Policy paper

Review of the pig industry structure in Great Britain (GB): government response

Published 14 March 2024

This was published under the 2022 to 2024 Sunak Conservative government

Applies to England, Scotland and Wales

Introduction

This document provides a summary of responses to the Review of the Great Britain Pig Industry Structure, which concluded in February 2022.

Defra commissioned the Agriculture and Horticulture Development Board (AHDB) to undertake a review of the Great Britain (GB) Pig Industry Structure and The Pigs, Records, Identification and Movement Order (PRIMO) 2011 legislation.

The purpose of the review was to better understand how changes in the structure and operation of the industry in the past decade could impact the effectiveness of the current legislation.

Defra carried out analysis of the 48 recommendations presented in the review. This document sets out the government’s response to the review.

Executive summary

Livestock identification and traceability are pivotal in containing and controlling disease outbreaks and managing meat related food safety incidents. This report, commissioned by government from the AHDB, provides valuable insight into the structure and operation of the GB pig industry, since the advent of current traceability legislation whilst simultaneously evaluating the effectiveness of our legislation and the current identification and traceability system for pigs in England.

The report was commissioned following concerns that changes in the pig industry over the past decade might have had a negative impact on the effectiveness of the current legislation in preventing or helping address disease outbreaks. Government welcomes the recommendations put forth in the report, many of which are in line with our own ambitions to increase our disease control capability, whilst considering the impacts any proposed changes would have on industry.

The current legislation is The Pigs (Records, Identification and Movement) Order 2011 (PRIMO), as amended for England, Wales, and Scotland, which set out requirements to register pig holdings, identify pigs and report their movements between holdings. The legislation applies equally to keepers rearing pigs for the food chain, hobby keepers, and those who keep pigs as pets.

The relevant Disease Control Orders for England, Wales and Scotland set out the 20-day standstill requirement preventing pigs moving off a holding, following the arrival of pigs from another holding. This allows for sufficient time for a disease to be recognised by the livestock keeper and reported to the authorities where disease was introduced onto their farm via an infected animal. Commercial holdings with a continuous one-way production system may be approved to operate under a derogation from the 20-day standstill to allow such supply chains to function effectively.

It is the responsibility of livestock keepers to correctly identify their pigs, and record and report movement within the statutory timeframe. Adherence to traceability requirements contribute to the effectiveness of GB’s ability to prevent and/or control disease outbreaks. Policy developments in this area could therefore have a direct impact on industry operations and their operational needs and must be carefully considered so that legislation and processes complement each other.

As a result of the COVID-19 pandemic, the pig industry has faced an unprecedented number of challenges, including the loss of exports to the Chinese market for some processors, disruption to CO₂ supplies, and temporary shortages of labour in abattoirs. This coincides with a 9% increase in the number of pigs in England between December 2020 and December 2021 to 4.1 million pigs, which was the largest December pig population in England for 20 years. This resulted in a significant backlog of pigs on farms by winter 2021/2022. This accumulation of challenges indisputably, and understandably, impacted pig farmers both financially and emotionally. Any policy changes within the pig sector must involve careful engagement with industry to minimise additional burdens.

Over the next few years, as part of Defra Group’s Livestock Information Transformation Programme (LITP), Defra is modernising and replacing the aged and separate species systems that farmers and livestock businesses in England to record and report the movements of their animals of various species to comply with traceability legislation. The first stage of this work was the transition in March 2022 of the existing sheep, goat and deer movement reporting service onto a new service platform - the Livestock Information Service (LIS). This service is being developed by Livestock Information Limited a joint venture between Defra and the AHDB. They are supported in this work by an executive number of industry stakeholders - the Traceability Design User Group (TDUG). LIS will become a multi‑species service as we also move our separate cattle and pig traceability services onto a new platform in the coming years and use LIS to record other information needed to support wider Defra policy objectives.

There is the complementary need for industry to effectively run their pig businesses, and for the government to understand and manage animal disease risks. For the government to implement effective disease controls, it must have clear knowledge of livestock keepers, their holdings and livestock and basic information regarding animal transportation, with all this data being easily accessible to those that need it (for example to the Animal and Plant Health Agency (APHA)) in as near to real time as possible. To obtain this data, Defra requires keepers in England to register their details, use appropriate means of identification and notify Defra of any change in their circumstances. This is achieved through a comprehensive legal framework, and data systems that allow the collection of data to be used and analysed.

Defra’s objective to build a multi-species LIS service with improved functionality will provide a more effective movement reporting system that collates the required information and creates a valuable dataset to underpin the delivery of statutory requirements. Therefore, ensuring effective traceability to maintain high levels of disease control across GB.

Several of the recommendations in this report will be considered in a longer time frame because their development is dependent on the transition of pig movement reporting data from eAML2 to LIS, which is likely to be the third species group to transition onto LIS.

In the interim, the government identified two pieces of work that we have taken forward:

Raising awareness of keepership registration & de-registration requirements

• Defra has utilised a public communications campaign, aimed at all pig keepers, to raise awareness of the importance of registration and de-registration.
• This aims to increase the number of keepers that update their registration details, including end-of-keepership registrations reported to APHA.
• We worked closely with the Defra communications team to develop this initiative, ensuring that the messages are accessible to all keepers, from those with commercial holdings to pet pig keepers with one pig.
• We have asked veterinary surgeries to display messaging, as well as Local Authorities, relevant trade associations, organisations within the pet pig sector, and the eAML2 website.

Raising awareness of biosecurity standards

• Through the same communications, Defra promoted awareness of the legal obligations of keepers to ensure they meet strict biosecurity standards.
• Messaging included information on good biosecurity practice to promote disease prevention.

Of the 48 recommendations within the report, covering keepership registration, identification, movements, imports/exports, businesses working within an approved pyramid and eAML2, the majority require long term reform that necessitate legislative or structural changes. The main ambition of the government is moving pig reporting from eAML2 to the new multi-species LIS system and to use the system to record other traceability data. This means that a significant portion of the recommendations will take time to deliver as we work towards that new system.

