitional regime is definitively maintained, transport and checking activities of 
those companies officially approved by the competent authorities of the three Member 
States  will  be  maintained.  From  the  consultation,  it  appears  that  the  UK  has  approved 
114 foreign and national companies, Ireland 9 and Malta 7.  

Competent authorities from the UK, Ireland and Malta also provided information on the 
number  of  pets  entering  their  country  per  year  and  subject  to  national  rules  (including 
pets returning from abroad), the number of applications handled per year by carriers and 
the cost of an operation. Limited figures are summarised in Annex 23.  

Member States were also asked to provide the cost of an operation for carriers, but were 
unable  to  do  so  because  this  is  considered  as  commercial  information.  Therefore,  a 
global estimation of incomes for those carriers is impossible.  

A global calculation of the costs incurred by pet owners is theoretically possible, except 
for  the  UK,  which  did  not  provide  figures,  but  this  will  not  produce  any  valuable 
information on the real incomes for carriers. 

Maintaining the national rules will anyway contribute to sustainable incomes due to the 
monopoly situation generated by the national system in place. 

EN 

44 

   EN 

 
6.5.1.6.  Quarantine facilities 

Approved  quarantine  facilities  are  used  to  accommodate  for  a  six-month  period  pet 
animals entering the UK, Ireland, Malta and Sweden when coming from non-listed third 
countries.  

If the transitional regime is definitively maintained, activities of quarantine facilities will 
be kept going. From the consultation, it appears that the UK has approved 31 quarantine 
facilities,  Ireland  1,  Malta  1  and  Sweden  2,  with  respectively  2 134,  71,  206  and  34 
applications  relating  to  dogs,  cats  and  ferrets  handled  in  2006.  The  number  of 
applications may be less than the number of animals entering quarantine as a licence can 
cover more than one animal. 

Member  States  were  asked  to  provide  the  cost  of  a  quarantine  stay  for  a  quarantine 
facility, but either failed to do so because it was considered as commercial information 
or provided information that was incomplete or not monetised.  

Therefore,  a  global  estimation  of  incomes  for  those  quarantine  facilities  is  impossible. 
Only  the  costs  incurred  by  owners  have  been  provided  by  Member  States  and  figures 
which range from €1 000 to €3 480 are presented in Annex 24.  

Maintaining  national  rules  will  anyway  contribute  to  sustainable  incomes  due  to  the 
monopoly situation generated by the national system in place. 

6.5.1.7.  Competent authorities 

From  the  Member  State  consultation,  it  appears  that  the  various  additional  guarantees 
cause  extra  work  because  it  is  not  easy  to  find  out  what  are  the  exact  rules  in  each 
country. 

For those Member States which have installed checks at the border either via "carriers", 
customs  or  veterinary  authorities,  in  contradiction  with  Community  law  (see  point 
3.2.1), maintaining the national rules will mean no let-up in the work, on a full or part-
time basis, of these categories of operators.  

6.5.1.8.  Impact on third countries 

Under  this  option,  the  more  restrictive  conditions  for  entering  the  five  countries  will 
remain and still apply to pets coming from third countries listed or not listed. The costs 
and burden on third countries' pet owners as well as on citizens from the five Member 
States returning home after a trip abroad are explained in section 6.1.2.  

6.5.2. 

Social impacts 

6.5.2.1.  Employment 

If  national  rules  are  maintained,  activities  of  EU-approved  serology  laboratories, 
'carriers',  quarantine  facilities,  authorised  veterinarians  and  anti-parasite  treatment 

EN 

45 

   EN 

 
suppliers  will  be  kept  going  and  there  should  consequently  be  no  particular 
unemployment.  

6.5.2.2.  Welfare of citizens 

If national rules are maintained, the quarantine placement which applies to pet animals 
coming  from  non-listed  third  countries  or  not  in  compliance  with  the  national  rules 
(short-term quarantine stays) will continue.  

In  such  cases,  social  (and/or  welfare)  impacts  should  be  considered  where  pet  owners 
are more often separated from their pet for a six-month period.  

As already mentioned in section 6.5.1.1, a lack of boxes at the quarantine stations could 
lead  to  travel  delays  for  pet  owners  which  may  cost  them  money  and  cause  them 
inconvenience. 

In extreme cases a decision may be taken to resort to euthanasia or re-export, with all the 
associated effects. 

6.5.2.3.  Public health 

If  national  rules  are  maintained,  it  can  be  reasonably  assumed  that  there  will  be  no 
significant  clear  benefits  in  terms  of  public  health. As  explained  in  section  6.2.2.3,  no 
human case of rabies within the EU due to lawful movements of pets has been reported 
in recent years (including from Baltic States or listed third countries such as the Russian 
Federation or the USA).  

6.5.3.  Environmental impacts 

This option means no major change as regards the situation today. Although pet travel is 
on the increase and may have implications for the environment, it is difficult to establish 
a  correlation  between  the  current  restrictive  regimes  and  the  number  of  pets  (and  pet 
owners) travelling. 

7. 

COMPARISON OF THE DIFFERENT OPTIONS 

7.1. 

Comparison of impacts 

To better compare the four options and clarify the magnitude of impacts according to the 
different groups of countries, distinction is made in the following tables between those 
groups: Member States currently under the transitional regime (Finland, Ireland, Malta, 
Sweden and the UK), Member States applying the general regime (EU-22 or EU-19 + 3 
Baltic States), listed third countries and non-listed third countries.  

For  options  1,  2  and  3,  separate  tables  visualise  the  impacts  on  the  costs  incurred  by 
travelling  pet  owners  according  to  the  origin  and  destination  of  the  movement.  The 
symbols 0 (neutral), + (positive impact) and – (negative impact) value the impact in the 

EN 

46 

   EN 

 
following  order:  marking,  passport,  anti-rabies  vaccination,  titration,  anti-echinococcus 
and anti-tick treatment. 

No table has been prepared for option 4, which reflects the current situation (baseline - 
all 0).  

NB: Although the free movement regime practised between Ireland and the UK is not in 
line with the Regulation, the impact assessment would be incomplete without evaluating 
the  consequences  particularly  for  this  aspect,  when  comparing  the  options,  and  in 
particular in the above-mentioned separate tables. 

EN 

47 

   EN 

 
ECONOMIC IMPACTS 
Impacts  on  costs  for  travelling 
pet owners  

EU 22 

m
o
r
f

g
n
i
m
o
C

Going to 

EU 19 
Baltic 
States 
FI 
IE 
MT 
SE 
UK 
Listed TC 
Non listed TC 

Impacts on authorised veterinarians 
Impacts on EU-approved rabies serology laboratories 
Impacts on suppliers of anti-parasite treatments  
Impacts on transport companies 
Impacts on quarantine facilities 
Impacts on third countries (pet owners) 
Impacts on MS competent authorities 

Enforcement costs 
Administrative 
costs 

SOCIAL IMPACTS 
Employment impacts 
Impacts on welfare of citizens 
Public health impacts 

ENVIRONMENTAL IMPACTS 

rabies 
E.multilocularis 
ticks 

Option 1 

EU 22 

EU 19 

Baltic 
States 

FI 

IE 

MT 

SE 

UK 

Listed 
TC 

Non-
listed 
TC 

0 

0 

0 
0 
0 
0 
0 
0 
0 

0 

0 

0 
0 
0 
0 
0 
0 
0 

0/- 
-/-- 
0 
N/A 
N/A 
+++ 
- 

+ 

0 
++ 
0 
0 
0 

0 

0000+037 

000+++ 

000+++ 

000++0 

000+++ 

0000+0 

000+++ 

000+++ 

000++0 

000+++ 

0 
0000+0 
0 
0 
0000+0 
0000+0 
0/- 
-/-- 
0 
N/A 
N/A 
+++ 
-- 

+ 

0 
++ 
0 
0 
0 

0 

000+++ 

0 
0 
---000 
000+++ 
+38 
+ 
-/-- 
0 
0 
--- 
+++ 
-- 

+ 

0 
++ 
0 
0 
0 

0 

000+++ 
0 

0 
0 
000+++ 
+2 
0/- 
-/-- 
0 
0 
--- 
+++ 
-- 

+ 

0 
++ 
0 
0 
0 

0 

000++0 
00-000 
0 

00-000 
000++0 
+2 
0/- 
-/-- 
0 
N/A 
--- 
+++ 
-- 

+ 

0 
++ 
0 
0 
0 

0 

000+++ 
---000 
0 
0 

000+++ 
+2 
+ 
-/-- 
0 
0 
--- 
+++ 
-- 

+ 

0 
++ 
0 
0 
0 

0 

0/- 
-/-- 
0 
N/A 
N/A 

0 
++ 
0 
0 
0 

0 

+ 
-/-- 
0 
N/A 
N/A 

0 
+++ 
0 
0 
0 

0 

37 
38 

EN 

marking-passport-anti-rabies vaccination-titration-anti-echinococcus treatment-anti-tick treatment. 
Skip the costs of quarantine stay which depends on the Member State. 

