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In December 2023, the European Commission published its proposal for a new EU regulation on the protection of animals during transport, updating the 20-year-old regulation currently in place. For the first time, this proposal includes specific requirements to protect fish and other aquatic animals during transport. Compassion in World Farming supports this regulation and issues recommendations for the welfare of aquatic animals in the revision of the EU Animal Transport Regulation.
Introduction
Up to 1.1 billion fish and 230 million crustaceans are farmed for food in the European Union (EU) each year(1). The vast majority of these animals are transported at least once during their lifetimes, whether to nurseries, grow-out facilities, slaughterhouses, or to markets where they may even be sold live. Additionally, many wild-caught aquatic animals are transported live throughout the EU, for trade (particularly decapod crustaceans) or to supply capture-based aquaculture (e.g. European eels, Bluefin tuna). This means that the welfare of up to 1.3 billion aquatic animals is impacted by transport annually within the EU. Given the substantial scientific evidence that aquatic animals (e.g. fish(2) , cephalopods(3) and decapod crustaceans(3)) are sentient beings, it is crucial that their welfare is protected. Indeed, this is supported by 91% of EU citizens who believe that fish welfare should be protected to the same, or greater, extent than the welfare of other animals we eat(4).
Transport is a significant risk to the welfare of aquatic animals because it involves a succession of stressors over extended periods of time (hours or days), such as handling, netting, pumping, crowding, environmental changes, and compromised water quality. The severity of these stressful procedures will determine their impact on welfare, and the risk of illness and death, both during transportation and over the following days/weeks. Aquatic animals should not be transported live if possible and should instead be humanely slaughtered on farm. However, when live transport is unavoidable, clear requirements should be followed to ensure that aquatic animals are able to cope with the challenges of transport and maintain good welfare.
Improving animal welfare during transport
Welfare issue
Transport is stressful, and sick animals are likely to be even more welfare-compromised by these events than healthy individuals.
Recommendation
Animals should be assessed for fitness to travel by a veterinarian. Only healthy animals that can cope with the transport process should be moved. Moribund or sick individuals should be euthanised or treated promptly.
Welfare issue
Aquatic animals are transported by various means (e.g. trucks, cars, vessels, aircrafts) and held in different containers (e.g. boxes, bags, or tanks). Inadequate or poorly designed transport systems can compromise welfare by failing to maintain appropriate environmental conditions (e.g. water quality and temperature) and by increasing the risk of physical damage during transport.
Recommendation
Aquatic animals are transported by various means (e.g. trucks, cars, vessels, aircrafts) and held in different containers (e.g. boxes, bags, or tanks). Inadequate or poorly designed transport systems can compromise welfare by failing to maintain appropriate environmental conditions (e.g. water quality and temperature) and by increasing the risk of physical damage during transport.
Welfare issues
Farmed aquatic animals are usually deprived of food for some time before transport to reduce metabolic activity and clear the gut (i.e. to reduce water quality issues). However, welfare will be impaired if fasting periods are long enough to cause hunger, distress and malnourishment.
Recommendation
Minimal fasting periods can benefit welfare by reducing the negative impacts of water fouling. However, fasting should be kept as short as possible, being no longer than is required for gut clearance according to the species and temperature.
Welfare Issues
Animals are moved from their rearing environment into containers and loaded into vehicles for transport. Following transport, they are then unloaded into new tanks etc. This typically involves crowding, netting, taking animals out of water and physical handling, all of which are inherently stressful and can lead to physical injuries and death when performed incorrectly.
Recommendation
Handling procedures should be performed in ways to minimise stress and injury, e.g. time and severity of crowding should be minimised. Ideally, aquatic animals should be handled without being taken out of water (e.g. using pumps to move fish). Otherwise, this should be done gently, in the shortest time possible, and all equipment in direct contact with the animals should be moistened. When handled, the body of the animals should be adequately supported; they should not be lifted by individual body parts (e.g. gill covers). When unloading, animals should be allowed to acclimatise to new conditions. In some cases, anaesthetics can be used to reduce stress responses.