Government response

Read the Review of the GB Pig Industry Structure

Response to each recommendation:

Records and registration

Recommendation 1

Revise the current legislation to make it a legal requirement for all pig owners to register and reregister pigs on an annual basis.

Government response

Defra is committed to supporting pig keepers to comply with their responsibilities to control disease outbreaks.

The current legislation in England is the Pigs (Records, Identification and Movement) Order 2011 (‘PRIMO’) Article 4 (Notification of holdings) which states that:

(1)    An occupier of a holding who begins to keep pigs on that holding, and any person who takes over the occupation of a holding where pigs are kept, must notify the Secretary of State within one month of—

(a) their name and address; and

(b) the address of the holding.

(2)    On receipt of a notification under paragraph (1) the Secretary of State must issue a herd mark.

(3)    The occupier must notify the Secretary of State of any change to the information in paragraph (1) within one month.

(4)    The occupier must notify the Secretary of State within one month if they cease to keep pigs at any holding notified under paragraph (1).

Similar obligations exist under the equivalent Scottish and Welsh Orders.

Pig keepers are therefore by law required to register their holding with the relevant Rural Payments body: Rural Payments Agency (RPA) in England, Rural Payments Wales and Payments & Inspections Division (RPID) in Scotland. They must also inform APHA, who should also be notified of any changes in circumstances.

Any legislative changes in England for pig keepership/holding registration requirements of PRIMO will require a strong evidence base and consultation with the industry. Defra will look at this in detail as a long-term option when the current movement reporting service transfers from the electronic Animal Movement Licensing system (eAML2) to the LIS as part of Defra’s LITP).

In the short-term, the government developed a communications campaign aimed at pig keepers to further educate and raise awareness on the rules pertaining to registrations, biosecurity, and traceability, which went live in May 2023.

Recommendation 2

As part of the legal registration process the information required from all commercial pig owners should include the details listed in the Top 10 questions outlined in the report from the Pig Health and Welfare Council.

Government response

The government notes this recommendation for the collection of wider data about commercial keepers when they register. The government will consider this in greater detail when the current movements reporting service transfers from eAML2 to LIS as part of Defra’s LITP. We will work closely with the RPA, APHA, the TDUG and the Pig Health and Welfare Council (PHWC) to agree how we might implement this after the eAML2 service transitions to LIS. The government will ensure transparent consultation and engagement with stakeholders ahead of any registration policy changes for keepers/owners.

Recommendation 3

As part of the registration process for pet pig keepers, hobby farmers, city farms and small holders there needs to be some assessment of the suitability of the owner and premises to keep pigs (for example, no pigs in inner city blocks of flats). The information required should be less than that for the commercial holdings but include that currently collected by APHA and those sections of relevance from the Top 10 questions when issuing the herd mark.

Government response

The government is committed to upholding the UK’s high animal welfare standards.

The Animal Welfare Act 2006 makes it an offence to cause any unnecessary suffering to an animal or to fail to meet their welfare needs. This includes the need for a suitable environment. Pet pig keepers, including their breeders, have an important responsibility for meeting this requirement. Keepers of pigs must comply with Schedule 1 of the Welfare of Farmed Animals (England) Regulations 2007: [S.I. 2007/2078](https://www.legislation.gov.uk/uksi/2007/2078/schedule/1]

The Animal Welfare (Licensing of Activities Involving Animals) (England) Regulations, introduced in 2018, require anyone in the business of selling animals as pets, to obtain a licence from their local authority. Licensees must meet strict statutory minimum welfare standards which are specified and enforced by local authorities. These Regulations are supported by statutory guidance on animal activities licensing for local-authorities

Defra’s Statutory Code of Practice for the Welfare of Pigs includes further guidance on the legal requirements and refers to pigs kept as pets. Whilst some provisions of this Code are specific to farmed pigs kept for breeding and fattening, others may offer valuable insights relevant to anyone who keeps pigs, including those keeping companion/pet pigs:

In the short-term, the government developed a campaign to provide guidance to pet pig keepers on their legal responsibilities regarding registration, traceability, and biosecurity, in addition to ensuring that the welfare needs of their pet pig(s) are met.

The current PRIMO legislation on registration, identification, and traceability of pigs, must continue to be followed and applies to all pigs, wherever they are kept, and whether they are kept as pets, as a hobby or for commercial purposes. Guidance on these requirements is on GOV.UK:

Keeping pigs in England

Report pig movements

Recommendation 4

Develop an online system to enable owners to enter their registration details, record their annual pig numbers and modify their information as necessary. Link the system to the existing eAML2 in England or its replacement in due course.

Government response

The government is committed to working with industry, APHA and other external stakeholders to ensure pig keepers can easily register where they keep their animals and record and report movements.

Defra is currently developing a new multi-species LIS for the purpose of reporting movements. Sheep movement reporting has transitioned onto LIS, with cattle moving on to the service by the end of 2024, to be followed later by pigs.

Thereafter, the service may have the capacity to either interlink or feed data across to update other relevant services.

The government will look into creating a consistent approach to the keepership registration process. We have not yet determined whether LIS will be the future system for keepership registration or whether that data will flow through from an existing data repository. 

Recommendation 5

Design a system that is compatible with LIS. Potentially merge into LIS the RPA, Defra, and APHA animal related registration systems, creating a one shop stop with all of the data in one place or alternatively set up a hub which can bring information together.

Government response

The government is committed to working with industry, APHA and other external stakeholders to ensure an improved facility for pig keepers to register their keepership and record their pig movements, as it develops a pig service within LIS. The service may have capacity to either interlink or feed data across to update other relevant services. The government will look to create a consistent approach to the keepership registration process.

Recommendation 6

Ensure all databases must be able to transfer information seamlessly, accurately and in a compatible format. This is critical with eAML2 and ScotEID and even more so with proposed development of the LIS in England, EID Cymru system in Wales and the changes to ScotEID.

Government response

The responsibility for Animal Health and Welfare controls, including livestock traceability, is devolved to Scotland and Wales where each of the Devolved Administrations (DAs) make their own legislation. The government is committed to working in partnership with the DAs to ensure each Administration’s planned multi-species traceability services will interface with each other for cross-border moves, which will enhance traceability.