48 

EN 

 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
                                                 
Going to 

EU 22 
EU 19  Baltic States 

FI 

IE 

MT 

SE 

UK 

Listed TC  Non-listed TC 

Option 2 

ECONOMIC IMPACTS 
Impacts on costs for travelling pet owners  

EU 22 

m
o
r
f

g
n
i
m
o
C

EU19 
Baltic States 
FI 
IE 
MT 
SE 
UK 
Listed TC 
Non listed TC 

0 
0 
0 
0 
0 
0 
0 
0 
0 

0 
0 
0 
0 
0 
0 
0 
0 
0 

Impacts on authorised veterinarians 
Impacts on EU-approved rabies serology laboratories 
Impacts on suppliers of anti-parasite treatments  
Impacts on transport companies 
Impacts on quarantine facilities 
Impacts on third countries (pet owners) 
Impacts on MS competent authorities 

Enforcement costs 
Administrative costs 

SOCIAL IMPACTS 
Employment impacts 
Impacts on welfare of citizens 
Public health impacts 

ENVIRONMENTAL IMPACTS 

rabies 
E.multilocularis 
ticks 

0/- 
-/-- 
0 
N/A 
N/A 
+++ 
- 
+ 

0 
++ 
0 
0 
0 

0 

0 

0→00-000 
0 

0 
0 
0→---000 

0 
0→0000+0 
0 
0 

0→0000+0  0→000+++  0→000+++  0→000++0  0→000+++ 
0→0000+0  0→000+++  0→000+++  0→000++0  0→000+++ 
0→000+++  0→000+++  0→000++0  0→000+++ 
0→---000 
0 
0 

0 
0 
0→0000+0  0→000+++  0→000+++  0→000++0  0→000+++ 
0→+1 
0→0000+0 
0/- 
0/- 
-/-- 
-/-- 
0 
0 
0 
N/A 
--- 
N/A 
+++ 
+++ 
-- 
-- 
+ 
+ 

0→+39 
+ 
-/-- 
0 
0 
--- 
+++ 
-- 
+ 

0→+1 
+ 
-/-- 
0 
0 
--- 
+++ 
-- 
+ 

0→+1 
0/- 
-/-- 
0 
N/A 
--- 
+++ 
-- 
+ 

0→00-000 

0 
++ 
0 
0 
0 

0 

0 
++ 
0/+ 
0 
0 

0 

0 
++ 
0/+ 
0 
0 

0 

0 
++ 
0/+ 
0 
0 

0 

0 
++ 
0/+ 
0 
0 

0 

0/- 
-/-- 
0 
N/A 
N/A 

0 
++ 
0 
0 
0 

0 

+ 
-/-- 
0 
N/A 
N/A 

0 
+++ 
0 
0 
0 

0 

Skip the costs of quarantine stay which depends on the Member State. 

39 

EN 

49 

EN 

 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
                                                 
Going to 

EU 22 

EU 19 

Baltic States 

FI 

IE 

MT 

SE 

UK 

Listed 
TC 

Non-listed TC 

Option 3 

costs 

ECONOMIC IMPACTS 
Impacts 
on 
for 
travelling 
pet 
owners  

m
o
r
f

g
n
i
m
o
C

EU 22 

EU 19 
Baltic States 
FI 
IE 
MT 
SE 
UK 
Listed TC 
Non listed TC 

0 
00--00 
0 
0 
0 
0 
0 
0 
0 

0 
00--00 
0 
0 
0 
0 
0 
0 
0 

of 

on 

suppliers 

anti-parasite 

Impacts on authorised veterinarians 
Impacts  on  EU-approved  rabies  serology 
laboratories 
Impacts 
treatments  
Impacts on transport companies 
Impacts on quarantine facilities 
Impacts on third countries (pet owners) 
Impacts 
competent 
authorities 
SOCIAL IMPACTS 
Employment impacts 
Impacts on welfare of citizens 
Public 
rabies 
impacts 
E.multilocularis 
ticks 

Enforcement costs 
Administrative costs 

on  MS 

health 

ENVIRONMENTAL IMPACTS 

0/- 

-/-- 

0 

N/A 
N/A 
+++ 
- 

+ 

0 
++ 
0 
0 
0 

0 

Skip the costs of quarantine stay which depends on the Member State. 

40 

EN 

0000+0 
00--+0 

0 
0000+0 
0 
0 
0000+0 
0000+0 
0/- 

000+++ 
00--++ 
000+++ 

0 
0 
---000 
000+++ 
+40 
+ 

000+++ 
00--++ 
000+++ 
0 

0 
0 
000+++ 
+1 
0/- 

000++0 
00--+0 
000++0 
00-000 
0 

00-000 
000++0 
+1 
0/- 

000+++ 
00--++ 
000+++ 
---000 
0 
0 

000+++ 
+1 
+ 

-/-- 

0 

N/A 
N/A 
+++ 
-- 

+ 

0 
++ 
0 
0 
0 

0 

-/-- 

0 

0 
--- 
+++ 
-- 

+ 

0 
++ 
0 
0 
0 

0 

-/-- 

0 

N/A 
--- 
+++ 
-- 

+ 

0 
++ 
0 
0 
0 

0 

-/-- 

0 

0 
--- 
+++ 
-- 

+ 

0 
++ 
0 
0 
0 

0 

-/-- 

0 

0 
--- 
+++ 
-- 

+ 

0 
++ 
0 
0 
0 

0 

50 

0/- 

-/-- 

0 

N/A 
N/A 

0 
++ 
0 
0 
0 

0 

+ 

-/-- 

0 

N/A 
N/A 

0 
+++ 
0 
0 
0 

0 

EN 

 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
                                                 
7.2. 

Discussing the options 

Building  on  the  analysis  of  section  6,  below  is  a  summary  of  the  advantages  and 
disadvantages of the four options.  

Option 1 

No action 

Disadvantages 

• 

• 

It would not take into account the EFSA approach to the definition of countries 
at risk with regard to rabies based only on the prevalence in pet animals. 

It would be likely to lead to a decrease in laboratory incomes with associated 
effects  on  staff,  although  activities  in  relation  to  non-listed  third  countries 
ought to compensate for those losses.  

Advantages 

• 

It  will  lead  to  perfect  harmonisation  and  simplification  of  the  legislation 
governing non-commercial movement of pet animals. It will respect the single 
market principles. 

• 

It would lead to proportionate measures that  

(cid:57) 

are the most advantageous to citizens who travel with their pet animals in 
terms of ease and cost-risk/benefit ratio, including citizens from the five 
Member  States  -  predominantly  Ireland  and  the  UK  -  who  are  affected 
when returning home. 

(cid:57) 

at the same  time,  preserve  and  help  ensure a high level  of safety  of  pet 
movements throughout EU territory and abroad. 

• 

• 

• 

The  current  provisions  of  the  general  regime  regarding  non-listed  third 
countries guarantee a sufficient level of safety which would allow the lifting of 
quarantine measures likely to boost tourism. 

It  would  acknowledge  the  huge  efforts  made  by  the  Baltic  States  with  the 
support of the Community to combat rabies in their territories and would avoid 
giving  them  an  unjustifiable  bad  reputation  and  treating  them  less  favourably 
than certain listed third countries. 

It would take into account most of the recommendations of the EFSA opinions, 
in particular those which recognise that  

(cid:57) 

any  measures  aimed  only  at  pets  for  the  control  of  ticks  may  have  a 
limited  effect  on  preventing  further  introduction  and  expansion  of  tick 
species, 

EN 

51 

   EN 

 
(cid:57) 

the  risk  of  introduction  of  E.  multilocularis  through  trans-boundary 
wildlife  movements  is  higher  than  through  movements  of  infected  pet 
animals. 

• 

It would not allow at Council and European Parliament level the reopening of 
the  debate  on  aspects  of  the  Regulation  not  covered  by  the  present  impact 
assessment.  

Option 2 

Extension of the transitional regime until 2011 

Disadvantages 

• 

• 

They are of the same nature as those highlighted in option 4 but on a shorter 
timescale.  

It would allow at Council and European Parliament level the reopening of the 
debate  on  aspects  of  the  Regulation  not  covered  by  the  present  impact 
assessment. 

Advantages 

• 

• 

• 

• 

It would pave the way for harmonising the rules at a sufficiently high level of 
protection  under  the  currently  established,  tried  and  proven  system  at  the 
earliest possible point of time when further reduced or even eradicated sylvatic 
rabies  in  the  EU  makes  the  risk-mitigating  measures  recommended  by  EFSA 
redundant.  

2011 also corresponds to the end of the eight-year transitional period, not under 
review  in  accordance  with  Article  23  of  the  Regulation,  after  which  only 
electronic identification will be accepted as the means of identifying an animal 
under  the  Regulation.  Thus,  this  option  would  contribute  to  clarity  of 
Community  legislation,  because  changes  to  two  aspects  of  rules  on  pet 
movements would coincide. 

It  would  give  the  competent  authorities  of  the  Member  States  under  the 
transitional  regime  more  time  to  provide  the  public  with  clear  and  easily 
accessible information on the new rules. 

It would enhance clarity by determining the regime to be applied for Articles 6, 
8 and 16 as of 1 January 2012 and allow technical adaptations to be made. 

Option 3 

Adjustment of the current rules applicable to all Member States based on a 
technically reviewed Regulation 

Disadvantages 

• 

It  would  lead  to  the  creation  of  two  groups  of  countries  with  differentiated 
rules according to the country of origin 

EN 

52 

   EN 

 
(cid:57)  while  singling  out  the  Baltic  States  despite  huge  efforts  and  positive 

developments over several years. 

(cid:57)  while causing extra confusion and inconvenience amongst travellers with 

new rules in place. 

• 

It  would  conflict  with  the  current  EU  approach  to  the  definition  of  safe 
countries with regard to rabies that has proved successful since the entry into 
force of the Regulation for third countries willing to be recognised as safe. 

•  When redesigning the rules for the movement of pets on technical grounds, the 
most likely scenario would be that those Member States that currently benefit 
from national rules would have no reason to depart from their privileged zero-
risk  policy,  other  equally  rabies-free  Member  States  might  well  perceive  the 
general  regime  as  excessive,  and  the  Baltic  States,  given  their  improved 
situation,  might  see  it  as  discriminatory.  The  result  would  be  a  compromise 
liable to further diversify the movement conditions and to significantly reduce 
the overall level of protection within the EU. 

• 

It  would  be  likely  to  lead  to  a  drop  in  laboratory  incomes  with  associated 
effects on staff, although activities in relation to non-listed third countries and 
to young animals from Baltic States could compensate for those losses. 

Advantages 

• 

• 

It  would  take  account  of  the  EFSA  opinion  on  rabies  which,  based  on  2005 
data, singles out the Baltic States as countries with a residual rabies risk due to 
overly  high  prevalence  in  pet  animals  which  requires  the  implementation  of 
additional risk-mitigating measures to enhance the level of safety. 

