|FINAL REGULATORY IMPACT ASSESSMENT|
4. Commission Decision 2000/68:
12. The Regulations will be enforced by Local Authority Inspectors.
13. Between 6,000 – 10,000 horses are slaughtered in England each
year for human consumption. It may be harmful to humans to eat horsemeat
if in the last six months of its life it had been administered veterinary
medicines for which no Maximum Residue Levels have been set, or if it
had been administered with a medicine which should never be given to a
(Note: These were the options considered before the Horse Passport (England) Regulations 2003 were made, and are included in this updated RIA for completeness.)
Option 1 (Complete Implementation)
16. This would require:
17. This would require:
18. For both categories stated above, it would be presumed that the horse
may enter the human food chain unless the owner signed the declaration
to the effect that the horse is not intended to be slaughtered for human
consumption. In the absence of such a declaration the use of certain medicines
would be recorded in the passport. These medicines are ones containing
substances not listed in annex I-III of Council regulation 2377/90. A
substance listed in Annex IV of that regulation may only be administered
if the passport is signed to the effect the horse is not intended to be
slaughtered for human consumption.
19. There is an issue of fairness and equity in relation to the semi
feral breeds or types of ponies because of the low value of these animals,
which is often less than the cost of the passport. This measure may, therefore,
effectively prevent these types of horses being sold for slaughter to
enter the food chain. However there are other avenues available for the
sale of these horses which owners can use. The Government has been prepared
to consider special arrangements for moors and other areas where large
numbers of ponies roam providing such arrangements were equivalent to
the European requirements. Special measures have therefore been agreed
for the New Forest and Dartmoor. They will entail the authorities in these
areas maintaining a list of the individual identification of such animals,
which mean that passports will not be required until animals leave these
areas. Additionally, the managers of the New Forest sought Government’s
agreement to put in place measures for foals sold in their year of birth.
The legislation provides for these measures.
20. It is not possible to put any realistic monetary value on the benefits of preventing horses entering the food chain that have been administered with certain veterinary medicines within the previous six-months; nor about the impact on the availability of horse medicines if this measure is not implemented. However, the value of the trade in horses slaughtered for human consumption is estimated to be about £2.5 million.
21. The benefit of option 1 is that it fully implements the Commission
Decision and has the support of most of the horse industry. It reduces
the risk that many commonly used veterinary substances administered to
horses and for which no Maximum Residue Levels have been agreed cannot
continue to be used.
24. It has been suggested that partial implementation of the requirements
of the EU legislation could still meet the objectives of the legislation
because no horse could be slaughtered for human consumption without a
passport showing the date medicines have been administered to it within
the previous six-months, or since birth if earlier. This suggestion was
included to avoid the need to implement the retrospective requirements
for registered horses because it would impose administrative and cost
burdens on societies that issue passports. Similarly it would target specifically
those horses entering the food chain and not require passports for all
horses, many of which will never go in the human food chain.
Compliance Costs for Business, Charities and Voluntary Organisations
26. Compliance costs for obtaining a passport will fall on owners of
horses. These will vary depending on personal circumstances and which
Passport-issuing organisation owners approach. Owners applying for a passport
for the first time, and who do not already have a valid silhouette for
their horse, and where the silhouette they provide is completed and signed
by a veterinarian might find that the cost of obtaining the silhouette
could be between £40 and £60. Owners that already have a valid
silhouette will only need to pay for the passport document. Passport average
costs are around £20. Some Passport-issuing organisations offer
special discounts for volume or charitable organisations.
30. There are no new burdens on Exchequer funds as a direct result of
this legislation. There has been an increase in the number of organisations
seeking recognition to issue horse passports but the associated costs
have been absorbed within existing Defra resources.
Costs of Option 1
31. For horses of known breeding, this would involve:
• For horses of no known breeding we estimate that up to 620,000
additional passports will be needed. Estimates of how many horses there
are in England vary – the UK estimate is between 600,000 and one
million. The average cost of the passport document will be £20,
costing some £12.4m. The costs are normally less for these types
of horses because this represents just the cost of a basic passport.
33. Following proposals made by the British Equestrian Federation, on
behalf of the equine industry, the Government announced on 14 February
2002 that a National Equine Database should be established. This would
be based on some basic ‘core’ information that the Passport-Issuing
Organisations would pass to the National Equine Database. The information
would be used by Defra to both help to monitor the horse passport requirements
and for disease control and veterinary surveillance measures. The industry
would use this information as the basis of a system designed to help improve
the breeding and performance of horses but this aspect of the database
would be entirely voluntary and designed to be self-funding after the
initial start up period.
35. Costs for adding the additional section to new passports for registered
horses would not be significant once the additional page has been added
to computer systems. Most passport-issuing organisations are doing this
already and not charging an additional cost for this.