Livestock Information Limited (LI Ltd.) is currently developing a ‘UK View’ function, which will have the capability to show an animal’s UK wide movement history if it has crossed borders. It will source data from England, Scotland, Wales and Northern Ireland related to births, deaths, movements (inter and intra-nation, including imports and exports), holdings, and keepers for species including sheep, goats, deer, bovine and pigs. This will ensure fast and reliable access to a consolidated UK dataset, providing a complete picture of livestock movements in the UK.

There is a commitment from all administrations to work together to ensure that each administration has a full picture of animal movements across the UK.

Recommendation 7

Further review the use of the Temporary Land Association (TLA) for pig holdings to assess risk and whether the distance should be reduced to 3km taking into account potential issues for outdoor pig units.

Government response

Livestock holdings can be made up of parcels of non-contiguous land up to 10 miles (16.09 km) apart. This distance limit for all species was agreed 10 years ago in consultation with industry (sheep holdings previously had a 5-mile rule).

A holding can be comprised of a mixture of permanent or temporary land.   

The government intends to consider this recommendation through a review and a consultation with the industry. We will then work closely with industry, APHA, TDUG and other stakeholders, on any proposed measures exploring issues and evidence to develop workable solutions which will generate good disease control outcomes. However, any proposed changes will be in the long-term and assessed against the impact on the industry to prevent any unintended consequences on the sector.

Recommendation 8

To ensure that pet pigs are registered, satisfactory ongoing recording or registration is required. This should be focusing on education and raising awareness via publicity and contacting those selling pigs especially via the internet.

Government response

Defra welcomes the recommendation for raising awareness and education of the responsibilities amongst pet pig keepers, including those who sell pigs to those who will then keep them. All pig keepers, including pet pig keepers, are by law required to register the location where they keep their pigs with the relevant Rural Payments body and inform APHA of any changes in circumstances.

The Animal Welfare (Licensing of Activities Involving Animals) (England) Regulations, introduced in 2018 and Scottish and Welsh equivalents, requires anyone in the business of selling animals as pets, to obtain a valid licence from their local authority. Licences must meet strict statutory minimum welfare standards which are enforced by local authorities, who have powers to issue, refuse or revoke licences. The 2018 Regulations are supported by statutory guidance on animal activities licensing for local-authorities

To support the delivery of this recommendation, Defra developed a communications strategy to deliver clear messaging to pet pig keepers on their legal obligations to register where they keep their animals, the importance of reporting their movements, and to increase compliance with those obligations. This messaging has been disseminated via English and Welsh Local Authorities, relevant trade associations, organisations within the pet pig sector, eAML2 and veterinary surgeries. The government is hopeful that targeted messaging will support an improvement in compliance.

Identification

Recommendation 9

The current system has disadvantages but using ear tags and tattoos is acceptable at present. In the longer term there should be a move to electronic tagging of pigs from the time they leave their holding of birth to ensure full traceability unless the current work on DNA tracing or facial recognition can deliver improved traceability. An economic assessment of introducing electronic tagging should be carried out.

Government response

All pigs moving to slaughter, and any pig over 12 months and moving anywhere, must be marked with either slap marks, an ear tattoo or an ear tag displaying the unique official herd mark of the holding when moving off the holding.

All pigs, regardless of age, moving to Artificial Insemination (AI) centres, to shows or for export must be individually identified (an ID number following the alpha numeric holding herd mark).

All pigs, regardless of age, moving to a market are required to be permanently identified, with the herd mark.

While the government recognises the opportunity this recommendation presents, any proposed changes will be assessed against the impact on industry, the cost of implementation and long term-benefits.

The government will review the data currently available, including an AHDB led project entitled “The End2End Traceability and Automated Data Capture”; which aimed to explore the value of automated data capture using UHF EID (Ultra High Frequency Electronic Identification) ear tags and maternal DNA traceability in the pork supply chain, specifically in outdoor pigs.

The government will work with industry as it considers how pig identification may evolve over the coming years. That may happen as, or after, pig movement reporting transitions over to LIS. This may involve trials, as well as formal consultation and continuous ongoing discussions with the sector.

Recommendation 10

There is currently a need to include electronic identification tags as an additional and acceptable method of officially identifying pigs. Legislation should specify that tags include the official herd mark and a unique individual identification number in all cases.

Government response

PRIMO (Article 7) sets out the legal requirement to tag, tattoo or mark pigs aged 12 months or older with the official herd mark of the departure holding, before they can be moved (with the number of animals also being included in the movement report).

There is an exemption from having a permanent mark for piglets aged less than 12 months when moving between two farms, whereby temporary paint marks are permitted (PRIMO Article 8).

PRIMO also states that pigs are not required to be individually identified nor their moves reported at individual identification level, except for moves to:

1. an exhibition or show
2. an artificial insemination (AI) centre or any other breeding location
3. another country (within, or outside the EU)

Therefore, movement reporting is mostly at batch level using the departure holding’s herd mark, with most movements pre-notified to eAML2 in England and Wales.

This recommendation describes a longer-term opportunity to increase our efforts to control disease outbreaks via individual identification. The government will consider this recommendation in detail as part of long-term policy thinking.

Recommendation 11

The issue of holes in the ears when exporting to China needs to be addressed both by dealing with the Chinese authorities but also reviewing the requirements for exports from Denmark and the Netherlands. There is a need to assess whether ears with holes would be prohibited or whether there would be a price reduction compared with ears without holes. The current trade is worth around £2.7 million (AHDB July 2021). (Since this report was written further information on exports to China has been obtained and is shown at Appendix 5 in the Review of the GB Pig Industry Structure

Government response

Pig keepers must identify pigs they want to export with an ear tag or tattoo that displays:

1. UK, (with a GB suffix added if identified in GB - for export to the EU or NI)
2. the animal’s herd mark
3. an individual ID number

Most (not all) pigs being slaughtered for the UK food chain are identified with slap marks (a type of tattoo applied on each front shoulder). The heads of cull sows with ears with holes or ear tag damage can be exported to the EU, where the ears with holes/damage would not be sold in retail but used in catering or manufacture. Whole heads can also be exported to China (c.10m p/a) where ears will commonly be consumed.