EFSA regime shifts the burden of risk mitigation to the Member State of origin 
of the risk and thus sets incentives for improvement. 

Option 4 

Continuation of the transitional regime on a permanent basis  

Disadvantages 

• 

• 

• 

It will not take account of the scientific opinions provided by EFSA, according 
to  which  the  five  Member  States  have  no  particular  status  with  regard  to  the 
diseases  concerned,  and  would  appear  disproportionate  in  the  light  of  our 
current knowledge of the risk posed in particular by ticks and echinococcus. 

It  would  not  remove  the  confusion  and  disruption  experienced  by  some 
travellers and would continue to be costly for pet owners (cost multiplied by 2 
to 10) including citizens from the five Member States – predominantly Ireland 
and the UK - who are affected when returning home. 

It  is  far  removed  from  the  desire  of  most  Member  States  to  achieve 
harmonisation  and  simplification,  considering  the  similar  animal  health 
situation  in  Europe  with  regard  to  the  diseases  concerned.  Keeping  different 

EN 

53 

   EN 

 
sanitary requirements in place in the EU is not supported by the evidence and 
experience gained so far. 

Advantages 

• 

• 

Apart from the financial aspect, the availability of a quarantine regime may be 
beneficial  for  those  that  need  to  depart  without  delay  due  to  professional  or 
personal reasons. 

In a quarantine regime, checks are performed post-arrival on the travelling pet 
by the competent authorities of the Member State of destination.  

8. 

MONITORING AND EVALUATION 

To  ensure  that  the  new  regime  achieves  the  objectives  set  in  section  4,  the 
Commission will regularly monitor several indicators to assess its performance. 

Data on indicators will be collected through different existing sources of information 
as summarised in the table on page 52. Additional data may be generated, especially 
by  means  of  surveys  and/or  interviews,  to  measure  the  level  of  satisfaction  among 
the population/pet owners. Data from Member States' authorities (on pet movements 
and  on  public  health)  will  be  collected  regularly  at  EU  level  as  part  of  reinforced 
cooperation processes with Member States by the Standing Committee on the Food 
Chain and Animal Health (SCoFCAH).  

The Commission will closely monitor the situation, especially as regards animal and 
public  health.  After  consulting  our  internal  evaluation  office  and  assessing  DG 
SANCO's  multi-annual  evaluation  programme,  it  was  decided  not  to  plan  external 
evaluations  at  this  stage  as  it  was  deemed  disproportionate.  In  our  view,  the 
monitoring  mechanisms  will  provide  sufficient  information  to  assess  the  case  for 
revising  the  Regulation  at  a  later  stage  (in  5-10  years).  However,  if  the  situation 
changes and animal and public health risks increase, we will consider conducting an 
external  evaluation  on  animal  and  public  health  issues,  which  would  cover  this 
Regulation. 

EN 

54 

   EN 

 
Issues to be 
monitored 

Indicators 

Source 

Animal and public 
health situation 
(equivalent in all 
MS) 

Incidence/prevalen
ce of rabies cases 
in pets per 
Member State 

WHO Rabies 
Bulletin Europe 

Incidence/prevalen
ce of ticks in pet 
population 

Incidence/Prevalen
ce of E. 
multilocularis in 
pet population 

Change in 
perception of the 
complexity 
amongst pet 
owners / level of 
satisfaction of pet 
owners 

Difficulties, 
complexity and 
burden for pet 
owners 

Implementation of 
the regime 

Level of 
implementation 

Frequency of data 
collection 

Quarterly data 
available 
(distinction per 
country and per 
type of domestic 
animal) 
periodically 

periodically 

FVO inspections 

Existing WHO 
monitoring  

yearly 

EFSA Annual 
report on zoonoses 
(based on Member 
States' data) 

n/a 

n/a 

3-5 years after 
entry into force of 
new regime in all 
MS 

1-2 years after the 
ending of the 
transitional period 
– and after that 
periodically 

Number of 
consumer 
complaints (via 
letters)  
Number of 
European 
Parliament 
questions 
Survey amongst 
pet owners  

Information via the 
SCoFCAH 
(questionnaires to 
Member States) 
Number of 
consumer 
complaints (via 
letters)  

9. 

CONCLUSION 

Following the analysis of the available options it appears that options 3 and 4 do not 
contribute  meaningfully 
the  most  acute  problems  voiced  by 
administrations and citizens affected by a complicated, burdensome and inconsistent 
system  of  excessive  and  unjustified  animal  health  requirements,  in  particular 
regarding rabies. 

to  solving 

EN 

55 

   EN 

 
 
 
 
 
 
 
 
 
 
 
 
Moreover, when redesigning the rules for the movement of pets on technical grounds 
(option 3), the most likely scenario would be that those Member States that currently 
benefit  from  national  rules  would  have  no  reason  to  depart  from  their  privileged 
zero-risk policy, while other equally rabies-free Member States might well perceive 
the general regime as excessive, and the Baltic States, given their improved situation, 
might  see  it  as  discriminatory  especially  in  comparison  with  certain  listed  third 
countries. The result would be a compromise liable to further diversify the movement 
conditions and to dismantle an efficient and well-tried regime and thus significantly 
reduce the overall level of protection within the EU. 

Options 1 and 2 are similar in principle and either would entail removing sooner or 
later the unjustified disparities and discriminations by implementing throughout the 
EU the harmonised rules of the general regime, whose  high  level of protection 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. 

Both options would ensure that there is sufficient time for the competent authorities 
of Finland, Ireland, Malta, Sweden and the UK to provide the public with clear and 
easily accessible information concerning the new rules.  

Option 2 has a slight advantage over option 1. In terms of lowering the public health 
risk, a reasonable extension 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 have rendered 
EFSA recommendations on risk mitigation obsolete.  

Moreover,  in  accordance  with  the  Regulation,  in  2011  electronic  identification  will 
be the only means of identifying an animal. This would ensure additional safety and 
security of the movement of pet animals since the new system in place would avoid 
falsifications and enhance legibility of the identification information.  

Option 2 would also clarify the regime that would apply at the end of the transitional 
period in all Member States. 

Given the enlargement of the Schengen area and the likely disappearance of control 
points, such a delay could be sufficient to dispel remaining concerns and prejudices 
about the perceived risks related to pet movements and thus facilitate acceptance of 
the general regime in all Member States. 

EN 

56 

   EN 

 
ANNEX 1 
Member State consultation on experience gained with the implementation of Article 6, 8 
and 16 of the Regulation 

EN 

57 

   EN 

 
EN 

58 

   EN 

 
ANNEX 2 
Commission request to Ireland, Malta, Sweden and the UK to provide a report 
according to Article 16 of the Regulation 

EN 

59 

   EN 

 
ANNEX 3 
Five Member States consultation on the impacts on approved transport companies and 
quarantine facilities if national rules were to be withdrawn 

EN 

60 

   EN 

 
EN 

61 

   EN 

 
EN 

62 

   EN 

 
Member State consultation on the preparation costs incurred by pet owners 

ANNEX 4 

EN 

63 

   EN 

 
EN 

64 

   EN 

 
ANNEX 5 
Member States consultation on bilateral arrangements between Ireland, Malta, Sweden 
and the UK 

EN 

65 

   EN 

 
 
Commission's request to EFSA for a scientific advice on the fox tapeworm  

ANNEX 6 

EN 

66 

   EN 

 
EN 

67 

   EN 

 
 
ANNEX 7 

Scientific advice from EFSA on the fox tapeworm 

EN 

68 

   EN 

 
  
ANNEX 8 
Consultation of EU-approved serology laboratories on potential impacts of a regime 
which may restrict the implementation of a test 

EN 

69 

   EN 

 
EN 

70 

   EN 

 
EN 

71 

   EN 

 
EN 

72 

   EN 

 
ANNEX 9 
UEVP's opinion on the review of the Regulation 

EN 

73 

   EN 

 
EN 

74 

   EN 

 
ANNEX 10 

Setting up of an Inter Service Steering Group 

EN 

75 

   EN 

 
EN 

76 

   EN 

 
ANNEX 11 

Pet passport 
(Commission Decision 2003/803/EC) 

EN 

77 

   EN 

 
ANNEX 12 

Transitional regime 
Summary of the different national animal health requirements in force in Finland, 
Ireland, Malta, Sweden and the UK 
(Source: Websites' competent authorities) 

FI 

Information extracted from  

http://www.evira.fi/portal/en/animals_and_health/import_and_export/dogs__cats_and_ferrets
_and_import_of_canine_semen/  

anti-parasite 
Mandatory 
treatment against echinococcus 

Dogs and cats must be given not more than 30 days before 
it  arrives  to  Finland  an  appropriate  dosage  of  medicine 
containing  praziquantel  or  epsiprantel  against  tapeworm 
causing echinococcosis approved for the species concerned. 
The medication against echinococcosis is entered to the pet 
passport by veterinarian.  

Medication  against  echinococcosis  is  not  required  if  the 
animal  is  imported  directly  from  Sweden,  Norway  (other 
parts than Spitsbergen), the United Kingdom or Ireland, or 
if  the  animal  is  brought  back  to  Finland  within  24  hours 
against 
from 
echinococcosis  is  also  not  required  for  animals  which  are 
less than three months old.  

country.  Medication 

leaving 

the 

IE 

Information extracted from  

http://www.agriculture.gov.ie/index.jsp?file=pets/travel.xml 

blood 

testing 
Mandatory 
their 
before 
a 
territory 
protective level of  anti-rabies 
antibodies 

into 
confirm 

entry 
to 

Subsequent  to  the  first  rabies  vaccination  (usually  about  a 
month later but your veterinarian will advise) your pet must 
be blood tested to confirm a neutralising antibody titration at 
least  equal  to  0.5  IU/ml.  The  test  must  be  carried  out  in  a 
laboratory approved for this purpose. If you keep your rabies 
vaccinations up to date you will only have to do this blood-
test  once.  However  if  there  is  any  break  in  vaccination  the 
test  must  be  repeated.  Blood  sampling  must  have  been 
carried out in an eligible country. Your pet may enter Ireland 
only when at least six months has expired since a successful 
blood-test.  This  provision  is  to  ensure  that  your  pet  is  not 
incubating rabies.  