Welfare issues
Water quality is crucial for the welfare of aquatic animals, as it encompasses animals’ physical and chemical environment. This comprises a complex set of interacting factors (e.g. oxygen levels, pH, salinity and temperature), and each species has specific requirements and broader tolerances that can vary with age and health status. The rate at which these parameters change is also important, as sudden variations can lead to stress or even death.
Recommendation
Aquatic animals should be transported in water of suitable quality according to species-specific welfare needs for water parameters (oxygen, pH, nitrates, nitrites, temperature, salinity) throughout the entire journey. Continuous remote monitoring of oxygen and temperature is essential for all transport vessels and measuring instruments must be accurate and calibrated before each journey. Transport systems should be capable of responding to water quality deviations to maintain good welfare.
Welfare issues
Stocking densities during transport greatly influence water quality. High densities can lead to rapid accumulation of metabolic wastes and reduced dissolved oxygen, compromising welfare. Overcrowding may also cause stress and injuries due to limited space and increased aggression, heightening the risk of infectious diseases and pathogen transmission.
Recommendation
Animals should be transported at stocking densities low enough to ensure that good water quality can be maintained and with limited social stress. Containers should be appropriate for transporting at these densities.
Welfare issues
Animal welfare is greatly impacted by stockmanship and management. Poor understanding of causes and prevention of stress for aquatic animals can severely decrease their welfare.
Recommendation
Staff involved in the transport of aquatic animals should receive comprehensive training to ensure that all activities (e.g. handling, monitoring, etc.) are carried out in ways to minimise stress, and to allow staff to adapt handling techniques to suit the species and/or individuals being transported.
Welfare issues
Issues can arise during transport that may impair welfare or even lead to the death of aquatic animals (e.g. delays meaning animals are kept in containers for longer than expected, leading to greater water deterioration.)
Recommendations
Transport system design should allow for welfare assessments and inspection of animals during transport, predominantly via remote observations and automatic measures (as manual inspections can cause stress). There should be contingency plans to ensure good welfare conditions can be maintained for longer, in case of delays.
Welfare Issues
The stress of transport may affect individuals’ physiology, stress responses and appetite before, during and after transportation.
Recommendation
Welfare status of transported animals should be monitored and recorded throughout the journey; operators should maintain detailed records of mortality, injuries, abnormal clinical signs, etc. Records should be used as feedback to improve management practices and welfare standards by transporters and competent authorities. There should be strict limits on mortality thresholds.
Recommendations for the revision of the EU Animal Transport Regulation
Regulation (EC) No 1/2005(5) on the protection of animals during transport covers all vertebrates, including aquatic vertebrates such as fish, but does not include specific provisions to ensure the welfare of fish and other aquatic animals. Compassion in World Farming (CIWF) welcomes the inclusion of specific provisions on the welfare of fish and other aquatic animals in the Commission’s proposal(6). Although the proposal sets out requirements for key areas of transport, there are some exclusions that leave a significant number of animals without legal protection, and more detail is needed to ensure the legislation is effective.
1. Include direct deliveries to food businesses supplying the final consumer
In Article 2 of the proposal, the Commission foresees a derogation from the whole Regulation for the direct deliveries of aquatic animals to food businesses supplying the final consumer. This exemption would apply, for example, to fish or crustaceans that are often sold live in EU restaurants, markets or supermarkets leaving huge numbers of animals unprotected during transport. For instance, only 14.7% of common carp farmed in Czechia (the second biggest producer of carp in the EU) are killed in slaughterhouses(7) . This derogation would mean that the welfare of up to 4.83 million carp sold live at Czech markets annually(8) may not be covered during transport. Additionally, up to 8.64 million carp are exported live out of Czechia(8). These fish could also be sold live in other Member States through direct delivery, thus bypassing the requirements of the animal transport Regulation. The welfare needs of aquatic animals are the same regardless of their destination, and EU legislation should protect them. The exclusion of these transport journeys cannot be justified.
