Improvements to equine identification and traceability in England: consultation results and government response

Question 1

Part 1 – Introduction

Accepted Answer

The purpose of this consultation was to seek views on the UK government’s proposals for improving equine identification and traceability in England.

Context

The existing equine identification system in England was developed in line with EU regulations. It is based on the requirement for paper documents (equine passports) and underpinned by a Central Equine Database of all equines recorded as resident in England. It was designed to support the EU-led priority of protecting public health, through maintaining the integrity of the human food chain.

However, while this remains a priority here, the UK government also needs the system to support the safeguarding of both equine health and welfare. Since it was not built with these functions in mind, it does not support them as well as it could.

It focuses on the owner and their responsibilities, rather than the location of the animal and those who are responsible for it on a day-to-day basis. This means we have limited knowledge of where equines are kept. As well as the welfare issues this creates, poor traceability poses a risk in terms of potential disease spread in an outbreak situation.

The UK’s departure from the EU has provided the opportunity to review the equine identification system and ensure that it supports all 3 of the government’s priorities effectively.

The review began with targeted engagement with a number of stakeholders to understand the shortcomings of the existing system and how it might be improved. This helped shape the proposals contained in the consultation.

Scope

The proposals relate to England only. We will also consider responses to the consultation with Scottish and Welsh Governments and the Northern Ireland Executive, to assess any impact on the UK internal market, and to ensure that any changes ultimately introduced, do not impede the movement of equines across national boundaries, and contribute towards a more robust and effective traceability system across the entire UK.

Responding to the consultation

This consultation opened on 5 April 2022 for a 12-week period and closed on 28 June 2022.

394 individuals and organisations responded to the consultation, almost all of which used Citizen Space Defra’s online consultation tool. A number of responses were also submitted by email, which have been included in this analysis.

The consultation launch was communicated within Defra-industry engagement sessions, articles in Horse & Hound magazine, the British Horse Society’s members’ newsletter and the World Horse Welfare newsletter.

It was also announced at the National Equine Forum in March 2022. An email with a link to the consultation was circulated to all key equestrian stakeholders.

Audience

A wide range of stakeholders responded to the consultation these included:

animal welfare organisations
breeders and studs
equestrian centres, riding schools, livery yards and training yards
horseracing interests
local authorities, trading standards and government departments
passport issuing organisations (PIOs)
private individuals and horse owners
professional riders
semi-wild equine interests
show, competition and race organisations
breed societies
traders and trade bodies
transport companies
the veterinary profession

A list of respondents that did not wish to remain anonymous can be found in Annex 1 to this report.

Of the responses received:

52% were from industry
48% private individuals and horse owners

Figure 1: A breakdown of the type of respondents

The responses came from different stakeholder groups, including:

7% from the veterinary profession
6% from studs and breeders
7% from welfare organisations
13% from PIOs and breed societies
4% from equine establishments (includes riding schools, livery yards and training yards)
2% from equine industry bodies
48% from private individuals and horse owners
13% from other stakeholder groups (includes equine businesses outside of those stated above, for example, professional riders, freelance coaches and trainers, transporters, local authorities, trading standards and other government departments

The British Horse Council submitted a response (included under ‘industry bodies’), which incorporated responses from a survey of horse owners they carried out alongside the consultation, which recieved 3,424 responses.

Question 2

Part 2 – consultation results and the government response

Accepted Answer

Proposals

See the consultation document Consultation on Improvements to Equine Identification and Traceability in England for the detail and context behind each proposal.

Central Equine Database (CED)

To what extent do you agree or disagree that owners or keepers should be able to update all identification records on the CED (not just microchip, food chain status and deaths), digitally (and to submit supporting documentation in the same way)?

Percentage of respondents for each answer option provided:

Response	Percentage of responses
strongly agree	42.64%
somewhat agree	22.84%
neither agree nor disagree	10.15%
somewhat disagree	4.57%
strongly disagree	16.24%
not answered	3.55%

Lead responses for stakeholder groups:

65.48% of respondents responded strongly agree and somewhat agree. This was the lead response for the following groups:
- breeders and studs
- equine vets
- horse owners
- industry bodies
- local authorities
- other
- other equine industry
- welfare organisations
13.71% of respondents responded neutrally. This was the lead response for for the following groups:
- PIOs – non-studbook
20.81% of respondents responded either strongly disagree or somewhat disagree. This was the lead response for for the following groups:
- breed societies

The aim of this question was to establish how stakeholders felt about having the option to update their equine’s data digitally on the CED, and submit supporting documents electronically, for example, through a smartcard or smartphone app. This would be in addition to retaining the option to update via the Passport Issuing Organisation (PIO) as they do now.

The consultation response revealed strong support for this proposal. Many respondents, including PIOs, equine vets, industry bodies and horse owners commented that this would be a welcome improvement to the current outdated, slow system.

Conversely, a number of PIOs felt that this move would undermine their role and would wish to keep the current system or felt it essential to retain the ability to check or approve changes before they are finalised. Some respondents expressed concern in relation to fraud and abuse of the system, whereby owners or dealers could, for example, falsify the age of their horse for re-sale value purposes.

Digital access was also frequently raised by respondents in terms of both internet access and computer literacy.

Respondents said:

“In order to give CED the best chance of containing up to date information, there needs to be a frictionless approach to updating equine ID and notifying changes of ownership, using the principle of digital by default. It should be possible for the operator to notify and confirm all changes (including any required intermediate checks) using secure digital technology. Digital technology should have offline access (a very big concern of BHC survey respondents), be fully optimised for mobile, accessible by desktop and at low or no cost. It has been estimated that between 50%-90% of the data held on CED is inaccurate, despite the legislation (SI 761/2018) having been in place since 2018.” – The British Horse Council (BHC)
“It is the effort and cost involved each time changes are made and then the passport needs to be sent recorded mail and you wait for it to be returned. I can honestly say that I have never bought a horse and found the passport to have been updated as to ownership-probably for those reasons.” – A horse owner
“The studbook PIO’s need to verify that information before it is uploaded and lodge it on their studbook database. Only then will the uploaded information be correct.” – A PIO
“My only worry is passports could be misused by someone who is not the owner, such as a leased horse.”– A stud

Defra’s response

There is clear strong support for this proposal from the majority of respondents, including most of our stakeholder groups. We will therefore engage further with key stakeholders to develop this proposal (for updates to identification that is, not studbook data). The considerations expressed within the consultation response will be addressed within the development.

For example, a means of ensuring that PIOs receive timely notifications of updates to the CED, verification tools, and establishing the types of updates that would be permitted. A number of concerns were raised within the response, and these will also be addressed in development of the proposal, paying particular attention to the following.

Digital access

We recognise that some parts of the country, particularly in rural areas, have limited broadband or Wi-Fi facilities. There are technological solutions to this, one example being a change that is keyed in ‘offline’ will upload to the database as soon as the device comes into internet range.

It is also worth noting that Defra’s Statistical Digest of Rural England 2022 June edition acknowledges that rural area download speeds are on average slower than urban areas (54 Mbit per second versus 81 Mbit per second).

However, the percentage of premises unable to access a fixed broadband service of at least 10Mbit per second (downloads) and 1 Mbit per second (uploads) was low, at 0.9% for rural areas (and 0.3% for urban). In 2020, 92% ^{[footnote 1]} of premises in predominantly rural areas have access to superfast broadband coverage (being 90% in mainly rural areas, and 93% in largely rural areas).

We also recognise that people do not always feel confident using digital applications and to reflect this, and we will explore ways to support this.

PIO Income

Processing updates to an equine’s record is a source of income for PIOs. However, the primary concern in relation to updating the CED is to enable this to be as quick and frictionless as possible to ensure the data is up to date and accurate, in order to best support the traceability and biosecurity of our national herd. This is in the best interests of everyone, and equine health and welfare.

The consultation has clearly informed us that updates must be made more accessible and ideally free of charge. PIOs would still receive income from issuing, duplicating and over stamping passports.

PIOs may wish to charge a small fee for updating their central records following a notification of an update to the CED, however, it must be borne in mind that charging could create a disincentive for owners to make updates.

This goes against the essential aim of achieving more accurate data on the CED.

To what extent do you agree or disagree that owners should be able to apply for a new digital passport rather than the initial passport needing to be a paper document (to note, paper documentation would still be needed for certain purposes such as some international movement which could be applied for at a later date)?

Percentage of respondents for each answer option provided:

Response	Percentage of responses
strongly agree	29.95%
somewhat agree	17.77%
neither agree nor disagree	12.69%
somewhat disagree	14.72%
strongly disagree	24.11%
not answered	0.76%

Lead responses form stakeholder groups:

47.72% of respondents responded strongly agree and somewhat agree. This was the lead response for the following groups:
- local authorities
- other equine industry
- welfare organisations
- equine vets
- horse owners
- industry bodies
- other
13.45% of respondents responded neutrally
58.83% of respondents responded disagree and somewhat disagree. This was the lead response for the following groups:
- breed societies
- breeders and studs
- PIOs – non-studbook

The intention of this question was to establish stakeholder feeling in relation to the potential future introduction of digital ID-only identification (for the equine’s basic details).

Just under half of respondents agreed that they should be able to apply for a digital identification.

Reasons supporting this view included digital being more secure, supporting traceability, avoiding lost, stolen and damaged passports, and generally being quicker, and easier to manage.

A large proportion of respondents who welcomed the idea of digital identification included Local Authorities, vets, welfare organisations and industry bodies.

Furthermore, the response from the British Horse Council incorporated the results of a survey they conducted in parallel with this consultation. Out of the 3,424 responses they received, 87% agreed or strongly agreed with digital means of equine identification.

A significant concern in this area related to digital access, with both internet access and computer literacy. However, many respondents saw the benefits of digital being far more secure than paper identification which can be tampered with more easily. Many were also concerned about fraud and abuse of the system.

Those in favour of retaining paper passports as the primary identification document gave a range of reasons, including paper being required for overseas travel, paper is easier to present to shows and vets (although most veterinary responses did not support this view), the belief that paper is more secure than digital, is simpler and is more familiar.

A number of PIOs felt that this move would undermine their role, however, the intention with this proposal was that PIOs would still issue identification, for example, paper ID for EU travel and those requiring a paper backup, and they would still be able to check and verify information in the application, as they do now, and make a charge for doing this.

Many respondents, including a number who in principle prefer paper, suggested that paper or digital could be a backup for whichever of those would be the primary method. There was also suggestion of adopting a robust verification system for data security, fraud and abuse prevention.

Respondents said:

“Paper documents are problematic in a number of ways. They are slower and more costly to create and update, prone to being lost or damaged, vulnerable to theft, and easier to falsify and use fraudulently. They also currently vary considerably in quality, layout and content depending on the PIO that issues them.” – Redwings Horse Sanctuary
“Owners frequently forget their passports and often fail to produce them when vaccinating or prescribing medication. They never forget their phone! A digital passport would be excellent in these cases.” – An equine vet
“As above, digital routes are safer, quicker and promote traceability. We currently already scan all paper documentation sent to us, so we have digital records, which provides a safer and more convenient way of storing information and ensuring it is up to date.Reducing physical paperwork bring cost savings and significant environmental gains.” – A PIO
“It shouldn’t be so easy for owners to obtain a new passport. Means the old one meant nothing. This makes it so easy for thefts.” – A horse owner

Defra’s response

This proposal is supported by just under half of respondents, and by most of our stakeholder groups. As explained in the consultation document, we expect paper identification to continue to be required for the time being, for the purposes of movements to and from the EU and Northern Ireland, as EU third country requirements.

The Welsh Government has also indicated their intention to retain paper identification.

We must seek to align requirements across the Devolved Administrations to avoid the complexity and confusion whereby equines and their owner or keeper live across borders from one another, move from one administration to another or live in one administration and have a passport from a PIO in another administration.

We will continue to engage with the Devolved Administrations and the EU in relation to development in this area.

In the meantime, the consultation (throughout) has indicated that there is strong appetite in the equine sector to embrace more digital technology to enhance and support equine identification.

Accordingly, we will further engage with stakeholders to explore the possibilities of digital identification without compromising the current paper passport system.

To what extent do you agree or disagree that changes to studbook or breed details should not be made digitally and continue to be notified direct to the relevant PIO as currently?

Percentage of respondents for each answer option provided:

Response	Percentage of responses
strongly agree	32.23%
somewhat agree	12.94%
neither agree nor disagree	23.35%
somewhat disagree	14.72%
strongly disagree	15.23%
not answered	1.52%

Lead responses from stakeholder groups:

45.17% of respondents responded strongly agree and somewhat agree. This was the lead response for the following groups:
- breeders and studs
- breed societies
- horse owners
- industry bodies
- local authorities
- other equine industry
24.88% of respondents responded neutrally. This was the lead response for the following groups:
- welfare organisations
29.95% of respondents responded disagree and somewhat disagree. This was the lead response for the following groups:
- equine vets
- PIOs– non-studbook
- other

Similarly, to the first question which dealt with changes to identification details, this sought to assess stakeholder appetite for the ability to update studbook and breed details digitally.