A minority of UK pigs will have ear tags at the time of slaughter. The British Embassy in Beijing have engaged with the General Administration of Customs of the People’s Republic of China (GACC) who have confirmed that ears from pigs slaughtered in the UK where they tagged (i.e. that (may) have a hole in them) will remain eligible for export to China. It is also understood that domestically, all live pigs in China need to have ear tags applied by 30 days old. 

The trade of pig ears to China should not therefore be interrupted if UK authorities were to require all pigs to have ear tags at the time of slaughter. The application of EID and/or conventional ear tags for all pigs, were that to be proposed in future, may potentially reduce their export value to the large and lucrative Chinese market.

The government recognises that the market export values of pig ears are based on China’s likely preference for ears without holes, and this may alter in the future if more pigs are ear-tagged. UK exporters of pigs ears to China will therefore need to continue to monitor and evaluate trends in that commercial market.

Under current market conditions, it is also reported that there is a difference in the value of consignments of tagged pig ears exported to China, when compared with pig ears that have not had an ear tag applied. Current market intelligence estimates this difference to be 200USD/tonne.  

The UK government will review how to improve the identification and traceability of pigs in the future. This will include exploring whether and how individual identification, including via EID, might work in practice and if there are any other considerations such as the economic impact that might have on trade of products such as ears with overseas markets.

Recommendation 12

It would be appropriate to have further discussions with the 3 major production companies (integrators) to assess whether they would prefer to develop their own systems or to have a uniform system across GB. Also, to ensure they are involved in any developments of the official livestock movements systems. A uniform and compatible system would be the most appropriate.

Government response

Defra will work with the major integrators and utilise wider data available within the integrated sector.

The government agrees that a future/revised regime for pig identification should ideally be harmonised as far as possible across GB Administrations. This includes compatibility between the intended new LIS traceability service for pigs in England, its equivalent services in the Devolved Administrations, and industry databases that may connect to them in order to report movements.

LIS is being designed in collaboration with industry via TDUG and others with an interest in livestock traceability. At present, its focus is on improvements to cattle traceability (expected to be operational by the end of 2024) to ensure the move onto the LIS platform is seamless. 

Defra will support discussions between integrators and LI Ltd. on the future development of LIS to inform their deliberations on compatibility with their own system or systems that they may develop. Close cooperation with stakeholders and the Devolved Administrations will also be important.

Recommendation 13

There must either be a voluntary arrangement or a compulsory requirement that where electronic tags are used and if the information is stored on private databases that these are compatible with the statutory transfer of the information to the official government livestock movement databases.

Government response

Also with recommendations 10-12, the government is committed to improving livestock traceability to allow effective management of a disease outbreak. EID options in the long-term will be considered and we intend that these will be subject to a public consultation if proposed. We will also work closely with third party developers to better understand how Application Programme Interfaces (APIs) from commercial software applications, that may store pig ID and movement data, can be compatible with the government’s livestock movements databases.

Recommendation 14

There should be a phased approach to any changes to identification in order to allow for technology to be fine-tuned and encourage industry engagement to maximise the use of the data.

Government response

The government welcomes this recommendation and agrees that future policy changes to pig identification should follow a phased approach to ensure industry have the necessary time to deliver and comply with any such changes. The government intends to consult with TDUG and other relevant stakeholders in due course.

Recommendation 15

In the short term as the pig industry already uses tags in their breeding stock a first step could be to make the electronic tagging of gilts, sows and boars compulsory by introducing legislation to that effect. A full economic assessment would be needed as there could be significant cost involved with a compulsory requirement.

Government response

The government will consider this recommendation including its impact on industry, long-term value for traceability, and the cost of implementation. The government intends to carry out research to develop an evidence base to inform this consideration.

Recommendation 16

Agreement is needed on the use of UHF or LF tags so that the corresponding readers on lorries and in abattoirs can read the tags. Discussions should be held with the pig industry and the tag manufacturers to decide which RFID system should be used. Once this is decided the frequency could be included in the legislation requiring the use of electronic tags. Note in the sheep industry legislation requires the use LF tags. An economic assessment of each system should be carried out.

Government response

Defra recognises the importance of a uniform approach across GB as to what transmission technology should be chosen if EID is introduced for official pig identification.

At present, Low Frequency (LF) transponders are the only option permissible for sheep and goat identifiers, since sheep EID was introduced in the EU in 2010 for member states with large national flocks. LF compared to UHF, where there is not yet an international standard for UHF, is being examined in relation to the impending introduction of cattle EID as part of LITP.

The introduction of pig EID, if agreed, is likely to be in the long-term and would be assessed against the impact on the industry to prevent any unintended consequences on the sector.

Close cooperation with TDUG (which includes representatives from the animal ID manufacturers) and other stakeholders, including the Devolved Administrations, will inform the development of future identification policy for pigs.  

Recommendation 17

In the longer term if the pig industry increasingly begins to use electronic tags a decision may be needed to introduce legislation that all pigs leaving the farm of birth must have electronic tags but unless there is agreement on the frequency to be use this could difficult

Government response

The government engages regularly with external stakeholders to inform policy development.

The government will continue to monitor EID developments in the pig sector. We recognise the importance of a uniform approach, and an in-depth review of the available transponder technologies may be required. Any legislative changes would require a substantial evidence base, a consultation with the industry, and an economic impact assessment.  

Recommendation 18

All pet pigs should be microchipped along the same lines as microchipping for cats and dogs and a single central register should be developed and used to ensure no microchipped pig enters an abattoir.

Government response

Pet pig keepers must follow the same identification, record keeping, and movement reporting rules as pig farmers (including hobby keepers) to support effective and accurate traceability in the event of a disease outbreak. Pet pigs must therefore be tagged, tattooed or marked as set out in PRIMO before any move away from where they are kept. These non-electronic methods of identification can be seen and read visually without specialist microchip reading equipment.