2. Provide more detailed requirements
Though the proposal sets out requirements for the key areas of transport, many of these measures are not detailed. For example, allowable stocking densities, water quality parameters and fasting periods are not specified, leaving significant gaps in how these requirements should be applied in practice. More detail should be added to the requirements based on the latest scientific understanding and best practices. If sufficient scientific advice is not available at the time of adopting the regulation, species-specific detailed requirements should be introduced by the Commission via delegated acts as soon as it is available.
3. Include CITES listed species and ornamental aquatic animals
Article 2 of the proposal states that the Regulation shall not apply to the transport of protected species, under the Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES). However, the welfare of these animals is inherently important and is particularly so due to their protected/conservation status. Although the CITES provides transport guidelines (e.g., guidelines for non-air transport(9)), they are not sufficiently detailed or legally enforceable. Further, some of these species are also transported in relation to farming in the EU. For example, up to 32 million European eels(10) (an endangered species) are caught from the wild and transported to farms for ongrowing in the EU annually. Therefore, their welfare should be protected as with other animals transported in connection with an economic activity. Similarly, ornamental species have also been excluded from this Regulation but there is no scientific basis for this exemption. Indeed, scientific reports indicate mortality rates of up to 73%(11) during ornamental fish transport, indicating that welfare improvements are urgently needed. To ensure comprehensive welfare protection of aquatic animals during live transport, the exemption for both CITES-listed and ornamental species in Article 2 should be removed, bringing these animals within the scope of the Regulation.
4. Include short transport distances
It is proposed that the specific requirements for the transport of aquatic animals will not cover short-distance transport (e.g., when farmers use their own vehicles for journeys up to 50 km). However, many farms have multiple facilities separated by relatively short distances (e.g., hatcheries and grow-out tanks), which still involve logistical steps for transport, such as loading, unloading, and handling, that can cause significant stress to aquatic animals, especially juveniles. If these short-distance journeys remain outside the scope of the Regulation, a future law on the welfare of farmed aquatic animals will need to address this gap.
References
1. From fishcount.org.uk. Estimate based on FAO data for 2022, according to method of Mood, A., Lara, E., Boyland, N. K., & Brooke, P. (2023). Estimating global numbers of farmed fishes killed for food annually from 1990 to 2019. Animal Welfare, 32, e12. doi:10.1017/awf.2023.4
2. Boyland. N.K (2019). Why fish welfare matters: the evidence for fish sentience. Compassion in World Farming.
3. Birch et. al. (2021). Review of the Evidence of Sentience in Cephalopod Molluscs and Decapod Crustaceans. LSE.
4. Sapience (2024). Public Attitudes Towards Aquatic Animal Welfare.
5. Council Regulation (EC) No 1/2005 of 22 December 2004 on the protection of animals during transport and related operations and amending Directives 64/432/EEC and 93/119/EC and Regulation (EC) No 1255/97 OJ L3 5.1.2005, p. 1–44
6. Proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL on the protection of animals during transport and related operations, amending Council Regulation (EC) No 1255/97 and repealing Council Regulation (EC) No 1/2005
7. Czech Ministry of Agriculture (2024). Situační a výhledová zpráva: Ryby 2023.
8. Estimate based on Czech Ministry of Agriculture data for 2022, according to method of Mood, A., Lara, E., Boyland, N. K., & Brooke, P. (2023). Estimating global numbers of farmed fishes killed for food annually from 1990 to 2019. Animal Welfare, 32, e12. doi:10.1017/awf.2023.4
9. CITES (2022). CITES Guidelines for the Non-Air Transport of Live Wild Animals and Plants.
10. From fishcount.org.uk. Estimate based on FAO data for 2022, according to method of Mood, A., Lara, E.,Boyland, N. K., & Brooke, P. (2023). Estimating global numbers of farmed fishes killed for food annually from 1990 to 2019. Animal Welfare, 32, e12. doi:10.1017/awf.2023.4
11. Stevens, C. H., Croft, D. P., Paull, G. C., & Tyler, C. R. (2017). Stress and welfare in ornamental fishes: what can be learned from aquaculture? Journal of fish biology, 91(2), 409-428.