Just under half of respondents, preferred to keep the current system as it is, by making studbook and breed details through the breed society or PIO, and not directly by digital means. Just under a third of respondents supported direct digital updates.

The main themes to support this position focused on breed societies retaining control of equine records, and fraud or abuse concerns. Many also felt that direct digital updates would undermine the role of the breed societies.

A number of respondents who welcomed digital updates stated preference for this due to it being quicker and more efficient, and many suggested allowing digital updates alongside the current process. Others suggested a system of verification of direct digital updates by the breed society. However, this was a minority view overall and was not supported by breed societies.

Respondents said:

“Provided the breed society has the technological capacity, changes could be made digitally, but they must be made through the breed society which holds the pedigree data”. – A PIO
“Changes should go through the relevant PIO to ensure the studbook is up to date. Updates also provide income to breed societies to help preserve the breed and its bloodlines.” – A PIO
“We strongly support the proposal that zootechnical information should continue to be verified and maintained by studbooks who are the experts in this area, allowing them to focus on maintaining bloodlines, advancing breeding for performance, underpinning zootechnical regulations and UK animal genetics resources (ANGR/UKGLE) requirements.” – The British Horse Council (BHC) (UKGLE is an advisory committee which stands for UK Genetics for Livestock and Equine, they used to be known as FAnGR which was farm animal genetic resource committee).
“It is imperative that all changes to studbook or breeding details continue to be notified direct to the studbook society. Nearly all studbook or breeding details are digital and a considerable amount of internal society work is already carried out by digital means. Changes could be made digitally, but not through the CED, and only to the original breed society. The breed society is the only organisation that holds the relevant records.” – A PIO

Defra’s response

The consultation revealed strong support for maintaining the current system whereby studbook and breed details are only updated via the breed society PIO (either digitally or through the post). We therefore do not propose any change to this process.

To what extent do you agree or disagree that vets should be allowed to update the CED digitally for the purpose of recording microchips, vaccinations and other medical treatments?

Percentage of respondents for each answer option provided:

Response	Percentage of responses
strongly agree	50.76%
somewhat agree	22.08%
neither agree nor disagree	8.38%
somewhat disagree	9.9%
strongly disagree	5.33%
not answered	3.55%

Lead response from stakeholder groups:

72.84% of respondents responded strongly agree and somewhat agree. This was the lead response for the following groups :
- breeders and studs
- equine vets
- horse owners
- industry bodies
- local authorities
- other
- other equine industry
- welfare organisations
11.93% of respondents responded neutrally
15.23% of respondents responded disagree and somewhat disagree. This was the lead response for the following groups:
- breed societies
- PIOs – non-studbook

This question sought views from stakeholders on allowing vets to update the CED either directly, or through Application Programming Interfaces (APIs) with their veterinary software, for example, to record microchips or those vaccinations and other medical treatments that would alter the equine’s food chain status.

A significant majority of respondents fully supported this proposal. Common themes in support of this were the simplification and efficiency it would promote as well as providing more accurate records.

There were a number of concerns, supported by equine vets, in relation to potential additional workload and a number of equine owners were concerned about the possible impacts of increased vets’ bills generated by additional admin time.

Many respondents felt that as trustworthy professionals, vets should be able to update records on CED and that this would likely reduce fraud and abuse. Some respondents were concerned about vet errors and digital access, especially in rural areas. There was also support for this to be a choice for vets and owners, not a mandatory requirement.

Some respondents provided suggestions such as automating vaccine records, scanning the equine’s microchip then scanning barcodes on medications administered to link the 2, and syncing records already held by the veterinary practice. Some respondents expressed a desire for a method of verification along with concerns in relation to fraud or abuse of the system.

Some expressed concern that the digital and paper ID records could become inaccurate if one is updated more than the other. Others also suggested that the CED should notify the PIO when a vet had updated the system so that the PIO could also update their own records.

Respondents said:

“It should be possible to set up the database such that attending vets have a time limited “guest login” for individual treatments/vaccinations for equines. It will be important that vets can delegate to admin officers and there should be some sort of verification from a MRCVS for vaccines. It would also be desirable that on entry, a vet can verify a vaccination history as being up-to-date on a specific timepoint so future vaccines can be added one by one. Ideally the vaccine status could be automated such that sporting organisations can see this without being able to see other confidential info such as previous owners etc.” – An equine vet
“I have known of incorrect updates for other purposes before. If it could be done via immediate scanning of the barcodes / batches - then that would be an amazing addition, would ensure effective and accurate updates and, reduce human error”. – A horse owner
“Veterinary updates are vital to add value to the data held for the individual horses and the national herd” – An equine vet
“Yet another vet fee for horse owners?” – A horse owner

A PIO said “There are 2 issues with this:

Currently Vets are part of the problem with inaccurate reporting, in fairness, because it usually is not part of their priorities.
As long as the CED and Vet’s informs the PIO that originally issued the passport of these updates / changes then this would probably be acceptable however we have no faith in the current technology to this. We would need a robust verification process in place.”

Defra’s response

There is very strong support from most stakeholder groups for enabling vets to update the CED with veterinary updates. We will continue to engage with equine industry and veterinary stakeholders to develop this proposal and explore the possibilities to enable vets to make safe, secure, efficient digital updates to equine records.

We will also take into account data access challenges and alerts to PIOs when updates have taken place. Throughout the development of this, consideration will be given to vet workload and costs implications for both veterinary practices and horse owners and or keepers.

Are there any other relevant groups that you think should be allowed to update the CED digitally (please specify)?

Percentage of respondents for each answer option provided:

Response	Percentage of responses
strongly agree	50.76%
somewhat agree	22.08%
neither agree nor disagree	8.38%
somewhat disagree	9.9%
strongly disagree	5.33%
not answered	3.55%

Lead responses from stakeholder groups:

24.11% of respondents responded strongly agree and somewhat agree. This was the lead response for the following groups:
- welfare organisations
34.77% of respondents responded neutrally. This was the lead response for the the following groups:
- equine vets
- horse owners
- local authorities
- other
33% of respondents responded disagree and somewhat disagree. This was the lead response for the the following groups:
- breed societies
- breeders and studs
- industry bodies
- other equine industry
- PIOs – non-studbook

This question aimed to establish if there are any other groups of people stakeholders felt would be appropriate to have access to update the CED digitally, and if so, which ones, and for what reasons.

The question generated a mixed response with a slight majority having no strong view either way. Slightly more respondents, about one third disagreed, as opposed to approximately one quarter agreeing.

Analysis of the qualitative responses has revealed that more respondents were in favour of certain, trusted organisations or professionals being able to update CED digitally rather than not allowing this at all. For example, selecting ‘disagree’ but stating that this would however be acceptable for some trusted organisations and professionals.

There were also significantly valid reasons for these being proposed, such as supporting welfare, improving traceability, enhancing enforcement, assisting biosecurity and protecting public health.

A large number of responses saw valuable benefit in recognised, well established welfare organisations, Local Authorities, Food Standards Agency and the police having access and being able to update CED for many of the reasons already stated.

Other suggestions from respondents included abattoirs, equine treatment professionals (for example, farriers or dentists), insurance companies and sports bodies. A small number of respondents suggested that yard or livery owners should be able to access and update records.

Many were concerned that more people having access to the CED would cause confusion and increase potential for fraud and abuse of the system, whereas conversely, others believed that it would potentially reduce fraud and abuse, and enable more accurate recording, for example, equine deaths. A number of respondents also felt it would be useful for insurance companies to be able to record loss of use of the equine in its CED record.

Respondents said:

“Foreign vet checks to speed up the process of transporting horses, reduce the amount of paperwork” – A professional rider
“Interference from busybodies should be discouraged” – A horse owner
“Police, border agencies RSPCA, other welfare charities, all need access”. – A horse owner
“It would be very useful for a potentially limited number of animal welfare organisations, such as the RSPCA, to be permitted to update equine identification information to the CED digitally. A fundamental difficulty the RSPCA face with the current legislation is that an estimated 70% of the equines taken into RSPCA care are not identified properly or indeed at all.” – RSPCA
“Insurance companies, especially in terms of claims for conditions and loss of use. Might cut down some of the poor horses being passed about as sound and healthy when anything but. to add any claims made or loss of used on the animal which probably wouldn’t be disclosed otherwise.” – A horse owner

Defra’s response

The quantitative analysis showed a slight majority of people had no strong views on this proposal, and slightly more disagreed than agreed. However, qualitative responses did provide further insight, in that, more respondents made suggestions and provided valid reasons for doing this, than stated that nobody else should be able to make updates.

It is clear from responses that certain bodies having update access to CED would be deemed extremely beneficial to improve equine welfare, traceability and biosecurity, for example:

recognised, well established welfare organisations (for welfare purposes)
Local Authorities (for welfare cases and enforcement purposes)
certain government agencies (for example, the Animal andPlant Health Agency and the Food Standards Agency – to record equine movements through borders, and deaths at abattoirs)
the Police (for welfare, incident, and criminal investigation purposes)

We will further engage with stakeholders to develop this proposal. Considerations will include, for example, criteria to be set for granting CED access, permissions, limiting access, controls and safeguards and verification.

Percentage of respondents for each answer option provided:

Response	Percentage of responses
strongly agree	28.43%
somewhat agree	13.96%
neither agree nor disagree	16.24%
somewhat disagree	18.27%
strongly disagree	19.29%
not answered	3.81%

Lead responses from stakeholder groups:

42.39% of respondents responded strongly agree and somewhat agree. This was the lead response for the following groups:
- equine vets
- local authorities
- other equine industry
- PIOs - non-studbook
- welfare organisations
20.05% of respondents responded neutrally. This was the lead response for the following groups:
- breed societies
- industry bodies
- other
37.56 % of respondents responded disagree and somewhat disagree. This was the lead response for the following groups:
- breeders and studs
- horse owners

As explained in the consultation document, some stakeholders have asked for historic ownership records to be made available to future owners.

Currently, this would require the previous owner’s consent (which we proposed to maintain for General Data Protection Regulation (GDPR) purposes). The purpose of this question was to establish stakeholder views on this point.

Slightly more respondents agreed than disagreed to this proposal. Reasons for this ranged from it being useful, or even imperative, to know a horse’s history, understand medical or behavioural issues the horse may have, trace breeding, and for general knowledge and information about their horse and its past.

A very large proportion, including amongst respondents who agreed, expressed GDPR concerns. Many respondents suggested that enabling a historic ownership record would reduce fraud and abuse of the system, with more transparency on the horse’s record. Many also saw no difference with the fact that current paper passports contain a visible record of previous owners.

Several respondents also commented that they would be happy to be contacted by a future owner to answer questions about a horse they once owned or bred, and to know about their previous horse’s new life.

Some respondents expressed a concern in relation to previous owners being recorded and visible who had, for any number of reasons, been prosecuted for welfare offences, or had the horse removed from their care for welfare reasons and the potential risk this could pose to their personal safety.

Respondents said:

“More accessibility to information on previous owners may help to clamp down on “rogue traders”, those knowingly selling horses with vices or injuries.” - A horse owner
“While we understand there may be implications in relation to General Data Protection Regulation (GDPR) rules and compliance which would need to be considered – and not all information may be appropriate to share – our overall view is that transparency should be encouraged on sharing information of appropriate previous ownership data, for example, to help combat emerging, or understand previous, disease outbreaks.” – British Horseracing Authority
“I think it is important to maintain confidentiality in this area. As long as the historical information is kept on CED, any authorities will should be able to access it - for example in welfare cases or instances of fraud/theft.” – An equine vet

Defra’s response

This proposal was supported by just under half of respondents, with about one fifth with no strong view either way.

The consultation response revealed a wide range of suggestions and considerations in relation to enabling visible historical ownership records with the owner’s consent. We will further engage with stakeholders in developing this proposal.

The key concern or consideration from many respondents was that of GDPR, however, the question stated that this proposal would be with the current owner’s consent, which would satisfy GDPR requirements. Many also made the comparison that presently, previous owners are visible on a paper passport and saw no difference with this in digital format.

To what extent do you agree or disagree that both the current and new owners should be responsible for notifying a change of ownership?