If your pet has had a break in its vaccinations and has had to 
repeat the blood-test, six months must pass from the date of 

EN 

78 

   EN 

 
Mandatory 
treatment 
echinococcus 

anti-parasite 
against 

the most recent test before your pet can enter Ireland. 

Between 24 and 48 hours before you check-in for travel you 
must bring your pet to a registered veterinarian to be treated 
against  tapeworm.  This  is  to  prevent  a  risk  of  potentially 
serious 
tapeworm 
(echinococcus  multilocularis) 
treatment  must  contain 
praziquantal as an active ingredient. 

Ireland.  The 

entering 

disease 

Mandatory 
treatment against ticks 

anti-parasite 

Between 24 and 48 hours before you check-in for travel you 
must bring your pet to a registered veterinarian to be treated 
against  tick.  This  is  to  prevent  a  risk  of  potentially  serious 
disease  entering  Ireland.  The  tick  treatment  must  be  other 
than by a collar impregnated with acaricide.  

MT 

Information extracted from  

http://www.veterinary.gov.mt/page.asp?p=6107&l=1 

blood 

testing 
Mandatory 
their 
before 
a 
territory 
protective level of  anti-rabies 
antibodies 

into 
confirm 

entry 
to 

Mandatory 
treatment 
echinococcus 

anti-parasite 
against 

Mandatory 
treatment against ticks 

anti-parasite 

The pet owner must refer to his/her Veterinarian in order to 
have  a  blood  sample  taken  at  least  30  days  after  the  rabies 
vaccination, and then sent to an authorised laboratory where 
a  seroneutralization  titre  test  is  carried  out  in  order  to 
determine the antibody titre. Pet animals cannot enter Malta 
until  at  least  six  calendar  months  after  the  date  that  the 
Veterinarian  took  a  blood  sample  that  give  a  successful 
seroneutralization titre test result. 

24-48  hours  prior  before  starting  the  journey  for  Malta,  it 
must  be  treated  with  praziquantel  for  tapeworm.  The 
treatment  must  be  carried  out  by  a  Veterinarian,  who  will 
then issue a certificate indicating the products used as well as 
the date and the time (in 24-hour system) when the treatment 
was carried out. 

24-48  hours  prior  before  starting  the  journey  for  Malta,  it 
must be treated with fiprinol for ticks. The treatment must be 
carried  out  by  a  Veterinarian,  who  will  then  issue  a 
certificate  indicating  the  products  used  as  well  as  the  date 
and  the  time  (in  24-hour  system)  when  the  treatment  was 
carried out. 

SE 

Information extracted from  

http://www2.sjv.se/webdav/files/SJV/trycksaker/Pdf_ovrigt/ovr76gb.pdf  

testing 
Mandatory 
before entry into their territory 

blood 

No sooner than 120 days and no more than 365 days after 
the basic vaccination against rabies, a veterinarian shall take 

EN 

79 

   EN 

 
to confirm a protective level of 
anti-rabies antibodies 

a blood sample of the animal in order to verify the level of 
rabies antibodies. 

Mandatory 
anti-parasite 
treatment against echinococcus 

A veterinarian shall deworm your animal against tapeworm 
(Echinococcus) 1-10 days before you bring it to Sweden. 

There is no requirement for deworming a cat or a dog that 
are to be imported into Sweden and that have only stayed in 
Finland and Norway at least one year prior to import. 

Four-week  certificate  for  commuting  between  Sweden  and 
Denmark:  by  derogation,  animals  that  live  in  Sweden  or 
Denmark  and  that  accompany  commuters  between  these 
two  countries,  are  allowed  to  be  dewormed  every  28  days 
by a veterinarian  

UK 

Information extracted from 

http://www.defra.gov.uk/animalh/quarantine/pets/procedures/vets_proc.htm  

blood 

Mandatory 
testing 
before 
their 
a 
territory 
protective level of  anti-rabies 
antibodies 

into 
confirm 

entry 
to 

To  be  carried  out  after  vaccination  against  rabies  by  an 
approved laboratory six months prior to travel 

Mandatory 
treatment 
echinococcus 

anti-parasite 
against 

Mandatory 
treatment against ticks 

anti-parasite 

The treatment must be carried out not less than 24 hours and 
not more than 48 hours before the pet is checked-in with the 
approved  transport  company  to  travel  on  the  return  journey 
to  the  UK.  The  treatment  must  be  given  every  time  a  pet 
enters the UK. 

The  tapeworm  treatment  must  contain  praziquantel  and  be 
the  manufacturer’s 
administered 
instructions. 

in  accordance  with 

The treatment must be carried out not less than 24 hours and 
not more than 48 hours before the pet is checked-in with the 
approved  transport  company  to  travel  on  the  return  journey 
to  the  UK.  The  treatment  must  be  given  every  time  a  pet 
enters the UK. 

The  tick  treatment  must  be  a  veterinary  product  which  has 
marketing authorisation in the country of use and is licensed 
for use against ticks. A tick collar is not acceptable.  

EN 

80 

   EN 

 
ANNEX 13 

Transitional regime 

Exemptions existing between Ireland, Malta, Sweden and the UK, as regard anti-rabies 
vaccination and antibody titration requirements  
in the context of Article 6(1) of the Regulation 
(Source: Member States' competent authorities' consultation) 

IE 

• 

MT 

• 

SE 

• 

• 

Ireland  currently  exempts  pets  entering  from  the  UK  from  vaccination  and 
antibody titration requirements. 

Malta  exempts  UK,  IE  and  SE  from  the  antibody  titration  but  not  from 
vaccination. 

Pets coming directly from the UK and Ireland: no rabies vaccination and no 
antibody titration 

Pets coming directly from Malta: Rabies vaccination + antibody titration at 
120 days post vaccination, at the earliest (Sweden is currently performing a 
review of the national regulation complementing Regulation 998/2003, and 
is  considering  abolishing  the  vaccination  and  titration  requirement  for  pets 
from Malta.)  

UK 

• 

The UK currently exempts pets entering from Ireland from vaccination and 
antibody titration requirements. 

• 

No exemption from vaccination and antibody titration requirements for pets 
entering the UK from Sweden and Malta 

EN 

81 

   EN 

 
ANNEX 14 

Transitional regime 

Exemptions existing between Sweden and Denmark 
in the context of Article 21 of the Regulation 
(Source: Commission Decision 2004/557/EC and MS consultation) 

SE/DK  By  way  of  derogation  of  Article  6  of  the  Regulation,  Sweden  exempts  the  Danish 
dogs  and  cats  travelling  to  the  Danish  island  of  Bornholm  via  Sweden  from  the 
passport,  rabies  vaccination  or  antibody  titration  requirements,  as  long  as  the 
animals  

• 

• 

• 

• 

• 

• 

are marked either by tattoo or transponder,  

travel directly along one of two given routes from Sealand through Sweden 
to Bornholm either way (maximum of 4 hours drive) and,  

have a ticket for the ferry trip,  

do not leave the car/truck/bus/train when in Sweden,  

are not in contact with any other animals, 

are de-wormed according to Swedish rules. De-worming has to take place 
either within 10 days before entry or continuously every 28 days according 
to the four-week certificate. 

EN 

82 

   EN 

 
ANNEX 15 

Figures on pet movements 
(Source: Member States' competent authorities' consultation) 

Number  of  pets  entering 
the  country  per  year 
(including  pets  returning 
from abroad) 

IE 

MT 

955 

1295 

127841 

289 

330 

N/A 

528 

UK 

41137 

55516 

65656 

79923 

84767 

99307 

10403142 

2002 

2003 

2004 

2005 

2006 

2007 

2008 

41 
42 

Last update 1/11/2007. 
Figures  extracted  from  http://www.defra.gov.uk/animalh/quarantine/pets/procedures/stats.htm  (Figures 
exclude  animals  entering  quarantine  and  do  not  include  animals  entering  UK  from  the  Republic  of 
Ireland as this information is not collected.). 

EN 

83 

   EN 

 
 
 
 
 
 
 
 
 
 
                                                 
ANNEX 16 

Complaints 

Complaints from individuals  

Since the entry into force of the Regulation, the Commission has registered many complaints 
from British, Irish and Swedish citizens submitted either directly or through their Member of 
the  European  Parliament.  It  is  certainly  the  case  that  national  rules  affect  primarily  citizens 
from those five Member States upon their return from a trip abroad. Complaints are mainly 
about: 

(1) 

(2) 

(3) 

(4) 

exorbitant cargo rates charged by international air carriers to transport pets due to the 
monopoly situation as a result of the obligation to transport pets as "cargo",  

limited  number  and  inequitable  geographical  distribution  of  entry  points  where 
necessary checks are performed, 

different  protocols  in  place  in  these  Member  States  leading  to  unfortunate 
misunderstandings, 

high fees requested by veterinarians situated in the proximity of exit ports to the UK, 
in  particular  the  area  of  Calais,  for  the  certification  and  treatment  required  for  pets 
accompanying UK citizens regularly holidaying outside the UK (stays of more than 
48 hours and during bank holidays/weekends may lead to additional costs in relation 
to the pre-entry anti-parasite treatment). 