If a pet pig is to be taken for a walk, a walking licence must first be obtained from APHA and the pig must be kept on a route approved by APHA. Pet pig movements are likewise also subject to standstill rules in the unlikely event that they move to/from locations where livestock reside.

Current guidance on keeping pet pigs, including supposed ‘micropigs’ must be followed:

The government will consider this recommendation. Economic assessments and a consultation with industry and companion animal bodies are likely to be needed to inform policy development.

As recommended elsewhere in the report, the government accepts that further education and awareness on identification and traceability rules is beneficial for pet pig keepers. A communication campaign launched in May 2023 informs pet pig keepers on how to support traceability, implement good biosecurity, and to protect the health of their pet pig(s).  

Recommendation 19

The identification requirements for pigs being imported from or exported to EU member states need to be updated in the legislation. Clarification is required on whether EID tags would be acceptable for export and if so which system LF or UHF is to be used.

Government response

The Border Target Operating Model (TOM), published on 29 August 2023, provides strategic direction for the implementation of controls on imports to Great Britain in keeping with the 2025 UK Border Strategy and includes a framework for how checks will apply to commodity types. It aims to protect the UK’s animal and plant health, striking a balance between minimising burdens on business while safeguarding biosecurity and reducing risks to public health.

The development and operationalisation of the TOM will continue to evolve with input from stakeholders and further details about its design and implementation will be confirmed over time.

The Government will review the current identification requirements for exports and imports at PRIMO articles 10 and 11 when it next updates the Order, in advance of the transition of pig movement reporting to LIS.

The GB PRIMO Orders do not provide for the use of electronic identifiers (tags or otherwise) domestically or for the purpose of live exports. The relevant legislation operates within the EU (EC Regulations 2019/2025 (Art 52) and 2021/520 (Annex II)) allows pigs there to be identified with a conventional or an EID ear tag (amongst other means) and at present where that is used specifies LF (low frequency technology as per ISO Standard 11784). If the identification requirements for the export or import of live pigs to/from the EU or elsewhere change, the relevant import certification/export certification and their accompanying guidance will be updated.

We will continue to work with the industry and the Devolved Administrations when considering policy change. Any proposed changes will be assessed against the impact on industry and the cost of implementation.

Movements

Recommendation 20

The livestock movement databases need to automatically identify non-compliance with the 20-day standstill. The information should then be provided to either APHA or the Local Authorities in a format which is simple and easy to follow.

Government response

Data on reported moves from the three species movement reporting databases in England (including the eAML2 pig database) are uploaded daily onto RPA’s AMLS (Animal Movement Licensing System) for standstill monitoring and other purposes. Local Authorities and APHA access that system. AMLS may be replaced at some point in the future once the movement reporting of all relevant species has transferred to LIS in England.

The government agrees that the automatic flagging of reported moves that are non-compliant with standstill requirements should be a feature of the future multi-species LIS and its equivalent movement databases in the GB Devolved Administrations.

The government will work in partnership with the Devolved Administrations and LI Ltd. on the transition from eAML2 to LIS for reporting pig moves. The focus will be the delivery of effective disease control.

The government will work in partnership with LI Ltd. to explore options, such as an automated warning to keepers advising on potential breaches to standstill requirements as the system’s functionality develops. The government will consider this option long-term. We will continue to work closely with APHA and Local Authorities to ensure data is effectively used and the best approaches for enforcement of standstill rules are implemented.

Recommendation 21

In order to carry out their enforcement function Local Authorities in England require an updated framework agreement and funding to provide specific services in relation to PRIMO. There would be separate requirements in Scotland and Wales.

Government response

The Government is committed to supporting and empowering Local Authorities (LAs) in relation to their enforcement functions. The development of the LIS multi-species movement reporting service remains a priority.

We are considering alternative options beyond further funding of Local Authorities. APHA’s RACE (Regulatory and Compliance Enforcement) function carried out a pilot study in 2021/22 focusing on improving the enforcement of Bovine Tuberculosis (bTB) policy. Three Local Authority officers were seconded into APHA to provide expertise, and act as a single point of contact for LAs; providing advice and practical enforcement support. This resulted in increased knowledge and understanding of bTB within LAs and tangible outcomes by dealing with priority areas of non-compliance.

We will work closely with APHA RACE to review and draw upon findings of the pilot study to determine the options to support the enforcement function of Local Authorities in relation to PRIMO.

Pyramids

Recommendation 22

Further work should be carried out to identify the detailed structure of each pyramid and the relationships at each level.

Government response

The structure of the pig industry in GB, specifically pig pyramids, are more complex than the theoretical top-to-bottom structure of vertically integrated pig production companies that were initially established.

APHA approve pig pyramid holdings under article 21 of PRIMO. A movement of pigs between (down) the approved holdings within a pyramid does not trigger the standstill period in the Disease Control (England) Order 2003 (Art. 5).

The Scottish Government Rural and Environment Science and Analytical Services Division (RESAS) have funded a descriptive analysis by the EPIC Centre of Expertise on Animal Disease Outbreaks of pig production pyramids in Great Britain in order to:

1. Characterise pyramids in GB, including the number of farms involved and their geographical distribution.
2. Describe patterns of movements between holdings involved in pyramids.
3. Measure the number of movements that would be affected for various scenarios of distance-based derogations.
4. Investigate the movements of pigs associated with pyramids to identify trading behaviours that may increase the likelihood of disease spread.

We will review the key findings of the EPIC analysis, and this report, and will work in partnership with the DAs to consider if further work is required to better understand the structure and operation of pig pyramids in GB, and future changes as to how they should operate in compliance with PRIMO.

Recommendation 23

Detailed discussions should be held with the individual heads of the breeding companies and the integrators once a year by APHA at a GB level to review their derogations, approval, and organisational structure.

Government response

The government wants organisations and integrators across GB to feel fully engaged with its traceability policies. It will support APHA in further developing relationships with industry, which may also open opportunities for communication on related issues.

APHA ran a pilot-level engagement session with one of the UK’s leading pork producers to discuss pyramid related issues. APHA will look to build on this positive relationship and extend it to other integrators when appropriate in the medium-term. 