Percentage of respondents for each answer option provided:

Response	Percentage of responses
strongly agree	53.55%
somewhat agree	23.6%
neither agree nor disagree	8.63%
somewhat disagree	5.58%
strongly disagree	4.82%
not answered	3.81%

Lead responses from stakeholder groups:

77.15% of respondents responded strongly agree and somewhat agree. This was the lead response for the following groups:
- breed societies
- breeders and studs
- equine vets
- horse owners
- industry bodies
- local authorities
- other
- other equine industry
- welfare organisations
12.45% of respondents responded neutrally. This was the lead response for the the following groups:
- PIOs – non-studbook
10.4% of respondents responded disagree and somewhat disagree.

This question intended to establish from stakeholders how they felt about both buyer and seller of an equine being legally responsible for notifying the change of ownership (from the current position of only being the responsibility of the buyer). The purpose of this proposal is to better support accurate, up to date records on the CED.

A large majority of respondents supported this proposal, seeing the benefits it would bring in reducing fraud and abuse of the system, whereby currently many equines are sold having been stolen, or fraudulently by the keeper of an equine on a loan arrangement, without the owner’s knowledge. Benefits were also seen to improving the accuracy of the CED to better support traceability.

A large number of respondents also made comparisons with the Driver and Vehicle Licensing Agency (DVLA) system for buying and selling cars and suggested that the same model should be followed for equine sales.

Suggestions varied between:

the previous owner confirming that they no longer own the equine and the buyer updating the system with their details as the new owner
the buyer confirming that they have bought the equine and the previous owner accepting or verifying this
either the buyer or previous owner notifying in the first instance with the other party verifying the transaction

Suggestions were also made in relation to online verification codes or digital handshakes for extra security.

Respondents said:

“This would provide a check and balance where one party is reluctant for whatever reason to update the records. If the onus remains solely on the seller, buyers have no way to ensure that the record is accurate and to assert their right as the new owner. This would also flag any dispute over ownership.” – British Veterinary Association
“I think this is a very good idea. Too many new owners do not record the change of ownership on the passport and they can’t be traced if there is a problem eg the horse is stolen or gets loose and is in an accident.” – A breeder
“Responsibility here is shared and ensures that fraudulent transfers cannot be initiated or accepted without the current owner and future owner being verified and notified first.” – Equidentify
“Both should be required by law to notify the CED digitally which would be even simpler if the horse has a digital passport as the problem in the past has been the need to return the paper passport to the PIO for amendment.” – A horse owner
“Up till now only production of a passport has been accepted as proof of ownership. Many horses pass through dealers and owners without the ownership being updated.” – A horse owner

Defra’s response

This proposal has strong support including from most of our stakeholder groups. Accordingly, we will work on developing an equine ownership transfer function that is easy to use, secure and achieves its objective.

We recognise that controls must be in place to prevent fraud and abuse of the system, particularly where a third party is selling an equine, not the owner. We will therefore explore the requirement for the previous or last recorded owner (as well as, or instead of the seller) to verify the sale.

We will also need to take into account other transfers of ownership, for example, when an equine is taken into the care of a welfare organisation, or when an equine is being sold or transferred by the legal representatives of a deceased owner, and of course for situations where ownership is in dispute.

To what extent do you agree or disagree that the time limit for notifying the PIO of a change of ownership should be reduced to 14 days?

Response	Percentage of responses
strongly agree	22.59%
somewhat agree	12.94%
neither agree nor disagree	19.54%
somewhat disagree	19.04%
strongly disagree	22.34%
not answered	3.55%

Lead responses from stakeholder groups:

35.53% of respondents responded strongly agree and somewhat agree. This was the lead response for the following groups:
- equine vets
- local authorities
- other equine industry
- welfare organisations
23.09% of respondents responded neutrally. This was the lead response for the following groups:
- industry bodies
41.38 % of respondents responded disagree and somewhat disagree. This was the lead response for the following groups:
- breed societies
- breeders and studs
- horse owners
- other
- PIOs – non-studbook

With this question, we wanted to explore to what extent stakeholders felt that the current timescale of 30 days for notifying a PIO of a change of ownership is too long.

Our proposal to reduce this time limit from 30 days to 14 days is with a view to increasing compliance and improving the accuracy of CED by making the notification a higher priority and potentially easier to remember to do.

Slightly more respondents disagreed with this proposal than agreed and a significant number of respondents provided suggestions for timeframes. It was clear from these suggestions, that a number of respondents disagreeing with the proposal actually felt that 14 days was still too long to allow for notifications of change of ownership.

The following graph illustrates, as a percentage, the timeframes that respondents felt were appropriate.

Response	Percentage of responses
Moment of sale	3.7%
Sooner the better	0.9%
3 days	2.3%
7 days	0.5%
Up to 14 days	32.7%
Up to 14 days if digital	16.2%
At least 14 days	17.5%
Up to 21 days	1.4%
Up to 28 to 30 days	21.1%
Up to 42 days	3.2%
Up to 60 days	0.5%

This equates to:

56.3% in favour of a timescale up to and including 14 days (including those in agreement if the notification is digitised)
43.7% in favour of at least 14 days to longer

However, ‘up to 14 days’ and ‘at least 14 days’ both accept 14 days as the lower and upper limit of their threshold. Combining these 2 results leads to 66.4%, a majority, in favour of a 14-day time limit.

Many respondents in favour of a reduced time limit for notifications of change of ownership cited improvements to compliance that this would generate on the basis that it would be more likely to focus minds to do this, rather than the current time frame in which the impetus to make the notification is prone to dwindling.

A number of respondents felt that rather than a change of timescale, Defra should concentrate on enforcing the current regulations to improve compliance.

A significant number of respondents felt that 14 days was too short due to people being too busy to notify the PIO of a change of ownership. This indicates that many respondents do not see the importance of prioritising this legal requirement.

A number of respondents also provided reasons for a 14-day time limit being impractical and not always possible to adhere to. Such reasons included the distraction of having a new horse, that it would cause challenges with a typical 14-day trial period whereby the horse may be returned if the buyer is not happy with it, and it being an administrative burden.

Some respondents also quoted postal delays and PIOs being slow to deal with notifications and needing the passport for vaccinations or competitions during the 14 day timeframe which would then make the submission late. Digitisation of equine records and notifications would mean that these issues would no longer be a consideration.

Many respondents in favour of the reduced time frame felt that this would afford flexibility, improve compliance, is a reasonable requirement, would reduce fraud and abuse of the system, and support traceability. Some respondents also commented that a 3-day time limit is achievable for sheep and cattle and there would be no reason why that wouldn’t be the case for equines.

Respondents said:

“I’d ideally prefer this to be done digitally at point of sale but that won’t be possible for everyone and every situation, so 14 days seems a reasonable compromise” – A horse owner
“It shouldn’t take people long to let you know they have sold/bought a horse. Very easily done within 7 days or less if you actually want to do it. I would apply to change ownership as soon as the horse is sold or arrives.” – A horse owner
“It might not always be possible to notify a change of ownership immediately for various reasons i.e., illness, holidays. Maybe a period of grace could be introduced.” – A horse owner
“If done digitally it could be part of the exchange process. That way it doesn’t get forgotten about and left for longer. The previous owner of my pony ‘lost’ the passport for 6 months, so I had to reapply. She was very unhelpful. If done digitally I could have applied at point of sale.” – A horse owner
“People have busy lives it’s not always possible” – A horse owner
“Currently people do not comply with the time limits, enforcement is more of an issue than changing the limits.” – A breed society
“The present 30 day rule does not work, so how will 14 days’ work either? Too little is known of the requirement. Needs more advertising. Needs policing too.” – A horse owner

Defra’s response

The quantitative response to this proposal indicated that just under half were opposed to it. However, on analysing the qualitative responses, it was clear that the majority response was not opposed to reducing the time limit for notifying of change of ownership, rather, that 14 days was still too long.

Those in favour of 14 days as either their upper or lower limit amounted to a majority of 66.4%, and the most popular suggestion for a reduced time limit was at birth, or as soon as possible afterwards.

We will therefore explore this proposal further, as there are many considerations to be taken into account in establishing the appropriate timeframe.

We also need to be clearer that the time limit for notification is for the application to reach the PIO, not for the whole change process to have been completed.

We will also explore digitisation in this regard to support quicker updates and therefore better accuracy on the CED, linked to the previous question and the first question. Many respondents felt this would be required to support the quickest possible updates.

Consideration will also be given to specific circumstances such as trial periods, holidays, illness or other specific circumstances that would impede the time limit. Another key consideration is that of enabling a separate notification for equines that are taken into the care of a large, well established welfare organisation.

To what extent do you agree or disagree that the time limits for all notifications to PIOs of changes to an equine’s records should be standardised?

Percentage of respondents for each answer option provided:

Response	Percentage of responses
strongly agree	47.21%
somewhat agree	27.92%
neither agree nor disagree	16.24%
somewhat disagree	2.79%
strongly disagree	2.03%
not answered	3.81%

Lead responses from stakeholder groups:

75.13 % of respondents responded strongly agree and somewhat agree. This was the lead response for the following groups:
- breed societies
- breeders and studs
- equine vets
- horse owners
- industry bodies
- local authorities
- other
- other equine industry
- PIOs non-studbook
- welfare organisations
20.05 % of respondents responded neutrally
4.82% of respondents responded disagree and somewhat disagree

This question sought to ascertain how stakeholders felt about the current differing timescales applicable to different categories of change to an equine’s records, and whether these should be aligned to be the same time limit for all changes to simplify the system.

The purpose of this is to make the timeframe easier to remember and thereby increase compliance with the regulations. As outlined in the consultation document, the three current time limits are:

30 days to notify of change of ownership
14 days to notify where a horse has received medications not permitted for animals intended for slaughter for human consumption
30 days to notify of a change to any other details (for example, a new address for the owner)

It is clear from the qualitative analysis of the responses to this question that many in the equine sector are unaware of, or confused by the current rules, including a number of breed societies that are issuing equine ID.

A significant number of respondents signalled that aligning all the timeframes would provide a level of consistency making the timeframes much easier to remember and would reduce the current confusion in this area. Many also felt that this in turn would lead to an increase in compliance.

Several respondents acknowledged that some changes are higher priority than others and that consideration should be given to this. Many respondents also felt concern around how this proposal would be enforced.

Some also highlighted that the rules should be aligned across the Devolved Administrations:

“If all POIs were to advertise these time limits it would be easier for owners. But it is sometimes difficult to find out where to notify any changes, especially if the original POI is overseas. The POIs must take more responsibility to make themselves available.” – A horse owner
“If people are aware of one standardised time limit they will be more likely to comply with them.” – An equine vet
“It is easier to monitor and enforce if there is one standard time limit for all notifications to PIOs.” – A breed society
“Are they not all 30 days at the moment? Change of ownership and death are? Honestly, I don’t think most owners have any idea that there are time limits!” – A breed society

Defra’s response

This proposal received strong support from all of our stakeholder groups. We will therefore develop this proposal with further engagement with stakeholders, as there are considerations to be taken into account. Examples are that some changes are higher priority than others, the advantages of alignment across the Devolved Administrations and what timeframes should be set to. It is also clear from the response that current understanding and awareness of the rules is lacking across the equine sector.

We will therefore ensure that any changes to timeframes are thoroughly communicated and encourage all PIOs to also make the regulations very clear (which many already do).

Similarly, to the previous question on reducing the time limit to notify of a PIO of a change of ownership, this proposal refers to the time limit for the notification of change arriving with the PIO, not the timeframe within which it must be completed. Will also explore digitisation to support this.

To what extent do you agree or disagree that other databases e.g., those belonging to PIOs, the horseracing and thoroughbred sectors, the Devolved Administrations and the Republic of Ireland should be allowed to update the CED via APIs?

Percentage of respondents for each answer option provided:

Response	Percentage of responses
strongly agree	30.46%
somewhat agree	23.35%
neither agree nor disagree	29.95%
somewhat disagree	5.84%
strongly disagree	5.33%
not answered	5.08%

Lead responses from stakeholder groups:

53.81% of respondents responded strongly agree and somewhat agree. This was the lead response for the following groups:
- breed societies
- equine vets
- horse owners
- industry bodies
- other
- other equine industry
- PIOs – non-studbook
- welfare organisations
35.02% of respondents responded neutrally. This was the lead response for the following groups:
- breeders and studs
- local authorities
11.17% of respondents responded disagree and somewhat disagree

As explained in the consultation document, we propose to allow the timely exchange of information from certain industry databases to the CED with the use of APIs (Application Programming Interfaces). We wanted to gauge stakeholder appetite for this proposal.

The analysis of the response to this question revealed strong support for this proposal, with a significant number of respondents, including breed societies, PIOs and vets, commenting that harmonisation of systems would be very beneficial. Many also felt this would achieve better accuracy of data on the CED and enable better efficiency and reduced administration.

