animals

animals Article

Brexit and Animal Protection: Legal and Political Context and a Framework to Assess Impacts on Animal Welfare Steven P. McCulloch Department of Politics and Society, University of Winchester, Winchester SO22 4NR, UK; [email protected]; Tel.: +44-(0)1962-827-465 Received: 22 September 2018; Accepted: 14 November 2018; Published: 18 November 2018







Simple Summary: The British public voted to leave the European Union (EU) in a 2016 referendum and the United Kingdom (UK) is set to leave in March 2019. The UK has been part of the EU or the European Communities (EC) before it for around 50 years. Britain has had a major impact on EU animal protection laws and the UK as a member state has been substantially influenced by EU law. Brexit represents a major political change that will affect animal protection in the UK, the EU and internationally. Given the far greater numbers of animals used in agriculture, the impact of the UK’s departure from the EU on farm animals will determine whether Brexit is overall good or bad for animal protection. A major threat that Brexit poses is importing lower welfare meat and dairy products to the UK. A major opportunity post-Brexit is reform of agricultural policy to reward high animal welfare outside of the EU Common Agricultural Policy (CAP). A soft Brexit, where the UK remains aligned to the EU in policy and trade, reduces the risks Brexit poses to animal protection. A hard Brexit means major threats to animal welfare are more likely to materialise. Further research is required to investigate whether the various threats and opportunities are likely to materialise and whether Brexit will be, all things considered, good or bad for animal protection. Abstract: The British people voted to leave the European Union (EU) in a 2016 referendum. The United Kingdom (UK) has been a member of the EU since the Maastricht Treaty was signed in 1993 and before that a member of the European Communities (EC) since 1973. EU animal health and welfare regulations and directives have had a major impact on UK animal protection policy. Similarly, the UK has had a substantial impact on EU animal protection. Brexit represents a substantial political upheaval for animal protection policy, with the potential to impact animal welfare in the UK, EU and internationally. Brexit’s impact on farmed animals will determine the overall impact of Brexit on animals. A major threat to animal welfare is from importing lower welfare products. A major opportunity is reform of UK agricultural policy to reward high welfare outside the Common Agricultural Policy (CAP). A soft Brexit, in which the UK remains in the single market and/or customs union, mitigates the threat of importing lower welfare products. A harder Brexit means threats to animal welfare are more likely to materialise. Whether threats and opportunities do materialise will depend on political considerations including decisions of key political actors. The Conservative Government delivering Brexit has a problematic relationship with animal protection. Furthermore, Brexit represents a shift to the political right, which is not associated with progressive animal protection. There is significant political support in the Conservative Party for a hard Brexit. Further research is required to investigate whether the various threats and opportunities are likely to materialise. Keywords: Animal health; animal welfare; animal protection; Brexit; Common Agricultural Policy; Conservative Party; European Union; World Trade Organisation

Animals 2018, 8, 213; doi:10.3390/ani8110213

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1. Introduction The British people voted in a 2016 referendum to leave the European Union (EU). The United Kingdom (UK) has been a member of the EU since the Maastricht Treaty was signed in 1993 and before that a member of the European Communities (EC) since 1973. EU regulation has had a major influence on UK animal health and welfare policy. Similarly, as one of the larger members of the EU and with a history as a leader in animal welfare, the UK has had a substantial influence on EU animal protection policy [1]. The European Union (EU) is a political and economic union composed of 28 member states. The total human population in the EU is around 510 million. Based on its size and economic importance, the EU has been described as an emerging superpower [2]. Its political institutions are the European Council, European Commission, Council of the European Union (Council of Ministers), European Parliament and the Court of Justice of the EU. The EU has an internal single market without borders of goods, services, labour and capital to promote free trade and economic prosperity. The EU is also a customs union and all 28 member states form an effective single territory for customs purposes [3]. Independent economic analyses have forecast that Brexit will have a negative economic impact in the medium term. The International Monetary Fund (IMF) has reported that Brexit has been associated with a weakening of Sterling, reduced business investment and lower growth [4]. The government’s own impact assessments have shown that Brexit will make the UK worse off in all scenarios. These scenarios include a Norway-style agreement that provides continued access to the EU single market, a Canada-style free trade agreement and a ‘no deal’ outcome in which the UK trades with the EU on World Trade Organisation (WTO) terms [5,6]. Over a 15 year timeframe, GDP will be two per cent lower in the Norway model, five per cent lower in the Canada free trade model and eight per cent lower trading on WTO rules [7]. In Theresa May’s Chequers 2018 agreement, the government put forward a policy that was effectively a soft Brexit for agriculture. The government proposed that goods, including agricultural goods, would remain in alignment with the EU’s rules – essentially following the single market [8]. This would mean that the UK would continue regulatory alignment with the EU, as well as applying the same external tariffs to agricultural imports in a facilitated customs union for agricultural products [9]. In the context of animal protection, a number of reports have been published on the potential impacts of Brexit [1,10–12]. This paper reviews the threats and opportunities discussed in these reports. The paper then discusses the EU/UK animal protection regulatory landscape and the political context of Brexit. The aim of the paper is to provide crucial regulatory and political context for future research on how likely threats posed by and opportunities presented by Brexit are likely to materialise. That future research will address the following question: Will Brexit, all things considered, be good or bad for animal protection? This paper provides a framework and explores salient factors to facilitate investigating this fundamental question in future research. This paper is structured in nine sections. Section 2 provides two vignette arguments from opposing sides on the impact of Brexit on animal protection. Section 3 describes a framework for assessing how Brexit is likely to impact animal protection. Section 4 discusses what categories of animals will be most affected by Brexit. Section 5 reviews some of the potential impacts of Brexit on animal protection discussed in various published reports. Section 6 describes the legal context of Brexit and animal protection. How are the EU and UK animal health and welfare regulatory landscapes related? Section 7 discusses the political context of Brexit. What are the political forces that have motivated and continue to shape Brexit? The political context is crucially important as the overall impact of Brexit on animal protection will be influenced, if not determined, by the various political developments in play. Section 8 discusses how different forms of Brexit—soft, hard and WTO rules—will impact animal protection. Finally, Section 9 discusses how policy making in a nation within a political union such as the EU differs from that in a nation outside of a political union, in the context of animal protection.

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2. Brexit and Animal Protection: Vignette Arguments for and Against To provide context for further discussion, especially for readers outside of the EU and UK, this section includes two opposing vignette characterisations of the Brexiteer case to leave the EU and the Remainer case to stay in the union. These sections are characterisations of Brexiteer and Remainer arguments and further analysis is required to investigate the validity of the various claims. 2.1. The Animal Protection Case for Leaving the European Union The UK is a world leader in animal welfare. She is held back in her ambitions by being part of the EU. For instance, the EU prevents the UK from banning live animal exports. Similarly, membership of the EU means the UK cannot ban the importation and sale of foie gras, the production of which is effectively banned in the UK. When the UK leaves the EU, she will be free to ban live animal transport and the importation and sale of foie gras. The Common Agricultural Policy (CAP) of the EU supports intensive farmers and large landowners. When the UK leaves the EU, she will be able to reward farmers for high animal welfare and export her high quality produce to the rest of the world. The UK will be free to independently trade with traditional allies like the US and Australia. The UK government has stated it will protect animal welfare standards after Brexit. If the UK does import US and other nation’s products as part of a trade deal, British consumers will be free to not purchase them, if they wish. Regardless, if chlorinated chicken is good enough for Americans, it should be good enough for Brits too. EU membership means that the UK cannot control her own borders and unscrupulous pet smugglers from Eastern European member states transport thousands of sick puppies and kittens into Britain each year. When the UK leaves the EU she will be able to make laws to clamp down on this practice. 2.2. The Animal Protection Case for Remaining in the European Union The UK is a world leader in animal welfare. She has used her position in the EU to influence animal protection policy in the largest trading bloc in the world. For instance, the UK was the driving force behind Article 13 of the Treaty of Lisbon, which recognises animals as sentient beings. Based on the Treaty of Lisbon, the EU and member states must pay full regard to the welfare of animals when formulating and implementing policy. The EU has some of the highest welfare standards in the world. The EU has banned barren battery cages for laying hens, calf crates for veal production and limits the use of sow stalls for pregnant pigs. Member states are free to implement even higher welfare standards, which the UK has in many cases taken advantage of. The EU prohibits hormone-treated beef, chlorine-washed chicken and growth promoters in pigs. The EU has fought trade battles with the US to prevent these products from entering the single market because they are associated with lower food safety and animal welfare standards. Outside of the EU, the US—with its powerful agricultural lobby—will force the UK to import US goods produced with far lower welfare and food safety standards. Where there is doubt the EU protects its citizens by applying the precautionary principle, whereas the US supports large agri-business. Chlorinated chicken will swamp British supermarket shelves. Brits will be consuming hormone-treated beef for their Sunday dinner. Finally, the EU has banned the importation and sale of dog, cat and seal fur based on public morality. It has some of the most stringent regulation on animal experimentation in the world. The EU has prohibited the testing of cosmetics and ingredients on animals and their import and sale, as this practice is impossible to justify on moral grounds. It funds an agency that shares data to avoid the unnecessary duplication of animal experiments for medical and toxicological research. These vignettes are useful to provide some context on the impact of Brexit on animal protection in the UK and further afield. The passages also hints at how the polarised debate on Brexit permits opposing sides to make claims related to animal protection to serve their purposes. For this reason, in order to investigate such claims, it is important to use a framework to assess them. The following section provides such a framework.

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3. A Framework to Investigate the Impact of Brexit on Animal Welfare Brexit is an enormous political upheaval between the UK and the EU. There are various categories of animals and species at play. Brexit will affect animals in the UK, in the EU27 and in future trading nations and blocs. There are substantial political and legal uncertainties. The following questions provide a comprehensive framework for assessing the impact of Brexit on animals: 1. 2. 3. 4. 5. 6. 7. 8. 9.

What is the current relationship between the UK and the EU in animal health and welfare policy, that is, what is the status quo? What is the political context of Brexit, that is, what are the political considerations that are likely to determine the impact of Brexit on animal protection? What are the threats and opportunities to animal protection of Brexit? What are the threats and opportunities to animal protection of Brexit to different categories of animals? What are the threats and opportunities to animal protection of different forms of Brexit? What are the threats and opportunities to animal protection of Brexit geographically, that is, in the UK, the EU and internationally? What are the magnitude of the various threats and opportunities of Brexit? How likely are the various threats and opportunities of Brexit to animal protection to materialise? All things considered, will Brexit be a net positive or negative for animal protection in the UK, EU and internationally?

How Brexit impacts animal welfare will be influenced by a number of factors that are complex and interrelated. Some of these factors will be related to and under the control of the UK government and Parliament; others will not. Broadly, these factors include first, the form of Brexit which the UK and EU conclude. Whether the UK and EU conclude a hard or a soft Brexit, for instance, will have a very substantial impact on animal welfare. Secondly, the political nature of the UK government and Parliament, now and in the medium term, will have a substantial impact on animal protection. Thirdly, EU policy toward the UK during and after the Brexit negotiations will have a major impact on animal protection. Fourthly, the policy of third countries such as the US, during Brexit negotiations and when negotiating free trade agreements, will have a major impact on animal protection. Fifthly, in addition to these factors, there are additional uncertainties such as how WTO rules on animal protection will be interpreted going forward. The discussion in the remainder of this paper focuses on questions 1–5 in the framework above. The paper discusses the legal and political context of Brexit. It describes how soft and hard forms of Brexit might impact animal protection. It also reviews threats posed and opportunities presented by Brexit discussed in a number of reports on the subject. Before discussing the legal and political context of Brexit, the next section of the paper aims to provide some focus based on the categories of animals that are more likely to be affected, positively or negatively, by Brexit. If, for instance, the impact on one particular category of animal is far greater than that on the other categories of animals, then we can focus our attention on that category. 4. What Categories of Animals will be Most Affected by Brexit? For the sake of convenience, I have adopted the following classification in accordance with human use of, or relationship with, animals: (i) animals in farming, (ii) animals in research, (iii) wild animals and (iv) companion animals (including equines). Table 1 below illustrates populations of each category of animal in the UK, EU and US. The US is included for illustration of a large nation outside of the EU which Brexit provides the potential for a change in the UK’s trading relationship.

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Table 1. Numbers of animals by category in the UK, EU and US. Category of Animal

Species

EU 28 (incl.UK)

UK

US

Agriculture

Includes poultry, pigs, cattle and sheep 1

4.7 billion [13]

1 billion [14]

10 billion [15]

11 million [16] Unknown 65 million [16] 99 million [16] 7 million [21]

4 million (procedures) [17] Unknown 51 million 4 9 million 8 million 1 million

12-27 million 2 [18] Unknown 58 million [19] 90 million [20] 94 million [20] 7.6 million [20]

Research Wild 3 Companion

Fish Dogs Cats Horses

1

The majority of agricultural animals raised and killed are poultry, specifically chickens; 2 US figures are imprecise as fish and birds are not officially recorded; 3 No figures for wild animals; 4 UK figure for companion animals includes aquaria and ponds.

Table 1 reveals that there are far larger numbers of farm animals across the UK, the EU and the US. In the UK, around one billion land animals are raised and slaughtered in each year [14]. In contrast, there are around four million experimental procedures performed annually on laboratory animals in the UK [17]. In the UK there are around 51 million pet fish, 9 million pet dogs and 8 million pet cats [22]. Finally, there are around one million equines [23]. To put these figures in context, the human population in the UK is around 66 million [24]. The numbers of animals in each of these categories are very substantial. We should remember that each of these animals is an individual sentient life. Government policy has the potential to affect the lives of all categories of animals [25,26]. However, for present purposes, the reality that farm animals vastly outnumber other categories means that how Brexit affects farm animals is very likely to determine whether Brexit has a net positive or negative impact on all animals. Matheny and Leahy describe the consequences of numbers on animal protection policy vividly in the US context: Farm animals represent ninety-eight percent of the animals raised and killed in the United States. Compared to farm animals, the number of animals hunted, kept as companions, used in labs, reared for the fur industry, raced and used in zoos and circuses is insignificant. The “animal-welfare issue” is thus numerically reducible to the “farm-animal-welfare issue”. (p. 326) [15] Of course, despite these numbers, it might be the case that Brexit disproportionately impacts not farm animals but wild, experimental or companion animals. This scenario, however, would be extremely unlikely. Indeed, Brexit will impact farm animals as a category more than other categories of animals. EU member states trade in the internal single market. To enable a level playing field, EU member states have substantial regulatory alignment in agriculture [10,27]. The Common Agriculture Policy (CAP), as its name suggests, is common to all EU member states. Brexit means the UK breaking away from the EU, being outside of the CAP and potentially outside of the single market. Thus, Brexit is likely to lead to divergence in agricultural policy and possibly trading relationships, between the UK and EU. Given these points, the impact of Brexit on animal protection will be reducible to its impact on farm animals in the UK, EU and internationally. The second major point to make based on the numbers in Table 1 relates to the relative numbers of animals in the UK, the EU and the US. There are far more farm animals raised and slaughtered in the US (10 billion) compared to the EU (4.7 billion) and the UK (1 billion). These numbers suggest that the overall impact of Brexit on animal protection may not be determined by its effect on animals in the UK but on animals in the EU and internationally. This is an important point, because in considering how Brexit will impact animal protection all things considered, there is a risk that one will have an undue focus on animals in the UK and perhaps the EU. The next section reviews some of the key findings of authoritative reports on Brexit and animal protection.

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5. Brexit Impacts on Animal Protection: Threats and Opportunities Brexit: getting the best deal for animals is a wide-ranging report published by the Wildlife and Countryside Link (Link) and the UK Centre for Animal Law (A-Law). The report is a product of a large coalition of leading UK animal protection NGOs including the Royal Society for the Prevention of Cruelty to Animals (RSPCA), Compassion in World Farming (CIWF), World Animal Protection (WAP) and the International Fund for Animal Welfare (IFAW). The report describes how Brexit presents a major juncture in the history of UK animal protection: As the UK prepares to leave the EU, the welfare of animals is at a critical crossroads and selecting the route ahead will determine the welfare of billions of animals. We have a once in a lifetime opportunity to either define or undermine our country’s identity and reputation as a global leader in animal welfare science and standards. (p. 5) [1] The report is authoritative and details potential reforms for the four major categories of animals: farmed, wildlife, research and companion. The report does not, however, assess the probability of the various opportunities and threats actually materialising. Rather, the report has been written after the referendum vote in 2016, with a view to maximising the benefits for animals. This quotation also highlights how many in the animal protection community view Brexit as an opportunity in a broad sense to campaign for reforms in animal protection policy. Thus, many of the opportunities discussed in the reports are not related to policy that could not be made before Brexit, with the UK as a member state of the EU. Rather, Brexit as a major political event is considered as an opportunity for reform. In the section on Animals in Agriculture the report states: Two factors will be decisive in determining the post-Brexit level of animal welfare: trade issues and the arrangements for farm support payments that replace the Common Agricultural Policy (CAP). (p. 24) [1] The authors writing these words are referring to animals in agriculture. Despite this, given that the impact of Brexit on animal protection is reducible to its impact on farm animals, the above statement is arguably applicable to animal welfare per se. Trade issues and arrangements for farm support payments are therefore critical to focus on when assessing whether Brexit is likely to have net positive or negative impacts for animal protection. Brexit and animals: Opportunities and threats, UK animal welfare under different models of relations with the European Union (EU) is a report produced by a smaller number of animal protection NGOs, including the RSPCA, CIWF and WAP. The report very usefully sets out the status quo on UK farm animal protection as an EU member state: The arrangement the UK currently has inside the EU is a high level of animal welfare standards protected by external tariffs. This should be retained in any future trade arrangement the UK will have with the EU and with other trade partners, to prevent the race to the bottom that could arise from a surge in imports of products produced to lower animal welfare standards. (p. 4) [11] This concise description of the status quo is elaborated on later in this paper. The situation of the UK as a member of the EU with high tariffs preventing the importation of agri-goods produced in lower welfare standards is a fundamental baseline to judge how Brexit might impact animal welfare. A 2017 House of Lords report Brexit: farm animal welfare describes farm animal welfare standards in the UK and the broad stakeholder support to retain these after Brexit: The UK has some of the highest farm animal welfare standards in the world. UK producers are rightly proud of these standards and there is cross-sector support for maintaining high levels of farm animal welfare after Brexit. (p. 3) [10] The Taskforce report assesses animal welfare under different models of Brexit. It assesses the following models of UK-EU relations: (i) continued EU membership; (ii) European Economic Area