Complaints from competent authorities of Member States  

Although  the  Member  States  consider  the  general  regime  under  the  Regulation  to  be  an 
improvement  overall  compared  to  the  previous  situation  in  which  the  individual  Member 
States applied their own import rules, the following shortcomings of the current transitional 
regime have been singled out:  

– 

– 

– 

– 

the reinforced protection measures between rabies-free Member States (most of the 
western  parts  of  the  EU  according  to  OIE)  and  those  with  a  long  history  of  rabies 
freedom  (UK or Ireland)  are considered  outdated and  discriminatory. OIE  does not 
justify such differences as there are two ways of achieving rabies freedom; 

the  transitional  regime  is  unfair  in  comparison  with  the  general  regime  that  has 
proved to be efficient, as no rabies cases have been reported in Member States other 
than  the  UK,  Ireland,  Malta  and  Sweden  although  they  allow  entry  of  pets  coming 
from non-rabies-free Member States without prior testing for antibodies; 

differences  in  sanitary  requirements,  including  amongst  the  five  Member  States 
concerned,  lead  to  a  lengthening  of  the  time  required  before  pets  are  authorised  to 
travel and hamper subsequent journeys through those five Member States, 

Denmark  raised  the  specific  issue  of  the  Swedish  national  transit  requirements, 
which cause serious inconvenience to pet owners travelling frequently. 

EN 

84 

   EN 

 
ANNEX 17 

Rabies epidemiology and control measures in the EU 

Rabies is one of the first diseases to be identified as a zoonosis. It causes encephalomyelitis 
and  can  affect  all  mammals  including  humans.  Virus  transmission  occurs  when  there  is 
contact with infectious saliva, i.e. bites, scratches, broken skin. In the absence of timely and 
appropriate treatment the disease is always fatal. 

Although  rabies  is  a  vaccine-preventable,  compulsorily  notifiable  disease,  it  is  still 
widespread  throughout  the  world,  responsible  for  about  55 000 human  deaths  every  year 
(99% occur in Asia and Africa), most often following an infection transmitted by a rabid dog 
(urban  rabies).  Each  year,  around  10  million  people  receive  treatment  after  exposure  to 
animals in which rabies is suspected. The World Heath Organisation (WHO) has developed 
strategies to  promote  wider access to  appropriate post-exposure treatment to prevent human 
rabies  cases  and  to  support  dog  rabies  control  by  mass  vaccination  campaigns  and  dog 
population management.  

I. 

Rabies eradication strategy in the EU 

With  wildlife  species  accounting  for  approximately  80%  of  all  rabies  cases  in 
Europe, rabies is predominately of a sylvatic nature. More than 80% of wildlife cases 
are  recorded  in  red  foxes  (Vulpes  vulpes).  Rabies  transmission  within  animal 
populations  is  largely  density  dependent.  In  the  past,  conventional  methods  of  fox 
rabies  control  such  as  intensive  culling  or  trapping  have  generally  failed  to  reduce 
and maintain the fox population below a certain level to extinguish rabies, not least 
because such measures also affect the social structure and behavioural patterns of the 
fox population.  

The  oral  vaccination  of  foxes  against  rabies  via  aerial  bait  distribution,  which  was 
introduced some 25 years ago, opened up a new avenue of rabies control in wildlife. 
Since then this method has proved to be the only effective way to eliminate rabies in 
foxes and other terrestrial reservoir species, such as raccoon dogs. Great progress has 
been made in the eradication of rabies in the EU with the optimisation of vaccination 
strategies:  aerial  bait  distribution  schemes  using  GPS  (Global  Positioning  System) 
technology, size of vaccination areas, timing and duration of vaccination campaigns, 
surveillance and monitoring (follow-up of bait uptake and immunity of foxes). 

Field  evidence  has  demonstrated  that  with  the  elimination  of  sylvatic  rabies  in  the 
EU, occurrence of the disease is diminishing in domestic animals.  

II. 

Community contribution to the rabies monitoring and eradication programmes 

The  results  obtained  with  EU-wide  oral  vaccination  of  foxes,  financed  by  the 
Community in the framework of rabies eradication and monitoring programmes, are 
outstanding.  Over  a  ten-year  period  more  than  €80 000 000  has  gone  towards 
eradicating  rabies  with  a  view  to  protecting  the  health  of  humans  and  facilitating 
movements of susceptible species within the EU. 

Therefore, in most parts of Western and Central Europe, rabies has been successfully 
controlled and eradicated. So far between 1991 and 2008, as a result of effective oral 

EN 

85 

   EN 

 
vaccination  programmes,  nine  Member  States  (Finland,  the  Netherlands,  Italy, 
France,  Luxembourg,  Belgium,  Czech  Republic,  Austria  and  Germany)  have 
declared  compliance  with  the  criteria  to  be  considered  free  of  rabies  in  accordance 
with  the  relevant  Chapter43  of  the  Terrestrial  Animal  Health  Code  of  the  World 
Organisation for Animal Health (OIE). 

Experience  has  shown  that  rabies  eradication  is  successful  when  eradication 
programmes are properly defined, resourced and implemented. Member States with 
positive findings in their wild carnivore population have eradication programmes in 
progress  or  planned.  In  order  to  eradicate  rabies  throughout  the  EU,  and  to  avoid 
reintroduction  of  rabies  from  neighbouring  countries  east  of  the  EU,  continuous 
vaccination programmes are important in high-risk areas. 

Council  Decision  90/424/EEC  of  26  June  199044  on  expenditure  in  the  veterinary 
field provides for the possibility of a financial contribution by the Community in the 
rabies eradication and monitoring programmes.  

The  Commission  has  intensified  exchanges  of  views  between  Member  States 
involved in co-financed eradication programmes by creating a task force45 dedicated 
to  rabies  and  aiming  at  improving  the  effectiveness  of  its  eradication.  The  rabies 
subgroup,  which  meets  regularly,  provides  technical  expertise  and  advice  for  the 
Member States and the Commission. 

Concerned by the residual risks arising from potentially infected wildlife in Eastern 
Europe and from the presence of rabies in neighbouring countries, the Commission 
also  increased  its  financial  contributions  to  cross-border  programmes  for  the  oral 
vaccination  of  wildlife  along  the  Community's  external  borders.  The  appropriate 
financial contributions were committed for the 2007 rabies eradication programme46 
to  be  implemented  by  Lithuania,  including  vaccination  along  the  border  with  the 
Kaliningrad Region of the Russian Federation.  

Legal  constraints  hampered  the  implementation  of  that  programme,  for  which  a 
solution  was  found  by  adopting  Council  Decision  2006/965/EC47  providing  a  legal 
basis for direct Community support of disease control measures outside the EU.  

Subsequently  the  Russian  Federation  submitted  a  multi-annual  rabies  eradication 
plan in the Kaliningrad Region for the period from 1 January 2009 to 31 December 
2011,  providing  for  anti-rabies  vaccination  of  wildlife  in  the  entire  region.  A  draft 
Commission  Decision  necessary  to  provide  the  required  Community  funding  is 
currently under consideration. 

A programme on  the territory of the Russian Federation at the border with Finland 
has been in place since 2000. Similarly, discussions are under way with Ukraine and 
are  at  a  less  advanced  stage  with  Belarus  about  joint  efforts  to  tackle  this  disease 
within their territories. 

43 
44 
45 
46 
47 

http://www.oie.int/eng/normes/mcode/en_chapitre_2.2.5.htm  
http://eur-lex.europa.eu/LexUriServ/site/en/consleg/1990/D/01990D0424-20070101-en.pdf  
http://ec.europa.eu/food/animal/diseases/eradication/taskforce_en.htm  
Commission Decisions 2006/687/EC and 2006/875/EC. 
OJ L 397, 30.12.2006, p. 22. 

EN 

86 

   EN 

 
                                                 
In  2007  the  Commission  initiated  discussions  with  the  Western  Balkan  countries 
(that have candidate or potential candidate status) aiming at supporting their efforts 
to  combat  animal  diseases  including  rabies  in  order  to  limit  the  risk  to  animal  and 
human health, not only in the countries themselves but also in regard to the Member 
States. The Commission's intention is to give financial aid to those countries via IPA 
funds  (the  instrument  for  pre-accession  assistance),  through  the  buying  of  vaccines 
and  the  possibility  to  drop  bait  from  airplanes.  All  Western  Balkan  countries  have 
submitted their national disease eradication programmes for financing under the IPA 
2008 budget.  

III. 

The role of the Community Reference Laboratory for rabies 

In  mid  2007,  the  Commission  decided  to  launch  a  procedure  for  designation  of  a 
Community  Reference  Laboratory  (CRL)  for  rabies.  The  existing  CRL  for  rabies 
serology only conducts serological tests to monitor the effectiveness of vaccinations 
against rabies for movements of pets and has very limited competence as regards the 
main tasks related to rabies control and eradication. There is indeed a need to have an 
EU  laboratory  with  special  expertise  on  analysis  relevant  to  the  detection  of  rabies 
which could provide advice on: 

(1) 

the latest methods for combating rabies via the use of vaccines which are based 
on the results of epidemiological investigations; 

(2)  harmonising  and  coordinating  the  use  of  methods  to  monitor  vaccination 

efficacy;  

(3)  making  it  easier  to  obtain  comparable  data  collected  in  countries  with 

eradication programmes;  

(4) 

analysing the data collected and sharing experience. 

This reference laboratory should also offer training and advice on rabies eradication. 
These tasks could be dealt with in close cooperation with the European Food Safety 
Authority (EFSA) or other relevant bodies. 

By Commission Regulation (EC) No 737/2008, the Laboratoire d'études sur la rage 
et la pathologie des animaux sauvages of the Agence Française de Sécurité Sanitaire 
des  Aliments  (AFSSA),  Nancy,  France,  was  designated  as  CRL  for  rabies  from  1 
July  2008  until  30  June  2013.  AFSSA-Nancy  is  also  the  existing  CRL  for  rabies 
serology, operative since 2000. 

EN 

87 

   EN 

 
IV. 