A number of respondents expressed concern that linking systems could introduce more errors and also felt that controls need to be in place, for example, vet verification, permission of the owner, restrictions on the types of updates and access allowed.

Some respondents expressed a desire for PIOs to be notified of updates made this way, in order that their own central records can also be updated.

Some respondents also expressed data security concerns, and that only breed societies or PIOs should have access to CED. Some felt that this proposal is not necessary or acceptable, however this was the view of a small minority.

Respondents said:

“Using a secure system which allows timely and relevant ID information to be shared from other databases would help ensure consistency of information being accessed by different organisations. It could also help reduce incidence of fraud and promote compliance by reducing the administrative burden on horse owners, vets and other users. For ease of use by both owner and enforcement agencies, consistency and to tackle fraud there must be consistency across all parts of the UK. Working closely with ROI is also vital as such a large percentage of UK horses are sourced from this country.” – Redwings Horse Sanctuary
“Subject to PIO involved in updates- key to CED is clean data so need to restrict/control entries.” – A breed society
“Enables automatic updating and improves reliability and efficiency of the process.” – A breed society
“The British Horse Society believes that the use of APIs will help data which is uploaded to the CED be as clean as possible and reduces error through dual entry. The use of APIs will also help data to be as ‘real-time’ as practically possible. The British Horse Society PIO function currently updates and uploads data onto the CED through an API function.” – The British Horse Society
“As long as there are rigorous checks and security measures then sure. We have to remember that the more entities that can alter/update records the more chances for mistakes.” – A horse owner

Defra’s response

There is strong support for this proposal, with very little opposition. The majority of respondents have recognised the clear benefits of enabling APIs to allow other industry databases to link to the CED.

We will therefore develop this proposal and work with stakeholders including the Devolved Administrations, the Republic of Ireland and government agencies to take this forward.

In developing this proposal, we will consider appropriate safeguards, permissions and verifications, as well as addressing the mitigation of errors or conflicting data from different sources, and notifications to PIOs when an update has been made.

To what extent do you agree or disagree that we should allow APIs to link data from the CED to other electronic systems used to support e.g., export health certification?

Percentage of respondents for each answer option provided:

Response	Percentage of responses
strongly agree	35.53%
somewhat agree	28.43%
neither agree nor disagree	24.87%
somewhat disagree	2.03%
strongly disagree	3.81%
not answered	5.33%

Lead responses from stakeholder groups:

63.96% of respondents responded strongly agree and somewhat agree. This was the lead response for the following groups:
- breed societies
- breeders and studs
- equine vets
- horse owners
- local authorities
- other
- other equine industry
- PIOs – non-studbook
30.2% of respondents responded neutrally
5.84% of respondents responded disagree and somewhat disagree

Similarly, to the previous question, we also propose to allow the timely exchange of information from the CED to certain industry databases with the use of APIs (Application Programming Interface) to support, for example, export health certification. Again, we wanted to gauge stakeholder appetite for this proposal.

This proposal received strong support. Qualitative analysis revealed that a significant number of respondents felt that this is an essential requirement for equine movements to the EU for competition, breeding and racing, making the system much more efficient and better supporting equine welfare.

A number of respondents expressed concerns over digital security and potential for errors and many made suggestions of ensuring that protections are adopted, such as permissions, verifications, and limitations of use and access.

Respondents said:

“Anything that will reduce the bureaucratic burden for moving horses across the channel would be sensible. You current system impacts poorly on horse welfare.” – A professional rider
“This will help with international horse movement which is a welfare issue currently.” – British Showjumping
“The amount of paperwork currently involved in exporting horses to the EU is both wasteful and inefficient. Anything that can be done to streamline the process should be encouraged.” – An equine vet
“Since the CED should be the ultimate reservoir of all information related to the horse it follows that other data such as export certification should also be linked to the CED. This would have real advantages in disease tracing.” – A horse owner
“Would need to be a secure system that allows relevant information only to be shared whilst maintaining the safety of the data on the CED.” – A horse owner

Defra’s response

Again, there was strong support for this proposal with very little opposition. The majority of respondents have recognised the clear benefits of enabling APIs to link from the CED to other electronic systems where appropriate.

We will therefore develop this proposal and work with stakeholders including other government departments and agencies to develop this proposal, taking into account appropriate safeguards, permissions and verifications.

Traceability

To what extent do you agree or disagree that it should be made a legal requirement to record the habitual location of each equine on the CED?

Percentage of respondents for each answer option provided:

Response	Percentage of responses
strongly agree	36.29%
somewhat agree	24.37%
neither agree nor disagree	11.68%
somewhat disagree	10.15%
strongly disagree	13.96%
not answered	3.55%

Lead responses from stakeholder groups:

60.66% of respondents responded strongly agree and somewhat agree. This was the lead response for the following groups:
- breed societies
- equine vets
- horse owners
- industry bodies
- local authorities
- other equine industry
- PIOs – non-studbook
- welfare organisations
15.23% of respondents responded neutrally
24.11% of respondents responded disagree and somewhat disagree. This was the lead response for the following groups:
- breeders and studs
- other

The proposal to make it a legal requirement to record the habitual location of each equine forms the bedrock of accurate traceability for biosecurity, in monitoring and controlling disease outbreak.

We wanted to understand from stakeholders how they felt about this in the context of recording the equine’s usual location (or intended location if recently purchased). The consultation document provided examples of this as being a home yard, training establishment or rehoming centre.

The consultation response revealed strong support for this proposal, with a very significant number of respondents feeling that this is an essential requirement for supporting biosecurity and traceability in the event of a disease outbreak. Some respondents also likened this to livestock recording and did not see why this could not also work for equines. Others felt that this would also help to reduce fraud and abuse of the system.

A number of respondents had concerns in relation to horses that move around a lot, for example, moving livery yards frequently, or regular attendance at training yards and that updating the habitual location of the horse would create too much work, and would also be difficult to enforce. Other respondents expressed concern over the level of detail required, such as individual fields, and some respondents expressed concern in relation to data privacy.

Some respondents felt that this move is unnecessary and that it constitutes a ‘Big Brother’ approach. The consultation document was clear in explaining that the purpose of this proposal is for the protection of our national equine herd in improving our ability to respond to, manage and contain a serious disease outbreak.

These are an ever-increasing threat, due to changes to our environment and increased travel. To support this, we need to be able to locate equines.

Respondents said:

“Livestock location is recorded for the purposes of disease control. It is not at all implausible that in the near future a notifiable disease epidemic will occur in UK equines, making traceability very important.” – An equine vet
“Horse traceability is essential to ensure effective disease control, meaningful checks on food chain status and the ability to identify lost, straying and stolen horses and reunite them with their keepers. Blue Cross believes a legal requirement to record the habitual location of each equine is fundamental to any efficient and comprehensive system of equine identification and traceability. This will help to improve welfare and help with the containment of any potential outbreaks of disease.” - Blue Cross
“This would be in line with livestock reporting and also useful in a notifiable disease outbreak.” – A Local Authority
“again, what is the point of the passport system if not for this?” – A horse owner
“For biosecurity measures this is a must.” – A horse owner
“This is all a bit big brother, no” – A breeder

Defra’s response

There is strong support for the mandatory recording of the habitual location of equines. We will therefore develop this proposal with further stakeholder engagement.

We will establish a definition of ‘habitual residence’ and a system to identify habitual location premises. As with all CED data, this information would only be visible to those with permitted access to the equine’s record.

We intend this to be, for example, limited to owners or keepers, the PIO, and upon request by authorities for specific purposes (for example, Defra, APHA, Local Authorities and the Police) in relation to disease outbreak, escaped or straying equines, and suspected stolen horses.

We must also consider appropriate ways to record equines that reside on common land, for example, our semi-wild populations, and those of the traveller community.

To what extent do you agree or disagree that some, or all, temporary locations should also be included on the CED?

Percentage of respondents for each answer option provided:

Response	Percentage of responses
strongly agree	14.47%
somewhat agree	17.51%
neither agree nor disagree	22.34%
somewhat disagree	18.27%
strongly disagree	23.86%
not answered	3.55%

Lead respones from stakeholder groups:

31.98% of respondents responded strongly agree and somewhat agree. This was the lead response for the following groups:
- industry bodies
- local authorities
- welfare organisations
25.89% of respondents responded neutrally. This was the lead response for the the following groups:
- breed societies
42.13% of respondents responded disagree and somewhat disagree. This was the lead response for the following groups:
- breeders and studs
- equine vets
- horse owners
- other
- other equine industry
- PIOs – non-studbook

To further support traceability for biosecurity purposes we are also exploring the scope for temporary locations of an equine to be recorded. As explained in the consultation document, this means a place where the equine does not normally reside.

Such locations could include, but are not limited to, showgrounds, race meets, sale events, dealer’s yards, stud visits, or a temporary stay at a livery yard from a private residence when an owner is away. A hack or day ride would not be included in the definition of a temporary location.

This proposal received a mixed response with a number of respondents stating that this is not necessary, and difficult to achieve on the basis that horses move around a lot, that many owners or keepers are too busy to update their horse’s temporary location, and it would be an administrative burden.

However, a number of respondents in support of the proposal commented on the benefits to biosecurity and traceability in the event of disease outbreak.

Many respondents provided suggestions for timeframes that should apply to the definition of ‘temporary’, and also purposes for the temporary move that should apply. These were:

Response	Percentage of responses
Overnight	11.5%
more than 3 days	7.7%
more than 7 days	26.9%
more than 2 to 3 weeks	3.8%
more than 1 month	30.8%
more than 2 months	3.9%
more than 3 months	15.4%

Percentage of respondents for each answer option provided:

Response	Percentage of responses
All temporary locations and any gatherings	5.2%
Dealer yards	6.5%
High level or longer shows	6.5%
Shows and events	20.8%
Holidays	3.9%
Long vet stays	9.1%
Sales	10.4%
Race	1.3%
Studs	15.6%
Schooling yard	15.6%
Rehabilation	2.6%
Other	2.5%

From these responses we can see the most popular suggestions for a timeframe are over one month, or over 7 days. Shows, events, studs and schooling yards were the most popular suggestions for temporary move purposes.

Respondents said:

“Once premises where horses are located can be centrally recorded, horses can be transferred digitally on a temporary or permanent basis from place to place, and some industry systems already exist to delivery this very effectively. Disease doesn’t know whether horses are permanently or temporarily located and recent industry examples of Equine Herpes Virus spread from Valencia across Europe in 2020 is an example of why temporary locations should be recorded.” – The British Horse Council
“Some horses travel a lot, and this may seem excessive to record all their locations but to avoid loopholes or trace disease outbreaks, this may be a good measure.” – A horse owner
“Horses are often competing and this would be impractical.” – A horse owner

Defra’s response

This proposal received a mixed response, and although more respondents opposed than supported it, many valid suggestions were made in support of it. Many also said they would be in support of this proposal if the means to record temporary locations were digitised (But were opposed to it on the basis of the current system of non-digital updates).

Our intention would be to digitise this process. We will further engage with stakeholders on this proposal, as we believe, and many responses recognised that this would have enormous benefits and is essential for supporting traceability and biosecurity in the event of a disease outbreak.

To what extent do you agree or disagree that organisers of events, sales, etc. should be required to keep a record of the equines involved?

Percentage of respondents for each answer option provided:

Response	Percentage of responses
strongly agree	46.45%
somewhat agree	23.68%
neither agree nor disagree	11.86%
somewhat disagree	7.36%
strongly disagree	6.85%
not answered	3.81%

Lead responses from stakeholder groups:

70.31% of respondents responded strongly agree and somewhat agree. This was the lead response for the following groups:
- breed societies
- breeders and studs
- equine vets
- horse owners
- industry bodies
- local authorities
- other
- other equine industry
- PIOs – non-studbook
- welfare organisations
15.48% of respondents responded neutrally
14.21% of respondents responded disagree and somewhat disagree

The purpose of this question was to ascertain how stakeholders felt about a requirement for events and sales to keep records of the equines that attended, such that they would be made available to competent authorities if requested, for example, in the case of a disease outbreak to support traceability and containment of the disease.

Many respondents in support of this proposal expressed that it is an essential requirement and would support biosecurity, improve traceability, help welfare, and that shows, events, already record details of the equines involved and it would be simply a matter of formalising this. Many also suggested that it would reduce fraud and abuse of the system.

A number of respondents voiced concern at the administrative burden this may present and that the size of the show or event should be considered, for example, limiting this requirement to larger or affiliated shows, international shows in the UK, and that small shows should be exempt.

Respondents also made suggestions to reduce the administrative burden, for example, using digital tools, quick response (QR) codes, barcodes and similar as a ‘digital check-in’ at the event.