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(EEA), or the ‘Norway model’; (iii) the ‘Swiss model’; (iv) continued membership of the EU customs union; (v) a deep and comprehensive free trade agreement (DCFTA); and (vi) WTO rules. Table 2 below is reproduced with permission from the Brexit and Animals Taskforce. Animals 2018, FOR Animals PEER REVIEW 2018, Animals 8,2018, xincluded FOR PEER 8,in REVIEW x FORREVIEW PEER REVIEW of 7 of 20 7 of 2 Animals 2018, Animals 8,8, xx FOR 2018, PEER 8, x FOR REVIEW Animals PEER REVIEW 8,2018, x FOR PEER 7 7ofpositive 2020 7 of 20 The animal welfare issues the table are formulated such that a tick is generally Animals 2018, Animals FOR 2018, PEER 8,FOR xREVIEW FOR 2018, PEER 8,REVIEW x FOR PEER REVIEW of20 20 of 20 Animals 2018, Animals 8, x FOR 2018, Animals PEER 8,8,xxFOR REVIEW 2018, PEER 8, xAnimals REVIEW PEER REVIEW 7 of 20 77of 7 of7 20 for animal protection. 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Method of Method production of Method production labelling of production is labelling supported is labelling supported by animal is supported by protection animal by protection NGOs animal because protection NGOs it because provides NGOs it because provides it prw Method Method of production Method of production labelling of production labelling is supported labelling is supported by is animal supported by protection animal by protection animal NGOs protection because NGOs because it NGOs provides because it provides it provides information for consumers information that information for is consumers likely to for reduce consumers that is the likely purchase that to is reduce likely and the consumption to reduce purchase the and purchase lower consumption welfare and consumption of lower welfare of the lower information for for consumers information that is likely that for is to consumers likely reduce to the reduce that purchase is likely purchase and to reduce consumption and consumption purchase of lower and of welfare consumption lower welfare ofproduction lower welfar ‘Norway ‘Norway model’ ‘Norway or model’ the ‘Swiss or model’ ‘Norway the model’ ‘Swiss or model’ the ‘Norway all model’ ‘Swiss preclude or the all model’ model’ preclude ‘Swiss the possibility all or model’ the preclude the ‘Swiss possibility all of the preclude method model’ possibility ofmethod all of method the preclude production possibility ofthe method of production the labelling. of possibility of method production labelling. of the production method labelling. ofthe labelling. lab model’ or the ‘Swiss model’ all preclude the possibility of of production labelling. crossThe is generally cross is‘Norway generally cross negative isinformation cross generally negative for animal isconsumers generally negative cross for protection. animal is negative generally for cross protection. animal For for is negative instance, generally protection. animal For instance, for continued protection. negative animal For instance, continued protection. for membership For animal instance, continued protection. For of continued instance, the membership EU, of For the the continued membership instance, EU, of the the membership continued EU, of EU, membership of the EU, of E the model,’ the ‘Swiss DCFTA model,’ the or ‘Swiss under the model,’ DCFTA WTO rules the or DCFTA under is positive WTO or under for rules animal WTO is positive protection. rules for positive animal for protection. aof protection. Inthat Inaisthe con the ‘Swiss the model,’ ‘Swiss the model,’ DCFTA the the ‘Swiss or DCFTA under model,’ or WTO under the rules DCFTA WTO is positive rules or under is positive for WTO animal rules for protection. animal is positive protection. In for contrast, animal In contrast, aconsumption protection. aiscontrast, In contrast, animal welfare animal The issues welfare animal The included issues animal welfare The included welfare in issues animal the table included issues in The welfare the are animal included table formulated in issues the welfare are table in formulated included the such issues are table formulated that in included such are the amembership tick formulated table that such in aare generally the tick that formulated such is ais generally tick are that formulated is such acontrast, generally tick that isanimal generally awelfare such tick generally a7 of tick ge Animals 2018, Animals 8, xThe FOR 2018, PEER 8,‘Swiss xThe FOR REVIEW PEER REVIEW 7table of 20 7In of 20of Animals 2018, Animals 8, x FOR 2018, PEER 8, x FOR REVIEW PEER Animals REVIEW 2018, 8, x FOR PEER REVIEW 20 7 of 2 post-Brexit model of the UK-EU relationship in some cases has little or no impact on animal information information for consumers information for consumers that is for likely consumers that to is reduce likely that to the is reduce purchase likely the to and reduce purchase consumption the and purchase consumption of lower and welfare of lower welfare of lower w information information for consumers information for consumers that for is consumers likely that is to likely reduce that is to the likely reduce purchase to the reduce purchase and the consumption purchase and consumption and of lower consumption welfare lower lower welfare products and increase products that and products higher increase welfare and that increase products. of higher that welfare of higher products. welfare products. products products and increase and increase that products of higher that and of welfare higher increase products. welfare that of products. higher welfare products. Method Method of production Method of production labelling of Method production labelling is of supported Method production labelling is supported of by production is labelling animal supported by protection is animal labelling supported by animal protection is NGOs supported by protection animal because NGOs by protection because NGOs it animal provides because it protection NGOs provides it because provides NGOs it because provides it pr Method of production labelling is supported by animal protection NGOs because it provides ‘Norwaypositive ‘Norway model’ or ‘Norway model’ the ‘Swiss ‘Norway or model’ the model’ ‘Swiss or model’ ‘Norway the all model’ ‘Swiss preclude or model’ the ‘Norway all model’ ‘Swiss preclude the or possibility the all model’ model’ preclude ‘Swiss the possibility all or of model’ the preclude the method ‘Swiss possibility all of the of preclude method model’ production possibility of all of method the preclude production possibility of labelling. method of production the labelling. of possibility of method production labelling. of production method labelling. ofthe production labelling. lab cross is generally negative cross is generally cross is negative generally protection. for negative animal For instance, protection. for animal continued protection. For instance, membership For continued instance, of the membership continued EU, the membership of EU, the of the E cross is generally cross is generally negative cross negative for animal is generally for protection. animal negative protection. For for instance, animal For instance, continued protection. continued membership For instance, membership of continued the EU, of the the membership EU, the of the EU, th positive for animal positive for protection. animal positive for protection. animal For for positive instance, protection. animal For for instance, protection. banning positive animal For instance, banning live for For exports animal instance, banning live protection. for exports fattening banning live for exports For fattening live and banning instance, exports for slaughter fattening and live banning for slaughter exports under fattening and live slaughter for under exports and fattening slaughter under for and fattening under slaughter and under slaughter products and products increase and products that increase of higher and that increase welfare of higher that products. welfare of higher products. welfare products. protection. For instance, Table 2 illustrates that all models permit continued participation in the PETS products products and increase products and increase that and of higher increase that of welfare higher that of products. welfare higher products. welfare products. The post-Brexit model The post-Brexit of the UK-EU The post-Brexit model relationship of the model UK-EU in some of the relationship cases UK-EU has relationship little in some no cases impact in some has little on cases animal or has no impact little or on no animal impact on The post-Brexit The post-Brexit model of model The the UK-EU post-Brexit of the relationship UK-EU model relationship in the some UK-EU cases in some relationship has cases little has oror in no little some impact or cases no on impact has animal little on animal or no impact anima information information for consumers information for consumers that is consumers likely that information for is to consumers likely reduce that is to for likely the reduce consumers that purchase to isof the reduce likely purchase and that to consumption is reduce purchase likely and the consumption to and reduce purchase of consumption lower the and of welfare purchase lower consumption of welfare lower and consumption welfare of lower welfare ofon lower information for consumers that isby likely to reduce the purchase and consumption of lower welfare Method Method of Method of production labelling Method of production labelling of isinformation Method production supported labelling is of supported Method production labelling is animal supported of by production is labelling protection animal supported by protection is animal labelling NGOs supported by animal protection because is NGOs supported by protection animal because itfor NGOs provides protection because NGOs it animal provides because it protection NGOs provides it because NGOs it because provides prtw Animals 2018, 8,production xThe FOR PEER REVIEW 7by of 20 Animals 2018, Animals 8, xfor FOR 2018, Animals PEER 8, x FOR 2018, REVIEW Animals PEER 8, xthe FOR REVIEW 2018, PEER Animals 8, xREVIEW FOR 2018, PEER 8, REVIEW xprotection. FOR PEER REVIEW 7production of 20generally 7 is of 20 of 2 ‘Norway model’ or ‘Norway the ‘Swiss model’ ‘Norway model’ or the all model’ preclude ‘Swiss or model’ the the ‘Swiss possibility all preclude model’ of all method the preclude possibility ofincluded production the of possibility method labelling. of production method production labelling. lab ‘Norway ‘Norway model’ or model’ the ‘Swiss ‘Norway or model’ ‘Swiss model’ all model’ preclude or the all ‘Swiss preclude the possibility model’ the possibility all of method of the of method production possibility production of labelling. method labelling. of labelling the ‘Swiss the model,’ ‘Swiss the the model,’ ‘Swiss DCFTA the the model,’ ‘Swiss or DCFTA under the model,’ the ‘Swiss or DCFTA WTO under the model,’ the rules DCFTA or WTO ‘Swiss under ismodel the positive rules or model,’ DCFTA WTO under is positive for rules the WTO or animal DCFTA under is rules positive for WTO or is positive under for rules protection. animal In WTO is contrast, protection. animal rules In contrast, ais for protection. positive animal In contrast, aimpact for protection. In animal aprovides protection. In atick contrast, In ait7con The animal welfare animal issues welfare included issues included in the table in are table formulated are formulated such that such apreclude tick that apositive generally tick is generally The animal The animal welfare welfare issues included issues The animal included inanimal the welfare table in issues are table formulated are formulated such in the that table such acontrast, tick are that formulated is aof generall such The post-Brexit The post-Brexit model The of the post-Brexit model UK-EU of the relationship model UK-EU of the relationship in UK-EU some cases relationship in some has little cases in or some has no little cases or has no on impact little animal or on no animal impact on The post-Brexit The post-Brexit model The post-Brexit of model the UK-EU of the relationship UK-EU of the relationship UK-EU in some relationship cases in some has cases in little some has or cases no little impact has or no little on impact animal or no on impact animal on animal scheme. The Pet Travel Scheme (PETS) was introduced to permit the travel of pet dogs, cats and protection. For instance, protection. Table protection. For 2 illustrates instance, For that Table instance, all 2 models illustrates Table permit 2 that illustrates continued all models that participation permit all models continued permit in the participation continued PETS participation in the PETS in th protection. protection. For instance, For instance, Table protection. 2 illustrates Table For 2 instance, illustrates that all Table models that all 2 illustrates permit models continued permit that all continued models participation permit participation in continued the PETS in the participation PETS in the PET products products and increase products and increase that and products of higher increase that of and welfare products higher that increase of products. welfare higher and that increase welfare products. of higher that products. welfare of higher products. welfare products. products and increase that of higher welfare products. information information for consumers information for consumers information that for is consumers likely information that for is to consumers likely reduce that information for is to the consumers likely reduce that purchase is to for likely the reduce consumers that purchase and to is the reduce consumption likely purchase and that to the consumption is reduce purchase likely and of lower the consumption to and reduce purchase of welfare consumption lower the and of welfare purchase lower consumption of welfare lower and consumption welfare of lower welfare of lower w Method of production Method labelling of Method production is supported of production labelling by is animal labelling supported protection ismembership supported by animal NGOs protection because animal it protection NGOs provides because NGOs because provides it prE2 Method Method of production ofnegative production labelling Method labelling of is production supported is supported by labelling animal protection animal supported protection NGOs by animal because NGOs protection because it provides NGOs it provides because itPETS provide cross is2018, generally cross generally cross negative isREVIEW cross generally negative for is generally cross for animal isfor negative generally for protection. animal For for negative instance, animal For instance, for continued protection. negative animal For instance, continued protection. for membership For animal instance, continued protection. For of continued instance, the membership EU, of For the the continued membership instance, EU, of the the membership continued EU, ofand the EU, the the EU, the of unde the Animals x is FOR PEER 7by of 20 positive positive for8,animal for protection. animal protection. For instance, For instance, banning banning live exports live for exports fattening for fattening and slaughter and slaughter under under An ma sanimal 2018 8For xprotection. FOR An PEER ma sFor 2018 REV 8EW xgenerally FOR PEER An REV ma sinstance, EW 2018 8by xis FOR PEER REV EW 7membership oof 20it 7 oth positive positive animal for protection. animal protection. positive For for For animal instance, banning protection. banning live exports For live instance, exports for fattening banning for fattening live slaughter exports and slaughter under for fattenin protection. protection. For instance, protection. Table instance, 2model illustrates For Table instance, 2include illustrates that Table all models 2relationship that illustrates all permit models that continued permit all models continued participation permit participation continued in the PETS participation in the in protection. protection. For instance, protection. instance, Table For 2cross illustrates instance, Table 2protection. illustrates Table that all 2Travel illustrates models that all permit models that all continued permit models continued permit participation continued participation in the participation PETS in the PETS in the PETS ferrets within the EU. It has since expanded to non-EU nations, which is why the UK would scheme. The Pet Travel scheme. Scheme The scheme. Pet (PETS) Travel The was Pet Scheme introduced (PETS) Scheme to was permit (PETS) introduced the was travel introduced to permit of pet dogs, the to permit travel cats and of the pet travel dogs, of cats pet dogs, ca scheme. scheme. The Pet The Travel Pet Scheme scheme. Travel (PETS) Scheme The Pet was (PETS) Travel introduced was Scheme introduced to (PETS) permit to the permit introduced travel the of travel pet to permit dogs, of pet cats the dogs, and travel cats of and pet dogs, cats an The post-Brexit The post-Brexit model The post-Brexit of model the The UK-EU post-Brexit of model the relationship UK-EU The of the post-Brexit UK-EU relationship in of some the relationship model UK-EU cases in some of the has in cases UK-EU little some has or cases relationship no little in impact some has or no little cases on impact in animal or some has no little on impact cases animal or has on impact little animal or on no animal impact on The post-Brexit model of the UK-EU relationship in some cases has little or no impact on animal The animal welfare issues included in the table are formulated such that awas tick is generally The animal The welfare animal The issues animal welfare The included welfare issues animal included issues in The welfare the animal included table in issues the welfare are table in formulated included the issues are table formulated in included such are the formulated table that such in aare the tick that formulated table such ano generally tick are that is such aof generally tick that isofand generall asuch tick tw i products products and products and that products and of higher that and products of welfare higher increase that of and products. welfare products higher that increase of products. welfare higher and that increase welfare products. of higher that products. welfare of higher products. welfare products. An ma s 2018 An 8ma xincrease sFOR 2018 An PEER 8the ma xincrease sDCFTA FOR REV 2018 An PEER EW ma 8the xmodel’ sincrease FOR 2018 REV PEER 8EW xall FOR REV PEER EW REV EW 7In ounder 20 7production oand 20 7isoproduction 20 7 formulated o 20 An ma sis 2018 8all xunder FOR PEER REV EW information for consumers information that information for is consumers likely to for reduce consumers that the likely purchase that to is reduce likely and the consumption to reduce purchase the and purchase lower consumption welfare and consumption of lower welfare lower information information for consumers for consumers information that is likely that for is to consumers likely reduce to the reduce that purchase is likely purchase and to reduce consumption and the consumption purchase of lower of welfare consumption lower welfare of lower welfar ‘Norway ‘Norway model’ or ‘Norway model’ ‘Swiss ‘Norway or model’ ‘Swiss or model’ ‘Norway the model’ ‘Swiss preclude or model’ the ‘Norway all model’ ‘Swiss preclude the or possibility the all model’ model’ preclude ‘Swiss the possibility all or of model’ the preclude the method ‘Swiss possibility of the of preclude method model’ production possibility of all of method the preclude production possibility of labelling. method of production the labelling. of possibility of method labelling. of method labelling. production labelling. lab the ‘Swiss the model,’ ‘Swiss the model,’ the or DCFTA under or WTO under rules WTO is positive rules is positive for animal for protection. animal protection. In contrast, contrast, a a the ‘Swiss the model,’ ‘Swiss model,’ the DCFTA the the DCFTA or ‘Swiss under or model,’ WTO rules the WTO DCFTA is rules positive or is positive for animal WTO for protection. animal rules is protection. positive In contrast, for In animal contrast, a pr scheme. The scheme. Pet Travel The scheme. Pet Scheme Travel The (PETS) Pet Scheme Travel was (PETS) introduced Scheme was (PETS) introduced tothe permit was introduced to the permit travel the of to pet permit travel dogs, of the pet cats travel dogs, and of cats pet and dogs, ca scheme. scheme. The Pet scheme. The Travel Pet Scheme The Travel Pet (PETS) Scheme Travel was (PETS) Scheme introduced was (PETS) introduced to was permit introduced to permit travel to the permit of travel pet the dogs, of travel pet cats dogs, of and pet cats dogs, and cats and remain a member of PETS under the various post-Brexit models in Table 2. Prior to PETS, the UK ferrets within the EU. ferrets It has within since ferrets the expanded EU. within It has the to since include EU. It expanded has non-EU since to expanded nations, include which non-EU to include is why nations, non-EU the UK which nations, would is why which the UK is why would the UK ferrets within ferrets the within EU. It the has ferrets EU. since It within has expanded since the expanded EU. to include It has to since non-EU include expanded nations, non-EU to which include nations, is non-EU which why the is nations, why UK would the which UK would is why the UK woul protection. protection. For instance, protection. For instance, Table protection. For 2 instance, illustrates Table protection. For 2 illustrates Table instance, that all 2 illustrates For models that Table instance, all 2 permit models illustrates that Table all continued models permit 2 that illustrates continued all permit participation models that continued participation permit all models in the continued participation PETS permit in the participation continued PETS in the PETS participation in the PETS in th protection. For instance, Table 2 illustrates that all models permit continued participation in the PETS positive for animal protection. For instance, banning live exports for fattening and slaughter under positive positive for animal positive for protection. animal for positive protection. animal For for instance, protection. positive animal For instance, banning for protection. For animal instance, banning live protection. For exports banning instance, live for exports For fattening live banning instance, exports for fattening and live banning for slaughter exports fattening and live slaughter for under exports and fattening slaughter under for and fattenin unde slaug post-Brexit The post-Brexit model The post-Brexit of model The the UK-EU post-Brexit ofma model the The relationship UK-EU post-Brexit of model the relationship UK-EU The of in the post-Brexit model some UK-EU relationship cases in of some the relationship model has UK-EU cases in little some of the has relationship or in cases no UK-EU little some impact has or relationship no little in on impact some has animal or no little cases on impact inEU, animal or some has no little on impact cases animal orsit has no on impact little animal or on no animal impact on animal welfare issues included in the table are formulated such that amembership tick is generally The an we fare The an ssues ma nc we uded fare The ssues n the an tab nc ma uded eanimal we are fare formu nby the ssues tab ated einstance, nc such are uded formu that nthe amembership ated the tprovides ck tab such einstance, genera are that formu a20 yittcontinued ck s 20 genera such products and increase products that and products higher increase welfare and that increase products. of higher that welfare products. welfare products. products products and increase and increase that products of higher that and of welfare higher increase products. welfare that of products. higher welfare products. Method Method of Method of production labelling Method of production labelling of isMethod production supported labelling isma supported production by labelling is animal supported of by production is labelling protection animal by protection is animal labelling NGOs supported by protection because is NGOs supported protection animal because it NGOs provides protection because NGOs it animal provides because it protection NGOs because provides NGOs because provides it cross generally cross generally negative negative for animal for animal protection. For instance, For instance, continued continued membership ofcases the EU, of the the An maThe sis2018 8 production x is FOR PEER REV EW 7by o 20 cross is cross generally generally negative negative for cross animal for generally protection. animal protection. negative For instance, for For animal continued protection. continued For membership of the of EU, mem tht2 An ma sthe 2018 An 8ma xprotection. sthe FOR 2018 An PEER 8of xMethod sis FOR 2018 REV An PEER 8EW x ma FOR REV shas 2018 PEER EW An 8supported xEU. REV ma FOR sis EW 2018 PEER 8of REV xhigher FOR EW PEER REV EW 7 othe 7ated othe 7UK opr ferrets the within ferrets It has the EU. since within It expanded has the since It expanded to has include since to non-EU expanded include nations, non-EU to include which nations, non-EU is why which nations, the is UK why which would UK isEU, why would the ferrets within ferrets within ferrets EU. It within has EU. since It the has expanded EU. since It expanded to since include expanded to non-EU include to nations, non-EU include which nations, non-EU is which nations, why the is which why UK would the is why UK would the UK would had aThe compulsory six month quarantine for imported pet dogs and cats. The quarantine period was remain aferrets member of remain PETS aEU. under member remain the of various athe member PETS under post-Brexit of PETS the various under models the post-Brexit in various Table 2. post-Brexit models Prior to in PETS, Table models the 2. UK Prior in Table had to PETS, 2. Prior the to UK PETS, had the U remain ainstance, remain member awithin member of PETS remain under of PETS athe member under various the of post-Brexit various PETS under post-Brexit models the various in models Table post-Brexit 2. in Prior Table to 2. models PETS, Prior to in the PETS, Table UK had 2. the Prior UK had to PETS, the UK ha scheme. scheme. The Pet scheme. The Travel Pet Scheme The Travel scheme. Pet (PETS) Scheme Travel The scheme. Pet was Scheme (PETS) Travel introduced The was (PETS) Pet Scheme introduced Travel was to (PETS) permit introduced Scheme to was the permit (PETS) travel introduced to the permit of was travel pet introduced to the dogs, permit of travel pet cats dogs, the of to and pet permit travel cats dogs, and of the pet cats travel dogs, and of cats pet and dogs, ca scheme. The Pet Travel Scheme (PETS) was introduced to permit the travel of pet dogs, cats and the ‘Swiss model,’ the DCFTA or under WTO rules is positive for animal protection. In contrast, the ‘Swiss the model,’ ‘Swiss the the model,’ ‘Swiss DCFTA the model,’ the ‘Swiss or DCFTA under the model,’ the DCFTA or WTO ‘Swiss under the rules or model,’ DCFTA WTO under is positive rules the WTO or DCFTA under is rules positive for animal WTO or is positive under for rules protection. animal WTO is for positive protection. animal rules In contrast, is for protection. positive animal In contrast, a for protection. In animal contrast, a pr The an ma The we an fare ma we ssues an fare The ma nc an we ssues uded ma fare nc we n ssues uded the fare tab nc ssues n e uded are tab nc formu n uded e the are ated tab formu n e such are tab ated formu that e such are a ated t formu ck that such s a genera ated t ck that such s a y genera t that ck s a y genera t ck s genera y y The an ma we fare ssues nc uded n the tab e are formu ated such protection. protection. For instance, protection. For Table protection. For 2 illustrates instance, Table protection. For 2 instance, illustrates Table that protection. For all 2 illustrates Table models instance, that all 2 illustrates permit For models that Table instance, all continued 2 permit models illustrates that Table all continued models permit participation 2 that illustrates continued all permit participation models that in continued the participation permit all PETS models in the continued participation PETS permit in the participation continued PETS in the PETS participation in the PETS in th positive for animal protection. For instance, banning live exports for fattening and slaughter under pos t ve for an ma pos protect t ve for on an For ma nstance protect pos t ve on bann for For an ng nstance ma ve protect exports bann on for ng For fatten ve nstance exports ng and bann for s aughter fatten ng ng ve under exports and s aughter for fatten unde notw The post-Brexit model The post-Brexit of the UK-EU The post-Brexit model relationship of the model UK-EU in some of the relationship cases UK-EU has relationship little in some no cases impact in some has little on cases animal or has no impact little or on no animal impact onIn The post-Brexit The post-Brexit model of model The the UK-EU post-Brexit of the relationship UK-EU model relationship of in the some UK-EU cases in some relationship has cases little has oror in no little some impact or cases no on impact has animal little on animal or no impact on anima information information for remain consumers information for consumers information that for is consumers likely information that for is to consumers likely reduce that information for is to the consumers likely reduce that purchase is to for likely the reduce consumers that purchase and to is the reduce consumption likely purchase and that to consumption is reduce purchase likely and of lower the consumption to and reduce purchase of welfare consumption lower the and of welfare purchase lower consumption of welfare lower and consumption welfare ofproduction lower welfare of lower ‘Norway ‘Norway model’ or model’ the ‘Swiss or the model’ ‘Swiss all model’ preclude all preclude the possibility the possibility of method of of method production of production labelling. labelling. ‘Norway ‘Norway model’ or model’ the ‘Swiss or the ‘Norway model’ ‘Swiss all model’ model’ preclude all or the preclude the ‘Swiss possibility the model’ possibility of all method preclude of method of production the possibility of labelling. of method labelling remain a member remain a of member PETS remain under of a member PETS the various under of PETS the post-Brexit various under the post-Brexit models various in post-Brexit models Table 2. in Prior Table models to PETS, 2. Prior in Table the to UK PETS, 2. Prior had the to UK PETS, had the U a remain member a remain member of PETS a under member of PETS the under of various PETS the under post-Brexit various the post-Brexit various models post-Brexit in models Table 2. in models Prior Table to 2. in PETS, Prior Table to the 2. PETS, Prior UK had to the PETS, UK had the UK had a compulsory six a month compulsory quarantine a compulsory six month for imported six quarantine month pet quarantine for dogs imported and cats. for pet imported The dogs quarantine and pet cats. dogs period The and quarantine cats. was The quarantine period was perio a compulsory a compulsory six month six a quarantine compulsory month quarantine for six imported month for imported quarantine pet dogs pet and for dogs cats. imported and The cats. quarantine pet The dogs quarantine and period cats. was The period quarantine was period wa considered to cause welfare problems and the PETS scheme a successful reform. However, if the UK ferrets within ferrets the within ferrets EU. It the within has EU. ferrets since the It has within expanded EU. since ferrets It has the expanded to EU. since within include It expanded has the to since non-EU include EU. It expanded to has include nations, non-EU since to non-EU expanded which nations, include is nations, which why non-EU to include the is which why UK nations, non-EU would the is why UK which nations, would the is UK why which would the UK is why would the UK ferrets within the EU. It has since expanded to include non-EU nations, which is why the UK would cross is negative for animal protection. For continued membership of the EU, the cross is generally cross is cross generally negative is generally negative cross for animal isby negative generally for cross protection. animal for is negative generally protection. animal For for protection. negative animal For continued protection. for For animal instance, continued membership protection. For continued membership of For the membership of the membership EU, of the EU, mem of th pos tThe vegenerally pos for an tPet ve ma pos for protect an tPet ve ma pos for on protect tThe an ve For ma for nstance on protect an For ma nstance on protect bann For ng on nstance bann For exports ng nstance bann ve for exports ng fatten bann ve for exports ng ng fatten and ve exports for stnc ng aughter fatten and for sparticipation ng aughter and under aughter and scats aughter under under pos tSw ve for an ma on For nstance bann ng ve exports for fatten nt scheme. scheme. The scheme. The Travel Scheme scheme. The Travel Pet (PETS) Scheme The Travel scheme. Pet was (PETS) Scheme Travel The introduced Pet was Scheme (PETS) Travel introduced The to was (PETS) Pet Scheme permit introduced Travel to the (PETS) permit introduced Scheme travel to was the permit of (PETS) travel introduced pet to the permit dogs, of was pet cats introduced to the dogs, permit of and travel pet cats dogs, the of to and pet permit travel dogs, and of the pet cats travel dogs, and of cats pet and dogs, ca the ‘Swiss the DCFTA or under WTO rules is positive for animal protection. In contrast, asupported the Sw ss mode the Sw DCFTA ss mode or under the the DCFTA WTO ss ru or mode es under sthe pos the WTO DCFTA ve ru for es an or sfatten ma pos under protect tsng ve WTO for on an ru In ma es contrast sprotect pos tit ve aon for In contrast anmodel,’ ma we fare ssues nc uded n the tab einstance, are formu ated aprotect tn ck stravel genera y an ma The we an fare The ma an we ssues ma fare The nc we ssues an uded fare ma nc The ssues n we uded the an fare tab nc ma n uded ssues einstance, we are tab fare formu the einstance, uded are ssues tab ated formu eunder n nc such are the uded ated formu tab that einstance, such n aare ated the tand ck that formu tab such scontinued aanimal einstance, genera tEU, ated are that ck formu ssuch aprotection y genera tcontinued ck that ated san genera y ama such tperio ckpr protection. For instance, protection. Table protection. For 2illustrates illustrates instance, For that Table instance, all 2was models illustrates Table permit 2that that illustrates continued all models that permit all models continued permit in the participation continued PETS participation in the PETS in th protection. protection. For instance, For instance, Table protection. 2scheme. Table For 2ve instance, illustrates that all Table models that all 2such illustrates permit models continued permit that all continued models participation permit participation in continued the PETS in the participation PETS in the PET products products and increase products and increase that products and of higher increase that and products of welfare higher increase that of and products. welfare products higher that increase of products. welfare higher and that increase welfare products. of higher that products. welfare of higher products. welfare products. Method Method of production of production labelling labelling is supported isthe supported by animal protection animal protection NGOs because NGOs because it provides it provides Method Method of production of production labelling Method labelling is supported of production is supported by animal labelling by animal protection is protection NGOs by because NGOs because provides it provide NGO a compulsory a compulsory six month a compulsory six quarantine month six quarantine for month imported quarantine for imported pet dogs for and pet imported dogs cats. The and pet quarantine cats. dogs The quarantine cats. period The was quarantine period was a compulsory a compulsory six a month compulsory six quarantine month six quarantine month for imported quarantine for imported pet for dogs imported pet and dogs cats. pet and The dogs cats. quarantine and The cats. quarantine period The quarantine was period was period was considered to cause considered welfare problems considered to cause welfare and to the cause problems PETS welfare scheme and problems asuccessful the successful PETS and scheme the reform. PETS aIn successful However, scheme aUK reform. successful ifmethod the UK reform. ifHowever, the UK if considered considered to cause to welfare cause considered problems welfare to problems cause the welfare PETS and the scheme problems PETS aan scheme and the successful PETS reform. scheme However, reform. aUK successful However, if the UK reform. ifsHowever, the UK However, if the UK remain ass remain member athe remain member of PETS ahas member under of remain PETS the aEU. of under member various PETS remain the under post-Brexit of various member PETS the various under post-Brexit of models PETS the post-Brexit various in under models Table the post-Brexit 2. models in various Prior Table to in 2. post-Brexit PETS, models Table Prior to 2. the in Prior PETS, Table models had to the PETS, 2. UK Prior in Table had the to UK PETS, 2. Prior had to UK PETS, had the Ut remain a‘Swiss member of PETS under the various post-Brexit models in Table 2. Prior to PETS, the UK had does not successfully negotiate aWTO withdrawal agreement with the EU, the UK will drop out of the EU ‘Norway model’ or the model’ all preclude the possibility of method of production labelling. ‘Norway ‘Norway model’ ‘Norway or model’ ‘Swiss or model’ ‘Norway the model’ ‘Swiss or model’ the ‘Norway all model’ ‘Swiss preclude all model’ model’ preclude ‘Swiss the all or model’ the preclude the ‘Swiss possibility all of the preclude method model’ possibility of all of method the preclude production possibility of of production the labelling. possibility of method production labelling. of productio method labelling the ss the mode Sw the the mode Sw DCFTA ss the mode Sw or DCFTA ss under mode the or DCFTA WTO under the ru DCFTA or es under saand ru or WTO es under tfor ve scases pos for ru WTO es an tor ve ma sthe ru pos for es protect tnstance ve spossibility ma pos for on protect tapermit an ve In ma for contrast on protect an ma contrast afor on protect In contrast aimpact on In contrast aof athe the Sw ss mode the DCFTA or under WTO ru es pos tpet ve for an ma pr ferrets ferrets the within ferrets EU. It the within has ferrets EU. since the within expanded EU. ferrets since the It has within expanded to since ferrets include has the expanded to EU. since within non-EU include It expanded has the to nations, since non-EU include EU. 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The Pet Travel scheme. Scheme The scheme. Pet (PETS) Travel The was Pet Scheme introduced Travel Scheme to was permit (PETS) introduced was travel introduced to of pet dogs, the to permit travel cats and of the pet travel dogs, cats pet and dogs, ca scheme. scheme. The Pet The Travel Pet scheme. 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However, reform. if the UK However, if the UK if the UK does not successfully does negotiate not successfully does a withdrawal not successfully negotiate agreement a negotiate withdrawal with a the withdrawal agreement EU, the UK agreement with will the drop EU, with out the the of UK the EU, will EU the drop UK out will of drop the EU out of does not does successfully not successfully negotiate does not negotiate a withdrawal successfully a withdrawal agreement negotiate agreement a with withdrawal the with EU, the the agreement UK EU, will the with drop UK will the out drop EU, the the out EU UK of the will EU drop out of the a compulsory a compulsory six a compulsory month six quarantine a month compulsory six quarantine month a for compulsory six imported quarantine month for imported pet six quarantine for dogs month imported pet and quarantine for dogs cats. imported pet and The dogs cats. for quarantine and pet imported The dogs cats. quarantine The period and pet quarantine cats. dogs was period The and quarantine cats. was period The was quarantine period was perio a compulsory six month quarantine for imported pet dogs and cats. The quarantine period was without any deal. This would mean that the UK membership of PETS would be jeopardised. The UK Method of production labelling is supported by animal protection NGOs because it provides Method Method of production Method of production labelling of Method production labelling is of supported Method production labelling is supported of by production is labelling animal supported by protection is animal labelling supported by animal protection is NGOs supported by protection animal because NGOs by protection because NGOs it animal provides because it protection NGOs provides it because provide NGO cross s genera cross s y genera cross negat s ve y cross genera negat for an s ve genera y ma negat for protect an y ve ma negat for on protect an ve For ma for nstance on protect an For ma nstance cont on protect For nued on nstance cont membersh For nstance cont membersh p of cont the membersh nued EU p of the the membersh EU p of the the p EU of the EU the cross s genera y negat ve for an ma protect on For nstance cont nued mem remain remain member aor remain member of PETS aprotection. remain under member of PETS ass the member under of remain various PETS the aof under member post-Brexit various PETS remain the under post-Brexit of various PETS models the various under post-Brexit in of models Table PETS the post-Brexit various 2. in under models Prior Table the post-Brexit to 2. models in PETS, various Prior Table to in 2. post-Brexit PETS, models Table Prior UK had to 2. in PETS, UK Table models had to PETS, 2.protect UK Prior in Table had to UK PETS, 2. Prior had the to UK PETS, had the ‘Norway model’ the ‘Swiss all preclude the of method of labelling. Norway mode Norway or the Sw mode ss mode or the aNorway Sw ss ude mode mode the poss aproduction or the prec Sw ude ty of ss the method poss aparticipation of prec product ty of ude method on the poss of product ng tyfor of on method abe ng oU the Swass mode the DCFTA or under WTO ru es sapossibility pos tTable ve for an ma protect on contrast aPrior the Sw the mode Sw the ss the mode Sw DCFTA ss the mode the Sw or DCFTA under ss the mode the DCFTA or WTO Sw under the ss ru or mode DCFTA WTO es under sillustrates pos ru the WTO or es tbthat DCFTA ve under sIn ru pos for es an WTO tmode or ve sPETS ma pos under for ru protect tban es ve WTO ma sfor pos on an ru twould In ma ve es contrast for sabe on protect pos an In tbma contrast ve aon protect In an contrast aEU ma on pr In ferrets within the EU. ferrets has within since ferrets the expanded EU. within It has the to since include EU. It expanded has non-EU since to expanded nations, include which non-EU to include is why nations, non-EU the UK which nations, is why which the UK is why would the UK ferrets within ferrets the within EU. It the ferrets EU. since It has expanded since the expanded EU. to include Itthat has to since non-EU include expanded nations, non-EU to which include nations, is non-EU which why the is nations, why UK would the which UK would is why the UK woul protection. protection. Forincrease instance, protection. For instance, Table 2model’ illustrates instance, Table protection. For 2Ithas instance, illustrates Table that protection. For all 2within illustrates Table models instance, that all 2member illustrates permit For models that instance, all continued 2prec permit models illustrates that Table all continued models permit participation 2the that continued all permit participation models that in continued the participation permit all models in the continued PETS permit in the participation continued PETS in the PETS participation in the PETS in th products products and and increase that ofFor higher that of welfare higher products. welfare products. products products and increase and increase that of products higher of welfare higher and increase welfare products. products. of higher welfare products. does not successfully does not successfully does negotiate not successfully a negotiate withdrawal a negotiate withdrawal agreement a withdrawal agreement with the EU, agreement with the the UK EU, will with the drop the UK EU, out will the of drop the UK EU out will of drop the out of does not does successfully not does successfully negotiate not successfully negotiate a withdrawal negotiate a withdrawal agreement a withdrawal agreement with agreement with EU, the the UK with EU, will the drop UK EU, will the out drop UK of the will out EU drop of the out EU of the EU without any deal. without This would any without mean deal. that This any the would deal. UK This mean membership that the mean of UK PETS that membership the would UK be membership of jeopardised. PETS would of The PETS be jeopardised. would be jeopardised. The Tt without any without deal. any This deal. would without This mean would any that deal. mean the This UK that would membership the UK mean membership that of PETS the would of PETS membership be would be of jeopardised. PETS The would The be jeopardised. UK The UK considered considered to cause considered to welfare cause considered to problems welfare cause welfare problems considered and cause the problems PETS and to the cause scheme problems PETS welfare the awould scheme successful PETS and problems scheme asuccessful the successful reform. PETS and amethod successful scheme the However, reform. PETS ajeopardised. successful reform. However, scheme ifabe the UK However, aifThe reform. successful if the UK However, if the reform. UK ifHowever, the UK if considered to cause welfare problems and the PETS scheme reform. However, the UK Government is seeking discussions with the EU on the issue and has published technical guidance on information for that is likely to reduce purchase and consumption of lower welfare information information for information for consumers information that for consumers likely that information for is to consumers likely reduce that is to for likely reduce consumers that purchase to is the reduce likely purchase and that to the consumption is reduce purchase likely and the consumption to and reduce purchase of consumption lower the and of welfare purchase lower consumption of welfare lower and consum welfar of low Norway Norway mode or Norway mode the Sw Norway or mode ss the mode Sw or mode ss the aPet mode prec Sw or the ss ude ato Sw prec the ss poss ude awelfare mode prec the ty poss aand ude of prec the method bof ude ty poss of the of method b product poss ty of bUK of product on ty of abe method of product on ng of product on ng abe on ng abe ng Norway mode or the Sw ss mode acats prec ude the poss b ty of method oU ascheme. compulsory ascheme. compulsory six ascheme. month compulsory quarantine compulsory month quarantine ascheme. month compulsory for imported quarantine month ascheme. for compulsory six imported quarantine pet month for dogs imported pet six quarantine and for dogs month cats. imported pet and The quarantine for dogs cats. quarantine imported pet and The dogs cats. for quarantine and pet imported period The dogs cats. quarantine was The period and pet quarantine cats. dogs was period and quarantine cats. was period The was quarantine period was perio Method of production labelling is supported by animal protection NGOs because it provides Method of product Method on abe of product ng sb on supported Method abe of ng by product sawas an supported ma on protect abe by on ng an ma NGOs ssome supported protect because on by NGOs tmembersh an prov ma des protect ton prov NGO de cross s genera yconsumers negat ve for an ma protect cont nued membersh p of the EU the cross s asix genera cross ssix yconsumers cross genera negat smode ve yFor negat cross for an yis ve sto ma negat genera for cross protect an ve ma y for s(PETS) negat genera on protect an For ma ve for y nstance on protect negat an For ma ve on nstance cont protect for For nued an nstance cont ma on membersh protect For nued cont nstance membersh on nued p of For the cont nstance EU p nued ofbecause the the membersh cont pEU of nued the EU mem p ha of th remain aascheme. member of remain PETS aThis under member remain the of various anstance member PETS under post-Brexit of PETS various under models the post-Brexit in various Table 2. post-Brexit models Prior to in PETS, Table models the 2. UK Prior in Table had to PETS, 2. Prior the to UK PETS, had the remain asix remain member member of PETS remain under of PETS agenera the member under various the of post-Brexit various PETS under post-Brexit models the various in models Table post-Brexit 2. in Prior Table to 2. models PETS, Prior to in the PETS, Table UK had 2. Prior UK had to PETS, UK The Pet The Travel Pet Scheme The Travel Pet (PETS) Scheme The Travel was (PETS) Scheme Travel The introduced Pet was Scheme (PETS) Travel introduced The was (PETS) Pet Scheme permit introduced Travel was to the permit introduced Scheme travel to the permit of (PETS) travel introduced pet to the permit dogs, of was travel pet cats introduced to the dogs, permit of and travel pet dogs, the of to and pet permit travel cats dogs, and of the pet cats travel dogs, and of cats pet and dogs, ca The post-Brexit The post-Brexit model of model the UK-EU of the relationship UK-EU relationship in some cases in some has cases little has or no little impact or no on impact animal on animal The post-Brexit The post-Brexit model of model the UK-EU The the post-Brexit UK-EU relationship relationship model in some of the in cases UK-EU has cases relationship little has or no little impact in or some no on impact cases animal has on little anima without any without deal. any without deal. would This any mean would deal. that This mean the UK would that membership the mean UK that membership of the PETS UK membership would of PETS be jeopardised. would of PETS be jeopardised. would The UK be jeopardised. The UK To without any without deal. any without This deal. would any This deal. mean would This that mean would the UK that mean membership the UK that membership the of UK PETS membership would of PETS be would of jeopardised. PETS be would jeopardised. The be UK jeopardised. The UK The UK Government is seeking Government discussions Government is seeking with the discussions is seeking EU on the discussions with issue the and EU with has on the published issue EU on and technical the has issue published guidance and has technical published guidance technical gu Government Government is seeking is discussions seeking Government discussions with is seeking the with EU discussions on the the EU issue on with and issue the has EU and published on has the published issue technical and technical guidance has published guidance technical guidanc does not does successfully not does successfully not negotiate successfully does negotiate a not withdrawal successfully does negotiate a withdrawal not agreement successfully a negotiate withdrawal agreement with a negotiate withdrawal the agreement with EU, a the the withdrawal agreement with UK EU, will the drop EU, UK agreement with will the out the UK drop of EU, the will with out the EU drop the of UK the EU, out will EU the of drop the UK EU out will of drop the EU out of does not successfully negotiate a withdrawal agreement with the EU, the UK will drop out of the EU products and increase of higher welfare products. products products and increase products and increase that and products of higher increase that and welfare products higher that increase of products. welfare higher and that increase welfare products. of higher that products. welfare of higher products. welfare products. Method Method of product Method product on Method abe of product on ng abe of sconsidered product supported on ng abe sreduce on supported ng by abe sss an supported ma ng by sof protect an supported ma by on protect an NGOs ma by on protect because ma NGOs protect because NGOs tand prov on des because NGOs twhy prov because des prov des tUK prov des this possibility [28]. Method of product on abe ng sude supported by an ma protect on NGO considered considered to cause considered to welfare cause considered problems to welfare cause to problems welfare cause the welfare problems considered PETS to and cause the scheme problems PETS welfare and to acause scheme successful and problems PETS welfare the ass scheme successful PETS reform. and problems scheme aan the successful However, reform. PETS and aon successful scheme the However, reform. if PETS the ais UK successful reform. However, scheme if the UK However, atUK reform. successful if the UK However, if the reform. UK ifcontinued However, the UK if t information for consumers that is likely to purchase and consumption of lower welfare nformat on for consumers nformat on that for consumers spermit ke nformat y to reduce that on sprec for the ke consumers purchase y to reduce that the consumpt sposs purchase ke y to on and reduce of consumpt ower the we purchase fare on of and ower consum we far Norway mode or the Sw ss mode aand prec ude the poss bthe ty of method of product on abe ng Norway Norway mode Norway or mode the Sw or mode Norway the mode Sw or mode the ss a Norway mode Sw prec or ude the a mode mode the Sw poss a ss or ude mode the prec the b Sw ude ty poss a of ss the prec method b mode ty of a b of method the prec product ty poss of ude method of b product on the ty abe of poss of method product on ng b abe ty of on ng product method abe ng o aof compulsory six a month compulsory quarantine a compulsory six month for imported six quarantine month pet quarantine for dogs imported and cats. for pet imported The dogs quarantine and pet cats. dogs period The and quarantine cats. was The quarantine period was perio aGovernment compulsory aGovernment compulsory six month six a quarantine compulsory month quarantine for six imported month for imported quarantine pet dogs pet and for dogs cats. imported and The cats. quarantine pet The dogs quarantine and period cats. was The period quarantine was period wa ferrets within ferrets the within ferrets EU. Itthat the within has ferrets EU. since It the within has expanded EU. ferrets since the It has within expanded EU. to since ferrets include It has the expanded to EU. since within non-EU include It expanded has the to nations, since non-EU include EU. It expanded to has which include nations, non-EU since is to non-EU expanded which nations, why include the is nations, which why UK non-EU to include would the which UK nations, non-EU would the is why which nations, would the is why which would the UK is why would UK protection. protection. For instance, For instance, Table 2 illustrates Table 2 illustrates that all models that all models continued permit continued participation participation in the PETS in the PETS protection. protection. For instance, For instance, Table protection. 