Community financial contribution to rabies eradication programmes since 1995 

EN 

88 

EN 

 
  
ANNEX 18 

Rabies data in EU-15 when the Regulation was adopted 
(Source 'Rabies Bulletin Europe'- years 2002/2003) 

total number 

wildlife 

domestic animals 

dogs 

cats 

others 

2002 

24 
0 
3 
0 
3 
43 
0 
0 
0 
0 
3 
0 
8 
0 
2 

22 
0 
0 
0 
0 
33 
0 
0 
0 
0 
0 
0 
0 
0 
0 

1 
0 
0 
0 
1 
1 
0 
0 
0 
0 
0 
0 
4 
0 
0 

1 
0 
0 
0 
0 
1 
0 
0 
0 
0 
0 
0 
0 
0 
0 

0 
0 
1 
0 
0 
0 
0 
0 
0 
0 
0 
0 
3 
0 
0 

total number 

wildlife 

domestic animals 

dogs 

cats 

others 

2003 

1 
0 
3 
1 
2 
37 
0 
0 
0 
0 
7 
0 
1 
0 
1 

0 
0 
0 
0 
0 
24 
0 
0 
0 
0 
0 
0 
0 
0 
0 

0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
1 
0 
0 

0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 

1 
0 
0 
1 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 

AT 
BE 
DK 
FI 
FR 
DE 
GR 
IE 
IT 
LU 
NL 
PT 
ES 
SE 
UK 

AT 
BE 
DK 
FI 
FR 
DE 
GR 
IE 
IT 
LU 
NL 
PT 
ES 
SE 
UK 

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ANNEX 19 

Comparative rabies data from 2003 to 2008 in Bulgaria, Belarus, Estonia, Croatia, 
Lithuania, Latvia, Poland, Romania, the Russian Federation and Ukraine  
(Source 'Rabies Bulletin Europe')  

BULGARIA 

total 
number 

wildlife 

domestic animals 

dogs 

cats 

others 

19 

11 

8 

10 

40 

51 

15 

4 

4 

4 

27 

41 

2 

0 

1 

1 

7 

5 

BELARUS 

total 
number 

wildlife 

1077 

211 

591 

1499 

823 

964 

761 

135 

442 

1136 

603 

735 

ESTONIA 

total 
number 

wildlife 

814 

314 

266 

114 

4 

3 

697 

254 

229 

101 

2 

1 

dogs 

133 

27 

63 

136 

61 

79 

dogs 

34 

24 

6 

5 

0 

1 

0 

2 

0 

4 

6 

4 

domestic animals 

cats 

119 

28 

41 

129 

79 

75 

domestic animals 

cats 

28 

20 

8 

4 

0 

0 

2 

5 

3 

1 

0 

1 

others 

64 

21 

45 

98 

80 

75 

others 

55 

16 

23 

4 

2 

1 

2003 

2004 

2005 

2006 

2007 

2008 

2003 

2004 

2005 

2006 

2007 

2008  

2003 

2004 

2005 

2006 

2007 

2008  

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CROATIA 

total 
number 

wildlife 

domestic animals 

dogs 

cats 

others 

633 
504 
557 
565 
635 
1061 

590 
471 
525 
516 
596 
982 

21 
13 
11 
24 
15 
29 

14 
15 
14 
12 
12 
30 

8 
5 
7 
13 
12 
20 

LITHUANIA 

total 
number 

wildlife 

domestic animals 

dogs 

cats 

others 

1108 
553 
1652 
2232 
432 
69 

796 
408 
1312 
1883 
313 
47 

56 
39 
89 
111 
34 
5 

81 
34 
92 
88 
43 
6 

175 
72 
159 
150 
42 
11 

LATVIA 

total 
number 

wildlife 

domestic animals 

dogs 

cats 

others 

964 
443 
421 
472 
203 
110 

282 
350 
353 
384 
145 
90 

62 
33 
20 
31 
26 
8 

52 
35 
29 
44 
27 
10 

21 
25 
19 
13 
5 
2 

POLAND 

total 
number 

wildlife 

domestic animals 

dogs 

cats 

others 

388 
136 
138 
82 
70 
29 

310 
103 
98 
59 
52 
21 

19 
4 
5 
4 
2 
1 

27 
10 
7 
6 
6 
1 

26 
9 
24 
9 
7 
3 

2003 
2004 
2005 
2006 
2007 
2008  

2003 
2004 
2005 
2006 
2007 
2008  

2003 
2004 
2005 
2006 
2007 
2008  

2003 
2004 
2005 
2006 
2007 
2008 

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ROMANIA 

total 
number 

wildlife 

domestic animals 

dogs 

cats 

others 

95 

187 

530 

293 

378 

1089 

67 

119 

354 

219 

269 

906 

RUSSIA 

total 
number 

wildlife 

2866 

1549 

3087 

1349 

3471 

3353 

1360 

563 

1306 

579 

1610 

1628 

8 

28 

64 

34 

40 

79 

dogs 

624 

361 

647 

261 

539 

758 

5 

18 

61 

17 

24 

47 

domestic animals 

cats 

347 

282 

493 

227 

517 

501 

UKRAINE 

total 
number 

wildlife 

2031 

907 

2113 

2020 

2932 

2164 

924 

425 

959 

982 

1348 

822 

domestic animals 

dogs 

369 

132 

358 

376 

495 

545 

cats 

442 

221 

470 

400 

669 

628 

15 

22 

51 

23 

44 

57 

others 

531 

330 

633 

280 

798 

454 

others 

293 

128 

324 

262 

417 

106 

2003 

2004 

2005 

2006 

2007 

2008  

2003 

2004 

2005 

2006 

2007 

2008  

2003 

2004 

2005 

2006 

2007 

2008  

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ANNEX 20 

Information on alveolar echinococcosis and tick borne diseases 
(Source EFSA opinion) 

Alveolar echinococcosis 

Alveolar echinococcosis, caused by the tapeworm E. multilocularis, is a rare zoonotic chronic 
cancer-like disease with a fatality rate of up to 100% in untreated patients. It is considered one 
of  the  most  severe  human  parasitoses  in  non  tropical  regions  and  has  received  considerable 
attention in recent years particularly in Europe, Japan and most recently China.  

E. multilocularis occurs throughout the northern hemisphere although its scale of distribution 
and  frequency  is  not  completely  known.  The  tapeworm  can  be  found  in  foxes  in  central 
Europe, to the north of Denmark, the Netherlands and Belgium, in the east to the Baltic States 
and  Slovakia,  in  the  south  to  north  eastern  Italy  and  Hungary  and  in  the  west  to  central 
France. Although the parasite has an extensive geographic distribution in most of Europe, it 
has never been recorded in the British Isles, Fennoscandia, and the Iberian Peninsula.  

A number of isolated surveys in wildlife show great variations from one country to another 
and even between regions in the same country. Therefore it is extremely difficult to compare 
epidemiological  situations  and  any  evaluation  of  the  epidemiology  can  only  be  an 
approximation. 

Risk factors are still incompletely known.  

The typical transmission cycle in Europe is wildlife-based, involving red foxes as final hosts 
and rodents as intermediate hosts. Domestic dogs and cats can be infested but they appear to 
be of secondary importance for the lifecycles' persistence. As potential definitive hosts they 
may, however, play a role in transmission to humans. 

There is evidence that prevalence rates in foxes have risen in many agriculturally dominated 
landscapes  of  France,  the  Netherlands,  Germany,  Austria,  Slovakia  and  Poland,  but  the  life 
cycle  is  now  also  established  in  many  urban  areas,  where  red  foxes  occur  with  high 
population  densities.  According  to  EFSA  and  more  recent  data  collected  by  the  Member 
States, with the increasing population of foxes in the Community and the migration of those 
animals  into  urban  areas,  there  may  be  an  increased  risk  of  humans  becoming  infected 
through  accidental  ingestion  of  fox  faeces  contaminating  fruits  and  vegetables.  Trans-
boundary  wildlife  movements  can  also  constitute  an  important  route  for  the  introduction  of 
the disease in certain countries. 

Very few data on the infection rates of pets (dogs and cats) are available, and existing data are 
difficult  to  interpret  due  to  a  lack  of  information  on  the  sampling  strategies.  Surveys 
conducted in Finland to detect E. multilocularis in dogs have so far yielded negative results. 
Ireland,  Malta,  Sweden  and  the  UK  have  not  provided  any  information  on  surveillance  in 
domestic dogs. From the limited number of published surveys 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. 

In  humans,  data  from  the  year  2005  point  to  an  apparent  increase  of  cases.  However,  as  it 
typically  takes  an  infected  person  10  to  15  years  to  develop  the  disease,  it  is  difficult  to 
determine the origin of the infection which is often not reported by Member States. Imported 

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cases have been reported in non-endemic areas. This shows that the risk of people travelling 
to  endemic  areas  (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.  

The  risk  for  humans  in  non  endemic  areas  cannot  therefore  be  limited  to  hazards  from 
infected pets introduced from endemic areas.  

Tick borne diseases 

Ticks as hematophagous parasites are known to transmit serious zoonotic diseases. They are 
also considered a major burden in livestock production due to their ability to transmit several 
diseases  as  well  as  causing  significant  irritation  to  animals  that  can  influence  their 
productivity. 

Out of the 866 tick species identified, approximately 54 affect pets. Pets can suffer from tick-
borne diseases but can also be a vehicle to transmit ticks to humans and to new environments 
and countries. 

Ticks  together  with  fleas,  are  the  most  widespread  ectoparasites  affecting  pets.  They  are 
indiscriminate  feeders  as  they  parasitize  a  large  range  of  small  mammals,  companion  and 
economic animals and humans.  

Tick  species  harboured  by  pets  are  widespread  in  Europe,  including  in  the  UK,  Ireland  and 
probably Malta. Surveillance systems for tick species and tick-transmitted diseases are limited 
and incomplete. The current available data indicate a lack of systematic specimen collection, 
epidemiological  background  and  effective  control  measures.  Some  of  the  available 
information is either anecdotal or outdated. 

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ANNEX 21 

Costs incurred by pet owners to prepare a pet under the different regimes 
(Source: Member State consultation) 

1. 