Several respondents felt that this proposal should only apply to sales, and not shows or events.

Respondents said:

“In an ideal world they should but it would be sad if events (particularly small local events) were lost because of an over burden of ‘red tape’” – A stud
“If the system is not made unwieldy then I agree. In this digital age this should be possible.” – A horse owner
“This would be entering 1984 Orwell territory. No need for this information at all. Unnecessary bureaucracy.” – A horse owner
“If it can be done digitally it shouldn’t be too onerous for the venue and could be very handy if there is a disease outbreak.” – An equine vet

Defra’s response

There is strong support for this proposal and accordingly we will engage with stakeholders to further develop this, to establish a means to make this as frictionless as possible and explore digital solutions to support it.

We do not intend this to be burdensome, especially on smaller gatherings and we will give consideration to what level or size of show, event or sale this would apply to, together with any appropriate exemptions to be considered.

We will also establish proportionate timescales for keeping the data after the event. This proposal has real advantages in supporting traceability and biosecurity in containing and managing a disease outbreak.

To what extent do you agree or disagree that organisers of events, sales etc. should also be required to log relevant details digitally on the CED (e.g., via the Digital Stable)?

Percentage of respondents for each answer option provided:

Response	Percentage of responses
strongly agree	21.07%
somewhat agree	18.27%
neither agree nor disagree	22.34%
somewhat disagree	11.93%
strongly disagree	25.63%
not answered	0.76%

Lead responses from stakeholder groups:

39.34% of respondents responded strongly agree and somewhat agree. This was the lead response for the following groups:
- equine vets
- horse owners
- industry bodies
- local authorities
- other equine industry
- welfare organisations
22.7% of respondents responded neutrally. This was the lead response for the the following groups:
- PIOs – non-studbook
37.56% of respondents responded disagree and somewhat disagree. This was the lead response for the following groups:
- breed societies
- breeders and studs
- other

As an extension to the previous question, we also wanted to assess stakeholder appetite for a requirement that events, sales, log details of equines attending on the CED via a digital means.

This question received a mixed response. Many respondents again saw the benefits to biosecurity and traceability, but also expressed concern in relation to administrative burdens, especially for smaller shows, often run and managed by volunteers.

Overall, and as illustrated by the chart below, there was less support for show and event organisers being required to update CED with details of the equines involved, but more in favour of the need for sales to do this.

Largely, the view in support of this was connected to the fact that equines change hands at sales and therefore they pose a greater traceability challenge than shows and events where almost all equines attend and return home with the same owner or keeper.

There was, however, some support for larger shows and events to log details of attending equines, for example, FEI events.

Percentage of respondents for each answer option provided:

Response	Percentage of responses
Sales - yes	42.9%
Events - no	24.5%
Depends on size	32.6%

Respondents said:

“This would also put event organisers off having an equine section. Especially events who run with volunteers and not paid staff.” – Rare Breeds Survival Trust
“…the thoroughbred industry already records this information digitally and API feeds could populate the CED. In addition, the non-thoroughbred industry also records a great deal of relevant details that must be accessed via a suitable interoperable system, not double data entry.” – Retraining of Racehorses
“Presumably those in saying racing, already are able to comply with this requirement; but local unaffiliated events would find this too much of a burden and the risk would be that many local horse riding events that are the mainstay of pleasure and leisure riders will end. The vast majority are run by volunteers and it is already difficult to find sufficient volunteers.” – A horse owner
“Organisers of events such as shows should not be required to log details of horses attending. It is far too onerous and should not be their responsibility to do so. However, if a horse is changing ownership at a sales ring then yes it would be appropriate for the organisers to record this. It would help to keep ownership records up to-date but the normal rules of changing ownership should still apply to the seller and the new owner to confirm correct information.” – A breed society

Defra’s response

This proposal received a mixed response, with slightly more in support than not. We will engage with stakeholders to explore frictionless ways to achieve this, so that we can better support biosecurity and traceability, taking into account the concerns of respondents.

We will also examine which gatherings this would be most appropriate for and look at digital tools to ensure establish what would make the process as quick and easy as possible. We also need to consider events such as traveller horse fairs.

Registration and identification

To what extent would you, or would you not, support a standard requirement to register equines by 31 December in the year of birth (with only very limited flexibility for those born on or shortly before this date) or before a foal without its dam leaves its place of birth permanently?

Percentage of respondents for each answer option provided:

Response	Percentage of responses
strongly agree	57.11%
somewhat agree	22.08%
neither agree nor disagree	8.38%
somewhat disagree	6.09%
strongly disagree	4.82%
not answered	1.52%

Lead responses from stakeholder groups:

79.19% of respondents responded strongly agree and somewhat agree. This was the lead response for the following groups:
- breed societies
- breeders and studs
- equine vets
- horse owners
- industry bodies
- local authorities
- other
- other equine industry
- welfare organisations
9.9% of respondents responded neutrally. This was the lead response for the following groups:
- PIOs – non-studbook
10.91% of respondents responded disagree and somewhat disagree

This proposal seeks to address the current confusion over the rules surrounding the deadlines for first application to a PIO for an equine’s ID. In particular the variation in requirements across the Devolved Administrations of the UK.

Previous stakeholder engagement had suggested that it should be made a requirement to apply to a PIO by 31 December in the year of birth (with some limited flexibility when it is born on or shortly before the deadline) or before a foal, without its dam, leaves its place of birth permanently. We sought wider stakeholder views on this proposal.

Many respondents to this proposal agreed that it is a good idea, or essential, recognising the benefits of this to better data accuracy and the improvements to traceability and biosecurity this supports.

A large number suggested the need to standardise the dates and align with the Devolved Administrations’ requirements. Many respondents also provided suggestions for alternative timescales:

Percentage of respondents for each answer option provided:

Response	Percentages of responses
As soon as possible, at birth	31.4%
Notification at birth, full registration later	4.7%
By 14 days	3.5%
By one month	9.3%
42 days (same as human)	1.2%
By 2 months	1.2%
By 3 months	5.8%
Before weaning	1.2%
After weaning	2.3%
Within a few months	1.2%
By 6 months	13.9%

Respondents also indicated that a means of digital application would be preferable with suggestions that this could support an initial notification of the birth with identification only data, to be followed up with a full passport application including breed details by 31 December in the year of birth.

There are concerns in relation to bunching up of applications towards the deadline date and how PIOs would manage this, especially the smaller ones. Again, suggestions of a digital notification of birth shortly after a foal is born would help to reduce this burden.

Respondents also suggested further encouraging compliance by offering reduced fees for early registration, or fixed penalties for late registration.

It was also clear from the responses that there is significant confusion in the equine sector of the meaning of ‘registration’, with many believing that microchipping the equine satisfies this requirement. Other misunderstandings include a belief that an equine passport is only required if the equine will be travelling overseas.

Respondents said:

“Standardisation general improves understanding and will make enforcement easier.” – A Local Authority
“Such a requirement would enable PIOs to issue passports in compliance with the Defra regulations and may prompt breeders to get their applications for registration to the relevant breed society in a timely fashion”. - A breed society
“Foal registration within the Thoroughbred industry requires breeders to notify all foal births within 30 days of birth. Most births are fully registered with the stud book (in addition to notification) before the 31 July in the year of foaling and the remainder are all registered before the year end.” – Weatherbys, The General Stud Book

Defra’s response

This proposal received strong support and very little opposition. We will therefore work with stakeholders including the Devolved Administrations to further develop this. We will further explore a means of initial notification of birth by digital means followed by full identification to follow within a set timeframe.

We recognise that there is a significant degree of confusion and lack of awareness within the equine sector in relation to the legal requirements for obtaining an equine’s identification, enabling it to be entered on the Central Equine Database. Accordingly, Defra will work with industry to communicate the requirements.

To what extent do you agree or disagree that a simplified temporary identification is appropriate to deal with moving equines to the protection of welfare organisations, direct to slaughter or for another purpose?

Percentage of respondents for each answer option provided:

Response	Percentage of responses
strongly agree	29.19%
somewhat agree	26.9%
neither agree nor disagree	20.81%
somewhat disagree	8.12%
strongly disagree	13.96%
not answered	1.02%

Lead responses from stakeholder groups:

56.09% of respondents responded strongly agree and somewhat agree. This was the lead response for the following groups:
- breed societies
- breeders and studs
- equine vets
- horse owners
- industry bodies
- local authorities
- other
- other equine industry
- welfare organisations
21.83% of respondents responded neutrally. This was the lead response for the following groups:
- PIOs – non-studbook
22.08% of respondents responded disagree and somewhat disagree

This proposal is intended to address the situations where it is difficult to arrange appropriate identification under the current rules, particularly within a short timeframe.

As explained in the consultation document, examples include where an equine needs to be taken into the urgent care of a welfare organisation or where a semi-wild equine is being moved from its derogated area direct to slaughter. We wanted to understand stakeholder views on the introduction of a simple, temporary identification to cover these situations.

Many respondents in support of this proposal favoured it for use in welfare settings, whereby a welfare organisation takes an equine into their care which is not microchipped or has no or a defective passport (for example, a forgery).

A number of respondents expressed concern about fraud or abuse with the issue of temporary identification, often citing it as an easy means for an identification to be obtained for a stolen horse.

Several respondents stated that they would agree to this proposal provided safeguards were in place, such as such identification only being issued under government or welfare organisation supervision.

A number of respondents who felt that this proposal is not necessary also stated that full identification should always be required, especially for slaughter for human consumption.

However, as explained in the consultation document, obtaining identification under the current rules is difficult in some situations, for example, welfare cases.

Respondents said:

“Temporary IDs should only be generated when horses are taken into care using appropriate legislation and with the authority of the LA or police. An official case number, for example, should be required in order for the ID to be created. In such cases, it would seem to be simpler for temporary IDs to be issued by the LA or police overseeing the removal of the animals concerned” – Redwings Horse Sanctuary
“I don’t agree that a simplified process should be available for taking horses direct to slaughter but I would agree if they were being moved for protection purposes to welfare organisations.” – A stud
“We are often involved in situations where the welfare of donkeys are compromised and the donkeys need to move from the location in their best interests but do not have any or accurate ID. This would provide an avenue for compliance in these situations but any application must be able to be completed without being too onerous in circumstances where time is short and the welfare has to be the priority.” - The Donkey Sanctuary

Defra’s response

This proposal received strong support for welfare care purposes, with most opposition being in relation to movements of equines direct to slaughter. It is also clear from the consultation feedback that it would be of great benefit to welfare organisations to be able to apply for a temporary identification for equines taken into their care.

We will therefore work with welfare organisations and other key stakeholders to develop a means of temporary identification for equines in these circumstances, until the animal is rehomed at which point a full, formal identification would be obtained.

We will also consider appropriate safeguards to prevent fraud and abuse, for example, limiting the issue of such identification to recognised, established welfare organisations only, and or potentially a Local Authority or the police, with authentication and verification tools in place.

To what extent do you agree or disagree that a temporary identification should be digital and applied for using a standardised digital application?

Percentage of respondents for each answer option provided:

Response	Percentage of responses
strongly agree	24.11%
somewhat agree	20.56%
neither agree nor disagree	27.41%
somewhat disagree	6.85%
strongly disagree	19.04%
not answered	2.03%

Lead responses from stakeholder groups:

44.67% of respondents responded strongly agree and somewhat agree. This was the lead response for the following groups:
- breeders and studs
- equine vets
- horse owners
- industry bodies
- local authorities
- other equine industry
- welfare organisations
29.44% of respondents responded neutrally. This was the lead response for the following groups:
- PIOs – non-studbook
25.89 % of respondents responded disagree and somewhat disagree. This was the lead response for the following groups:
- breed societies
- other

In expansion to the previous question, we sought views on whether such a simple temporary identification should be digital and applied for using a standardised digital application process.

Many respondents in support of enabling any temporary identification to be digital, provided reasons of efficiency, speed, security, ease of use. Those who disagreed with the proposal largely quoted digital access and fraud and abuse concerns.

Respondents said:

“Given that temporary identification is likely to be applied for by organisations with the technical ability to apply for a digital temporary ID rather than individuals who potentially may struggle with technology and given the efficiency benefits represented by digital rather than paper applications, it seems clear that both application and the temporary ID should be digital in nature. The temporary digital ID must, of course, be tied to physical ID on the horse, i.e., microchip, and accessible to all organisations (such as RSPCA) that require verification of this ID- in the same way an equine’s permanent ID can be verified currently through microchip and passport.” – The RSPCA
“Quicker and easier so no delays on moving horses in need.” – Blue Cross
“Yes agree if the process was automated and instant- as a welfare organisation there is not often lead time for taking equines into our care. Having a clear and easy system to aid us in our identification of these animals at an early stage would be very helpful.” – Bransby Horses

Defra’s response

In support of the previous question, the proposal to make a temporary ID digital was supported by a majority. Accordingly in developing this proposal we will work with stakeholders to establish a digital identification for welfare care purposes.