Recommendation 24

Develop information systems which hold all the details of all pyramids and their members in one place along with the movement data which is easy to update and interrogate. A system is needed that can be automatically updated when new information is available.

Government response

Defra will consider this recommendation and how it could be delivered when LI Ltd. and TDUG begin to set out a specification for the future transition of pig movement reporting in England from the eAML2 service to LIS. It intends to consult with the GB Devolved Administrations on where the function and data can reside given that it appears that some pyramids stretch across the England/Scotland, or England/Wales borders.

Recommendation 25

In the longer term there is a need to consider the removal of the derogations although this would need discussion with industry to assess how this could be introduced over time with changes to industry practices.

Government response

The derogation from the 20-day standstill rule for APHA approved pyramids as set out in Article 21 of PRIMO is as follows:

1. The Secretary of State may approve a holding for the purposes of movements of pigs intended for breeding or growing.
2. The approval must specify which holdings pigs may be moved from and which holdings they may be moved to.
3. A movement of pigs between holdings approved under this article does not trigger the standstill period in the Disease Control (England) Order 2003.

As eAML2 transfers to LIS, Defra will continue to work closely with TDUG and LI Ltd. on the development of functions such as an automatic validation programme and an automated warning to keepers of potential breaches to standstill requirements. This will help us to generate accurate data and improve communication with pig keepers.

In the longer term, any legislative changes to the standstill derogation for pig pyramids will likely require a substantial evidence base and a consultation with the industry.

Recommendation 26

Discussions with the industry are needed to clarify and agree the definitions of the different types of herd and movements which are and are not permitted.

Government response

The government agrees that a clear and consistent approach towards terminology, both in terms of agreed definitions of herd types in an approved pyramid as well as the rules on movements within and into pyramids, is crucial in ensuring a thorough understanding of the identification and movement reporting requirements within a pyramid.

The government will work with APHA, the Devolved Administrations and the pig sector to ensure that they all have a role in improving the understanding of the terminology used across the pig pyramids/supply chains, to support a unified and consistent GB approach to compliance. As and when eAML2 transfers to LIS, we will work closely with LI Ltd. in England to ensure that it employs the appropriate terminology, and that its guidance on movements within pyramids is clear.

The government launched a communication campaign in May 2023, which provides guidance on conditions for APHA approval of holdings within pig pyramids.

Recommendation 27

Continued training and audit of APHA Veterinary inspectors to ensure there is uniform action across GB with regard to the approval and management of pyramids.

Government response

APHA continue to prioritise the operation of their pyramid holding approvals function under PRIMO. They have revised guidance and delivered substantial training to staff who carry out this function.

The government is committed to working with industry, APHA and other stakeholders to gain a more in-depth understanding of the current structures of pyramids to ensure improved oversight.

Recommendation 28

Ensure and maintain biosecurity requirements for all approved holdings and hauliers to prevent disease entering a pyramid and being spread via hauliers.

Government response

The government agrees that ensuring high standards of biosecurity for approved holdings in pyramids and hauliers is crucial in preventing the spread of disease, both into and throughout pyramids.

The government has launched a communication campaign promoting the importance of biosecurity and the steps that approved holdings and hauliers need to take to meet these requirements.

Education and awareness of good biosecurity within pig pyramids and the wider industry is a priority for all concerned. The government will continue to seek ways to support industry to improve biosecurity and deliver consistent and effective enforcement of compliance with biosecurity rules.

Recommendation 29

The biosecurity requirements for outdoor units should be reviewed and must be implemented rigidly for the nucleus/ multiplier and multiplier herds with no room for any concessions to be granted for example in respect of the double fencing of outdoor units by the Veterinary Inspector of the Department responsible for approval.

Government response

The government acknowledges that, in general, there are challenges in maintaining biosecurity requirements for outdoor units. The government will consider this recommendation in the long term, exploring further how biosecurity requirements for outdoor units should be reviewed regularly and improved where necessary – for example, following a disease outbreak. Investigations into disease outbreaks can shed light on biosecurity issues, highlighting potential disease entry points which could effectively contribute to any reviews of the biosecurity requirements.

The implementation and enforcement of biosecurity requirements should be consistent across all outdoor premises. The government agrees that no concessions should be made, for example for rented land, double fencing requirements, or concrete pads to enable cleansing and disinfection of vehicles. There is still an inherent biosecurity risk in these circumstances, and so the biosecurity standards should be maintained and enforced consistently. 

Recommendation 30

Prohibit the use of the TLAs for outdoor herds or failing that reduce the distance from 10 miles to 3km to mirror the zone if notifiable disease were to occur.

Government response

The government’s overarching goal remains to prevent and manage disease outbreaks. The government will consult industry on this recommendation. We will work closely with industry, APHA and other stakeholders to explore the issues in more detail and develop workable solutions to support good disease control outcomes.

Any proposed changes may be in the long-term and assessed against the impact on the industry to prevent any unintended consequences. 

Recommendation 31

Within a single pyramid the source of pigs moved vertically onto approved holdings should continue to be limited to two with all sources being recorded on the APHA approval documents.

Government response

APHA allow sourcing from more than one holding within a single breeding company, and occasional additional sourcing from one further source outside that company. The government will consult industry on this recommendation. We will work closely with APHA and other stakeholders on any proposed changes.

Any proposed changes may be in the long-term and assessed against the impact on the industry to prevent any unintended consequences on the sector.

Recommendation 32

Require any movement into a pyramid from another pyramid or any other site to either trigger the 20-day standstill on the whole site or place the pigs into an APHA approved isolation unit before movement.

Government response

The government’s overarching goal remains to prevent and manage any disease outbreaks. We will work closely with APHA and other stakeholders on any proposed measures to explore issues in more detail. Any proposed changes will be in the long-term and assessed against the impact on the industry, to prevent any unintended consequences on the sector.

Recommendation 33

Enforce the ban on pigs moving back up a pyramid unless they go to a 20-day isolation approved by APHA with no movement up to a nucleus herd permitted.