2 illustrates Table 2 illustrates For that instance, all models that Table all models permit 2 illustrates continued permit that continued participation all models participation permit in the PETS in the PET pa Government Government is seeking Government is discussions seeking discussions is with seeking the EU discussions with on the the EU issue with on and the issue has EU on published and the has issue published technical and has guidance technical published guidance technical guT is seeking Government is discussions seeking ismean discussions seeking with discussions the with EU on the the with EU issue on the and EU issue on has the and published issue has and published technical has published technical guidance technical guidance guidance on this possibility on [28]. this possibility on this [28]. possibility [28]. on this possibility on this possibility [28]. on [28]. this possibility [28]. without any without deal. without any This deal. would any without This deal. mean would This any that without deal. would the UK that This any mean membership the would deal. that UK This mean membership the UK would of that PETS membership the mean would of UK PETS that membership be of the would jeopardised. PETS UK be membership would of jeopardised. PETS The be jeopardised. would UK of The PETS be UK jeopardised. would The UK be jeopardised. The UK without any deal. This would mean that the UK membership of PETS would be jeopardised. The UK The post-Brexit model of the UK-EU relationship in some cases has little or no impact on animal The post-Brexit The post-Brexit model The post-Brexit of model the The UK-EU post-Brexit of model the relationship UK-EU The of the post-Brexit model UK-EU relationship in some the relationship model UK-EU cases in some of the has relationship in cases UK-EU little some has or cases relationship no little in impact some has or no little cases on impact in animal or some has no little on impact cases animal or has no on impac little anima o nformat nformat on for consumers nformat on for consumers nformat on that for s consumers on ke that for y to consumers s reduce ke that y to s the reduce that ke purchase y s to the reduce ke purchase y and to the reduce consumpt purchase and the consumpt purchase on and of consumpt ower on and of we consumpt ower fare on of we ower fare on of we ower fare we fare nformat on for consumers that s ke y to reduce the purchase and consum does not does successfully not does successfully negotiate not does successfully not negotiate a withdrawal successfully does negotiate a not withdrawal successfully agreement does negotiate a withdrawal not agreement successfully a with negotiate withdrawal the agreement with EU, a negotiate withdrawal the the agreement UK with EU, will a the the withdrawal agreement with drop UK EU, will the out drop EU, UK of agreement with the will the out the EU UK drop of EU, the will with out the EU drop the of UK the EU, out will EU the of drop the UK EU out will of drop the EU out of products andproduct increase that of higher welfare products. products and ncrease products that and of h ncrease gher we products that fare of products hPETS and gher ncrease fare products of hUK gher we fare products Method of on abe ng sof supported by an ma protect NGOs because t2. prov des Method Method of product Method of product on abe of Method product ng abe sthe of on supported Method product ng abe son supported of ng on by product saabe an supported ma ng by on protect an ssuccessful abe supported ma by on ng an protect ma NGOs sthe supported by on protect an because NGOs on by protect because NGOs tthe an prov ma on because des tpermit protect NGOs prov des ton because prov NGO de considered to cause considered welfare problems considered to cause welfare and to cause problems PETS welfare scheme and problems awe the successful PETS and scheme reform. PETS ahad successful However, scheme ama reform. successful ifthe the UK However, reform. ifHowever, the UK if considered considered to cause to welfare cause considered problems welfare to problems and cause the welfare PETS and the scheme problems scheme successful and the athat PETS reform. scheme However, reform. athe successful However, if UK reform. if the UK However, if the UK remain ascheme. remain member aremain member ofthis PETS aremain under member of PETS athe member under remain various PETS the aof under member post-Brexit various PETS remain the under post-Brexit of various aon member PETS models the various under post-Brexit in of models Table PETS post-Brexit various 2. in under models Prior Table the post-Brexit to 2. models in PETS, various Prior Table to in the post-Brexit PETS, models Table Prior to 2. in Prior PETS, UK Table models had to the PETS, 2. UK Prior in Table had to UK PETS, 2. Prior had the to UK PETS, had thean Ut scheme. The Pet The Travel Pet Scheme Travel (PETS) Scheme was (PETS) introduced was introduced to permit to the permit travel the of travel pet dogs, of pet cats dogs, and cats and scheme. scheme. The Pet The Travel Pet Scheme Travel scheme. Scheme (PETS) The was (PETS) Pet introduced Travel was introduced Scheme to permit (PETS) to permit was travel introduced of travel pet dogs, of to pet cats dogs, and the cats travel on this possibility on this possibility [28]. on this [28]. possibility [28]. on possibility on this possibility on [28]. this possibility [28]. [28]. Government Government isthat seeking Government discussions seeking Government is seeking discussions with Government is discussions the seeking with EU on the discussions ist the with seeking EU issue on the the EU discussions and with issue on has the the and published EU issue with has on and the published technical issue has EU on published and technical the guidance has issue published technical guidance and has guidance technical published guidance technical gu Government is seeking discussions with the EU on the issue and has published technical guidance Table 2. Animal welfare and Brexit Reproduced with permission from the Brexit & Animals protection. For instance, Table 2isthat illustrates that all models permit continued participation in the PETS protection. protection. For instance, protection. For instance, Table protection. For 2scenarios. instance, illustrates Table protection. For 2y illustrates Table instance, that all 2that illustrates For models that Table instance, all 2to permit models illustrates that Table all continued models permit 2we that illustrates continued all permit participation models that continued participation permit all models in the continued participation PETS permit in the participation continued PETS in the PET pa products products and ncrease products and ncrease products and of hdeal. gher ncrease and of we h that gher fare of products we h that gher fare of products we h gher fare we products fare products and ncrease that of h gher we fare products any deal. any without This deal. would without any This mean would any without This that deal. mean would the This any UK that without mean deal. would membership the UK that This any mean membership the would deal. that of UK PETS This mean membership the UK would would of PETS membership the mean be would of UK jeopardised. PETS that membership be of the would jeopardised. PETS UK The be membership would of UK jeopardised. PETS The be jeopardised. would UK of The PETS be UK jeopardised. would The UK be jeopardised. The UK The post-Brexit model of the UK-EU relationship in some cases has little or no impact on animal The post-Brex t mode The post-Brex of the UK-EU mode re The of at the onsh post-Brex UK-EU p n some t re mode at cases onsh of the has p n UK-EU some tt e or cases re no at mpact onsh has tt p on e n an or some no ma mpact cases has on an tt ma e nformat on for consumers that sferrets ke yncrease to reduce the purchase and consumpt on of ower fare nformat nformat on for consumers nformat on for consumers on nformat that for consumers s on ke that nformat for to s consumers reduce that ke on y s to for the reduce ke consumers that purchase y s the reduce ke purchase and that y to consumpt reduce s purchase and ke y consumpt to on and reduce purchase of consumpt ower on the and of we purchase ower consumpt fare on of we and ower fare on consum we of far ow not successfully does negotiate not successfully does a withdrawal not successfully negotiate agreement a negotiate withdrawal with a the withdrawal agreement EU, the UK agreement with will the drop EU, with out the the UK the EU, will EU the drop UK out will of drop the EU out of does not does successfully not successfully negotiate does not negotiate a withdrawal successfully a withdrawal agreement negotiate agreement a with withdrawal the with EU, the the agreement UK EU, will the with drop UK will the out drop EU, of the the out EU UK of the will EU drop out of the EU awithout compulsory awithout compulsory six adoes month compulsory six a quarantine compulsory month six quarantine a month compulsory for six imported quarantine month a for compulsory six imported quarantine pet month for dogs imported pet six quarantine and for dogs month cats. imported pet and The quarantine for dogs cats. quarantine imported pet and The dogs cats. for quarantine and pet imported period The dogs cats. quarantine was The period and pet quarantine cats. dogs was period The and quarantine cats. was period The was quarantine period was perio ferrets within ferrets the within EU. It the has EU. since It has expanded since expanded to include to non-EU include nations, non-EU which nations, is which why is why UK would the UK would within ferrets the within EU. the It 2.has EU. since ferrets It has expanded since within expanded the to include EU. Itto has include non-EU since non-EU expanded nations, nations, which to include is which why non-EU the isBrexit why UK nations, would the UK which woulTo Table 2. Animal welfare Table and 2. Animal Brexit Table scenarios. welfare Animal and Reproduced Brexit welfare scenarios. and with Brexit permission Reproduced scenarios. from Reproduced with the permission Brexit & with Animals from permission the Brexit from & Animals the Brexit & Anima Table 2.[28]. Animal Table 2. welfare Animal and welfare Table Brexit and 2.scenarios. Animal Brexit welfare scenarios. Reproduced and Reproduced Brexit with scenarios. permission with permission Reproduced from the Brexit from with the & permission Animals Brexit & Animals from the & Animals on this possibility on this possibility on this possibility on [28]. this possibility [28]. on this [28]. possibility [28]. on this possibility [28]. Taskforce [11]. scheme. The Pet Travel Scheme (PETS) was introduced to permit the travel of pet dogs, cats and scheme. scheme. The Pet scheme. The Travel Pet Scheme The Travel scheme. Pet (PETS) Scheme Travel The scheme. Pet was Scheme (PETS) Travel introduced The was (PETS) Pet Scheme introduced Travel was to (PETS) permit introduced Scheme to was the permit (PETS) travel introduced to the permit of was travel pet introduced to the dogs, permit of travel pet cats dogs, the of to and pet permit travel cats dogs, and of the pet cats travel dog an The post-Brex The post-Brex t mode The post-Brex of t mode The the UK-EU post-Brex of t mode the re UK-EU at t of mode onsh the re UK-EU p of at n the onsh some UK-EU re p at cases n onsh some re has at p cases onsh n tt some e has or p cases n no some tt mpact e has or cases no on tt mpact e has an or ma no tt on e mpact an or no ma on mpact an ma on an ma The post-Brex t mode of the UK-EU re at onsh p n some cases has eUK Government Government is seeking Government is discussions seeking Government is discussions seeking Government with is seeking discussions the with EU Government is discussions on the seeking the with EU issue on the discussions is the with and seeking EU issue on the has the EU discussions and published with issue on has the the and published EU issue technical with has on and the published technical guidance issue has EU on published and technical the guidance has issue published technical guidance and has guidance technical published guidance technical gu protection. For instance, Table 2 illustrates that all models permit continued participation in the PETS protect on For nstance protect on Tab For e 2 nstance ustrates protect Tab that e on a 2 For mode ustrates nstance s perm that Tab a t cont mode e 2 nued ustrates s perm part t that c cont pat a on nued mode n the part s PETS perm c pat t on cont n nued the PET pa products and ncrease that of h gher we fare products products products and ncrease products and that ncrease and products of h ncrease that gher of and we products h that gher fare ncrease of products we h and gher fare that ncrease we products of h fare gher that products we of fare h gher products we fare products without any deal. without This would any without mean deal. that This any would deal. UK This mean membership that the mean of UK PETS that membership the would UK be membership of jeopardised. PETS would of The PETS jeopardised. would be jeopardised. The Tot without any without deal. any This deal. would without This mean would that deal. mean the This UK that would membership the UK mean membership that of PETS the UK would of PETS membership be would be ofwith jeopardised. PETS The would UK be jeopardised. UK The considered considered to cause welfare cause considered to welfare cause considered to problems welfare and cause the welfare problems considered PETS to and cause the scheme problems PETS welfare and to the a[11]. cause scheme successful and problems PETS welfare the awould scheme successful PETS reform. and problems scheme apermission the successful However, reform. PETS and apost-Brexit successful scheme However, reform. ifReproduced PETS the ajeopardised. UK successful reform. However, scheme ifUK the UK However, apost-Brexit reform. successful if the However, ifThe the reform. UK ifHowever, the UK if remain aremain member aconsidered member of to PETS under ofproblems PETS the under the post-Brexit various post-Brexit models in models Table 2. in Prior Table to 2. PETS, Prior to the PETS, UK had the had remain aremain member aany member of PETS of under PETS remain the under various aReproduced member the various post-Brexit of PETS under models the models in various Table in 2. Table Prior to 2.UK Prior PETS, models to the PETS, UK in Table had the& UK 2.tt Pri ha Table 2.various Animal Table welfare 2. Animal Table and welfare Brexit 2.the Animal scenarios. and Brexit welfare Reproduced scenarios. and Brexit Reproduced with scenarios. permission with permission from the Brexit from permission &be the Animals Brexit from & Animals the Brexit Anima Table 2. Animal Table 2. welfare Animal Table and 2. welfare Animal Brexit and scenarios. welfare Brexit and scenarios. Reproduced Brexit scenarios. with Reproduced with permission from with the permission Brexit from the & Animals Brexit from the & Animals Brexit & Animals Taskforce [11]. Taskforce [11]. Taskforce Taskforce Taskforce [11]. [11]. Taskforce [11]. ferrets within the EU. It has since expanded to include non-EU nations, which is why the UK would ferrets within ferrets the within ferrets EU. It the within has EU. ferrets since the It has within expanded EU. since ferrets It has the expanded to EU. since within include It expanded has the to since non-EU include EU. It expanded to has include nations, non-EU since to non-EU expanded which nations, include is nations, which why non-EU to include the is which why UK nations, non-EU would the is why UK which nations, would the is UK why which woul the protect on protect For nstance on protect For Tab nstance on protect For e 2 on Tab nstance ustrates For e 2 nstance Tab that ustrates e a 2 Tab mode that ustrates e a 2 s perm mode ustrates that t a s cont perm mode that nued a t s cont mode perm part nued c t s pat cont perm part on nued t c n cont pat the part on nued PETS c n pat the part on PETS c n pat the on PETS n the PETS protect on For nstance Tab e 2 ustrates that a mode s perm t cont nued pa on this possibility on this possibility on [28]. this possibility [28]. this possibility on [28]. this possibility [28]. on this [28]. possibility [28]. scheme. The Pet Travel Scheme (PETS) was introduced to permit the travel of pet dogs, cats and scheme The Pet scheme Trave Scheme The Pet (PETS) Trave scheme was Scheme ntroduced The (PETS) Pet Trave was to perm Scheme ntroduced t the (PETS) trave to perm of was pet t ntroduced the dogs trave cats of to and pet perm dogs t the cats trave an The post-Brex t mode ofis the UK-EU re onsh p nsuccessfully some has tt ep or no mpact on an ma The post-Brex The post-Brex tat mode The post-Brex of t with mode the The UK-EU t[11]. of mode the re UK-EU The of atthe tand the onsh post-Brex mode UK-EU re at n onsh some the tdrop re mode UK-EU at p cases onsh n some of the has re p at cases n UK-EU some tt onsh efor has or cases pre no n at tt some mpact eonsh has or no cases tt pon empact n an or some has no ma on mpact tt cases an etechnical or ma has no on an mpac tt wa ma e qo Government isaseeking seeking Government discussions Government seeking the discussions ispost-Brex seeking EU on discussions with issue the and EU with has on the published issue EU on and technical the has issue published guidance and has technical published guidance gu Government Government is discussions seeking discussions with is seeking the with EU discussions on the EU issue on with issue the has EU and published on has the published issue technical and technical guidance has published guidance technical guidanc not adoes successfully not does successfully negotiate not does successfully not negotiate successfully does negotiate aTaskforce not withdrawal successfully agreement does negotiate ais[11]. withdrawal not agreement awith negotiate withdrawal the agreement with EU, acats. negotiate withdrawal the agreement UK with EU, will aand the the withdrawal agreement with UK EU, will the out drop EU, UK of agreement with will the out the EU UK drop of EU, the will with out the EU drop the of UK the EU, out will EU the of drop the UK EU out will of drop the EU out of adoes compulsory compulsory six month six quarantine month quarantine for imported for imported pet dogs pet and dogs The cats. quarantine The quarantine period was period was awithdrawal compulsory aGovernment compulsory six month six quarantine month acases compulsory quarantine for imported six for month imported pet quarantine dogs pet and dogs cats. imported The cats. quarantine The pet quarantine dogs period and cats. was period The Taskforce [11]. Taskforce Taskforce Taskforce [11]. Taskforce [11]. [11]. Model of Relation with the EU27 Table 2.PETS Animal Table welfare Animal Table and 2.various welfare Animal Brexit Table and welfare scenarios. 2.ntroduced Animal Brexit Table and scenarios. Reproduced welfare Brexit 2. Animal scenarios. and Reproduced with Brexit welfare permission Reproduced scenarios. and with Brexit permission from Reproduced with scenarios. the permission Brexit from Reproduced with the &the Animals permission from Brexit the & with Animals Brexit from permission &the Animals Brexit from & Animals the Brexit &UK Anima Table 2.2. Animal welfare and Brexit scenarios. Reproduced with permission from the Brexit & Animals remain aon member of under the post-Brexit models in Table 2. Prior to PETS, the UK had Animal Welfare Issue remain aon remain member aon remain member of PETS aon member under of remain PETS the aEU of under member various PETS remain the under post-Brexit of various aewould member PETS the various under post-Brexit of models PETS post-Brexit various in under models Table post-Brexit 2. models in various Prior Table to in 2. post-Brexit PETS, models Table Prior to 2. the in Prior PETS, UK Table models had to the PETS, 2.the UK Prior in Table had the to PETS, 2. Pri ha scheme scheme The Pet scheme The Trave Pet Scheme scheme The Trave (PETS) Scheme The Trave Pet was (PETS) Scheme Trave was Scheme (PETS) ntroduced to was (PETS) perm ntroduced was to tthat the perm ntroduced trave to tude the perm of trave pet to tthe the perm dogs of trave pet tude cats the dogs of and trave pet cats dogs of and pet cats dogs and cats and scheme The Pet Trave Scheme (PETS) was ntroduced to perm t ons the trave Model of Relation with Model the of EU27 Relation Model with of Relation the EU27 with EU27 Model of Model Relation of with Relation the Model EU27 with the of Relation EU27 with EU27 ferrets the EU. Itcause has since expanded to include non-EU nations, which is why the UK wou d ferrets w th n the ferrets EU It w has th s n nce the expanded ferrets It has to s w nce th nc n expanded the non-EU EU It to has nat nc s ons nce non-EU expanded wh ch s nat why to ons nc the ude wh ch non-EU wou s why d nat the UK wh wou ch protect For nstance Tab eAnimal 2Pet ustrates that a mode s perm t cont nued part c pat on n the PETS protect protect For nstance protect For Tab nstance protect For e 2 nstance Tab ustrates on e protect For 2 Tab nstance ustrates on a 2 For mode ustrates that Tab nstance a e s 2 perm mode that ustrates Tab a t s cont mode perm e 2 that nued ustrates t s cont a perm part mode nued t that c cont pat s part perm a on nued mode c n t pat the cont part s on PETS perm nued c n pat the t part on cont PETS n c nued the pat PET on pa on this possibility on [28]. this possibility on this [28]. possibility [28]. on this possibility on this possibility [28]. [28]. this possibility [28]. withoutwithin any without any without This deal. would without any This deal. mean would any without This that deal. mean would the This any UK that without mean deal. would membership the UK that This any mean membership the would deal. that of UK PETS This mean membership the UK would of that PETS membership mean be would of UK jeopardised. PETS that membership be of the would jeopardised. PETS UK The be membership would of jeopardised. PETS The be jeopardised. would of The PETS be UK jeopardised. would The UK be jeopardised. The UK T considered considered todeal. cause to welfare problems welfare problems and the PETS and the scheme PETS a scheme successful a successful reform. However, reform. However, if the UK if the UK considered considered to cause to welfare cause welfare problems considered problems and to the cause and PETS welfare the scheme PETS problems scheme a successful and a successful the reform. PETS reform. However, scheme However, a successful if the UK if the refor UK 1 2 3 4 5 AnimalWelfare Welfare Issue Animal Welfare Animal Issue Welfare Animal Issue Welfare Issue Animal Welfare Issue Issue Taskforce Taskforce Taskforce [11]. [11]. Taskforce [11]. EU EEA CH CU DCFTA WTO Taskforce [11]. 1 with 2Brexit 1the 24UK 4the 1& 3UK 5quarantine 2from 34Brexit 5 wa 4 q 1non-EU 2Animals 32expanded 3imported 1Animals 2Animals 45d 3was 5with 4&EU27 Model of Relation Model of with Relation Model EU27 with of Relation the EU27 the Model of Model Relation of Model with Relation of EU27 with Relation the EU27 with the EU27 Table Table 2. welfare Table and Table Brexit and 2.scenarios. welfare Brexit Table and welfare scenarios. 2.ntroduced Animal Brexit Table and scenarios. Reproduced Brexit 2. with Animal scenarios. permission and Reproduced with Brexit welfare permission Reproduced scenarios. from and with the Brexit permission Brexit from Reproduced scenarios. the & permission from Reproduced with the & Animals permission from Brexit the & with Brexit permission the Brexit &period Animals the Anima ascheme compulsory six month quarantine for imported pet dogs and cats. The quarantine period was ascheme compulsory ascheme compulsory six ascheme compulsory month six quarantine ascheme month compulsory six quarantine month ascheme for compulsory six imported quarantine for imported pet six quarantine for dogs month imported pet and for dogs cats. imported pet and The dogs cats. for quarantine and The dogs cats. quarantine The period pet dogs The quarantine was period The EU EEA CH EU CU EEA EU DCFTA CH EEA CU WTO CH DCFTA CU DCFTA WTO ferrets th2. nAnimal the w ferrets EU th nAnimal It[11]. the w has ferrets EU th2.welfare s nAnimal nce It[11]. has expanded th EU sWelfare nAnimal nce the ItaTaskforce has expanded EU to sReproduced nce Itnc has ude expanded to swith nce non-EU nc expanded ude to nat non-EU nc ons ude to wh nat ude ch ons sntroduced wh nat why ch ons the s1quarantine nat wh why UK ons ch wou the s32mode wh why UK d ch wou the sto why d wou the wou dand EU EEA EU CH EEA CU CH EU DCFTA EEA CU DCFTA CH WTO CU WTO DCFTA WTO ferrets w th n the EU It has sto nce to nc ude non-EU nat ons wh chw rema nw aferrets member of PETS under the var ous post-Brex twelfare mode snegotiate Tab entroduced 2nc Pr or to PETS the UK had rema n aw member rema of PETS nAnimal ais member under the of var PETS rema ous under n post-Brex amonth member the var tpublished of mode ous post-Brex sScheme under n Tab the ewithdrawal tpublished var Pr or ous spet n post-Brex PETS Tab eof 2and the Pr tpublished UK mode or had to PETS scats nEU, Tab the eUK 2UK Pr ha The Pet Trave Scheme (PETS) was to perm tthe the trave of pet dogs cats and The Pet The Trave Pet Scheme The Trave Pet (PETS) Scheme Trave The Pet was Scheme (PETS) Trave The was (PETS) Pet Scheme Trave was to (PETS) perm ntroduced tguidance was the perm (PETS) trave ntroduced to tguidance the perm of was trave pet tfrom ntroduced to the dogs perm trave pet cats tcats. dogs the of to and pet perm trave dogs tcats. and of the pet cats trave dog an Government Government is seeking Government is discussions seeking Government is discussions seeking Government with is seeking discussions the with EU Government discussions on the seeking the EU issue on the discussions is the with and seeking EU issue on has EU discussions and published with issue on has the the and EU issue technical with has on and the published technical issue has EU on and technical the has issue published technical guidance and has guidance technical guidance technical gu does not does successfully not successfully negotiate negotiate athe withdrawal withdrawal agreement agreement with the with EU, the the UK EU, will the drop UK will out drop of the out EU of the EU Animal Welfare Animal Issue Welfare Animal Issue Welfare Issue does not does successfully not successfully negotiate does an withdrawal not successfully anon-EU withdrawal agreement negotiate agreement with a the with EU, the EU, UK agreement will the UK drop will with out drop the of the out EU the of the EU Animal Animal Issue Welfare Issue Welfare Issue 1 CU 24 DCFTA 1 CU 3 445 2 DCFTA 1 2 EU 11 3221 EU 332 EEA 3 CH 45534 WTO 5 5 4 EU EEA CH EEA CH WTO CU DCFTA WTO EEA EU CH EEA EU CU CH EEA DCFTA CU CH DCFTA CU WTO DCFTA WTO Ban live exports for fattening and slaughter Taskforce Taskforce [11]. Taskforce [11]. Taskforce [11]. Taskforce [11]. Taskforce [11].  x    for          Model     or       Tab  Ban live exports for fattening live exports and Ban slaughter for live fattening exports for and fattening slaughter and slaughter Ban exports Ban live for exports fattening for Ban fattening and live slaughter exports and slaughter slaughter considered to cause welfare problems and the PETS scheme afor successful reform. However, if the UK considered to cause to welfare cause considered to problems welfare cause welfare problems to and cause the problems and to the cause scheme and PETS the a scheme successful PETS and problems scheme a the successful reform. and aUK successful scheme the However, reform. PETS aEU27 successful reform. However, scheme ifRelation the UK However, aUK reform. successful ifswith the UK Howeve if the refor UK rema aany rema member nspossibility axany rema member of PETS nlive arema under member of PETS n[11]. athe member under of var PETS ous of under post-Brex var PETS ous the under post-Brex var twelfare the var post-Brex sfor tfattening n mode ous Tab post-Brex ePETS swelfare tand 2PETS n mode Pr Tab or eproblems sjeopardised. tEU to 2why mode nwelfare PETS Pr Tab or sRelation enon-EU to the 2nUK Tab Pr UK or ewith had to 2PETS the Pr PETS had to the PETS UK had the UK had rema nEU awould member of under the var ous post-Brex tod mode n e 2wou Pr Model of Relation of Model with the of Relation EU27 Model the of with EU27 Relation Model the with of the EU27 the EU27 Model of Relation with EU27 Table 2. Animal welfare Table and 2. Animal Brexit Table scenarios. 2. Animal and Reproduced Brexit welfare scenarios. and with Brexit permission Reproduced scenarios. from Reproduced with the permission Brexit & with Animals from permission the Brexit from & Animals the Brexit & Anima Table 2. Table 2. welfare Animal and welfare Table Brexit and 2.pet scenarios. Animal Brexit welfare scenarios. and Reproduced Brexit with permission with permission Reproduced from the Brexit from with the & permission Animals Brexit & Animals from the Brexit & Animals awithout sory month quarant ne for mported dogs and cats The quarant ne per od was aconsidered compu sory sBan aconsidered xthe compu month sory quarant smode xous ne month aconsidered compu mported quarant sory ne pet sscenarios. for dogs month mported and quarant cats pet The ne dogs quarant and mported cats ne The per pet quarant dogs was and ne cats per od The wa q ferrets th ndeal. the EU It has sAnimal nce expanded to nc ude non-EU nat ons wh ch the wou dthe ferrets w ferrets th n the w ferrets EU th n It the w has th EU ferrets sUK n nce the It has w expanded EU th sReproduced ferrets nce It n has the expanded to EU sw nce th nc It n expanded ude has the to snon-EU nc nce ude It expanded to has nat nc sPETS ude ons nce to non-EU expanded wh nat nc ch ons ude s nat wh why non-EU to ons ch nc the sjeopardised. ude wh why UK nat ch non-EU wou ons the sjeopardised. why wh d nat wou the ch ons sUK d why wh the ch oncompu thisnw possibility on this on [28]. this possibility on [28]. this possibility on [28]. this possibility [28]. on this [28]. possibility [28]. without This deal. would This mean would that mean the UK that membership the membership of PETS of be would be jeopardised. The UK The UK without without any deal. any This deal. would This without mean would that any mean the deal. that UK This membership the UK would membership mean of PETS that of the would PETS UK be membership would be of The PETS UK would The UK b Animal Welfare Animal Issue Welfare Animal Welfare Issue Animal Issue Welfare Animal Issue Welfare Issue Animal Welfare Issue Introduce method of production labelling                  Ban live exports Ban live for exports fattening Ban for live and fattening exports slaughter for and fattening slaughter and slaughter Ban live exports Ban live for exports Ban fattening live for exports fattening and slaughter for fattening and slaughter and slaughter                                   Introduce method of Introduce production method Introduce labelling of production method of labelling production labelling 1 2 1 3 2 1 2 3 1 4 3 2 4 5 1 3 4 5 2 5 3 4 5 4 Introduce Introduce method of method production Introduce of production labelling method labelling of production labelling 1 2 3 4 5 does not successfully negotiate a withdrawal agreement with the EU, the UK will drop out of the EU does not does successfully not does successfully not negotiate successfully does negotiate a not withdrawal successfully does negotiate a withdrawal not agreement successfully a negotiate withdrawal agreement with a negotiate withdrawal the agreement with EU, a the the withdrawal agreement with UK EU, will the drop EU, UK agreement with will the out the UK drop of EU, the will with out the EU drop the of UK the EU, out will EU the of drop the UK EU ou acons compu a sory compu s x a sory month compu s a x quarant sory compu month s x sory ne quarant month for s x mported ne quarant month for mported quarant ne pet for dogs ne mported pet and for dogs cats mported pet and The dogs cats quarant pet and The dogs cats ne quarant and per The cats od ne quarant was The per od quarant ne was per od ne was per od was a compu sory s x month quarant ne for mported pet dogs and cats The EU EEA EU CH EEA EU EEA CU CH EU DCFTA CH CU EEA EU DCFTA CU CH WTO EEA DCFTA CU WTO CH DCFTA WTO CU DCFTA WTO EU EEA CH CU DCFTA WTO Taskforce [11]. Taskforce [11]. Taskforce [11]. Taskforce Taskforce [11]. [11]. Taskforce [11]. dered to cause we fare prob ems and the PETS scheme a successfu reform However f the UK cons dered to cause cons we dered fare to prob cause ems we cons and fare the dered prob PETS to ems cause scheme and we the a fare successfu PETS prob scheme ems reform and a successfu the However PETS reform scheme f the UK However a successfu f the refor UK rema n a member of PETS under the var ous post-Brex t mode s n Tab e 2 Pr or to PETS the UK had remanew n adiscussions rema member n arema member of with PETS n aseeking member under of rema PETS ndiscussions the aof under member var PETS rema ous the under npost-Brex of var aModel member PETS ous the var under post-Brex tpublished of mode ous the post-Brex sEU27 var tunder n mode Tab ous the eRelation sEU27 post-Brex twith 2mode nwith var Pr Tab or ous sthe eEU27 to 2ntpost-Brex PETS mode Tab Pr eEU27 to 2the swith Pr PETS ntUK Tab mode or toethe PETS 2guidance swith UK Pr n Tab or had the topublish eEU27 UK PETS 2 Pr haqw Model of Relation Model with Relation the of Model with Relation the of Model the of with Model theor of thehad EU27 Government Government is seeking is discussions seeking with the EU on the the EU issue on the and issue has and published has technical technical guidance guidance Government Government is is seeking Government discussions with the isof with seeking on the the EU discussions issue on the and issue has and published has EU on published technical the issue technical and has Introduce farm support system to encourage      Relation    Relation       EU high             guidanc Introduce method Introduce of production method Introduce of production labelling method of labelling production labelling Introduce Introduce method of Introduce method production of method production labelling of production labelling labelling Introduce new farm Introduce support system new Introduce farm to encourage support new farm system high support to encourage system to high encourage high Introduce Introduce new farm new support farm Introduce system support to new system encourage farm to support encourage high system high to encourage Animal Welfare Animal Issue Welfare Animal Issue Welfare Animal Welfare Issue Animal Issue Welfare Animal Issue Welfare Issue                           without any deal. This would mean that the UK membership of PETS would be jeopardised. The       Ban live exports Ban live for Ban exports fattening live for exports Ban fattening and live slaughter for exports fattening and Ban slaughter for live and fattening exports slaughter for and fattening slaughter and slaughter without any without deal. without any This deal. would any without This deal. mean would This any that without mean deal. would the UK that This any mean membership the would deal. that UK This mean membership the UK would of that PETS membership the mean would of UK PETS that membership be of the would jeopardised. PETS UK be membership would of jeopardised. PETS The be jeopardised. would UK of The PETS be UK jeopardis would The b Ban live exports for fattening slaughter cons dered cons to dered cause cons to we dered cause fare cons prob to we dered cause fare ems to prob we and cause fare ems the we prob PETS and fare ems the scheme prob PETS and ems the a scheme successfu and PETS the a scheme successfu PETS reform scheme a successfu However reform a successfu However reform f the UK reform However f the UK However f the UK f the UK cons dered to cause we fare prob ems and the PETS scheme a successfu refor 1 2 1 3 2 1 3 2 1 4 2 3 1 4 5 3 2 4 5 1 3 4 5 2 5 3 4 5 4UK for  for          od    not successfu yAnimal negot ate a aon w thdrawa agreement w th the EU the UK drop out of the EU Table 2.this Animal Table 2. welfare Table and 2. welfare Animal Table Brexit and 2. scenarios. welfare Animal Brexit and scenarios. Reproduced 2. Animal Brexit and scenarios. Reproduced welfare Brexit 2. with Animal scenarios. permission and Reproduced with Brexit welfare permission Reproduced scenarios. from with the Brexit Brexit from Reproduced with scenarios. the & permission Animals Brexit from Reproduced with & Animals permission from Brexit the & with Animals Brexit from permission & the Animals Brexit from & Animals the Brexit & Anima                  not successfu ywelfare not negot ate thdrawa y negot not ate agreement successfu aand w thdrawa w y th negot the agreement EU ate a the w w UK thdrawa th w the drop EU agreement the out UK of the w w th EU drop the EU out the of the UK EU adoes sory sIntroduce x [28]. month quarant ne for mported pet and The quarant ne per od was adoes compu sory compu sTable adoes xsystem sory compu month spossibility xsuccessfu sory quarant aTable month compu sadogs xwsystem ne quarant month sory adoes for compu scats mported quarant x ne month sory ne mported pet sw quarant xpermission for dogs month mported pet ne and quarant dogs cats pet mported and The ne dogs cats for quarant and pet mported The dogs cats quarant The per and pet quarant cats ne dogs was per The and od ne quarant cats was per od The ne wa qw EU EEA EU CH EEA EU CU CH EEA EU DCFTA EEA CU CH EU DCFTA CH CU EEA WTO EU DCFTA CU CH WTO EEA DCFTA CU WTO CH DCFTA WTO CU DCFTA WTO high level of animal welfare oncompu this possibility on possibility [28]. this possibility on this [28]. [28]. on this possibility [28]. Model of Relation with Model the of EU27 Relation Model with of Relation the EU27 with the EU27 Introduce new Introduce farm support new Introduce farm system support new to farm encourage system support to high encourage system to high encourage high Model of Model Relation of with Relation the Model EU27 with the ofne Relation EU27 with the EU27 Introduce new farm Introduce new support farm new support farm to system encourage support to encourage high to encourage high high level of animal welfare level oflevel animal level welfare of animal welfare level of animal level of welfare animal welfare of animal welfare                                  Introduce Introduce method Introduce of method production of method Introduce production labelling of production method Introduce labelling of production labelling method of labelling production labelling Introduce method of production labelling Government is seeking discussions with the EU on the issue and has published technical guidance      Government Government is seeking Government is discussions seeking Government is seeking discussions with Government is discussions the seeking with EU on the discussions is the with seeking EU issue on the the EU discussions and with issue on has the the and published EU issue with has on and the published technical issue has EU on published and technical the guidance has issue published technical guidance and has guidanc technic publish does not does successfu not does successfu y negot not does successfu ate y not negot a w successfu thdrawa ate y negot a w thdrawa y ate agreement negot a w thdrawa ate agreement a w w th thdrawa the agreement w EU th the the agreement UK w EU th w the the w drop UK EU th w the out drop EU UK of w the out EU UK drop of the w out EU drop of the out EU of the EU               Animal Welfare Issue Animal Welfare Animal Issue Welfare Issue does not successfu y negot ate a w thdrawa agreement w th the EU the UK w Animal Welfare Animal Issue Welfare Issue Animal Welfare Issue Participate in PETS Taskforce Taskforce [11]. Taskforce [11]. Taskforce [11]. [11]. Taskforce [11]. Taskforce [11].                                  w thout anyto dea Th sBan wou d mean that the UK membersh p of PETS wou d be eopard sed The Ban live exports Ban live for exports fattening for Ban exports fattening and live slaughter for exports Ban fattening and live slaughter for exports fattening and Ban slaughter for live and fattening exports slaughter for and fattening slaughter and slaughter wlive thout any dea w Th thout s wou any d dea mean Th that w s wou thout the UK d any mean membersh dea that Th the s p UK wou of PETS membersh d mean wou that d p be of the eopard PETS UK membersh wou sed d The be eopard p of PETS sed wou The d b cons dered cause we fare prob ems and the PETS scheme a successfu reform However f the UK cons dered cons to dered cause cons to we dered cause fare cons to prob we cause dered fare ems we prob cons to and fare cause ems the dered prob PETS we and to ems fare the cause scheme and prob PETS we the a ems scheme fare successfu PETS and prob scheme a the successfu ems reform PETS and a successfu scheme the However reform PETS a successfu reform However scheme f the UK However a reform successfu f the UK Howeve f the refor UK 1 2 3 1 2 4 1 3 5 2 3 4 5 4 1 2 1 3 2 3 1 4 2 4 5 3 5 4 level of animal level welfare of animal level welfare ofin animal EU EEA CH CU EEA DCFTA CH CU CU WTO level of animal level of welfare animal level of welfare animal welfare EU EEA EU CH EEA CU CH EU DCFTA EEA CU CH WTO system   high   EU   EEA DCFTA  CU  DCFTA  WTO     EU     WTO WTO CH DCFTA   DCFTA  Participate in PETS Participate inParticipate PETS in welfare PETS Participate Participate insystem PETS in PETS Participate PETS Introduce Introduce new farm Introduce new support farm new system Introduce support farm to support encourage new Introduce farm to system encourage high support new to farm encourage system high support to high encourage to high encourage Introduce new farm support system to encourage high Additional veterinary requirements for dogs and on this possibility [28]. on this possibility on this possibility on [28]. this possibility on [28]. this possibility [28]. on this [28]. possibility [28]. w thout any w thout dea any w Th thout dea s wou w any Th thout d dea mean s wou any Th that d dea mean s wou the Th UK that d s mean wou membersh the UK d that mean membersh the p that of UK PETS membersh the p UK wou of PETS membersh d p be wou of eopard PETS d p be of wou sed eopard PETS d The be wou sed UK eopard d The be sed eopard UK The sed UK The UK w any dea Th snegot wou dof mean that the UK membersh p of PETS wou dEU b Reproduced the   permission                 from      EU    Introduce Introduce of Introduce method production Introduce of production labelling of method Introduce production labelling of production method Introduce labelling of production labelling method of labelling production labelling Government smethod seek ng dlive scuss ons w the EU on the ssue and has pub shed techn ca gu dance                           Government sth seek Government ng d scuss srequirements ons seek w ng Government th d the scuss EU ons on sof the w seek th ssue the EU d and scuss on has the ons pub ssue w shed th and the techn has EU on pub ca the gu shed dance ssue techn and ca has gu pub danc sh Table 2. Animal Table 2. welfare Animal and welfare Brexit and scenarios. Brexit scenarios. Reproduced with permission with from the Brexit from the & Animals Brexit & Animals does not successfu yBan negot ate amethod w thdrawa agreement w th EU the UK drop out EU      Table 2. Animal Table 2. welfare Animal and welfare Brexit Table and scenarios. Brexit Animal scenarios. Reproduced welfare Reproduced and with Brexit permission with scenarios. permission the from Brexit the & with Animals Brexit permission &EU Animals from tw does not does successfu not does successfu yrequirements not negot successfu does ate y negot anot w thdrawa successfu yin ate does negot athout w not thdrawa ate agreement y successfu a2. negot w thdrawa agreement ate w y ang th w the agreement thdrawa w EU ate th a the the w agreement w UK thdrawa EU th w the drop EU UK agreement w th w the out the UK drop of the w out the th EU drop the of UK the out w EU the of drop the UK ou            Participate in Participate PETS Participate PETS in PETS Participate Participate in PETS Participate in PETS in PETS         Reproduced                    w    Ban live exports for Ban fattening live exports and Ban slaughter for live fattening exports for and fattening slaughter and slaughter Additional veterinary Additional requirements veterinary Additional for dogs veterinary and cats requirements for dogs and for cats dogs and cats exports Ban live for exports fattening for Ban fattening and live slaughter exports and slaughter for fattening and slaughter Additional Additional veterinary veterinary requirements Additional for veterinary dogs and for dogs cats requirements and cats for dogs and cats Model of Model Relation with Relation the of EU27 with Relation the of Relation EU27 with Model of with EU27 Relation Model the EU27 of Relation EU27 with the EU27 level of animal level of welfare animal level of welfare animal level welfare of animal level welfare of animal welfare level of animal welfare cats moved via non-commercial means into UK system   techn w the   gu   gu  and    the Model  Model      with the  has  Introduce Introduce newb farm Introduce new support farm Introduce system new support farm to new system encourage Introduce support farm to system support encourage new high Introduce farm to system encourage high support new to farm encourage system high support to high encourage to high encourage high Government Government s[11]. seek Government ng s d seek Government scuss ng s ons d seek scuss w ng th s ons seek d the scuss w EU ng th d on ons the scuss the w EU th ssue ons on the the w and EU th ssue on the has the EU and pub ssue on has shed and pub techn ssue has shed and ca pub gu has shed dance pub ca techn gu shed dance ca techn dance ca dance Government s seek ng d scuss ons th the EU on the ssue pub sh Animal Welfare Animal Issue Welfare Animal Issue Welfare Animal Welfare Issue Animal Issue Welfare Animal Issue Welfare Issue Taskforce [11]. onthout thTaskforce s poss ty [28] Taskforce Taskforce [11]. [11]. Taskforce [11]. on th s poss b ty on [28] th s poss b ty [28] on th s poss b ty [28] w any dea Th s wou d mean that the UK membersh p of PETS wou d be eopard sed The UK w thout any win thout dea w any Th thout dea sIntroduce wou any w Th d dea thout mean smethod wou Th any that d w sof mean dea wou the UK d that Th any mean membersh the wou dea that UK d membersh the spEEA UK wou of that dcats mean pCH wou of UK d be of the wou eopard PETS p wou sed of eopard d4 The wou sed eopard UK p of5The PETS be sed UK eopard wou The s Additional Additional veterinary requirements veterinary Additional requirements veterinary for dogs and requirements for dogs and dogs and Additional Additional veterinary Additional veterinary requirements veterinary requirements for dogs requirements and for dogs cats and for dogs cats and cats  for    d      cats               b Introduce method of Introduce production method Introduce labelling of production method of labelling production labelling 1 thout 2into 1s 3cats 2Th 1mean 3PETS 2 1membersh 4the 2 3PETS 1membersh 4 5p 3 2 4DCFTA 5 be 1membersh 3PETS 5be 2 3d 4  5 d 4UK moved via non-commercial moved via means non-commercial moved into UK via non-commercial means UK means into UK Introduce Introduce method ofmethod production of production labelling labelling production labelling moved via moved non-commercial via non-commercial moved means into via means non-commercial UK into UK means into UK             that  UK   EU EEA EU CH EEA EU CU CH EEA EU DCFTA CU CH EU DCFTA CU EEA WTO EU CU CH WTO EEA WTO CH DCFTA WTO CU DCFTA WTO            Maintain ban on testing of cosmetics products and    Participate Participate PETS Participate in PETS in Participate PETS in Participate PETS in PETS Participate in PETS     DCFTA   Reproduced    the             CU     Brexit Animal welfare and Brexit scenarios. Reproduced with permission from the Brexit & Animals Table 2.[28] Animal Table 2. welfare Animal Table and 2.into Animal Brexit Table and welfare scenarios. 2. Animal Brexit Table and scenarios. Reproduced welfare Brexit 2.UK Animal scenarios. and Reproduced with Brexit welfare permission Reproduced scenarios. and with Brexit permission from Reproduced with scenarios. the permission Brexit from with the & Animals permission from Brexit & with Animals Brexit from permission &the Animals from &A t of animal level of welfare animal of welfare animal level of welfare animal level welfare of animal level welfare of animal welfare on thTable s poss on2.th blevel ty poss on [28] th bingredients sIntroduce ty poss on [28] th bfarm slevel poss ty b ty [28] on th shigh poss bdencourage ty [28] moved via non-commercial moved via non-commercial moved means via non-commercial into means UK into UK means into UK moved via moved non-commercial via moved non-commercial via means non-commercial means UK into means UK into Introduce new Introduce support system new Introduce farm to encourage support new farm system high support to encourage system to high encourage high Government ssIntroduce seek ng d scuss ons w th the EU on the ssue and has pub shed techn ca gu dance Maintain ban on testing Maintain of cosmetics ban Maintain on testing products ban of on and cosmetics testing of products cosmetics and products and new farm new support farm Introduce system support to new system encourage farm to support encourage high system to high Government Government s seek Government ng s d seek scuss Government ng s ons seek d scuss w ng Government th d ons s the seek scuss w EU th ng ons on the s the w scuss seek EU th ssue on the ng ons the EU d and w scuss th ssue on has the the ons and pub EU ssue w has on shed th and the pub techn has EU ssue shed on pub ca and techn the gu shed has dance ssue ca pub techn gu and shed dance ca has gu techn pub danc sh c Maintain Maintain ban on testing ban on of testing cosmetics Maintain of cosmetics products ban on testing and products of cosmetics and products and on animals and marketing ban on                                  Ban live exports Ban live for exports Ban fattening live for Ban exports fattening and live slaughter for exports Ban fattening and live slaughter for exports fattening and Ban slaughter for live and fattening exports slaughter for and fattening slaughter and slaughter Additional Additional veterinary Additional veterinary requirements Additional veterinary requirements for dogs requirements veterinary Additional and for dogs cats requirements veterinary for and dogs cats and requirements for cats dogs and for cats dogs and cats Additional veterinary requirements forin dogs and cats Model of Model Relation of with Relation the EU27 with the EU27 Model Model Relation ofRelation with EU27 Model the  EU27 of  Relation           the               with                   Participate Participate in PETS Participate PETS Participate in PETS Participate PETS in Participate PETS in2rom PETS Taskforce [11]. Taskforce Taskforce [11]. Taskforce [11]. [11]. Taskforce [11]. Taskforce [11].   marketing           of    Reproduced             Maintain ban Maintain testing ban Maintain of on cosmetics testing ban of products on cosmetics testing of products cosmetics and products and e 2 An ma we are and Brex scenar os Reproduced h perm ss on he Brex & An ma s Animal Welfare Animal Issue Welfare Issue Maintain Maintain ban on testing Maintain ban on of testing cosmetics ban on of testing products of cosmetics and products products and Tab ein 2labelling An ma we Tab are ecosmetics and 2[28] An Brex ma we scenar Tab os and Reproduced e2Brex An scenar ma w we os hon are perm Reproduced and ssBrex on rom w scenar h he perm Brex os ss5  & on An ma he swBrex h perm &An ss on ma rom s  Animal Welfare Animal Welfare Issue Issue Animal Welfare Issue                 level of animal welfare level of animal level welfare of animal welfare            rom  ingredients on animals ingredients and marketing on ingredients animals ban on and on animalanimals marketing and ban on animalban level of animal level of welfare animal welfare level of animal welfare ingredients ingredients on animals on and ingredients marketing and marketing ban on animals on animalban and on marketing animalban animalanimal-tested cosmetics from outside UK and EU on thTab s poss bmoved ty [28] on th sIntroduce poss on th banimals son ty poss on [28] th b svia poss ty on b th ty sw poss [28] on b1are th ty sand [28] poss ty             animal   1    Introduce Introduce method of Introduce method production of method production of method Introduce production labelling of production method Introduce labelling of production labelling method of labelling production labelling 1 bUK 3on 2[28] 3  4 DCFTA 4 5 WTO 2 1  CH 2 3  4DCFTA 1 WTO 4 52 WTO via moved non-commercial via moved non-commercial via means non-commercial moved into means UK non-commercial moved into means UK via non-commercial into means UK into means into UK moved via non-commercial means into UK EU EEA EU CH EEA CU CH DCFTA CU WTO EU EEA EU EEA CH CU EU DCFTA CU 3 EEA CH CU