Respondents’ concerns in relation to fraud and abuse of the system are addressed in the previous response, such as, that this would only be implemented for recognised, established welfare organisations and or potentially a Local Authority or the police, with authentication and verification tools in place.

To what extent do you agree or disagree that paper passports should be retained for use domestically in England, as well as to accompany international movements, e.g. to the EU?

Percentage of respondents for each answer option provided:

Response	Percentage of responses
strongly agree	50.76%
somewhat agree	18.02%
neither agree nor disagree	11.42%
somewhat disagree	5.84%
strongly disagree	9.9%
not answered	4.06%

Lead responses from stakeholder groups:

68.78% of respondents responded strongly agree and somewhat agree. This was the lead response for the following groups:
- breed societies
- breeders and studs
- equine vets
- horse owners
- local authorities
- other equine industry
- PIOs – non-studbook
15.48% of respondents responded neutrally. This was the lead response for the following groups:
- other
- welfare organisations
15.74% of respondents responded disagree and somewhat disagree. This was the lead response for the following groups:
- industry bodies

We are very keen to utilise the benefits of digital technology to support improved equine identification and traceability. However, we recognise that paper documents will, for the time being, continue to be required for movements to and from the EU and Northern Ireland (Wales also intend to continue following the EU in underpinning their identification regime with paper).

Therefore, we are not yet in a position to remove paper passports altogether.

However, we welcomed stakeholder views on the retention of paper passports for use domestically (aside from the need for them for travel to the EU).

The most popular reasons for supporting the retention of paper passport were provided as:

digital access concerns – ranging from people’s digital capability and confidence to power cuts, device shutdown and access to broadband in rural areas
paper being easier to view or use, for example, with the vet, at shows, and for when travelling with a horse
for entry to the EU for competition, racing, stud visits and other purposes
the belief that a paper format is more secure than digital

Some also suggested that they would prefer a digital identification but retaining the paper passport as a backup document. However, a strong concern with this route was that a dual system would be complex and that paper and digital records could become misaligned as one is favoured over the other by individual owners.

A number of respondents suggested making changes to paper identification rather than replacing it with digital, for example, the use of chips within the paper document to make it more tamper-proof and or the use of smart cards and QR codes to digitise elements of the paper identification system.

Respondents said:

“I would say the majority of people have their life on their phone these days. I would find it much easier to keep my horse’s passport details on mine, along with my other apps.” – A horse owner
“I think something should be available to accompany the horse, maybe something like the scotequine scheme I’ve heard of.” – A horse owner
“Working in a rural area, reliance on a digital platform will mean many animals cannot be identified stable side.” – An equine vet
“For accessibility and compliance with current international expectations, paper passports need to continue to be available to those who require them. However, paper passports are always going to have the problem that the information they contain is quickly out of date. Digital passports are therefore a superior solution and should be phased in, with hybrid options (for example, QR codes on passports that link to digital information, and/or plastic cards that can be carried in wallets and link to digital information) to be explored.” – A PIO

Defra’s response

There is strong support for this proposal, however a significant number of respondents agreed with retaining paper passports as a backup for digital identification (therefore supporting digital as a primary means of ID).

Many other respondents agreeing with the retention of paper passports for use domestically gave the reason that these are still required for EU movements, despite this purpose being ‘set aside’ for the context of this question.

This, together with the support expressed for digital ID-only identification in the earlier question has been taken into consideration in analysing the response to this question.

As explained in the consultation document, we expect paper identification to continue to be required for the time being, for the purposes of movements to and from the EU and Northern Ireland, as EU third country requirements. Wales have also indicated their intention to retain paper identification.

We must seek to align requirements across the Devolved Administrations to avoid the complexity and confusion whereby equines and their owner or keeper live across borders from one another, move from one administration to another, or live in one administration and have a passport from a PIO in another administration.

We therefore do not intend for the time being to move away from paper passports. However, in line with the response to the earlier question on the introduction of digital ID-only identification, there is clearly an appetite within the equine sector to embrace more digital technology to enhance and support equine identification.

Accordingly, we will further engage with stakeholders to explore the possibilities of digital identification without compromising the current paper passport system, and the need to retain these for the purposes already outlined.

To what extent do you agree or disagree that paper passports and the application forms necessary to obtain them should be in a standardised format?

Percentage of respondents for each answer option provided:

Response	Percentage of responses
strongly agree	58.88%
somewhat agree	21.07%
neither agree nor disagree	11.17%
somewhat disagree	3.81%
strongly disagree	1.52%
not answered	3.55%

Lead responses from stakeholder groups:

79.95% of respondents responded strongly agree and somewhat agree. This was the lead response for the following groups:
- breed societies
- breeders and studs
- equine vets
- horse owners
- local authorities
- other
- other equine industry
- PIOs – non-studbook
- welfare organisations
14.72% of respondents responded neutrally. This was the lead response for the following groups:
- industry bodies
5.33% of respondents responded disagree and somewhat disagree

The purpose of this question was to ascertain views from stakeholders on the standardisation of the application forms for equine passports, and of the passports themselves.

This proposal aims to assist enforcement authorities in identifying fraudulent equine passports, given the significant variation in size, colour and design of these documents (as well as their paper and ink quality – and other security features) and we propose to attempt to standardise these.

We also see benefit in standardising passport application forms on the same basis. We believe this would also be particularly helpful for owners registering with multiple PIOs.

The consultation response revealed strong support for standardising the format of passports and the application forms used to apply for them.

A large number of respondents commented that the current system of different PIOs with different forms and formats is confusing and that standardising would make it easier to apply and to find information in passports (particularly vets looking for medical treatment pages).

Others, including Local Authorities also stated that if passports were in a standard format, it would make it much easier to identify forgeries.

Some respondents were concerned that it will be difficult to standardise application forms due to differing requirements of different PIOs, mostly the difference between ID-only and breed society PIOs.

Respondents said:

“I would like to see paper passports disappear but in the meantime standardisation seems sensible.” – An equine vet
“It would make checks smoother, never understood why details were in so many different places in passports depending on who issued them!” – A horse owner
“The wide range of passport application forms and passports causes confusion and is time wasting, e.g., trying to work out which page to update passport info or having the vaccination info across two pages!” – An equine vet
“Some pages need to be standardised but PIOs should be able to have pages relevant to their breed/society - for example, stallion licensing, performance records etc.” – A breed society

Defra’s response

There was strong support for this proposal due to the complexity and disparity with the current system across a large number of PIOs.

We will therefore engage further with PIOs and other stakeholders to develop a standardised application form and passport format as far as possible, recognising differing requirements where appropriate.

We will also introduce a standard format for passports themselves.

To what extent do you agree or disagree that it should be possible to add a note in supplementary pages of identification-only passports to confirm that the equine is not eligible to be registered?

Percentage of respondents for each answer option provided:

Response	Percentage of responses
strongly agree	23.1%
somewhat agree	17.51%
neither agree nor disagree	38.07%
somewhat disagree	5.08%
strongly disagree	11.17%
not answered	5.08%

Lead responses from stakeholder groups:

40.61% of respondents responded strongly agree and somewhat agree. This was the lead response for the following groups:
- breeders and studs
- horse owners
- local authorities
- other equine industry
43.14% of respondents responded neutrally. This was the lead response for the following groups:
- equine vets
- industry bodies
- other
- PIOs – non-studbook
- welfare organisations
16.25% of respondents responded disagree and somewhat disagree

As explained in the consultation document, some breed societies produce identification-only passports, as well as studbook and pedigree passports for their breed. Equines that do not qualify as ‘registered’ equines (which in simple terms, are those entered or eligible for entry in the main part of a recognised studbook or are registered with an international organisation or national body thereof for racing or sport) must be issued with an identification-only passport.

This has been highlighted to Defra by some breed societies as a particular problem for buyers of some crossbred equines who are under the impression that they are buying a purebred ‘registered’ equine by the fact that the passport has been issued by a breed society, and not recognising that it is in fact an identification-only passport.

We want to explore how we can make it easier to identify from the passport whether or not an equine is entered on the passport-issuing breed society’s studbook. It has been suggested that adding a note on the passport cover could be a solution to this problem, to indicate that it is an ‘ID-only’ passport.

Currently, no changes are allowed to the passport cover. However, it is possible to add supplementary pages to identification-only passports. Additional coloured pages could be added which would be distinguishable from the rest of the passport, where a note saying this equine is not eligible for registration on the studbook of the passport-issuing breed society, could be added.

We also know that Official Vets (OVs) have experienced problems in determining definitively whether an equine is ‘registered’ or not, particularly when they come to sign off EHCs for international movements and they may have doubts about the authenticity of the accompanying passport.

This is an important distinction for international movements which demands different requirements for registered and unregistered equines.

It was evident from the consultation response that there is confusion in the equine sector over the meaning of ‘registered’. Many believe that this simply means the equine has a microchip, passport and or entry on the Central Equine Database.

Many respondents had also taken this question to mean that non-studbook PIOs could confirm in the ID-only passports they issue that an equine is not eligible to be entered in a studbook.

The consultation document clearly indicated that this question only related to breed society issued ID-only passports, which, carrying the breed society’s logo on the front, causes potential confusion to buyers, believing they are purchasing a purebred equine.

A number of respondents felt that this proposal was a good idea in aiding better clarification and provided some valuable suggestions for making it more apparent whether a horse is registered or not. These included:

clearly marking the front of the passport ‘ID-only’
colour coding passport pages or the cover to distinguish between ID-only and pedigree
watermark the background of the passport pages as ‘ID-only’
clearly marking the front of the passport ‘this equine is not a registered (name of breed) or ‘not eligible for registration into (breed name) studbook’
a note on the front page of the passport to explain the difference between a registered and unregistered equine
state on the front of the passport that the sire or dam are unregistered
state the reasons for non-eligibility

Respondents said:

“Great idea, then buyers are aware of the fact.” – A breed society
“This would be useful information for a new owner and needs to be held in the passport.” – A stud
“People not in the know can be duped into thinking the horse or pony must be fully registered as it has the breed society passport.” – A horse owner

Defra’s response

This proposal generated no strong feeling either way, however, more were in support than opposed, indicating an appetite across the equine sector to make it clearer on equine passports whether the equine is registered or not.

We will therefore explore ways to achieve this, both digitally, and on paper by engaging further with breed societies who issue ID only passports, and other connected stakeholders, on the most cost-effective means of doing so.

We will also seek to add an explanation in an equine’s ID of the difference between a registered and unregistered horse due to the significant degree of confusion over this across the equine sector.

Enforcement

Do you have any suggestions as to how enforcement of the equine identification rules could be improved?

We are currently considering the potential for making it easier for local authorities to enforce the provisions of the equine identification legislation. We were interested to hear stakeholder’s views of enforcement and how it could be improved.

Many respondents have commented throughout the consultation response that they feel current enforcement levels are inadequate, and in some areas, extremely low.

A significant number of respondents provided suggestions to improve enforcement and the most popular suggestions are indicated:

Percentage of respondents for each answer option provided:

Response	Percentage of responses
Better information to owners	12.1%
Mandatory spot checks	38.4%
Concentrate on specific groups	15.9%
Fixed penalties	16.8%
Resource enforcement bodies	16.8%

Better information to owners

Better information to owners included suggestions such as a national campaign of communication to help owners understand their legal responsibilities with regard to microchipping, obtaining an identification document and ensuring details are kept up to date and accurate on the Central Equine Database.

Suggestions also included working with the British Horse Society and including social media channels for a communications campaign. Many respondents also felt that more could be done in understanding the reasons for non-compliance to then help address these with education and guidance rather than heavy handed enforcement.

Mandatory spot checks

Mandatory spot checks included ID checking and microchip scanning at:

sales, auctions and fairs
ports
traveller settings, for example, sites and tethered horses
equines on wastelands or on urban areas
abattoirs
shows, events and competitions
veterinary treatments
livery yards to check new arrivals

Many also suggested this should be backed up with a system enabling officials (for example, Local Authority officers, show organisers or vets) to report non-compliance online. Others suggested not allowing entry to competitions or sales without valid equine identification.

Concentrating on specific groups

Concentrating on specific groups entailed increasing enforcement activity on those groups felt to be regularly non-compliant by the sector, rather than focusing on law-abiding horse owners. Such groups suggested were horse dealers, non-registered breeders, the traveller community and those equine owners who do not comply with the law.