COSTS INCURRED BY PET OWNERS TO PREPARE A PET UNDER THE GENERAL REGIME 

1.1.  Movement within, and entry from listed third countries into, the EU 

Preparation costs include those incurred for identification and vaccination of the pet 
animal. 

(1) 

Identification costs48 

According  to  the  Regulation,  a  pet  animal  (cat,  dog  or  ferret)  is  regarded  as 
identified  when  it  bears  either  a  clearly  readable  tattoo  or  a  microchip 
(transponder)  and  when  it  is  accompanied  by  a  passport.  After  3  July  2011, 
tattooing will no longer be accepted. 

As part of the consultation, Member States were asked to provide the cost of 
both a tattoo and implantation of a microchip and the cost of issuing a passport, 
including  service  fees.  With  a  view  to  comparing  costs  between  Member 
States, the information was requested for a pet of average size and if necessary 
with distinction of the species. 

From the consultation, it appears that the cost of a tattoo is no longer relevant 
since  most  Member  States  have  already  banned  it.  Where  tattooing  is  still 
authorised, the cost provided by 8 out of 18 Member States ranges from €1.95 
(Czech Republic) to €72 (Denmark), with an average cost of €25.5, including 
where necessary the sedation of the animal.  

The  cost  of  a  microchip,  which  may  include  the  vet's  charge  to  the  owner  to 
cover issuing of a passport, ranges from €5 (Romania) to €64 (Finland), with 
an average cost of €34.3. A microchip is usually more expensive than a tattoo. 
In the same Member State it may be 12 times more expensive. In two Member 
States, however, it is cheaper. 

The  veterinary  charge  to  the  owner  to  cover  issuing  of  a  passport,  when  not 
included in the cost of the microchip, ranges from 0 (Ireland) to €45 (Sweden), 
with an average cost of €16.2. 

It should be noted that since identification of dogs is obligatory under national 
law  in  most  Member  States,  a  tattoo  or  microchip  may  not  necessarily 
constitute an additional travel-related cost. 

(2)  Health costs25 

Health costs consist of the cost of an anti-rabies vaccination.  

48 

Median value not indicated when not significantly different from average. 

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According to the Regulation, a vaccination against rabies is valid 21 days from 
completion  of  the  vaccination  protocol  for  the  primary  vaccination  and  from 
the date of revaccination where the vaccine is administered within the period of 
validity  of  a  previous  vaccination.  It  should  be  noted  that  where  anti-rabies 
vaccination  of  domestic  carnivores  is  obligatory  under  national  law  (in  the 
framework  of  rabies  eradication  programmes),  there  are  no  additional  travel-
related costs. 

Several  vaccines  against  rabies  are  marketed  and  a  vaccine  produced  by  one 
company  may  have  a  distinct  period  of  validity  according  to  the  marketing 
authorisation granted by the competent authority in the country of origin of the 
vaccinated  pet.  These  differences  in  vaccination  validity,  which  affect 
travellers  through  different  frequencies  of  revaccination,  do  not  exist  for 
vaccines  for  which  the  manufacturer  holds  a  marketing  authorisation  granted 
by  means  of  a  centralised  procedure  according  to  Directive  2001/82/EEC  of 
6 November  2001  of  the  European  Parliament  and  of  the  Council  on  the 
Community code relating to veterinary medicinal products.  

The  vaccination  must  be  carried  out  by  an  authorised  veterinarian  who  must 
endorse the passport or issue a certificate to that effect.  

As part of the consultation, Member States were therefore asked to provide the 
average  cost  of  an  injection  of  anti-rabies  vaccination  including  vaccine, 
visit/act fees and passport documentation.  

From  the  consultation,  it  appears  that  the  cost  of  the  anti-rabies  vaccination 
ranges from €2 (Romania) to €65 (Denmark), with an average cost of €26.7. 

1.2. 

Entry from non-listed third countries into the EU  

Preparation costs include, in addition to the identification and anti-rabies vaccination 
costs, the cost of sampling with certification of the laboratory result in the passport 
and laboratory analysis, since that category of pets must be subjected to blood testing 
to confirm the protective level of anti-rabies antibodies.  

As  part  of  the  consultation,  Member  States  were  therefore  asked  to  provide  the 
average cost25 of sampling with certification of the laboratory result in the passport 
and  EU-approved  laboratories  were  asked  to  provide  the  cost  of  an  analysed  post-
vaccination serum.  

From  the  Member  State  consultation,  it  appears  that  the  average  cost  of  sampling 
with certification of the laboratory result in the passport ranges from €5 (Lithuania) 
to €65 (the UK), with an average cost of €34. 

25 out of the 36 EU-approved laboratories officially consulted by the Commission on 
27 September 2007 sent the standardised questionnaire back. 

From the replies, although some laboratories did not provide a response concerning 
the  cost,  it  appears  that  the  average  cost  of  titration  of  a  post-vaccination  serum  is 
€50, with a range of between €23 (the UK) and €88 (France). 

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It should be noted that since a veterinarian is allowed to order an analysis at any of 
the  53  EU-approved  laboratories  in  the  world,  knowledge  of  the  average  cost  of 
titration is of value.  

2. 

COSTS  INCURRED  BY  PET  OWNERS  TO  PREPARE  A  PET  UNDER  THE  TRANSITIONAL 
REGIME, I.E. FOR MOVEMENT TO A MEMBER STATE APPLYING NATIONAL RULES 

2.1.  Movement within, and entry from listed third countries into, that Member State 

Under  existing  national  rules,  preparation  costs  include  where  appropriate,  in 
addition to the identification and anti-rabies vaccination costs, the costs of sampling 
with  result  certification  and  laboratory  analysis,  anti-parasite  treatments  and 
'carriers'. 

1. 

Anti-parasite treatment costs25 

Anti-parasite treatments must be carried out by an authorised veterinarian who 
must endorse the passport or issue a certificate to that effect.  

As part of the consultation, Member States were therefore asked to provide the 
cost  of  an  anti-parasite  treatment  including  drug  and  visit/act  fees  and  where 
necessary a distinction by species and weight. It should be noted that veterinary 
fees provided by Member States are those usually requested during weekdays. 
Indeed, fees may be higher where the service is provided during a weekend or 
on  bank  holidays  due  to  protocol  time  constraints  (treatment  24  to  48  hours 
before check-in for travel) or where, when making long-distance trips, owners 
have  to  visit  another  vet  en  route  to  the  final  destination  to  comply  with  the 
deadline  constraints  of  the  anti-parasite  treatment  protocols.  Although  the 
amount  of  this  extra  cost  may  be  sizeable,  Member  States  were  not  asked  to 
provide it since it is considered to be too uncertain and probably variable. 

From  the  consultation,  it  appears  that  some  Member  States  provided  unique 
average data while others made a distinction by species and/or by weight or a 
range  of  costs.  Calculation  of  an  average  cost  for  that  treatment  is  therefore 
difficult.  

€16.8 could be considered the average cost of anti-echinococcus treatment for a 
dog of 10 kg but with a great variation from €1 (Romania) to €39 (Finland). 

€18.8 could be considered the average cost of anti-tick treatment for a dog of 
10 kg but with a great variation from €5 (Romania) to €56 (Denmark). 

2. 

Carriers' costs 

From the consultation it appears that Sweden does not hire the services of these 
'carriers'.  Finland  has  only  one  company  specialising  in  pet  transport  but  did 
not  provide  the  requested  figures.  As  regards  the  UK,  Ireland  and  Malta, 
'carriers' act as transport providers and checking companies which could charge 
their services separately. 

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Finland 

1 transport company 

Ireland 

Ferry: €20 to €25 (car travel only) 

Air travel: around €700 as airline cost from continental Europe 
+ €210 as 'carrier's' cost 

Malta 

Pets less than 5kg: €46. Additional €5.3 for every kg above 5kg 

Sweden 

No carriers 

United 
Kingdom 

Not provided: carriage charges are variable 

2.2. 

Entry from non-listed third countries into that Member State 

According to the Regulation, pets coming from non-listed third countries must fulfil 
a quarantine period when entering the UK, Ireland, Malta and Sweden. For the same 
category of third countries, the other Member States request blood testing to confirm 
the level of rabies antibodies. 

The following figures about quarantine facilities emerge from the consultation: 

Malta 

€3.5  per  small  dog/cat  per  day  (+18%VAT)  (i.e.  around  €740 
VAT incl. for a 6-month quarantine) 

€4.7  per  dog>  5kg  weight  per  day  (+18%VAT)  (i.e.  around 
€1000 VAT incl. for a 6-month quarantine) 

Between €2000 and €3000 approximately depending on species 
and size for a 6-month quarantine 

No  approved  quarantine  facilities  for  dogs,  cats  and  ferrets 
(application of home quarantine isolation) 

€3300 – €3400 per dog and €2050 - €2200 per cat for quarantine 
of at least 120 days 

Ireland 

Finland 

Sweden 

United 
Kingdom 

£2500  for  dogs  and  £1800  for  cats  (i.e.  around  €3480  and 
€2500) for a 6-month quarantine 

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ANNEX 22 

Main elements of EFSA’s conclusions/recommendations 

Rabies risk assessment 

A  rabies  vaccination  using  an  authorised  vaccine  administered  according  to  the  approved 
vaccination schedule is considered to be the key requirement for pet movement between and 
into  Member  States,  provided  that  protective  immunity  has  been  established  and  is 
maintained. 

A serological titre of 0.5 IU/ml of neutralising antibodies measured in a sample taken after the 
prescribed  period  following  primo-vaccination  with  a  single  dose  is  considered  to  be 
indicative of a high probability of protection and is used as the threshold titre. 

Because this assumption is not related to the efficacy of any vaccine but to the definition of a 
certain level of risk, the following issues must be specifically addressed: 

– 

– 

– 

as  a  function  of  time,  vaccinating  an  already  rabies-incubating  animal  may  have 
limited or no effect on subsequent development of the disease; 

no  discriminatory  methods  are  available  to  detect  infection  in  a  live  vaccinated 
animal; 

due to individual biological variations, a small fraction of vaccinated pets, especially 
animals younger than 1 year ("low responders"), may not achieve the threshold titre 
after a single dose of primary vaccination. 