Additional Additional veterinary Additional requirements Additional veterinary requirements for Additional veterinary dogs requirements and for dogs cats requirements veterinary Additional and for dogs cats requirements veterinary for and dogs cats and requirements for cats dogs and for cats dogs and cats Tab eorce 2 An Tab ma e veterinary 2we An Tab are ma eon and 2we An Tab Brex are ma eorce and 2on scenar we An Brex are ma os and we scenar Reproduced Brex are os and scenar Reproduced Brex w os hmarketing scenar perm w ss os h on perm Reproduced w ss h he on perm Brex rom w ss h & he on perm An Brex rom ma ssBrex & on she An Brex rom ma he & s An Brex ma s An s  Tab eoutside 2rom An ma we are and scenar os w h permsson rom    & ingredients ingredients animals on and ingredients animals marketing and on animals ban on animaland ban on animalban on animalingredients ingredients animals ingredients on and animals marketing on and animals marketing ban and on animalmarketing ban on animalban on animal           the Continued collaboration with key EU regulatory           ma of Participate in PETS Participate in Participate PETS in PETS Task 11 tested cosmetics from tested outside cosmetics UK tested and from EU cosmetics outside from UK and EU UK and EU Participate Participate in PETS in PETS Participate in PETS Task 11 Task orce 11 Task orce 11 tested cosmetics tested cosmetics from outside from tested UK outside and cosmetics EU UK and from EU outside UK and EU   Reproduced  marketing           of  Reproduced    Model of Relation with the EU27 Introduce Introduce new farm Introduce new support farm Introduce system new support farm to new system encourage Introduce support farm to system support encourage new high Introduce farm to system encourage high support new to farm encourage system high support to high encourage system to high encourage high Model of Model Relation Model Relation the of EU27 with Model EU27 Relation Model the  EU27 with of Relation EU Maintain Maintain ban on testing Maintain ban on of testing cosmetics ban Maintain on of testing cosmetics products ban Maintain of on cosmetics and testing products ban of products on and cosmetics testing and of products cosmetics and products and Maintain ban on testing of cosmetics products and ?                with  Relation the  with      Ban live exports Ban live for exports fattening for fattening and slaughter and slaughter Ban live Ban exports live for exports fattening for fattening and Ban slaughter live and exports slaughter for fattening and slaughter moved via moved non-commercial via moved non-commercial via moved means non-commercial into via means non-commercial moved UK into via means UK non-commercial moved into means UK via non-commercial into means UK into UK means into UK                                  Animal Welfare Issue Animal Welfare Animal Issue Welfare Animal Welfare Issue Animal Issue Welfare Animal Issue Welfare Issue agencies/enforcement bodies Task orce Task 11 orce Task 11 orce Task 11 orce 11 tested cosmetics tested from cosmetics outside tested from cosmetics UK outside and EU from UK and outside EU UK and EU Task orce 11 tested cosmetics tested cosmetics from tested outside cosmetics from UK outside and from EU UK outside and EU UK and EU Additional veterinary Additional requirements veterinary Additional for dogs requirements veterinary and cats requirements for dogs and for cats dogs and cats Continued collaboration Continued with key collaboration Continued EU regulatory collaboration with key EU with regulatory key EU regulatory Additional Additional veterinary veterinary requirements Additional requirements for veterinary dogs and for dogs cats requirements and cats for dogs and cats Continued Continued collaboration collaboration with Continued key EU with regulatory collaboration key EU regulatory with key EU regulatory 1are 2Brex 3 Brex 4ma 5hhe 1 2 1rom 3 2Brex 1os 2 3perm 1 4ma 3on 2 4ma 5 1& 3 Brex 4ma 52 DCFT Tab e 2 An ma we are and Brex scenar os Reproduced w h perm ss on rom he & An s Tab e 2 An Tab ma e 2 we An Tab are ma e and 2 we An Brex Tab are ma and e we scenar 2 An Brex ma Tab os and scenar Reproduced we e 2 An are os scenar and ma Reproduced w Brex we os h are perm Reproduced scenar and w ss Brex h on os perm Reproduced w scenar ss on perm rom Reproduced ss w & on he h An Brex rom ss he & s w An Brex h perm rom s he An ss on rom s & A level of animal level of welfare animal level of welfare animal level of welfare animal level welfare of animal level welfare of animal welfare                      EU EEA CH CU DCFTA WTO       ingredients ingredients on animals ingredients on and animals marketing ingredients on and animals marketing ban on and ingredients on animals marketing animalban on and on animalanimals ban marketing on animaland ban marketing on animalban on animalEU EEA EU CH EEA EU EEA CU CH EU DCFTA CH CU EEA EU DCFTA CU CH WTO EEA DCFTA CU WTO CH WTO CU ingredients on animals and marketing ban on animal                                                                 Introduce method of method production of production labelling labelling            ? ? ? Introduce Introduce method of method production of production Introduce labelling labelling method of production labelling ? ? ? Mode of Re a on w h he EU27 Mode of Re a on Mode w h he of Re EU27 a on w h Mode he EU27 of Re a on Maintain Maintain ban Introduce on testing Maintain ban on of testing cosmetics Maintain ban on of testing cosmetics products ban Maintain on of testing cosmetics and products ban Maintain of on cosmetics and testing products ban of products on and cosmetics testing and of products cosmetics and products and Continued full access toma TRACES (tracking of Continued collaboration Continued collaboration Continued with key EU collaboration with regulatory key EU with regulatory key EU regulatory Continued Continued collaboration Continued collaboration with key collaboration EU with regulatory key EU with regulatory key EU regulatory moved via non-commercial moved via means non-commercial moved into UK via non-commercial means into UK means into UK agencies/enforcement agencies/enforcement bodies agencies/enforcement bodies bodies moved via moved non-commercial via non-commercial moved means into via means non-commercial UK into UK means into UK agencies/enforcement agencies/enforcement bodies agencies/enforcement bodies bodies An ma We fare Issue An We fare Issue An ma We fare Issue An ma We fare            haIssue     on     he    Participate Participate insupport PETS Participate in PETS Participate in PETS in Participate PETS in Participate in PETS Task orce 11 tested cosmetics tested cosmetics from tested outside cosmetics from tested UK outside and from cosmetics EU UK outside tested and from EU cosmetics UK outside and EU from UK and outside EU UK EU       Task orce Task 11 orce Task 11 orce 11 Task orce 11 Task orce 11 tested cosmetics from outside UK and EU         WTO     of    Ban live for fattening and slaughter Ban live exports Ban live for Ban exports fattening live for exports Ban fattening and live slaughter for exports fattening and Ban slaughter for live and exports slaughter for fattening slaughter and slaughter     ?w   CU  DCFTA    high       ? ?Mode ? aWTO ? ?EEA Mode of Mode Re afattening on of Mode w Re haand he on of Mode EU27 w Re he of on Re EU27 w ah he EU27 h EU27 Introduce Introduce new farm new support farm system to system encourage to encourage high high Re on Introduce Introduce new farm new support farm system support Introduce to system encourage new to farm encourage high support system to encourage   PETS            CH          high CH         EU EEA CH CU DCFTA WTO ingredients ingredients onexports animals ingredients on and animals ingredients marketing on and animals marketing ban ingredients on and animals on animalmarketing ban on and ingredients on animals marketing animalban on and on animalanimals ban marketing on animaland ban marketing on animalban on animalEU EEA EU EEA CU EU CH CU shipment and use within the territory) agencies/enforcement agencies/enforcement bodies agencies/enforcement bodies bodies agencies/enforcement agencies/enforcement agencies/enforcement bodies bodies bodies           DCFTA Maintain ban on testing Maintain of cosmetics ban Maintain on testing products ban of on and cosmetics testing of products cosmetics and products and                  An ma We An fare ma Issue We An fare ma Issue We An ma fare We Issue fare Issue Continued full access Continued to TRACES full Continued (tracking access to of full TRACES shipment access (tracking to TRACES of shipment (tracking of shipment Maintain Maintain ban on testing ban on of testing cosmetics Maintain of cosmetics products ban on testing and products of cosmetics and products and An ma We fare Issue Continued Continued full access full to TRACES access Continued to (tracking TRACES full access (tracking of shipment to TRACES of shipment (tracking of shipment Additional Additional veterinary Additional veterinary requirements Additional veterinary requirements for Additional veterinary dogs requirements and for dogs cats requirements veterinary Additional and for dogs cats requirements veterinary for and dogs cats and requirements for cats dogs and for cats dogs and cats       Continued Continued collaboration Continued collaboration with collaboration Continued key EU with regulatory key collaboration Continued with EU regulatory key EU collaboration with regulatory key EU with regulatory key EU regulatory                          Introduce method of production labelling Continued collaboration with key EU regulatory Introduce Introduce method Introduce of method production of method Introduce production labelling of production method Introduce labelling of production labelling method of labelling production labelling     WTO     DCFTA  EU   WTO      level animal level of welfare animal welfare              EEA EU CH EEA EU CU EEA EU DCFTA EEA CU CH CH CU DCFTA CU WTO WTO level ofEU animal level of welfare animal welfare level animal EEA CH CU Tariff-free access for ? ? testedvecosmetics tested from tested outside cosmetics from tested UK outside cosmetics from EU tested UK outside and from cosmetics EU UK outside tested and from EU cosmetics UK outside and EU from UK and outside EU UK and EU         Ban expor sofcosmetics or aContinued en ng and sand augh er Ban ve expor sagricultural or Ban aaccess en ve ng expor and saccess swithin or augh a(tracking er en Ban ng ve and expor sCH augh sof or er en ngDCFTA and saaugh er goods  (tracking   marketing       welfare    on                 ha      a  a ? ? ?Mode ?hMode ? he ?w Mode of Re aof on w hanimalhe EU27 Mode of Mode Re of Mode Re he of on EU27 w h on he w EU27 Re aheon EU27 w of Re h a  on EU Continued full Continued access to full Continued TRACES to (tracking full TRACES of to shipment TRACES shipment (tracking of shipment Continued full access Continued full to TRACES access full to (tracking TRACES access to (tracking of TRACES shipment of shipment of shipment                          Re   of    ingredients on animals ingredients and marketing on ingredients animals ban on and on animalanimals marketing and ban on animalban on animaland use within the territory) and use within and the use territory) within the territory) ingredients ingredients on animals on and animals ingredients marketing and marketing ban on animals on animalban and on marketing animalban on and use within and use the within territory) the and territory) use the territory) moved via moved non-commercial via moved via moved means into via means non-commercial moved UK into via means UK non-commercial moved into means UK via non-commercial into means UK into UK means into UK agencies/enforcement agencies/enforcement agencies/enforcement agencies/enforcement bodies agencies/enforcement bodies bodies Introduce new farm support system to encourage high agencies/enforcement bodies Introduce Introduce new farm Introduce new support farm new system Introduce support farm to system support encourage new Introduce farm to system encourage high support new to farm encourage system high support to encourage system to high high An ma We fare Issue An ma We An fare ma Issue We An ma fare We Issue An fare ma Issue We An fare ma Issue We fare Issue   PETS encourage  ng             ahigh       er            Tar ree access obodies ve er nary med cbodies nes ?           Participate Participate insve PETS in PETS Participate Participate in PETS in PETS Participate in                Ban veContinued expor Ban sveContinued or expor Ban anon-commercial en ng or Ban expor and anon-commercial en ve sabe augh ng expor or and a er en s s or augh ng a and er en s ng augh and er s augh er Ban ve expor s or en ng and s augh   Continued collaboration collaboration with Continued key collaboration EU with regulatory collaboration Continued key EU with regulatory key collaboration Continued with EU regulatory key EU collaboration with regulatory key EU with regulatory key EU regulatory          n roduce me hod o produc on ng n roduce me hod o n roduce produc me on hod abe o ng produc n roduce on abe me hod ng o produc on abe                     EEA   ? DCFT   EU EEA CH CU DCFTA EU EEA EU CH EEA EEA CU CH CH CU CU WTO CU WTO WTO CU and use within and the use territory) within and the use territory) within the territory) and use within and use the within and territory) use the within territory) the territory)    DCFTA tested cosmetics from tested outside cosmetics UK tested and from EU cosmetics outside from UK outside EU UK and EU    EU    CH   Tariff-free access for Tariff-free agricultural access Tariff-free goods for agricultural access for agricultural goods goods ?shipment ? ?DCFTA tested cosmetics tested cosmetics from outside from tested UK outside and cosmetics EU UK and from EU outside UK and EU Tariff-free Tariff-free access for access agricultural for Tariff-free agricultural goods access goods for agricultural goods ? ? ?EEA ?? ? CH    of  and       WTO ?EU  EU  DCFTA ? and ? ? ? Maintain Maintain ban on testing Maintain ban on of testing cosmetics Maintain ban on of testing cosmetics products ban Maintain on of testing cosmetics and products ban Maintain of on cosmetics and testing products ban of products on and cosmetics testing and products cosmetics and products Continued Continued full access Continued full to TRACES access full Continued to access (tracking TRACES to full Continued TRACES (tracking of access shipment to (tracking of full TRACES shipment access of (tracking to shipment TRACES of shipment (tracking of level of animal welfare Continued full access to TRACES (tracking of shipment level of animal level of welfare animal level of welfare animal level welfare animal level welfare of animal welfare Un mpeded movemen o an ma sng be ween he EU Additional Additional veterinary veterinary requirements requirements for dogs and for dogs cats and cats Additional Additional veterinary veterinary requirements requirements Additional for dogs veterinary for and dogs cats and requirements cats for dogs and cats                            n roduce n me roduce hod o n me produc roduce hod o n me on roduce produc hod abe o me ng on produc hod abe o produc on abe on ng abe ng n roduce me hod o produc on abe ng agencies/enforcement agencies/enforcement agencies/enforcement bodies agencies/enforcement bodies agencies/enforcement bodies bodies agencies/enforcement bodies bodies n roduce new arm suppor sys em o encourage h gh n roduce new arm n suppor roduce new sys em arm o suppor encourage n roduce sys h em gh new o encourage arm suppor h gh sys em o encourage h gh                                      augh   Tariff-free access Tariff-free for agricultural Tariff-free for agricultural goods access for agricultural goods goods ? ?   ? ?  ? ?                  Ban ingredients ve expor s on or ause en ng and son augh er Tariff-free Tariff-free access for Tariff-free access agricultural for access agricultural goods for agricultural goods goods ?a ? ?? er ? ? Ban ve expor Ban sve or Ban expor aveterinary en ve saccess ng expor or Ban and ato en ssanimals ve or augh ng expor aand er en Ban sEU sng augh or ve and aexpor er sanimalen augh ng sban and or er s en ng er and s augh            Continued collaboration Continued with key collaboration Continued EU regulatory collaboration with key with regulatory key EU regulatory          Tariff-free access to veterinary Tariff-free access medicines Tariff-free veterinary access to medicines veterinary medicines ? Continued Continued collaboration collaboration with Continued key EU with regulatory collaboration key EU regulatory with key EU regulatory Tariff-free Tariff-free access to veterinary access to Tariff-free medicines access medicines to veterinary medicines ?                         ingredients on animals ingredients and animals ingredients marketing on and animals ban ingredients and animals on animalban on and ingredients on animals marketing animalban on and on animalban marketing on animaland ban marketing on on animal and within and use the within and territory) use the within territory) and the use territory) within and the use territory) within the territory) and he UK   Participate in PETS and use within the territory) Participate Participate in PETS Participate in PETS in Participate PETS in Participate in PETS  PETS  we o   h gh      ?             ?  ? moved via moved non-commercial via non-commercial means into means UK UK ? ? ?  moved via moved non-commercial via non-commercial means moved into means UK via non-commercial into means into UK n roduce n new roduce arm n new suppor roduce arm nsys new suppor roduce em arm omarketing new sys encourage suppor em arm omarketing sys suppor hinto em gh oaccess sys encourage h em gh omedicines h gh h gh no roduce new arm suppor sys em encourage Continued Continued full access Continued full TRACES access Continued full to (tracking TRACES access full Continued to access (tracking of TRACES shipment to full Continued TRACES (tracking ofme access shipment to (tracking of full TRACES shipment access of (tracking to shipment TRACES of shipment (tracking of shipment eve oto an ma we are eve oencourage an ma we eve are oencourage an ma we are eve oUK an ma are                                                 n roduce me hod o produc on abe ng Tariff-free access Tariff-free to veterinary Tariff-free to veterinary access to medicines veterinary medicines ? ? ? n roduce n me roduce hod o n roduce produc hod o me on n produc hod roduce abe ng produc on me n abe hod roduce on o ng produc abe me hod ng on o produc abe ng on abe ng Tariff-free Tariff-free access to Tariff-free veterinary access to veterinary access medicines to veterinary medicines medicines ? ? ? agencies/enforcement agencies/enforcement bodies agencies/enforcement bodies bodies Unimpeded movement Unimpeded of animals Unimpeded movement between of the movement animals EU and between of animals the between EU and the EU and agencies/enforcement agencies/enforcement bodies agencies/enforcement bodies bodies                       Unimpeded Unimpeded movement movement of animals Unimpeded of between animals movement the between EU and of the animals EU and between the EU and                                     testedMaintain cosmetics tested cosmetics from tested outside cosmetics from tested UK outside cosmetics from EU tested UK outside and from cosmetics EU UK outside tested and from EU cosmetics UK outside and from UK and outside EU UK and EU    Tariff-free Tariff-free access for Tariff-free access agricultural for access Tariff-free agricultural goods for agricultural access Tariff-free goods agricultural goods access for agricultural goods ? goods ? ?for ?products ? ? 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Tariff-free access for agricultural goods ?of ? Additional veterinary requirements for dogs and cats Additional Additional veterinary Additional veterinary requirements Additional veterinary requirements for dogs veterinary Additional and for dogs cats veterinary for and dogs cats for cats dogs and cats dogs and we      Maintain ban on testing ban on of testing cosmetics of cosmetics products and products and requirements           ?  d  Norway mode Sw ss Cus oms Un on Deep and comprehens ve ree rade agreemen Maintain Maintain ban on testing on of testing cosmetics Maintain ofeEU cosmetics products ban products on and testing and cosmetics eve o an eve ma owithin we an are eve ma oand we an eve are ma owithin an ma are we are eve oand an ma are     andarm use within use the and territory) use the within and territory) use the territory) and the use territory) within and the use territory) within the territory)          Par cand pa eUnimpeded nmovement PETS Par cmode pa eUK nban PETS Par crequirements pa n PETS Par crequirements pa e n PETS              and Wor          n roduce new suppor sys em o encourage hwe gh Unimpeded movement Unimpeded of movement animals between of movement animals the between of EU animals and between EU and the EU and n roduce n new roduce arm nUK new suppor roduce arm new sys suppor nTariff-free roduce em arm o sys suppor encourage new em nof roduce arm osys encourage h suppor em gh new othe encourage arm sys h gh suppor em oof h encourage gh sys em oh encourage gh  hgh Unimpeded Unimpeded Unimpeded movement of animals movement of between animals of the between animals EU and the between EU and the EU and Continued full access Continued to TRACES full Continued (tracking access to of full TRACES shipment access (tracking to TRACES of shipment (tracking shipment the the UK the UK Continued Continued full access full to TRACES access Continued to (tracking TRACES full access (tracking of shipment to TRACES shipment (tracking of shipment the UK the the UK                      Continued Continued collaboration Continued collaboration with Continued key collaboration EU with regulatory collaboration Continued key EU with regulatory key collaboration Continued with EU regulatory key EU collaboration with regulatory key EU with regulatory key EU regulatory     Tariff-free Tariff-free access to Tariff-free veterinary access to access veterinary Tariff-free medicines to veterinary access medicines to medicines veterinary access to medicines veterinary medicines ? ? ? ? ? moved via non-commercial means into UK Tariff-free access to veterinary medicines ? 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The UK does not lose or gain an ability to defend trade restriction based on animal welfare or to promote better welfare in partner countries based on each scenario. However, this ability might seriously decrease with the loss of the access to the EU market as leverage particularly for farm animals. This could have a very detrimental long-term impact on animal welfare in the UK . . . but it cannot be represented in the table. (p. 10) [11] Given the impact of Brexit on animal protection will be reducible to its effect on farm animals, this is a major point. Furthermore, trade deals will influence animal protection on an international basis, which means potentially impacting a far greater number of animals. Hence, access to the EU market as leverage will be critical to how Brexit impacts animal protection. The Brexit and Animals Taskforce also report how leaving the EU affects the UK’s access to key animal protection agencies. Under all scenarios aside from remaining a member state of the EU, the UK will no longer have full access to the Trade Control and Expert System (TRACES). TRACES is a system used by EU member states to monitor the movement of animals commercially into and within the union. TRACES also underpins the Tripartite Agreement regulating trade in horses between the UK, France and Ireland. The loss of TRACES may lead to a significant increase in checks at borders [11]. Increased checks take significantly more time and could lead to a substantial worsening of welfare for farm animals and equines. Finally, Peter Stevenson has published A better Brexit for farm animals: What the Government must do to protect welfare standards [12]. Stevenson is legal advisor to CIWF and has written a number of reports on UK and EU regulation, trade and related matter such as the WTO and animal protection. In his report, he lists the following as key factors that will determine how Brexit impacts animal welfare: i. ii. iii. iv. v.