Fixed penalties

Fixed penalties was felt by many to be a solution to improving enforcement, which would help to focus owners’ minds on their legal responsibilities. Fixed penalties were viewed as a relatively simple, proportionate response to non-compliance.

Resource enforcement bodies

Resource enforcement bodies was another popular suggestion. Many respondents felt that enforcement bodies are underfunded and understaffed, impacting their ability to enforce equine identification compliance. Some also suggested that making equine identification enforcement a duty rather than a power would make this area a higher priority for Local Authority resources.

Other suggestions to support enforcement included:

the ability for officials to report concerns of non-compliance online (including, Local Authorities, show and sale organisers and vets)
make the whole process of equine identification simpler and standardised, including digitising the system
addressing dealers and internet sales selling equines without passports
include photos in equine identification

Respondents said:

“More spot checks on horses in transport and at events - microchip scanners cheap and easy to use, most people can be trained to check a horse against a passport. Like most things, needs funding and boots on the ground.” – An equine vet
“I think shows are very lapse at checking passports as are transporters, with sheep etc you have to have a movement licence why can’t horses” – An equestrian centre
“There must be much better funding and training for all enforcement agencies, particularly for local Trading Standards offices , which are almost always totally uninterested in enforcing equine passport regulations etc.” – A breed society

Defra’s response

Respondents have provided a number of suggestions for consideration to improve enforcement of the equine identification regulations. We will consider these in further engagement with stakeholders, including communications in respect of the legal obligations on owners with equine identification.

It is clear from responses throughout the consultation that there is much confusion and lack of awareness across the sector of what the rules are.

We will also engage with stakeholders to explore ‘spot checks’ at certain venues and activities and explore digital tools to support this, as well as means of reporting non-compliance. It is clear from responses throughout the consultation that there is a lot of confusion and lack of awareness of an owner’s legal obligations with regard to equine identification.

We will therefore develop sector-wide communications and work with organisations such as the British Horse Council, breed societies, PIOs and other key industry stakeholders to support and further promulgate the messaging.

We will also work with industry to enable spot checking at certain venues and activities and explore how digital tools can enable reporting of non-compliance. Fixed penalty notices will also be considered.

Semi-wild equines

To what extent do you agree or disagree that the existing rules for the movement of semi-wild equines over 12 months old to slaughter should be changed?

Percentage of respondents for each answer option provided:

Response	Percentage of responses
strongly agree	16.5%
somewhat agree	9.9%
neither agree nor disagree	63.96%
somewhat disagree	1.02%
strongly disagree	3.3%
not answered	5.33%

Lead responses from stakeholder groups:

26.4% of respondents responded strongly agree and somewhat agree. This was the lead response for the following groups:
- industry bodies
- other
69.28% of respondents responded neutrally. This was the lead response for the the following groups:
- breed societies
- breeders and studs
- equine vets
- horse owners
- local authorities
- other equine industry
- PIOs – non-studbook
- welfare organisations
4.32% of respondents responded disagree and somewhat disagree

As explained in the consultation document, we know that there are particular challenges with the management and record-keeping of semi-wild equines in designated areas. We propose to work with these interests to make the arrangements as effective as possible in maintaining the desired biosecurity, whilst reflecting the unique nature of these populations.

The procedure for sending semi-wild equines to slaughter from designated areas changed in 2018, in line with EU legislation. These new arrangements, which include the requirement for all equines over 12 months old to have full identification, have been difficult for semi-wild interests to implement and have involved increased bureaucracy.

Semi-wild equine representatives have asked for the ‘pre-2009’ (sic) arrangements to be re-instated, such as, requiring only a rump sticker and declaration that the animal has not received any veterinary medication that would preclude it from the human food chain (this would clearly require the keeping of appropriate and accurate records).

We will need to ensure that whatever solution is ultimately agreed provides the necessary robust public health protection.

A number of respondents commented that the existing rules have not been implemented properly, rather than there being a need to change them. It has been suggested that Defra work with PIOs to ensure they understand the current legislation, that PIOs can produce passports for these equines older than 12 months and intended for slaughter without the need for a microchip (because in practice, microchips are being requested for these ponies (as for any other equine).

Microchipping these animals causes great difficulty both practically as they are not used to being handled, and economically given their low economic value).

Some respondents have cited that it is a waste of time and resources to issue a full passport before a semi feral pony leaves a derogated area to go to slaughter (often only a week before). They would like to see a return to the 2009 arrangements whereby a rump sticker and a derogation form is all that is required.

Respondents said:

“There is no benefit in passporting and microchipping a semi feral equine that is going direct to slaughter. A rump sticker issued by an authorised body should be sufficient. We do not consider the age of the animal to be of any relevance and would want the same process available to all semi feral equines.” – Semi-Feral Equine Interest
“there should be no age limit on this, every pony regardless of age should go on a rump sticker and disposal form issued the PIO, the same as cattle and sheep. currently a pony has to be microchipped as the passport cannot be issued without a microchip, although we have been told they can go on a passport without a microchip. please sort this out.” – Semi Feral Equine Interest

Defra’s response

This question generated no strong feeling either way from a significant majority of respondents, due to a feeling that it was not applicable to them.

Of the stakeholders that have an interest in this area, there was a clear indication of confusion with interpretation of the current legislation. In the first instance, we will clarify the legislation with semi-feral equine interests and PIOs.

We will further engage with the semi-wild equine interests on this issue. We recognise that obtaining a full passport is burdensome in proportion for the length of time that it will be required for the equine (for example, for a week before slaughter).

However, we must also balance this with public health protection by ensuring correct identification and traceability are in place.

As most horsemeat produced in the UK is intended for export, it must also be a consideration that robust identification is required to support market access overseas.

If you do believe the existing rules should be changed, should the pre- 2009 arrangements be reinstated, should a simpler temporary identification system be introduced, or do you have another suggestion?

Percentage of respondents for each answer option provided:

Response	Percentage of responses
Pre[sic]-2009 arrangements	7.36%
Simpler temporary identification system	25.38%
Other suggestion	22.34%
Not answered	44.92%

Responses to this question were:

7.36% of respondents selected pre(sic)-2009 arrangements
25.38% of respondents selected simpler temporary identification system
22.34% of respondents selected other suggestions
44.92% of respondents did not answer

To further expand on the previous question as to whether the current rules should change, we also wanted to know from stakeholders what they feel the rules should be.

Respondents said:

“Whatever needs to ensure ponies outside that definition cannot enter the food chain using a loophole” – a horse owner
“sort out issue of no chip, no passport for semi wilds” – Semi-Wild Equine Interest
“‘ID’ is open to wide interpretation and used to negate the derogation - i.e., seen as requirement for passport and chip” - Semi-Wild Equine Interest

Defra’s response

As with the response to the previous related question, we will further engage with the semi-wild equine interests on this issue.

Slaughter

To what extent do you agree or disagree that it should be possible to allow equines previously signed out of the human food chain to be re-instated at a future point?

Percentage of respondents for each answer option provided:

Response	Percentage of responses
strongly agree	9.9%
somewhat agree	13.71%
neither agree nor disagree	18.02%
somewhat disagree	9.9%
strongly disagree	44.42%
not answered	4.06%

Lead responses from stakeholder groups:

23.61% of respondents responded strongly agree and somewhat agree
22.07% of respondents responded neutrally. This was the lead response for the following groups:
- other
- PIOs – non-studbook
54.32% of respondents responded disagree and somewhat disagree. This was the lead response for the following groups:
- breed societies
- breeders and studs
- equine vets
- industry bodies
- local authorities
- other equine industry

Currently, equines that have been signed out of the human food chain cannot subsequently be reinstated. Many equines are signed out by owners who would not wish them to be consumed. However, if they are subsequently sold, the new owner may think differently.

The consultation document explained that we were interested in views on whether, in these circumstances, the decision could be reversed, particularly in the interests of the animal’s welfare at ‘end of life’.

The problem is that once the animal is signed out, any vet subsequently administering medicines that are not permitted in animals for human consumption, is no longer required to record them (in the passport or otherwise).

Therefore, to allow for the safe reinstatement of the animal, it would be necessary to introduce a strict legal requirement to ensure the application of any such medicine is fully recorded by the administering vet (preferably in the passport) regardless of the equine’s current food chain status.

The majority of respondents disagreed with this proposal, for a number of reasons. In the main, respondents were concerned that not all medicines are recorded once an equine is signed out and that it would be very onerous to back check a horse’s medication history prior to slaughter.

The alternative of recording all medicines to all equines and or a change in the way equines are treated so as not to affect their food chain status were viewed as detrimental. Others held a firm belief that once an equine is signed out it should stay out and many felt strongly that equines should not be in the food chain.

Some respondents expressed concern that this could potentially support a horsemeat trade and fuel theft, citing examples of equines being bought or stolen, fattened up, have their food chain status changed and then slaughtered for commercial gain. However, many respondents also felt that this proposal would help to ensure an equine’s welfare, especially at the end of life.

Respondents said:

“Horses change owners & owners should have the option to send to slaughter- there is a fate worse than death.” – A horse owner
“As a breeder I sign all of my stock out - and it should stay that way!” – A breeder
“For human health protection equines previously signed out of the human food chain must remain so.” – A horse owner

Defra’s response

This proposal attracted strong opposition, and accordingly, the current rules will remain in place. We will not allow equines currently signed out of the human food chain to be reinstated at a later date.

To what extent do you agree or disagree that we should remove the current ability for owners to sign an equine out of the food chain for any reason?

Percentage of respondents for each answer option provided:

Response	Percentage of responses
strongly agree	9.9%
somewhat agree	13.71%
neither agree nor disagree	18.02%
somewhat disagree	9.9%
strongly disagree	44.42%
not answered	4.06%

Lead responses from stakeholder groups:

16.5% of respondents responded strongly agree and somewhat agree. This was the lead response for the following groups:
- local authorities
18.78% of respondents responded neutrally. This was the lead response for the following groups:
- PIOs – non-studbook
64.72% of respondents responded disagree and somewhat disagree. This was the lead response for the following groups:
- breed societies
- breeders and studs
- equine vets
- horse owners
- industry bodies
- other
- other equine industry
- welfare organisations

We also sought views on removing an owner’s ability to sign their equine out of the food chain for any reason. This would simplify the matter of different owners having contradicting views on whether the equine should be eligible for slaughter for human consumption.

The majority of respondents disagreed with this proposal, with many citing reasons that it should be an owner’s choice whether their equine is signed in or out of the food chain. Many respondents disagreed with the concept of equines being in the food chain as they are predominantly regarded as pets and part of the family, or a strong partnership.

Some respondents expressed concern that removing this provision could encourage non-compliance with owners deliberately submitting passport applications late and or removing or destroying food chain status pages in order to automatically sign the equine out of the food chain.

Some respondents felt that the decision should be discussed with a vet so that the implications of signing in or out can be explained and considered.

Respondents said:

“If an owner can’t sign their foal out of the food chain they may be incentivised to apply late and so obtain a passport that is automatically signed out by the PIO”. – A PIO
“Many owners do not understand the long-term implications of signing out, and that it can actually lead to a worse welfare outcome for the equine”. – a breed society
“Owners need to be sure that their horse, who in most cases is considered as a family member, will not enter the food chain” – A horse owner

Defra’s response

This proposal also generated strong opposition, and therefore the current rules will remain in place. We will continue to enable equine owners to sign their equine out of the food chain for any reason.

Zootechnics

To what extent do you agree or disagree that it is appropriate to establish a clear distinction between identification and studbook records?

Percentage of respondents for each answer option provided:

Response	Percentage of responses
strongly agree	36.04%
somewhat agree	18.02%
neither agree nor disagree	23.6%
somewhat disagree	8.88%
strongly disagree	11.93%
not answered	1.52%

Lead responses from stakeholder groups:

54.06% of respondents responded strongly agree and somewhat agree. This was the lead response for the following groups:
- breed societies
- breeders and studs
- equine vets
- horse owners
- industry bodies
- local authorities
- other
- other equine industry
- welfare organisations
25.13% of respondents responded neutrally. This was the lead response for the the following groups:
- PIOs – non-studbook
20.81% of respondents responded disagree and somewhat disagree

The purpose of this question was to establish stakeholder views on whether it would be beneficial to have a clear distinction between identification and studbook records.

In the main, respondents agreed with the proposal that we should look to establish this distinction. Many respondents did express concern that identification and studbook records go hand in hand and indeed, zootechnical information forms part of the passport.

A number of respondents made the suggestion that identification only records could be digitised and issued soon after the application is made, with the full breed record to follow later when the physical passport is issued.

Similarly, others suggested identification records to establish ownership and basic details, with a digital link to studbook information.

Identification documents should be considered as the document which accompanies an equine throughout its lifetime. The studbook record is concerned more with how the equine came to be, and the legacy and bloodline it leaves behind.