From the above it is possible to identify two risk scenarios which require additional mitigating 
measures to prevent spread of the disease: 

– 

– 

the animal was vaccinated while incubating the disease (type A risk), and 

a  low  responder  becomes  infected  and  incubates  the  disease  despite  a  positive 
vaccination record (type B risk). 

A  protocol  including  the  following  risk-mitigating  measures  would  be  the  best  way  to  deal 
with the risk of rabies introduction: 

– 

– 

a  waiting  time  (time  spent  between  vaccination  and  movement)  following  primo-
vaccination with a single dose would allow clinical disease to develop if the animal 
was  infected  before  primo-vaccination.  EFSA’s  risk  assessment  has  modelled  the 
effect of the waiting time on the probability of developing clinical signs before the 
end of the waiting time, for the two risk scenarios. As an example, an animal has a 
95.2% probability of developing clinical signs before the end of a waiting period of 
60 days.  

serological  testing  or  administration  of  a  second  injection  of  vaccine  4  to  6  weeks 
after the first vaccination, to overcome the problem of low responders, provided that 
approved  vaccination  schedules  are  amended  to  include  such  an  option  in  the 
marketing authorisation. 

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There is no rationale for including a waiting time beyond the point where protective immunity 
has been reached for animals coming from countries with a negligible incidence of rabies in 
pets (lower than one case per million pets per year). According to EFSA's opinion, the highest 
rabies prevalence in pets in 2005 within the EU was to be found in Baltic States. 

Very  little  published  data  are  available  to  support  the  positive  impact  of  a  second  injection 
and  the  assumption  is  mainly  based  on  expert  advice  from  laboratories  authorised  to  do 
serological  tests.  Consequently  the  number  of  true  non-responders  after  two  injections  is 
considered negligible. 

Echinococcosis risk assessment 

The  opinion  addresses  the  risk  of  introduction  of  Echinococcus  multilocularis  into  free 
Member States, through pet movements, if the pre-movement treatment is abandoned. There 
are very few data on the prevalence or incidence of infections with E. multilocularis in pets, 
in particular in pets to be moved into an area considered free of this parasite. Therefore EFSA 
could not carry out a quantitative release and exposure assessment of the risk of introduction 
and establishment of E. multilocularis in the five Member States. 

Risk factors are still not fully known. The typical transmission cycle in Europe is indirect and 
wildlife-based:  eggs  shed  in  the  faeces  of  infected  definitive  hosts,  mainly  the  Red  Fox 
(Vulpes vulpes) and to a lesser extent domestic dogs and cats, are ingested by and develop to 
the  metacestode  stage  in  arvicolid  rodents,  which  are  the  prey  of  carnivores  and  serve  as 
intermediate hosts. 

In accidental cases, humans may also become an intermediate host and acquire the infection 
by  egg  ingestion  through  manipulation  of  definitive  hosts,  ingestion  of  row  fruits,  plants  or 
garden vegetables, ingestion of contaminated water or picking-up of wood. Only preventive 
hygiene measures can minimise the risk of infection, the complete eradication of the parasite 
being utopian. 

There is evidence that prevalence rates in foxes have risen in many agriculturally dominated 
landscapes  of  France,  the  Netherlands,  Germany,  Austria,  Slovakia  and  Poland,  but  the  life 
cycle  is  now  also  established  in  many  urban  areas,  where  red  foxes  occur  with  high 
population densities due to abundant availability of anthropogenic food. Infection rates can be 
high  but  tend  to  be  lower  than  in  surrounding  rural  areas,  probably  because  of  the  limited 
presence of habitats suitable for voles (intermediate hosts) in urban areas. However, due to the 
high density of fox populations in urban areas, the absolute number of infected foxes may still 
be higher than in rural areas and the close proximity between foxes and humans is a cause for 
concern. 

There  are  no  records  of  E.  multilocularis  from  the  Iberian  Peninsula,  Fennoscandia  (in 
Norway  the  parasite  was  introduced  only  into  the  arctic  islands  of  Svalbard  through  grain 
deliveries inhabited by voles) and the British Isles. The reasons for unequal prevalence are not 
yet clear, but appear to be linked to agricultural land use and landscape patterns. The presence 
of  permanent  grassland  favours  populations  of  the  parasite's  most  important  intermediate 
hosts and is likely to be of primary importance for transmission. 

Infection of domestic carnivores appears to be a rare event that is difficult to detect as large 
numbers of samples per geographical unit must be analysed to obtain an accurate estimate of 
the  prevalence  of  the  infection.  While  domestic  dogs  and  cats  are  sporadically  naturally 

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infected, they appear of secondary importance for the life cycle, which is typically wildlife-
based.  The  low  infestation  rates  in  domestic  dogs  in  Europe  are  most  likely  due  to  low 
exposure to the invasive stage of the parasite and to routine deworming of domestic pets. The 
suitability of cats as final hosts is less clear. 

In humans, data from the year 2005 point to an apparent increase of cases. EFSA recognises 
that the situation is not elucidated: is it the result of an expansion of E. multilocularis in wild 
hosts  and  an  increased  host  population  in  Europe  or  of  intensified  investigations  combined 
with improvements in diagnosis.  

The  risk  of  introducing  E.  multilocularis  from  endemic  areas  into  a  country  where  the 
intermediate hosts (rodents) are present but is considered free from the disease on the basis of 
national  surveys  is  greater  than  negligible  and  could  be  reduced  if  pets  are  treated  before 
movements.  However,  the  estimation  of  the  risk  is  impaired  by  a  lack  of  reliable  data  in 
particular  on  the  frequency  of  pet  movements,  their  infestation  rate,  the  quality  of  hygiene 
measures  taken  by  owners  to  remove  droppings,  the  likelihood  of  contact  between 
intermediate  hosts  and  contaminated  faeces,  and  the  tenacity  of  the  invasive  form  of  the 
parasite in decomposed rodents, in so far as rodents die soon after infestation. 

With  the  overall  expansion  of  the  endemic  area,  it  is  most  likely  that  the  parasite  will  be 
introduced through wild carnivores or infested rodents. 

The  opinion  recommended  that  surveillance  systems  for  wildlife  and  pets  should  be 
established  in  Europe  in  order  to  define  risk  areas  and  criteria  for  freedom  from  E. 
Multilocularis. Until such systems have been implemented and evaluated, it is not possible to 
give firm recommendations as to the minimum surveillance requirements to document disease 
freedom. 

Final Host 

Predation of 
Intermediate Host

Ingestion of eggs 

Intermediate host 

Ticks risk assessment 

EFSA clearly indicated a lack of sufficient evidence as regards the epidemiological situation 
in the UK, Ireland and Malta to refute or accept the justification for the additional measures 
currently applied by these countries.  

EN 

101 

   EN 

 
 
 
ANNEX 23 

Outcomes of the Member State consultation on approved 'carriers' 

IRELAND 

MALTA 

(year 2007 to date) 

(year 2007 to date) 

9 

1278 

7 

528 

1278  (774  using  ferries,  504  using 
airlines) 

60 

UK 

(2006) 

114 

84767 

84767 

Ferry: €20 to 25 (car travel only) 

Under 5 kg: €45 

Carriage charges are variable 

Air  travel  (as  cargo  only):  around 
€700 as airline cost from continental 
Europe + €210 as 'carriers" cost 

Above 5 kg: €5.3 per additional kg 

Number of approved 'carriers' 

Number  of  pets  entering 
country 

the 

Number of applications per year 

Cost  of  an  operation  for  pet 
owners 

Cost of an operation for carriers 

Commercial information 

Not available 

Not provided 

Global cost for pet owners 

Ferry: €15 480 to 19 350 

Air travel: €458 640 

Calculation  impossible  due  to  lack 
of detailed information 

EN 

102 

EN 

 
  
 
 
Outcomes of the Member State consultation on quarantine facilities 

ANNEX 24 

Year 2006 

IRELAND 

MALTA 

SWEDEN 

of 

pets 

Number  of  approved 
quarantine facilities 
Number 
quarantined per year 
Number  of  applica-
tions per year 
Cost  of  a  quarantine 
stay  for  pet  owners 
(6 months quarantine) 

Between  €2000  and  3000 
approximately  depending  on 
species and size 

1 

- 

71 

1 

206 

206 

2 

34 

34 

UK 

31 

3281 

2134 

€ 3.5 per small dog/cat per day 
(+18%VAT) (i.e. around €740 
VAT incl.) 
€4.7  per  dog>  5kg  weight  per 
day  (+18%VAT)  (i.e.  around 
€1000 VAT incl.) 
The  costs  of  9  full 
workers49 

time 

33000-34000  SEK  (~  €3300-
3400)  per  dog  and  20500-
22000  SEK  (~  €2050-2200) 
per cat. 

£  2500  for  dogs  and  £  1800 
for  cats  (i.e.  ~  €3480  and 
2500€) 

available 

Not 
facilities 
independent 
businesses 

as 
operate 

these 
as 
commercial 

Border  inspection  2046  SEK, 
veterinary  inspections  during 
stay  5600  SEK,  feed  1500 
SEK,  toys/bedding/treats  etc 
1200 SEK, full time employee 
(based  on  full  time  with  30 
pets  a  year)  12000  SEK,  plus 
other costs50  

Cost  of  a  quarantine 
stay  for  a  quarantine 
facility 

Not mentioned 

49 
50 

EN 

Including night watchmen, the pet food which is consumed, water/ electricity and maintenance of the premises. 
Rent, maintenance, telephone, fax, transport vehicle and gasoline, security alarm system, waste disposal, electricity, etc. (costs for rent, maintenance and electricity are quite 
large but have not been specified in detail). 

103 

EN