Trade Agricultural subsidies Consumer support for higher welfare products based on labelling by method of production Public procurement (e.g. the National Health Service procuring high welfare food) Continuing political commitment to animal welfare

Early in his report, Stevenson summarises how the UK government’s stated political ideals may be difficult to realise in the real world: A Written Ministerial Statement refers to the Government’s ambition to “set a global gold standard for animal welfare as we leave the EU.” However, future trade deals may make these ambitions very difficult to realise in practice. (p. 6) [12] These four reports are well researched and are either informed or written by leading experts. They provide an indispensable resource on the potential impacts of Brexit on animal welfare. This paper is informed by these reports but seeks to go beyond the reports by providing a firm basis to investigate whether, all things considered, Brexit will be positive or negative for animal protection. How likely is it that the various threats and opportunities discussed in the reports cited above will materialise? This question is informed by the legal context of the EU and UK regulatory landscape, as well as the political context of Brexit. Section 6 discusses the EU and UK animal health and welfare regulatory landscape. 6. EU Animal Health and Welfare Regulation The UK as a Member State of the EU: The Status Quo and Animal Welfare The UK has been a member of the EU or its precursor the European Economic Community (EEC) and EC for around fifty years. EU and UK animal protection regulation, especially on farmed animals, has co-evolved during the last 43 years, when the first farm animal welfare regulation was passed. Around 80 per cent of UK animal protection regulation is based on EU laws [29,30]. Of the 44 EU animal welfare laws, 31 in the acquis communautaire are regulations and decisions and 13 are