Government response

APHA approve holdings within a pig pyramid so that they can operate under a derogation from stand still rules as referred to in Article 21 of the Pigs (Records, Identification and Movement) Order 2011. Moves between the approved holdings in a pyramid must be one way (vertical). The government will work with industry, APHA and other stakeholders to ensure operators at these holdings have a better understanding of, and compliance with, the requirement for vertical movements only (in the absence of, and use of isolation facilities).

Recommendation 34

Publicity and education are needed to ensure that any movements out of a pyramid to non pyramid holdings would trigger the 20-day standstill unless the pigs were isolated for 20 days in approved isolation by APHA.

Government response

The government welcomes the recommendation for raising awareness and education surrounding pig pyramids and moves to non-pyramid holdings.

The government has developed communications to ensure clearer messaging to all pig keepers, including messaging on movements from pig pyramid holdings to non-pyramid holdings to clearly set out the receiving keepers’ legal obligations to comply with standstill rules. This communication campaign was launched in May 2023.

Recommendation 35

Discuss with the breeding companies and the integrators the redesign of the system to take into account the informal pyramids both to enable movements and as part of the overall contingency plans in the event of a notifiable disease outbreak.

Government response

The government will consider this recommendation through a review and a consultation with the industry, including a better understanding of informal pyramid type operations where they may exist. We will work closely with the industry, APHA and other stakeholders to explore issues and the evidence in more detail and any proposed measures to support disease control. However, any proposed changes will be in the long-term and assessed against the impact on the industry to prevent any unintended consequences on the sector.

Imports and exports

Recommendation 36

The introduction of the new electronic system “Import of products, animals, food and feed system” (IPAFFS) by APHA for recording imports must be directly linked to the new LIS. This is to enhance traceability of imported pigs in the event of notifiable and/or non-notifiable diseases such as PRRS 2.

Government response

The government recognises the importance of enabling effective traceability of imported pigs. A link between IPAFFS and LIS would contribute to effective disease control in England.

Along with APHA, we will consider how best to implement this recommendation during the move the current eAML2 pig traceability service on to LIS in the coming years. This will enhance traceability in the event of a disease outbreak.  

The Devolved Administrations will also need to consider whether the systems they are developing for pig traceability can link to IPAFFS.

Recommendation 37

The new LIS could record the details of export movements or alternatively a separate more comprehensive system should be established to identify number and consignments of pigs.

Government response

The government plans to investigate this capability in the development of the new multi-species service.

Along with APHA, we will consider how best to implement this recommendation before we move the current eAML2 pig traceability service on to LIS in the coming years.

Recommendation 38

An improved system needs to be developed to record and trace pigs arriving from Northern Ireland or the Republic of Ireland via Cairnryan or Fishguard.

Government response

Movements of live animals from Northern Ireland or the Republic of Ireland to Great Britain, via Cairnryan or Fishguard, must be notified on the new electronic system IPAFFS before the animals are expected to arrive at the point of entry.

The onward move from the GB port must then be reported on the relevant movement reporting system (presently eAML2 for England and Wales, and ScotEID for Scotland).

There is currently no link between IPAFFS and eAML2 or ScotEID - see the response to recommendation 36.

Recommendation 39

Consideration should be given to establishing the BCP for imports of breeding pigs from the Republic of Ireland via Fishguard at an isolation unit established by the importing company.

Government response

The prohibition and regulation and control of the movement of animals into and out of Wales for the purpose of protecting human and animal health is a devolved matter and it is for the Welsh Government to identify the appropriate infrastructure required at their ports. The Border Target Operating Model (TOM) provides strategic direction for the implementation of controls on imports to Great Britain in keeping with the 2025 UK Border Strategy and includes a framework for how checks will apply to commodity types. The development and operationalisation of the TOM will continue to evolve with input from stakeholders and further details about its design and implementation will be confirmed over time. 

The current legislative requirements for official controls and BCPs are set out in the Regulation (EU) 2017/625 and relevant implementing legislation. Current legislation requires BCPs to be located at the Point of Entry except in the event of specific geographical constraints. As the development and operationalisation of the TOM continues to evolve, any legislative amendments to BCP location requirements will be driven by the requirement to ensure biosecurity risks are sufficiently mitigated.

Recommendation 40

Imports of breeding stock via BCPs at airports should be organised so that the pigs do not need to be unloaded and the physical and identity checks carried out at the isolation unit to which the pigs are moved.

Government response

The Official Control Regulation (retained Regulation (EU) 2017/625) sets out the official controls that must be carried out on consignments of animals on first entry into GB.

The government is currently working on what our future borders policy will be and how it will impact BCP capacity. This includes developing policy thinking on the wider reset of import controls and looking at what this means for capacity and BCP functionality. This will drive discussions on the infrastructure and any changes required to the legislative framework. As pigs are a potential disease risk species, we would need to give any proposed changes considerable risk assessed thought.

Government made the decision not to introduce any further import controls from July 2022, therefore businesses can continue to import live animals and animal products from the EU as they do today. The government published The Border Target Operating Model (TOM) on Tuesday 29 August 2023. It sets out the new model that has been developed through engagement with stakeholders. It will protect the UK’s animal and plant health and public health, striking a balance between minimising burdens on business while safeguarding biosecurity and reducing risks to public health.

The TOM provides strategic direction for the implementation of controls on imports to Great Britain in keeping with the 2025 UK Border Strategy and includes a framework for how checks will apply to commodity types. The development and operationalisation of the TOM will continue to evolve with input from stakeholders and further details about its design and implementation will be confirmed over time. 

Recommendation 41

The BCPs for imports of breeding pigs via European ports could be established inland at an APHA approved isolation unit to which the pigs are moved.

Government response

A BCP is the one-stop site usually located at the Point of Entry and is the location to which checks on animals, plants, and products derived from them are carried out. The current legislative requirement for official controls and BCPs are set out in the Regulation (EU) 2017/625 and relevant implementing legislation.

The government is currently working on what our future borders policy will be and how it will impact BCP capacity. This includes developing policy thinking on the wider reset of import controls and looking at what this means for capacity and BCP functionality. This will drive discussions on the infrastructure and any changes required to the legislative framework.