Respondents said:

While the two records can function independently, they are inextricably linked, and every effort should be made to ensure that records held across both sectors are harmonised and complement each other.” – A breed society
“The legal requirement to provide identification records (and in a timely manner) can be compromised by studbook requirements concerning the recording of pedigrees and grading information. Digital solutions could provide an effective way of allowing PIO’s to provide identification documents very quickly, while providing time to verify and attach pedigree and grading records.” – A breed society
“As a PIO we believe both ID and studbook status can be dealt with together, as they are at the moment. Horse owners will not want to pay two fees, one for an ID passport and then separately for a breed registration certificate. It could double the costs for them. The risk to us as a PIO is they will apply for the passport and then not register. We will then lose much needed revenue but more importantly we will lose valuable blood lines from our breed registry.” – A breed society

Defra’s response

This proposal was strongly supported. We will explore development on whether a clear distinction between identification and studbook records can be made, but consideration must be given to the fact that current zootechnical legislation requires the Zootechnical Certificate to be included at Section 5 of the equine identification document.

To what extent do you agree or disagree that there is value in digitising studbook records?

Percentage of respondents for each answer option provided:

Response	Percentage of responses
strongly agree	38.83%
somewhat agree	30.02%
neither agree nor disagree	22.34%
somewhat disagree	2.03%
strongly disagree	2.28%
not answered	4.31%

Lead responses from stakeholder groups:

69.03% of respondents responded strongly agree and somewhat agree. This was the lead response for the following groups:
- breed societies
- breeders and studs
- equine vets
- horse owners
- other
- other equine industry
26.66% of respondents responded neutrally. This was the lead response for the following groups:
- industry bodies
- local authorities
- PIOs – non-studbook
- welfare organisations
4.31% of respondents responded disagree and somewhat disagree

We were also interested to know how stakeholders felt about the digitisation of studbook records.

Respondents in support of this proposal welcomed the easier access to look up breeding records. Others mentioned that it would help to protect the purity of the breed.

Many respondents expressed the wish to retain paper studbook records alongside digital versions and some suggested that breed societies could make a charge to have access to view digital records which would help their funding in protecting the breed they represent.

Respondents said:

“Owners/potential owners and breeders can access breeding information easily. My breed society has digitised records which members can access.” – A horse owner and breeder
“This would enable other registries from around the world to check pedigrees etc for imported animals.” – A breed society
“We strongly believe digitised and accessible studbook data drive breed improvement by making vital information accessible to all breeders (not just from our own studbook), traceability and accuracy are improved through digitisation and digital studbook records reduce cost and benefit the environment” - A breed society
“This improves availability of breeding records, pedigrees, progeny etc.to the general membership/ public, but ‘hard’ copies of the studbook must be kept in case of technological disasters, and a copy should be lodged with the British Library with an appropriate ISSN.” – A breed society

Weatherbys, The General Stud Book said “ we could list many more advantages to digitizing studbook records:

Digital records are easier to access than paper records.
Digital records are secure against fraud. Paper records are not.
Digital records can be amended/updated/added to etc. anywhere, 24/7.
Digital records can be processed by multiple parties remotely at the same time. “
Digital record capabilities can be reformatted/adjusted/added to/improved easily. The paper passport cannot. It is a fixed format.
Digital record dashboards can provide data any time to show trends, patterns, statistics etc. instantly
Digital records have a digital audit trail.
Payment can be made at the same time.”

Defra’s response

There is very strong support for digitising studbook records. Although we do not propose to require the digitisation of studbook records for the purposes of updating them, the studbooks themselves may of course choose to do so.

Impact of proposals

A statement of impacts has been prepared to explore the potential impacts on businesses, as a result of any proposals to introduce changes to legislation on equine identification and traceability. Following the consultation, an impact assessment will be prepared to measure impacts of legislative change more fully.

To assist the impact assessment, we asked respondents for some additional information about equine owners. There were some questions aimed at all respondents, and some for ‘private equine owners’ such as, non-business owners.

The results of these questions will be assessed separately from this report in the preparation of the above-mentioned impact assessment.

Consultation tool feedback

Overall, how satisfied are you with our online consultation tool?

Percentage of respondents for each answer option provided:

Response	Percentage of responses
Very satisfied	10.4%
Satisfied	41.6%
Neither satisfied nor dissatisfied	27.4%
Dissatisfied	6.9%
Very dissatisfied	4.3%
Don’t know	2.5%
Not answered	6.9%

Legal status

Some of these policy proposals will require changes to legislation.

Question 3

Annex 1 – list of respondents

Accepted Answer

This section contains a list of respondents who did not wish to remain anonymous

A number of respondents wished to remain anonymous, and they are not included in this section of the response document.

A number of private individuals and horse owners responded to the consultation and had stated organisations they are a member of (for example, breed societies, BHS or riding clubs) as their ‘organisation’. These have been counted as ‘private individuals’ rather than an official response from those organisations.

Names besides organisations are in the following list are those with an official role within the organisation or society:

826 Equine Studbooks Association
Abbeylands
American Miniature Horse Club Great Britain
American Quarter Horse Association, UK (AQHA)
Anglo European Studbook, British Breeding, World Breeding, Federation for Sport Horses
Appaloosa Horse Club UK
Arab Horse Breeder
Blue Cross
Bransby Horses
Breeders, various
British Connemara Pony Society
British Horse Council
British Morgan Horse Society
British Percheron Horse Society
British Showjumping
British Veterinary Association (BVA)
Caspian Horse Society
Chiltern Welsh Pony & Cob Association
Coomanore South Equestrian
Coosheenstud
Country Land and Business Association (CLA)
Department of Agriculture, Environment and Rural Affairs (DAERA)
Dartmoor Commoners’ Council
Dartmoor Hill Pony Association
Dartmoor Livestock Protection Society
Dartmoor Pony Heritage Trust
Dartmoor Pony Society
E-horse Equine CPD
Enborne EC
Equidentify
Equine Insight
Equine vets, numerous
Equiventus Ltd
Exmoor Pony Project
Fell pony breeder
Flydon Stud
Former Chief Executive Officer of British Eventing
Friars Hill Stables
Friends of the Dartmoor Hill Pony
Giselle Lockett Coaching Ltd
Harc Hope Animal Rescue
Hawarden Farms
Highland Pony Society
Horse Passport Agency Ltd
HorseHour
Horses and Ponies Protection Association (HAPPA)
HR Saddlery
Hurston Dressage & Eventing
IRT GB Ltd
JB Equestrian Services
Kingswood Equestrian Centre
Livery yards and riding schools, various
LiveryList
Llanarth Stud
Local Authorities, numerous
Manager and Coach (BHS)
Monarch Farm Riding Stables
National Pony Society
New Forest Pony Breeding and Cattle Society
Newcroft Stud
Northwest & Glenkee Shetland Pony Studs
Otter Creek
Pentafarn
Pentrefelin Stud
Pet ID Equine Ltd
Pet ID UK Ltd
Governing body of the sport of polo in the UK and Ireland, The Hurlingham Polo Association
Private individuals, numerous
Professional rider
Racehorse Trainer
Rare Breeds Survival Trust
Redwings Horse Sanctuary
Retraining of Racehorses (RoR)
Riding coach
Royal Society for the Prevention of Cruelty to Animals(RSPCA)
Serendipities Ltd
Seven Hills Stud
Slade Farm
Spanish Horse Ltd (BAPSH Ltd)
Sparsholt College
Sport Horse Breeding of Great Britain
Stable routes cic
Swarthdale Stables
The Arab Horse Society
The British Association for the Purebred
The British Hanoverian Horse Society
The British Horse Racing Authority
The British Horse Society
The Coloured Horse & Pony Society (UK)
The Donkey Breed Society
The Donkey Sanctuary
The Irish Draught Horse Society (Great Britain)
The Self Help Group for Farmers, Pet Owners and Others Experiencing Difficulties with the RSPCA (The SHG)
The Sports Pony Studbook Society (SPSS)
Traditional Gypsy Cob Association (TGCA)
Trakehner Breeders Fraternity
Unnamed studs and private yards, various
Weatherbys, The General Stud Book
Welham Stud
Welsh Pony & Cob Society
West Moor Stud
World Horse Welfare

Predominantly Rural area is where 50% or more of the resident population lives in rural areas or rural-related hub towns. Mainly Rural area is where 80% or more of the population lives in rural areas including hub towns. Largely Rural area is where 50% to 79% of the population lives in rural areas including hub towns. Based on population, not amount of countryside. ↩

Cookies on GOV.UK

Part 1 – Introduction

Context

Scope

Responding to the consultation

Audience

Part 2 – consultation results and the government response

Proposals

Central Equine Database (CED)

To what extent do you agree or disagree that owners or keepers should be able to update all identification records on the CED (not just microchip, food chain status and deaths), digitally (and to submit supporting documentation in the same way)?

Defra’s response

Digital access

PIO Income

Defra’s response

To what extent do you agree or disagree that changes to studbook or breed details should not be made digitally and continue to be notified direct to the relevant PIO as currently?

Defra’s response

To what extent do you agree or disagree that vets should be allowed to update the CED digitally for the purpose of recording microchips, vaccinations and other medical treatments?

Defra’s response

Are there any other relevant groups that you think should be allowed to update the CED digitally (please specify)?

Defra’s response

To what extent do you agree or disagree that the release of historic ownership data contained on the CED to future owners should continue only to be available with the consent of the current owner?

Defra’s response

To what extent do you agree or disagree that both the current and new owners should be responsible for notifying a change of ownership?

Defra’s response

To what extent do you agree or disagree that the time limit for notifying the PIO of a change of ownership should be reduced to 14 days?

Defra’s response

To what extent do you agree or disagree that the time limits for all notifications to PIOs of changes to an equine’s records should be standardised?

Defra’s response

To what extent do you agree or disagree that other databases e.g., those belonging to PIOs, the horseracing and thoroughbred sectors, the Devolved Administrations and the Republic of Ireland should be allowed to update the CED via APIs?

Defra’s response

To what extent do you agree or disagree that we should allow APIs to link data from the CED to other electronic systems used to support e.g., export health certification?

Defra’s response

Traceability

To what extent do you agree or disagree that it should be made a legal requirement to record the habitual location of each equine on the CED?

Defra’s response

To what extent do you agree or disagree that some, or all, temporary locations should also be included on the CED?

Defra’s response

To what extent do you agree or disagree that organisers of events, sales, etc. should be required to keep a record of the equines involved?

Defra’s response

To what extent do you agree or disagree that organisers of events, sales etc. should also be required to log relevant details digitally on the CED (e.g., via the Digital Stable)?

Defra’s response

Registration and identification

To what extent would you, or would you not, support a standard requirement to register equines by 31 December in the year of birth (with only very limited flexibility for those born on or shortly before this date) or before a foal without its dam leaves its place of birth permanently?

Defra’s response

To what extent do you agree or disagree that a simplified temporary identification is appropriate to deal with moving equines to the protection of welfare organisations, direct to slaughter or for another purpose?

Defra’s response

To what extent do you agree or disagree that a temporary identification should be digital and applied for using a standardised digital application?

Defra’s response

To what extent do you agree or disagree that paper passports should be retained for use domestically in England, as well as to accompany international movements, e.g. to the EU?

Defra’s response

To what extent do you agree or disagree that paper passports and the application forms necessary to obtain them should be in a standardised format?

Defra’s response

To what extent do you agree or disagree that it should be possible to add a note in supplementary pages of identification-only passports to confirm that the equine is not eligible to be registered?

Defra’s response

Enforcement

Do you have any suggestions as to how enforcement of the equine identification rules could be improved?

Better information to owners

Mandatory spot checks

Concentrating on specific groups

Fixed penalties

Resource enforcement bodies

Defra’s response

Semi-wild equines

To what extent do you agree or disagree that the existing rules for the movement of semi-wild equines over 12 months old to slaughter should be changed?

Defra’s response

If you do believe the existing rules should be changed, should the pre- 2009 arrangements be reinstated, should a simpler temporary identification system be introduced, or do you have another suggestion?

Defra’s response

Slaughter

To what extent do you agree or disagree that it should be possible to allow equines previously signed out of the human food chain to be re-instated at a future point?

Defra’s response

To what extent do you agree or disagree that we should remove the current ability for owners to sign an equine out of the food chain for any reason?

Defra’s response

Zootechnics

To what extent do you agree or disagree that it is appropriate to establish a clear distinction between identification and studbook records?

Defra’s response

To what extent do you agree or disagree that there is value in digitising studbook records?

Defra’s response

Impact of proposals

Consultation tool feedback

Overall, how satisfied are you with our online consultation tool?