Small Firms Impact test
37.All recognised breed societies and other societies or organisations that issue horse passports were consulted about this measure and their estimated cost have been included in the compliance costs above. A wide selection of horse industry organisations were also consulted.
38. We do not expect that the favoured option, option I, would have a
significant effect on competition. This view is based on the fact that
the costs from the proposals for horse owning businesses, such as riding
schools, would not be sufficiently high to deter new entry or alter existing
levels of competition. Competition between Passport- Issuing Organisations
is increasing and as stated previously, this is having the effect of reducing
passport prices. The market is not a concentrated one and the proposals
would not create any additional barriers to entry for equine passport
39. This measure is not expected to have any significant resource implications
for Defra. Because all horses are now required to have passports, a number
of new applications to become Passport Issuing Organisations have been
received. The cost of this additional work has been met from within existing
resources. There is also the cost of publicity campaign to inform horse
owners, and other interested parties, of the requirement for all horses
to have a passport and how to get one. As explained above, the cost of
obtaining a horse passport will fall to individual horse owners.
40. A consultation exercise which set out various options for implementation for both registered horses and all other horses known as ‘horses for breeding and production’ was issued in July 2000. 120 Letters were sent out and 47 responses received. Reaction was split – individual horse owners considered that only horses being slaughtered for human consumption (currently between 6 – 10,000 per year) should have to have a passport. The Small Businesses Service has been consulted and has expressed a preference for option II because this would limit the impact on small businesses such as horse riding schools. However the proposal that all horses should have to have passports received strong support from the major players in the equine industry, including the British Horse Industry Confederation which was set up to represent all sections of the equine industry to government.
41. A further consultation exercise was carried out in March 2003 asking
for comments on the draft Horse Passports Legislation. The letter, and
draft Regulatory Impact Assessment, was sent to 176 organisations and
88 responses were received. Comments made during this consultation exercise
have been taken into account in finalising the legislation.
43. Cost of horse passports will be borne by individual horse owners
and will depend on their individual circumstances and how many horses
are owned. For example, if a riding school had 20 horses and passports
cost £20 each the cost to the riding school would be £400.
In addition there would be costs associated with obtaining a silhouette
for the horse if one did not already exist, and notional costs of the
person completing the application forms. The cost to the industry for
buying passports are estimated to be:
44. The benefits of the measure to protect the human food chain and to
ensure the availability of veterinary medicines – cannot be quantified
but the value of the trade in slaughtering horses for human consumption
is estimated to be about £2.5 million.
45. Enforcement of the legislation rests with local authorities’
Trading Standards Departments. The Meat Hygiene Service will continue
to use existing powers to undertake documentary checks as part of their
ante-mortem checks to satisfy themselves the horse can be slaughtered
for human consumption. In addition, the Agriculture Departments have authority
to withdraw recognition from any studbook organisations that they have
authorised to issue passports if they consistently fail to abide by the
prohibitions of the legislation.
46. Guidance notes on the legislation will be issued to interested parties
as soon as possible.
47. This RIA summarises the two main options for implementing the measure,
which were considered by the initial consultation, which took place in
the summer of 2000. The first (option I) would fully implement the Commission
Decision, and would reduce the risk that commonly used horse medicines
for which no Maximum Residue Levels have been approved or which are not
intended for food producing animals would have to be withdrawn from the
market. It provides for the flexibility sought by welfare organisations
and others about how and when owners should sign the declaration as to
whether or not the horse is intended for human consumption. It also provides
for equivalence measures at the request of the managers of Dartmoor and
the New Forest. The second (option II) would meet the objectives of the
legislation by targeting just those horses entering the human food chain
but would not meet the European legal requirements and so be open to legal
challenge. Neither option (apart from the National Equine Database which
is not yet a requirement of the EU legislation) proposes any measures
that are additional to those required by the Commission Decision.
49. After considering the results of the consultation, the Minster for State (Rural Affairs and Urban Quality of Life) decided to implement Commission Decision 2000/68/EC by requiring all equines to have a passport that meets the EU requirements and for a National Equine Database to be established. This was introduced through The Horse Passports (England) Regulations 2003, which required passports for older horses to be obtained by 30 June 2004. The Horse Passports (England) Regulations 2004 confirm the requirement for passports but with some changes both to the policy and in how the legislation was set out to try and make it clearer what is required. The main changes are that-
• The declaration that the horse is ultimately intended for human
consumption does not now have to be signed until the horse is exported
or sent for slaughter.
50. I have read the Regulatory Impact Assessment and I am satisfied that
the benefits justify the costs.
Date: 19th May 2004
1. Bitting Advice - Mouth Conformation
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