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directives. The European Union (Withdrawal) Act 2018 has nationalised the great majority of this law, although there are concerns about the powers the Act gives to ministers to amend legislation where relevant to make it appropriate after Brexit [31]. As an EU member state, regulations and decisions are applicable to UK law without national implementation. For instance, Regulation (EC) No. 1/2005 on the protection of animals during transport and related operations was directly applicable. Directives are implemented by member states to satisfy the policy objectives of the EU directive. For instance Directive 2008/120/EC laying down minimum standards for the protection of pigs is transposed into English law via The Welfare of Farmed Animals (England) Regulations 2007 and The Mutilations (Permitted Procedures) (England) Regulations 2007. Since animal health and welfare policy is a devolved responsibility in the UK, similar regulations are in place in Scotland, Wales and Northern Ireland. The UK has been a beacon for animal protection in the EU, being instrumental to a progressive culture for animal welfare policy and providing the political impetus for reform. In effect, the UK has leveraged its progressive animal welfare stance to benefit a much larger community of currently 510 million people [11,32]. For instance, the UK was instrumental in lobbying for Article 13 of the Treaty of Lisbon. Article 13 recognises animals as sentient and mandates that the EU and member states must pay full regard to animal welfare in formulating and implementing policy in certain policy areas [33]. On a global basis, the EU has very high welfare standards relative to other nations. The EU has general farm animal welfare legislation for animals on farm, in transport and at slaughter. It has species-specific legislation for veal calves, pigs, broiler chickens and laying hens. In most areas of on-farm animal welfare policy, EU member states are free to implement more stringent animal welfare laws. Indeed, the UK and some other member states have on a number of occasions transposed EU directives into national laws in terms that are more stringent than those mandated by the EU. Table 3 outlines some key EU and UK animal protection regulation for the different categories of animals. Table 3. Key EU animal protection regulation. Category