The development and operationalisation of the TOM will continue to evolve with input from stakeholders and further details about its design and implementation will be confirmed over time. Any legislative amendments to BCP location requirements will be driven by the requirement to ensure biosecurity risks are sufficiently mitigated.

eAML2

Recommendation 42

The output from eAML2 or replacement databases must be in a prescribed format which provides the information needed by APHA for tracing animals.

Government response

The government agrees that all movement reporting databases should provide appropriate information to APHA when required, to effectively trace pigs in the event of a disease outbreak.

eAML2 provides an online platform to record and report movements, whilst providing a bureau service for the few keepers who do not have computer and/or internet access. The system is accessible to APHA, supporting traceability in the event of a disease outbreak.

We will work closely with APHA and LI Ltd. on the transition of pig movement reporting onto LIS in England to ensure it can generate the data outputs needed to support APHA’s tracing needs.

Recommendation 43

The functionality for mapping holdings within 3 and 10km restrictions zones for both notifiable and non-notifiable diseases must continue and be improved by the development of LIS.

Government response

In the event of an exotic notifiable disease outbreak, legal powers exist for movement control zones to be declared in order to control the spread of the disease. These include protection zones (PZ), surveillance zones (SZ) or restricted zones (RZ), as described in the Contingency Plan for Exotic Notifiable Diseases of Animals in England (publishing.service.gov.uk). The government’s goal remains to effectively manage and shut down any disease outbreaks. We have worked closely with AHDB to add value to eAML2 through its ability to identify premises in 3km and 10km zones.

The ability to visually map restriction zones on eAML2 provides further clarity as to affected premises in the event of a disease outbreak. The government and livestock keepers can see details of the zone boundaries to identify which premises are within, or in close proximity to, any of the movement control zones and therefore take any necessary action. This is particularly important for approved pig holdings i.e. pyramids.

The government agrees with this recommendation and will continue to work collectively with RPA, APHA and LI Ltd., to enhance this functionality when pig movement reporting transition on to the LIS platform.

Recommendation 44

Specific terminology which relate to pigs and the supply chain must be considered with the development of those parts of LIS relevant to the pig industry.

Government response

The government agrees that a clear and consistent approach towards terminology is crucial in ensuring that the new multi-species LIS accurately mirrors the terminology used across the supply chain.

As eAML2 transfers to LIS in England, we will work closely with LI Ltd. to ensure appropriate terminology (industry and regulatory) is used on LIS.

Recommendation 45

Automatic validation programmes should be included in any movement database with output in a format which can either require the pig owner to rectify or the authorities to carry out an investigation.

Government response

LIS is being developed as a multi-species platform and is being designed in collaboration with industry and TDUG, which includes representatives from industry sectors with an interest in livestock traceability, including the pig sector. At present, the focus remains on cattle traceability to ensure the move of cattle reporting in England off CTS onto the LIS platform is seamless. In the future, the movement reporting of pigs will transition from eAML2 to the LIS, and data validation will be a key consideration in its development.

In the long term, the government will work with LI Ltd. on the development of LIS with a view to including automatic validation; for example, directing pig keepers to correct erroneous movement data entered during pre-notification. Automatic validation could also provide other benefits such as reducing delays due to manual identification of incomplete moves by providing an alert to the relevant authorities post-move to carry out any necessary investigations.

Recommendation 46

Any new movements database for England such as LIS must provide better linkages to the movement systems of the Devolved Administrations including Northern Ireland in order to have full traceability of imported and exported pigs. In addition, links to the APHA databases for pyramids, pet pigs, import and export as well as the RPA and Red Tractor databases are crucial.

Government response

The government is committed to working in partnership with the Devolved Administrations to ensure that the three planned GB multi species movement reporting systems support seamless cross-border movement reporting and traceability.  

Data from LIS and the equivalent services in Scotland (ScotEID), Wales (EID Cymru) and Northern Ireland (Animal and Public Health Information System (APHIS) to be replaced by the Northern Ireland Food Animal Information System (NIFAIS)) will feed into the UK View (see recommendation 6), to produce fast and reliable access to a consolidated UK dataset and will serve UK-wide tracing needs. We will also consider how to develop links between LIS and IPAFFS (see recommendation 36).

We acknowledge that the links to the APHA databases, RPA databases, and establishing a link to the Red Tractor database could enhance disease control.

Defra will consider this recommendation in the long term, working in partnership with LI Ltd., TDUG, and other stakeholders to consider appropriate linkages to relevant databases during the development of LIS.

Recommendation 47

Output should be categorised as routine and ad hoc. Routine outputs should be regular and directed to those organisations such as the Local Authorities to enable them to identify issues and take appropriate action rapidly and clearly.

Government response

Presently, eAML2 produces weekly reports shared with Local Authorities. The government will continue to work with Local Authorities to ensure this information is received appropriately. 

The government agrees that the ability to output data from eAML2/LIS is needed for enforcement; for example, via configurable reports to which competent authorities including enforcers should have access. In the long-term, the government will work with LI Ltd., industry representatives and enforcers to develop LIS so that it has comprehensive data output/management information reporting functions.

Recommendation 48

Every effort must be made to ensure that the three systems, LIS, ScotEID and EID Cymru are similar to ensure producers and other users in England, Wales and Scotland are able to understand and work with any of the systems. As legislation is likely to be needed to implement any changes it is equally important that the differences in any Statutory Orders between the countries are kept to an absolute minimum.

Government response

It is important that users understand all three movement systems, to ensure consistency when reporting moves across GB. The government will work in close partnership with LI Ltd., to ensure LIS will be compatible with equivalent services in Scotland (ScotEID), Wales (EID Cymru), and Northern Ireland (APHIS>NIFAIS).

The responsibility for Animal Health and Welfare controls and their regulation is a devolved competence with each of the Devolved Administrations making their own legislation. The government will look to work in partnership with them to avoid differences that might hinder effective disease control and traceability.

The government will continue to ensure effective and transparent consultation and engagement with stakeholders ahead of any regulatory changes.