EU Law

Farmed animals

Directive 98/58/EC concerns the protection of animals kept for farming purposes Regulation (EC) No. 1/2005 on the protection of animals during transport and related operations Regulation (EC) No. 1099/2009 on the protection of animals at the time of killing Directive 1999/74/EC laying down minimum standards for the protection of laying hens Directive 2007/43/EC laying down minimum rules for the protection of chickens kept for meat production Directive 2008/119/EC laying down minimum standards for the protection of calves Directive 2008/120/EC laying down minimum standards for the protection of pigs

Companion animals

Regulation (EU) No 576/2013 of the European Parliament and of the Council of 12 June 2013 on the non-commercial movement of pet animals and repealing Regulation (EC) No 998/2003

Research animals

Directive 2010/63/EU of the European Parliament and of the Council of 22 September 2010 on the protection of animals used for scientific purposes Regulation (EC) No 1907/2006 of the European Parliament and of the Council of 18 December 2006 concerning the Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH), establishing a European Chemicals Agency

Wild animals

The Convention on the Conservation of European Wildlife and Natural Habitats The Convention on the Conservation of Migratory Species of Wild Animals Council Directive 92/43/EEC of 21 May 1992 on the conservation of natural habitats and of wild fauna and flora Directive 2009/147/EC of the European Parliament and of the Council of 30 November 2009 on the conservation of wild birds Regulation (EU) No 1143/2014 of the European Parliament and of the Council of 22 October 2014 on the prevention and management of the introduction and spread of invasive alien species

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There is substantial trade in live animals and animal products between the UK and the EU. The UK is the largest export market for animal products of the EU27 (The EU27 refers to the 28 EU member states minus the UK). Similarly, the EU27 is the largest export market for animal products of the UK. The UK imports around Euros 11 billion in livestock products from the EU and exports around Euros 5.2 billion. Hence, the UK and EU27 currently have a very substantial trade relationship in animal products, with the EU27 having a significant trade surplus with the UK [32]. The EU largely prevents the importation and sale of animal products produced with lower food safety and animal welfare standards by setting high tariffs to protect its farmers and prohibiting through legislation imports of products such as beef from cattle injected by hormones that are illegal in the EU. Article 12 of Council Regulation 1099/2009 provides that imported meat products need to have been from animals slaughtered to welfare standards that are at least equivalent to those of the EU. Regulation (EC) No 1523/2007 prohibits the importation and sale of products which contain dog or cat fur. EU policy restricts the importation of certain other products: Regulation (EC) No 853/2004 of the European Parliament and of the Council of 29 April 2004 laying down specific hygiene rules for food of animal origin prohibits chlorine-washed chicken; Directive 96/22/EC as amended by Directive 2003/74/EC prohibits hormone-treated beef; and EC Directive 96/22/EC as amended by Directive 2003/74/EC prohibits ractopamine pork. These are common agricultural practices in the US, Australia and New Zealand. However, it is high tariffs that prevent the importation of most animal products. For instance, the EU has tariffs of over 40% for pig meat and 50% for sheep and dairy products. Without such high tariffs, the EU would be flooded with animal products produced with far lower animal welfare and food safety standards [30]. In other policy areas, the EU has progressive animal welfare regulation. For instance, Directive 2010/63/EU of the European Parliament and of the Council of 22 September 2010 on the protection of animals used for scientific purposes prevents duplication of animal testing. The European Union Reference Laboratory for Alternatives to Animal Testing (EURL-ECVAM) is the EU agency that helps to implement the Directive 2010/63/EU. EU law also prohibits the testing of cosmetic products or ingredients on animals, as well as banning the importation and sale of the same. 7. Brexit: The Political Context and Animal Welfare 7.1. The UK Referendum and Brexit The 2016 UK referendum on EU membership was in large part motivated by an internal Conservative Party issue. Since the 1990s, the Conservative Party has been divided on Europe, with a significant right wing Eurosceptic faction [34]. Concerned about the growth of the United Kingdom Independence Party (UKIP) and wanting to settle the Europe question, the Prime Minister David Cameron held a referendum in 2016. Boris Johnson and Michael Gove, both on the right of the Conservative Party, campaigned for Vote Leave [34,35]. Vote Leave won by 51.9% against Britain Stronger In Europe’s 48.1%. Cameron had campaigned to remain in the EU. When the result was announced, he announced his resignation and, later that year, Theresa May became Prime Minister. Despite May campaigning to remain, she appointed several right wing Eurosceptics to Cabinet to deliver Brexit. These included Boris Johnson (Foreign Office), Liam Fox (International Trade) and David Davis (Secretary for exiting the EU) [36]. Michael Gove later re-entered Cabinet as Department for Environment, Food and Rural Affairs (Defra) Secretary in 2017 [37]. Theresa May called an earlier than expected general election in 2017, with the objective of increasing her working majority of 17 seats in Parliament to give her government leverage on Brexit. Despite this aim, the Conservative Party lost 13 seats. Both the Conservatives and Labour, the two largest parties in UK politics, had manifesto pledges to leave the single market and the customs union. The Liberal Democrats and the Green Party had pledged to hold a second referendum on EU membership. At the time of writing (November 2018), Theresa May is the Prime Minister of a minority Conservative Government. The Conservative Party is supported in a confidence and supply

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arrangement by 10 Democratic Ulster Unionist (DUP) Members of Parliament (MPs). Jeremy Corbyn leads the Labour Party, which forms the Official Opposition. Corbyn’s Labour Party has effectively supported the government to deliver Brexit, though its policy is for a softer Brexit that maintains regulatory alignment with the EU to protect workers and the environment [38]. 7.2. British Politics and Animal Welfare Of the two main parties, it is the centre-left Labour Party that is generally identified with more progressive animal protection policy [39–41]. Chaney, for instance, writes: ‘The Left exhibits a greater general propensity to advance animal welfare measures, whilst the Right is more reliant on the actions of individual MPs’ [41]. In line with this, the 2000–2005 Labour Government passed the Hunting Act 2004, which effectively outlaws foxhunting. The 2005−2010 Labour Government passed the Animal Welfare Act 2006, which advanced animal welfare from an anti-cruelty to a welfare-based paradigm [42]. In 2018 the Labour Party has published a radical 50 point plan to reform animal protection across the board in the UK. The plan includes measures such as enshrining animal sentience in law, strengthening the Hunting Act, mandatory method of production labelling of meat products and ending the badger cull [43]. In contrast, the Conservative Party has a problematic relationship with animal protection policy. For instance, the Conservative leadership pledged a free vote on the fox hunting issue in the 2017 general election campaign [44]. Theresa May publicly supported a vote to repeal the Hunting Act, despite the Act being supported by a large majority of the British public [36]. Similarly, the Conservatives have maintained a strong badger culling stance under both David Cameron and Theresa May. Badgers are culled to prevent bovine tuberculosis infection in cattle, which causes economic losses to government and the farming industry. However, independent experts, such as the Independent Scientific Group, recommended against badger culling based on a decade long field trial [45]. The badger culling policy is highly contentious in the UK and the Conservative Party and the National Farmers Union (NFU) have been heavily criticised for supporting it [46]. What of the current Conservative Government, which if it remains in power will have substantial influence on animal protection policy during Brexit? In late 2017 the Conservative Party launched a pro animal welfare publicity campaign [47]. This was motivated largely by two events. First, the Conservative Party pledge in its 2017 manifesto to have a free vote on repealing the Hunting Act 2014 was widely criticised; some argued that it contributed to May losing her majority in Parliament [36]. Secondly, the Conservative Government came under intense scrutiny in the media in late 2017 for an animal welfare issue directly related to the EU. 7.3. Article 13 of the Treaty of Lisbon and UK Animal Sentience Policy In November 2017 the Conservative Government was hit by a media furore on the issue of animal sentience. The European Union (Withdrawal) Act 2018 repeals the European Communities Act 1972, which led to the UK formally joining the EC in 1973. At the same time, it nationalises EU laws onto the UK statute. EU regulations on animal welfare policy, such as on transport and slaughter, are therefore transposed into UK legislation. (EU directives were implemented onto the UK statute at the time they were passed). Article 13 of the Treaty of Lisbon recognises that animals are sentient and mandates member states to pay full regard to animal welfare when formulating and implementing policy [33]. In contrast to EU regulations, Article 13 is part of the Treaty on the Functioning of the EU (TFEU) and so would not be transposed in the European Union (Withdrawal) Bill. For this reason, Caroline Lucas, the sole Green Party MP, tabled an amendment to incorporate Article 13 to the European Union (Withdrawal) Bill during its passage through Parliament. The Conservative Party in Parliament were whipped to vote against the amendment and the government carried the vote [48]. (Government whips are party officials that enforce party discipline by providing voting instructions to Parliamentarians.)

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The Conservative Party position on the Lucas amendment caused substantial public controversy and was widely reported in the media. The government argued that Article 13 is unnecessary, since UK laws, such as the Animal Welfare Act 2006, recognise animals as sentient. However, the government’s position was roundly criticised by animal protection groups [49]. The Animal Welfare Act, for instance, is not concerned with wild animals, whereas Article 13 covers all categories of animals. Furthermore, Article 13 confers a duty on government to pay full regard to animal welfare when formulating and implementing policy. This is an important higher order protection that animal welfare laws in the UK do not prescribe [42,50]. Ultimately, the government published its own draft Animal Welfare (Sentencing and Recognition of Sentience) Bill. This, in turn, was roundly criticised, including by the Environment, Food and Rural Affairs Select Committee (EFRA Committee) for being ‘not properly thought through’ [51,52]. More importantly, the draft Bill substantially watered down obligations under Article 13. For instance, whereas Article 13 states that member states must pay ‘full regard’ to animal welfare, the draft Bill contains only ‘regard’ and in the related consultation on the Bill the government asked for input on the level of regard. Further, whereas the duty in Article 13 is conferred on the state broadly, the duty in the government bill is restricted to ‘Ministers of the Crown’ [53]. In August 2018, the government published a response to the consultation on the Animal Welfare (Sentencing and Recognition of Sentience) Bill. The government advised in its response that it will continue to consult with stakeholders on its approach to sentience and ensure that sentience is recognised after the UK leaves the EU [54]. 7.4. Spotlight on the Conservative Government and Animal Welfare The foxhunting pledge in the manifesto and the furore related to rejecting the sentience amendment meant that the Conservative government was under the spotlight. From an electoral perspective, animal protection is an increasingly salient policy issue, especially amongst younger voters [41,55]. Theresa May, as Chairwoman of the party in 2002, had spoken of the need for the Conservatives to rid themselves of the image of being the ‘nasty party’ [56]. In late 2017, the Conservative Government launched a media campaign to improve the Conservative Party image on animal welfare. Conservative MPs were called into Ten Downing Street, the Prime Minister’s office, to be briefed by her chief of staff on the party’s political narrative. There was an emphasis on the Conservatives being caring about the environment, animal welfare and social justice [47]. The Defra Secretary Michael Gove is a leading Brexiteer in government. Aside from animal experimentation and food labelling, Defra has responsibility for all animal health and welfare policy, including farm animals. As a leading Brexiteer now at the helm of the UK Government’s food and farming policy, Michael Gove has a considerable stake and influence in whether Brexit goes well for animal protection. Michael Gove is a politician that divides opinion. As Education Secretary he was a controversial figure for his policy of free schools and faced down opposition from the educational establishment [57]. At Defra, Gove has made very positive policy statements on animal protection. He has launched consultations on a raft of animal protection and environmental issues [58–60]. Indeed, he has published so many consultations at Defra that he has been dubbed the ‘Secretary of State for Consultations’ by his opposite number Sue Hayman [61]. Hayman was insinuating that Gove was launching consultations to defer genuine animal protection reforms and placate lobby groups. Nevertheless, Gove was awarded the ‘Politician of the Year’ by the RSPCA for his support for animal welfare policies [62]. The RSPCA was criticised for its award to Gove, in part related to his rolling out the controversial badger cull and in part because some simply did not trust the Defra Secretary on animal protection [63,64]. However, during 2017–2018 the Conservative Government has made some genuinely progressive animal welfare policy. After being criticised for omitting a pledge to ban the sale of ivory in the UK, Theresa May’s government has committed to passing legislation to effectively prohibit the trade. Boris Johnson, then Foreign Secretary and touted as a future leader of the Conservative Party, made preventing poaching elephants in Africa one of his key policies whilst in office [65]. The Mandatory Use of Closed Circuit Television in Slaughterhouses (England) Regulations 2018 makes

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it a legal requirement for CCTV to be used in all abattoirs in England. The passing of the law on CCTV follows a number of exposés of slaughterhouse workers abusing animals [66]. Based on the Lucy’s Law campaign [67], the government has committed to banning the commercial third-party sale of puppies and kittens in England. Those who sell puppies and kittens must now hold a licence under the Animal Welfare (Licensing of Activities Involving Animals) (England) Regulations 2018. Wookey has discussed the opportunities and threats Brexit offers for animal welfare in the UK. He argues that the potential opportunities Brexit presents should be viewed with ‘scepticism and scrutiny’ [68]. He offers three reasons for this: First, the transposition of EU animal protection law to the UK will not be simple. Secondly, he argues that the Conservative Government position on some animal welfare issues ‘undermines its credibility’ on positive policy statements it has made on Brexit and animal welfare. Thirdly, he notes that animal welfare must be balanced with other interests (p. 29) [68]. Ultimately, Wookey argues that we should scrutinise the Conservative Government’s rhetoric on animal protection and replace any ‘unearned optimism’ with a sense of ‘critical scepticism’ (p. 47) [68]. 7.5. Post-Brexit Trade Policy: Donald Trump’s Intervention At the time of writing, the UK has not completed a divorce agreement with the EU. As a member state of the EU, the UK is not able to negotiate free trade agreements with third countries until it formally leaves the EU [69]. The EU27 has held firm to this position and prevented its member states from negotiating with the UK. Despite this, informal negotiations, or at least a public conversation, have started. For instance, the US President, Donald Trump, was publicly critical of Theresa May’s Chequers agreement, her government policy on Brexit, during his 2018 visit to the UK. Trump criticised May’s plan in a much publicised tabloid newspaper interview [70]. Trump’s position was motivated in part because it would prevent the US exporting its agricultural products, such as hormone-beef, to the UK [71]. A major issue relating to post-Brexit trade policy for the UK is that US and EU agricultural policy is not aligned. EU regulation is based on higher food safety and animal welfare standards [72]. In areas of significant doubt, the EU employs the precautionary principle. Indeed, the precautionary principle is a core principle in EU environmental law, enshrined in Article 191(2) of the Treaty on the Functioning of the EU [73]. In contrast, the US is a long way behind the EU in terms of animal welfare [15]. In food safety, the US does not apply the precautionary principle and puts the burden of proof squarely on those with concerns about, for instance, hormone-treated beef. Arguably, the EU situation favours citizens, whilst the US policy favours agri-business. These differences have played out in the media particularly in the controversy over chlorine washed chicken [74,75]. However, they apply similarly to hormone treated beef, ractopamine pork and bovine somatotrophin use in dairy cattle [72]. 8. Forms of Brexit and Animal Welfare The form Brexit takes will have a substantial impact on whether threats and opportunities to animal protection materialise. This section discusses how a soft and hard Brexit might impact animal protection. A hard Brexit includes the possibility of a so-called ‘no deal’ Brexit, in which the UK and EU fail to agree on the Brexit terms. This means that trade between the UK and the EU and indeed between the UK and non-EU nations, would be on WTO terms. 8.1. A Soft Brexit A soft Brexit means that the UK remains close to the EU in regulatory terms once it leaves the EU [69,76]. For our purposes, a soft Brexit might mean that the UK remains in either the single market and/or the customs union of the EU or negotiates a Free Trade Agreement meaning the same thing, with respect to agricultural goods. If the UK were to remain a member of the EU single market, it would retain regulatory alignment in agricultural policy, as well as a number of other policy areas that affect animal protection. If the UK were to remain in the customs union of the EU, it would retain the high EU tariffs on agricultural imports [77].

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A soft Brexit therefore avoids the major risk of importing animal products that were raised and slaughtered in lower welfare standards compared to the EU/UK [10]. A soft Brexit leaves the UK to determine its own agricultural policy outside of the CAP [11]. However, continued membership of the single market would mean that the UK is not free to prohibit the live export of animals, or to ban the import and sale of goods produced in the EU such as foie gras. Table 2 in this paper highlights further policy changes based on different types of Brexit. The above point about live animal transport and foie gras, however, should be considered in context. Simply because a soft Brexit permits the UK to prohibit live animal transport and the importation of foie gras does not mean that the government will implement these policies. Indeed, there will be significant political pressures to maintain the status quo. To illustrate, despite membership of the EU and therefore the single market precluding the prohibition of the importation of foie gras, nations that export the product, such as France, might challenge any UK prohibition at the WTO. The WTO is discussed in a later section. 8.2. A Hard Brexit A hard Brexit means that the UK does not remain close to the EU in policy terms after leaving it [69,76]. For our purposes, a hard Brexit means that the UK leaves the single market and customs union of the EU. This means that the UK does not maintain regulatory alignment with the EU in agricultural and other policy areas. It also means that the UK is free to set its own rates on tariffs for imported goods, including animal products. Like a soft Brexit, a hard Brexit also means that the UK can determine its own agricultural policy outside of the CAP [11]. At least in relation to being outside of the single market, it is not prevented from prohibiting the export of live animals and the prohibition of foie gras, although such a stance might be challenged at the WTO. A hard Brexit means that the UK is not a member of the customs union and can set its own tariffs. A hard Brexit is supported by many on the right of the Conservative Party in government because this enables the UK to set its own trade policy. However, given that high EU tariffs prevent the importation of goods produced to low welfare standards, a hard Brexit means there is a major risk of importing such goods and a race to the bottom in animal welfare [10–12]. 8.3. Free Trade Agreements and WTO Rules Post-Brexit, the UK government will aim to negotiate free trade deals with the EU and non-EU nations and trade blocs. The Department of Trade, led by the Atlanticist Liam Fox, has already launched consultations on free trade deals with the US, Australia and New Zealand [78]. Under free trade agreements, governments negotiate terms of the overall deal, including those related to animal welfare. Outside such bilateral and multilateral free trade agreements, nations that are members of the WTO are bound by its rules. The WTO is an intergovernmental organisational that exists to provide a framework for international trade and includes a dispute resolution system [79]. The WTO promotes free trade and its rules are concerned with preventing governments making policy to protect their own national industries at the expense of others. The UK has more progressive animal protection laws compared to most of the rest of the world. The more stringent regulation generally means it costs more for British farmers to produce meat and dairy products compared to international competitors with lower standards. For this reason, it is rational for the UK government to argue that animal welfare is a legitimate reason to restrict the importation of products produced to lower animal welfare standards. For instance, the UK government might insist that imports meet UK animal welfare standards, or it might erect protective tariffs for imports that do not [12]. If the UK does not do this, British farmers will be at a competitive disadvantage and may ultimately go out of business. However, whether the WTO will view animal welfare as a legitimate reason to restrict trade is open to dispute. There is case law that does support animal welfare being considered as a legitimate reason to restrict imports [80]. These include the US-shrimp case, where the WTO Appellate Body ruled

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that it was permissible to condition market access based on methods with comparable effectiveness under WTO Article XX. Similarly, in the EC-Seal Products case, the Appellate Body of the WTO ruled that animal welfare is a legitimate issue of public morality in the EU [1]. Despite these cases, arguably there remains considerable uncertainty about how the WTO will rule on challenges to protection based on animal welfare. 9. Animal Protection Policy Making Inside and Outside of a Political Union Given the UK’s decision to leave the EU, this paper has had three broad aims: (i) to provide a framework to investigate whether, all things considered, Brexit will be a net positive or negative for animal protection; (ii) to discuss the legal context of animal protection in the UK as a member state of the EU; and (iii) to discuss the political context of Brexit, which is key to investigating whether potential threats and opportunities related to Brexit and animal protection are likely to materialise. Brexit is a major political event and the UK’s departure from the EU has the potential to have substantial and longstanding implications for animal protection. This is the case particularly because the UK is a relatively large nation in terms of population size and is an economically and politically powerful state. Furthermore, the UK has been a global leader in the area of animal protection, which is the object of our concern. As a political event per se, Brexit therefore has enormous implications for animal protection. However, the EU-UK relationship and Brexit might serve as a useful case study to illustrate broader principles about animal protection policy making in a supranational body such as the EU versus that outside such a body. Indeed, the same or similar principles might apply to policy making in a federation of states, such as the US or Australia, compared to a non-federal state outside any supranational body, such as the UK post-Brexit. As a member state of the EU, animal protection policy from the UK perspective is characterised by three considerations. First, as a powerful member state, the UK has leveraged its progressive animal protection stance to have a greater impact than it could otherwise have outside of the EU. The UK, with a human population of 67 million people, has positively influenced animal protection policy in the much larger EU of 510 million people. In effect the UK has leveraged its membership of the EU to impact animal welfare on a market seven to eight times the size of the UK itself. Indeed, the positive impact of the UK within the EU does not end there. The EU has itself used its status as the largest economic bloc in the world to influence animal protection internationally. Thus, as a member state of the EU, the UK has been able to multiply its progressive stance on animal protection to have a far greater impact than it could have achieved outside of the union. Secondly, as a member state of the EU, the UK has in some cases been hampered in its more progressive stance on animal protection. The EU is composed of 28 member states that are involved in policy making in the various EU institutions. Whether voting is by qualified majority or by unanimity, less progressive EU members can hamper progressive reforms. This can leave some nations frustrated at either not being able to implement progressive reforms or being at a competitive disadvantage if they do so. In the EU, the member states in the north of Europe and in particular the UK, Sweden, Denmark and the Netherlands tend to be more progressive on animal protection. These nations sometimes implement EU directives earlier and/or with more stringent conditions compared to other EU member states. Thirdly, the EU is a single market without borders for goods, people, services and capital. The rationale is to improve economic performance within the bloc by reducing barriers to trade. However, the single market also means that the UK as a member of the EU cannot restrict the importation of goods from the EU27 even in areas where it has higher standards of animal protection. For instance, the UK has effectively prohibited the production of foie gras on welfare grounds. Despite this, the UK is unable to prevent the importation and sale of foie gras from France and other EU nations, because of the single market. We can call these three considerations first the leverage, secondly the inertia and thirdly the single market principles. The leverage and the inertia principle appear to be universal principles, in that

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they apply to any supranational body or federal nation that pool sovereignty to make common laws for economic and other advantages. In any supranational body or federal nation, the principle of leverage can be used either to reform or obstruct animal protection. The UK has used its membership of the EU to reform animal protection based on its progressive stance. However, a conservative or regressive nation or member, if sufficiently powerful, could employ the same leverage principle to obstruct such reforms. In contrast to the leverage principle, the inertia principle will, however, act to obstruct potential reforms that more progressive members lobby to have implemented. The single market principle does not appear to be universal. The single market is a key element of the EU, which considers the free movement of goods, capital, services and labour as sacrosanct. Despite this, the free movement of goods, for example agricultural products, is not a necessary condition for a supranational body, including a federation. For instance, in 2018 the US state of California has effectively prohibited the production and the importation of eggs produced in battery cages. California Proposition 12, the Farm Animal Confinement Initiative, establishes minimum space requirements for egg-laying hens. It also prohibits the importation of eggs into California produced from hens raised in confined conditions. The prohibition of the importation of eggs includes those produced in the other 49 states in the US. Proposition 12 also establishes minimum space requirements for calves raised for veal and breeding pigs [81]. These considerations about principles of policy making on animal protection both within supranational bodies and outside of them are key factors to consider when investigating whether Brexit is, all things considered, a net positive or negative for animal protection. The considerations also, however, have far wider relevance, in that they may be applicable in a broader sense outside of the EU-UK and Brexit context. 10. Conclusions Brexit represents a major political upheaval for UK governance. It has the potential to have substantial impacts on animal protection policy not only in the UK but also in the EU and internationally. This paper has reviewed the relation between animal protection regulation in the EU and UK. A number of informed reports have been published on the threats and opportunities that Brexit presents. Whether these threats and opportunities materialise is dependent on a range of political factors. The paper therefore reviewed the political context of Brexit with a view to further research on whether the various threats and opportunities are likely to materialise. The UK has been a member of the EU since 1993 and before that a member of the EC since 1973. Around 80 per cent of UK animal protection regulation is based on EU law. The European Union (Withdrawal) Act 2018 has nationalised the great majority of this law, although there are concerns about the powers the Act gives to ministers to amend legislation where relevant to make it appropriate after Brexit. Article 13 of the Treaty of Lisbon recognises animals as sentient beings and confers a duty on the EU and member states to pay full regard to animal welfare when formulating and implementing policy. Article 13 is part of the Treaty on the Functioning of the EU (TFEU) and therefore has not been carried over to UK law in the European Union (Withdrawal) Act 2018. The UK referendum on EU membership was motivated by the Eurosceptic right wing of the Conservative Party and the rise of the UK Independence Party (UKIP). Since the referendum, Theresa May, who replaced David Cameron as Prime Minister, has appointed a number of right wing Eurosceptics to Cabinet to deliver Brexit. Key figures in the UK Government that will influence the impact of Brexit on animal protection are Theresa May, the Prime Minister, Michael Gove, the Defra Secretary and Liam Fox, the International Trade Secretary. The Conservative Government has made official policy statements to maintain and enhance animal protection after Brexit. However, the Conservative Party has a problematic relationship with animal protection. For instance, it faced a media furore after voting against a Green Party amendment to include Article 13 in the European Union (Withdrawal) Bill. Ultimately, the Government was forced to publish its own Bill, which contained a watered down version of Article 13. Similarly, the Conservative leadership

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faced widespread criticism over its decision to pledge a free vote on foxhunting in its 2017 general election manifesto. The Conservative Party has responded with a communications campaign to improve its image on animal welfare. The Government has published a number of consultations on animal protection issues. The impact of Brexit on animal protection will be determined by its impact on farm animals. This is because of the far larger numbers of farm animals and also the reality that Brexit is more likely to impact animals used in agriculture more than experimental, wild and companion animals. Furthermore, the impact of Brexit on animal protection may be determined by its impact on animals in the EU and internationally. This is because there are far larger numbers of animals in the EU and internationally compared to the UK. For instance, whilst around 1 billion farm animals are raised and slaughtered in the UK annually, the figure for the EU is 4.7 billion and for the US 10 billion. A major threat of Brexit is the importation of lower animal welfare products, for instance from the US, after the UK leaves the EU. A major opportunity that Brexit presents is the potential for major reform of UK agricultural policy based on a subsidy system focused on rewarding animal welfare as a public good. Softer forms of Brexit, in which the UK remains in the single market and/or the customs union of the EU or their equivalents, mitigate this major threat. A soft Brexit, with respect to agriculture, makes it very unlikely that the UK will import lower welfare animal products. Theresa May’s Chequers agreement, which established the policy of the UK Government on Brexit in June 2018, is effectively a soft Brexit for agriculture and therefore effectively for animal protection. Trade in goods, including agricultural goods, would be governed according to a ‘common rule book.’ This effectively would mean a continuation of the single market for agriculture. The potential for Brexit having an international impact on animal welfare was demonstrated during the visit of the US President, Donald Trump, to the UK. Trump was publicly critical of May’s Chequers agreement soft Brexit. The US is a major exporter of agricultural products such as beef. Based on trade considerations, a hard Brexit is far more favourable to Trump and the US, than a soft Brexit where the UK continues regulatory alignment with the EU. Brexit is highly unstable and its impacts on animal protection are uncertain. This paper has provided an overview of the EU and UK regulatory relationship on animal protection to provide a baseline of the status quo. Whether the various threats and opportunities that Brexit presents will materialise depends on a range of political factors. This paper has discussed the political context of Brexit to inform that issue, which has the potential to affect the welfare of billions of animals in the UK, the EU and internationally. Further research is needed to assess if the major threats and opportunities related to Brexit are likely to materialise. Funding: This research received no external funding. Acknowledgments: The author would like to thank David Bowles, Paula Sparks and a third unnamed person for invaluable discussions about Brexit and animal protection and for very useful comments on the manuscript. The author would also like to thank three anonymous reviewers and the editorial team at Animals for very useful comments on the manuscript. Conflicts of Interest: The author declares no conflict of interest.

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